ML19325E144

Responds to NRC 890829 Ltr Re Violations Noted in Insp Repts 50-454/89-16 & 50-455/89-18.Corrective Actions:Valve 1CV8110 Opened & Daily Order Written to Reemphasize That Operators Are to Comply W/Requirements for Abnormal Valve Log Sheets

ML19325E144
Person / Time
Site:	Byron
Issue date:	09/28/1989
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8911020099
Download: ML19325E144 (4)

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) Commonwealth Edison .

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Sj&r, < l s i n. 'Mr. A..Bert Davls! . . ,

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Regional Administrator

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Subject:

'. Byron' Station Units 1 and 2 Response to Inspection Report 1 50-454/89016 and 50-455/89018 NRC Docket Nos. 50-454 and 50-455 l 3

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Reference:

(a) ' August 29, 1989, letter from H. D. Shafer to Cordell Reed ' '

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Dear Mr. Davis:

u . 'i H This. letter is in response to the inspection. conducted by Messrs. H.

, J. Kropp, and R. H. Sutphin, and Messrs.'N. V. Gilles and D. R..Calhoun from (

July 1 through August 19, 1989, of activities at Byron Station. Reference (a)' .

' indicated.that certain activities appear to.be'in' violation of NRC

' requirements. Attachment A provides the response to the proposed violation. ,

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, , Pleace direct any questions regarding this matter to this office, o

r Very truly yours, j Ma l' /r T.] Kovach .

j. Nuclear Licensing Manager  ;

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I. t y cc: Resident Inspector - Byron  :

l> NRC Document Control Desk l

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0911020099 8909289 PDR ADOCK 05000454 a eq ggP29199g O __ _ _. _ . . . - . . . _ . - . - . . - .- .. . . . - _ - . -

(o, RESPONSE TO NOTICE OF VIOLATION 454/89016

'10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison  !

Company's Quality Assurance Manual, Quality Requirement 5.0, requires that h activities affecting quality shall be prescribed and accomplished in accordance with documented instructions and procedures. -

c BAP 1210-5, Revision 6, 10 CFR 59 Safety Evaluation Procedure", Step C.2, requires a review of how operation is being revised to identify if there are l(

affects on any of the following:

a. Mechanical functions'  ;

b. Electrical functions'  !

c. Instrumentation and Control functions BAP 340-2, Revision 23, " Initiation and Use of System Lineups (Mechanical &

Electtical)", Step C.10, states that when twe (2) SR0s determine a valve requires a different position from that listed in the BOP "M" lineup and the ,

time period in an'" abnormal position" extends beyond one (1) shift turnover, I an Abnormal Valve Position Log shall be used to record the status of that valve.

BAP 330-6, R6 vision 1, " Caution Card Procedure", states that the procedure is designed to call attention to temporary information relating to equipment performance that is not. normal.

Contrary to the 0bove:

.a. The licensee failed to perform a 50.59 safety evaluation when the Unit 1 "B" Centrifugai Charging Pump's mini-flow recirculation valve, ICV 8110, was closed for an extended period of time (June 21-June 30, 1989). With ICV 8110 closed, the automatic ESF feature of ICV 8114 would have required operator action to open ICV 8110. The Updated Final Safety Analysis Report, Section 6 3, states that no manual actions are required of the l o)erator for proper operation of the ECCS during the cold leg injection i p plase. Also, the ticensee failed to document the abnormal position of  :

E valve ICV 8110 on an Abnormal Valve Position Log. Valve ICV 8110 was closed i for greater than one shift and was not repositioned as a result of an I out-of-service or surveillance activity. '

b. The licensee failed to place a Caution Tag on Unit 1 "A" Steam Generator e (SG) Power Operated Relief Valve (PORV) controller located on the Unit 1 ,

. Remote Shutdown Panel. A Caution Tag had been placed on the 1A SG PORV L controller located on the main control board that identified the block valve, IMS019A, for the 1A SG PORV as closed. A similar occurrence for a Unit 2 PORV was documented in the previous inspection report, o

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454/89016-01a (Part 1)

'The following excerpt from the NRC Inspectors' report describes the first part

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" Updated Final Safety Analysis Report (UFSAR), Section 6.3, states that 0

y no manual actions were required of the operator for proper cperation of t the ECCS during cold leg injection. With valve ICV 8110 closed, operator action was required for proper operation of the IB CV pump during cold .

leg injection. Therefore, since the licensee operated from at least June 21'to June 30, 1989 with ICV 8110 closed, a 50.59 review in J accordance with procedure BAP 1210-5, "10 CFR 50.59 Safety Evaluation",

Revision 6, was required as the plant was not operated as described in the UFSAR."'

Corrective Action Taken and Results Achieved m Valve ICV 8110 was opened. In addition, Byron Station requested Hestinghouse ,

Corporation to perform a 50.59 evaluation for operating the CV (Chemice.1 t Volunia Control) . system with the ICV 8110 closed. Westinghouse performed the ,

evaluation and submitted it to Byron Station August 23, 198S. The evaluation  ;

concluded that no unreviewed safety questiu had existed for the configuration described above.  :

Corrective Action to be Taken to Avoid Further Violattom  ;

In the event 1(2)CV8110 or 1(2)CV8111 are required to be closed in the future, Byron Station will take the conservative action of declaring the associated CV pump inoperable with respect to ECCS subsystems 3/4.5.2 and 3/4.5.3.

Commonwealth Edison will corporately restew the generic applicability of 10 CFR 50.59 safety evaluations prior to manipulating ECCS system valves to a position different from the normal valve lineup and not repositioned as a result of an out-of-service or an approved procedure. ,

A supplemental response addressing the.results of this review will be substtted by November 1, 1989.

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154/89016-01a (Part 2)

~The following excerpt from the NRC Inspectors' report describes the second part of violation la: 1

" Procedure BAP 340-2, Initiation and Use of Systems Lineups (Mechanical  ;

and Electrical), Revision 23, required that an Abnormal Valve Position  ;

Log sheet be completed when a valve was not in a position consistent with the valve lineup sheet (M-1) for longer than one shift, unless the valve was identified on an Out-of-Service (005) tag or repositioned for a surveillance. Since valve 1CV8110 was not 00S or repositioned for a ,

survelliance, an Abnormal Valve Position Log Sheet was required. No Abnormal Valve Position Log Sheet as completed and reviewed by the ,

cognizant shift personnel. However, the valve's position was documented as " closed" on the Shift Turnover Sheets."

Correj;tive Actions Taken and Results Achieyed A daily order was written to re-emphasize that licensed operators are to comply with the requirements for Abnormal Valve Log Sheets.

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'3<- H CQrJ1tt.13t Action to be Taken to Avoid Further Violation

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This violation and response will be included in the Required Reading / Listening i

Program by October 31, 1989, to further reinforce the requirement of using the Abnormal Valve Log Sheet.

1 454 /8901'6-Ol b. J The following excerpt from the NRC Inspectors' report describes Part 1b of the violation: ,

"No' Caution Tag was placed on the controller for the Unit IA Steam Generator Power Operated Relief Valve (PORV) located at the Remote <

Shutdown Panel (RSP). The controller for 1MS018A had a Caution Tag on the Main Control Board which identified that block valve, IMS019A, for the 1A PORV was closed. A similar occurrence on the Unit 2D PORV was reported in Inspection Report 50-455/89016. Procedure BAP 330-6, Revision 2 " Caution Card Procedure" states that Caution Tags were l . designed to call attention to temporary information relating to ,

equipment performance that was not normal. Failure to place a Caution Tag on the 1A PORV controller on the RSP is another example of failure to follow procedures and is considered a violation of 10 CFR 50, Appendix B, Criterion V. The licensee's immediate corrective action included placement of a Caution Tag at RSP and initiation of a revision to BAP 330-6 to emphasize the requirement for Caution Tags on the RSP, when required."  ;

Corr 1ctive Action Taken and Results Achltyrd Caution Cards were immediately placed at the RSP.

Corrective Action to be Taken to Avoid _f_pr.ther Viola.tlnni H The Caution Card is the mechanism used to relay off normal conditions and i f' information and is used at the discretion of the Shift Engineer. BAP 330-6 7 has been revised to state "If placing Caution Card (s) on McB, remember to l include Remote Shutdown Switch (es) and/or Local Control Switch (es) which may L be applicable." This should remind the Shift Engineer to consider putting a l card on the RSP when cards are placed at the MCB. It should be noted that the L NOTE placed in BAP 330-6 says when applicable. The RSP is only required to l' have instrumentation OPERABLE in Modes 1, 2 & 3 as designated by Tech Spec l

3.3.3.5. It is not; the intent of this note to require cards when the RSP is not required to be OPERABLE, or the condition identified by the Caution Card does not affect operation at the RSP.

The Date Hhen Full Como11ance Hill b.e_Achleye.d ,

The violation and response will be placed in the Byron Required Reading / Listening program by October 31, 1989. Byron Station is in full compliance with all other items at this time.

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