ML20029C203
| ML20029C203 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/31/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9103260430 | |
| Download: ML20029C203 (5) | |
Text
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C:mm::nwealth Edissn m
1400 Opus Place
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Downers Grove, Illinois 60515 December 31, 1990 Mr.'A. Bert Davis
- Regional Administrator
'U.S. Nuclear Regulatory Commission 799 Roosevelt Road-RIII
- Glen Ellyn, 11 60137 1
Subject:
Byron Station Units I and 2~
Reply to Notice of Violation Inspection Report Hos. 50-454/87027 & 50-455/87025 BRC Doc Mt_Nos :-50-454 and 50-455
Reference:
a) February 5,1988 letter from J.J. Harrison to Cordell Reed b)' December 3, 1990 letter from A. Bert Davis to
'Cordell Reed
Dear Hr. Davis:
- Reference (a) designated the status of an item identified in NRC Inspection Report Nos. 50-454/87027; 50-455/87025 as an Unresolved = Item. This
-item was. tracked on the Inspection Report as (454/87027-01; 455/87025-01).
'The Unresolved Item was the. subject of a subsequent NRC Office of--
Investigation Report 3-87-019.
The letter of Reference b) contained a Notice of. Violation and. indicated-that certain activities at Byron Station appeared-to-be-in violation of HRC. requirements.
The Commonwealth Edison Company response to.the Notice of Violation.is-provided in Attachment A.
Commonwealth Edison acknowledges the violation and recognizes the significance of the
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. concerns expressed both.during the Enforcement Conference of August 2, 1990
.and in the letter of Reference-(b). The-Notice of Violation response:has been identified.as 1 tem:(454/87027-01;-455/87025-01) although it was not indicated-
'as such l'n'the' letter of Reference (b).
If.this is incorrect, please notify us of the' correct identifier, If you have'any questions'regarding this response, please direct them to this office,
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Very.truly yours,.
/
r T.J. K ch Nuclear Licer.,ing Manager Attachment
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NRC Resident' Inspector-Byron NRC Document Control Desk 1A.-Hsla-NRR 0 DI
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ATTACHMENT A-g Comonwealth Edison Company Reply to Notice of Violation l
-NRC INSPECTION REPORT NO. 50-454/87027 & 50-455/87025 i
Violatio.D-During an NRC inspection conducted between July 7 and August 21, 1987, and during an NRC investigation conducted between October 8, 1987 and January 6, l
1989, a violation of NRC requirements was identified.
In accordance with the 1
" General Statement of Policy and Procedure for Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below:
10 CFR Part 50, Appendix B, Criterion III, states, in part, that " measures shall be established to assure that applicable regulatory requirements and-the design basis, as specified in the license appilcation...are correctly translated into_ specifications, drawings, procedures and instructions."
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Contrary to the above, Commonwealth Edison Company failed to perform adequate reviews and evaluations to assure an adequate design was used in the Emergency Diesel Generators' electrical overspeed trip circuitry.
Consequently, seismically unqualified-switches were wired into the Emergency Diesel Generators from approximately October 31, 1984 for Byron l
Unit l'and November 6, 1986 for Byron Unit 2 until December 17, 1986, j
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Renonst Commonwealth Edison Company (Ceco) acknowledges that we failed to assure an adequate design was used in the Emergency Diesel Generators' (EDGs')
electrical overspeed trip circuitry.
The initial failure by the equipment-i manufacturer and design reviewers to identify the deficiency in the design of 1
'the EDGs occurred-in the late 1970s The design review process used in the 1970s has been. replaced by more detailed design reviews.
Changes.have occurred gradually over the years, with major improvements made in 1987 when the modification program was completely revised. CECO's commitment to proper design reviews is documented in the ENC-QE-06 series procedures.
The procedures discuss'the engineer's obligations to perform design reviews and document said reviews.
Procedure ENC-QE-06.3, Engineering Evaluation of i
Designs Produced by_0utside Organizations, requires a review of the adequacy-of the.-design. input requirements._ Two of the design inputs required to be l
considered by the designer under section 7.8 of the CECO guide book for Architect Engineers are seismic qualificattan and suitability of parts.
In
-addition, procedure ENC-QE-06.1 "10 CFR 50.59 Safety Evaluation" requires a review-of_the need for seismic qualification of equipment.
l In addition, CECO acknowledges that the delay in declaring the EDGs' inoperable was due to poor communications and inadequate training of personnel at the time of transition from the construction to operating phase for the Byron /Braidwood units.
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' ATTACHMENT A (CONTINUED)
Co.tte.cihe_Atj;lons Taken and Results Athleyrd After taing notified of_ the EDG circuitry problem on December 17, 1986 CECO initiated a temporary alteration to bypass the unqualified switthes, This activity was completed by 8:55 p.m. on December 17, 1986.
Permanent modifications H6-1/2-86-292, for both unit's EDGs, were completed by April 22, 1987.
The NRC staff's concern regarding the flow of significant safety information within-our organization, both at the equipment manufacturer / contractor level and within our own organization to_ support operability decisions has been addressed by CECO.
In-house procedures have been revised and developed to reflect the individuals' responsibilities with respect to communications with our Architect-Engineers and station management on significant deficiencies.
On August-10, 1990, a guideline was issued for evaluating and informing appropriate levels of management of potential concerns brought to the attention of Engineering and Construction (ENC) personnel.
The guideline outlined the individual's responsibility to evaluate and inform supervision, in a timely manner,-of potential concerns which may-impact plant operation.
Attached to the guideline as additions) reference material was an NRC memo from J. G. Partlow to the five Regional Administrators discussing guidance for-operability determinations in current and improved technical specification programs.
ENC personnel were required to review the guideline and use it until the. formal operability determination procedure was issued in October, 1990.
A lessons-learned document discussing this event was distributed to Nuclear Operations Engineering personnel on August 10, 1990.
This document highlighted the weaknesses identified by a CECO in-house investigation, an independent review by EG&G and the NRC concerns related to this event.
On October-3, 1990, EHC Procedure ENC-QE-40.1, " Evaluation and Review of Potential 10esign Concerns for Impact on Plant Operability" was issued.
Copies were distributed to ENC persvnnel on October 5,1990, with a cover letter signed by-the. Assistant Vice President of ENC discussing the reason for developing _the procedure and conveying the expectation that ENC personnel would adhere to it.
In addition to proceduralizing the program for reviewing potential operability concerns, CECO performed a re-evaluation of the Part 21 program.
It was concluded that revisions were necessary to the Part 21 proct-dures to ensure that timely evaluations of the impact of a Part 21 issue on plant operation were performed and adequately documented.
It was also recommended that a-review schedule be implemented, that reflects on the significance of the issue as determined by a review group consisting of supervisory personnel within the Engineering organization. The recommendations from the re-evaluation-have
-been reviewed and accepted by senior management and procedure revisions are currently-in progress.
Due to the volume of procedures requiring revision, it is' expected that the new process will not be fully proceduralized until the third quarter of 1991; however, ENC intends to initiate the process informally by Apri'l,-1991. Until that time the existing program remains in place.
Ceco _ believes this schedule to be appropriate considering the training being
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ATTACllMENT A (COTINUED) given to the ENC personnel on the operability procedure and the need for promptly addressing potential concerns which may impact plant operation, and the significant emphasis recently given these topics.
CECO has also taken steps to ensure that the architect engineers (A/Es) under our employ perform timely reviews of potential design concerns and promptly report those concerns to the appropriate CECO personnel.
On October 1, 1990, the Nuclear Engineering Department Manager issued a letter to the architect engineers providing a copy of the guideline Ceco issued to it's ENC employees.
This letter directed the A/Es to establish the appropriate procedural guidance to govern reporting of potential operability concerns to CECO.
The A/Es were also requested to place the letter and guideline into the Interim Guidance section of the A/E Guidebook.
The NRC staff's concern that given the CECO engineer's background at the time of this event, he was placed in a responsible position without proper training has been addressed by revising the initial "QA Manual and ENC QA and QE Procedure Indoctrination Training Program".
The Program was revised to include the guideline issued August 10, 1990 to assure the proper levels of management are aware of safety significant issues in a timely manner.
The revised Program was first presented to Engineering personnel on August 27, 1990.
The training program was again revised, to include the operability procedure (ENC-QE-40.1), when ENC-QE-40.1 was approved in October 1990.
Additionally, the procedure and a flowchart outlining the process were discussed in a Nuclear Engineering Department meeting of approximately 100 attendees on October 24, 1990.
Corrective Steos to Avold Further flo]At10R5 The corrective actions taken to date have substantially raised the level of awareness of both CECO engineering personnel as well as A/E personnel of the need for prompt, aggressive reporting and resolution of potential concerns which may impact plant operation.
To ensure that the actions taken thus far are effective, CECO is collecting the operability evaluations which have been completed using the new procedure as well as comments and suggestions for improvement provided by the individuals completing these evaluations.
These items will be reviewed by key ENC personnel and appropriate revisions will be made to the ENC procedure.
Also, recognizing that a factor in this event was inadequate training being provided to the engineer, ENC has developed an enhanced training program on technical specifications, FSAR and accident analyses.
This training is site specific.
It includes a discussion of the licensing basis documents, accident analyses assumptions, accident analyses key parameters and the interrelationships between the technica'. specifications and the FSAR.
The Zion specific class material has been developed and a trial class has been given. Additional Zion specific classes are scheduled for January, 1991.
It is expected that an initial round of classes for the other five stations, including Byron, will be developed and provided at each site and the corporate engineering offices by October, 1991.
The program will then be incorporated into the ongoing training program for engineering personnel.
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ATTAGl MENT A (CONTINUED)
D&tr_When Ful1 Ccepliance Hi11 Br_AcAleysA Full compliance was achieved on December 17, 1986 when the seismically unquallfled switches were jumpered out of the overspeed trip circuitry for the Byron Diesel Generators. Additional corrective actions pertaining to the training of engineering personnel and the flow of safety significant information will be taken and completed as discussed in prior sections of this response.
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