ML20059G299

Notice of Violation from Insp on 930707-0930.Violation Noted:Licensee Did Not Follow Appropriate Surveillance Test Procedures by Failing to Have Independent Verification Performed

ML20059G299
Person / Time
Site:	Byron
Issue date:	11/01/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059G298	List: ML20059G294 ML20059G299 ML20059G316
References
50-454-93-12, 50-455-93-12, NUDOCS 9311080061
Download: ML20059G299 (3)

Text

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NOTICE OF VIOLATION Commonwealth Edison Company Dockets No. 50-454; 50-455 Byron Station, Units 1 and 2 Licenses No. NPF-37; NPF-66 During an NRC inspection conducted from July 7 through September 30, 1993, two violations of NRC requirements were identified. In accordance with.the

" General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1993), the violations are listed below:

1. 10 CFR Part 50, Appendix B, Criterion V states, in part, that activities -

affecting quality shall be prescribed by documented instructions or procedures, of a type appropriate to the circumstances, and shall be.

accomplished in accordance with these instructions or procedures.

2BOS 3.2.1.1.a-1, " Unit Two Train A Manual Safety injection Initiation and Manual Phase A Initiation Surveillance," requires placing Abe input error inhibit switch in the inhibit position as part of the restoration from the surveillance. Independent verification is required for this step.

280P IP-6, " Restoring AC Input to an Instrument Bus Inverter," provides the sequence of steps for returning an instrument bus from an alternate power supply to the main power supply.

Fire protection test procedure 2BHS 7.10.3.2.b.1-7, " Low Pressure CO, i System Actuating 18 Month Surveillance," provides the' sequence of steps for testing the CO, system in the lower cable spreading rooms.

Contrary to the above:

a. On September 5,1993, during the performance of 280S 3.2.1.1.a-1, a licensed operator did not follow the appropriate surveillance test procedures by failing to have an independent. verification performed and then manipulating the incorrect switch.

b. On September 7,1993, while performing electrical preventive maintenance on inverter 211 for instrument bus vcitage adjustment, the operators did not follow the sequence required by the procedure and incorrectly transferred bus 213, instead of bus 211, to the main feed inverter, which was out of service.

c. On September 10, 1993, during the performance of 2B0P IP-6, in the  !

Unit 2 lower cable spreading room, the technicians did not follow procedures and manually actuated the CO, system in the wrong lower cable spreading room zone. The CO, system should nave been actuated in zone 2S-46; however, it was activated in zone 2S-45.

This is a Severity Level IV violation (Supplement I).

93110B0061 931101 .

PDR ADDCK 05000454 0 PDa 1

Notice of Violation 2

2. Byron Technical Specification 6.8.1 states, in part, that the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, shall be established, implemented, and ,

maintained. Administrative procedures are included in those procedures t recommended by Regulatory Guide 1.33, Revision 2, February 1978.

r Byron Administrative Procedures, BAP 1210-1 Attachment A.3, " Review of. '

Special Procedures / Tests / Experiments"; BAP 1310-8, "Special Procedures / Test / Experiments"; BAP 1400-6, " Technical Specification -

Limiting Condition for Operation Action Requirements (LC0AR)"; and BAP  ;

1600-llA1, " Nuclear Work Request Testing Requirements," require proper distribution and review of special tests and work activities.

Contrary to the above,

a. On June 14, 1993, it was identified that a post maintenaEce test '

work package, dated March 1993, for the Containment Chilled Water system, was not properly completed by the Tech Staff Engineer, nor :

was it properly reviewed by the Senior Reactor Operator.

b. On June 25, 1993, it was identified that the Byron Administrative Procedures for the review and distribution of 66 Special Plant Procedures and 70 LC0ARs were not properly followed, between 1985 '

and 1992.

This is a Severity Level IV violation (Supplement I).

With respect to violation 1, pursuant to the provisions of 10 CFR 2.201, -

Commonwealth Edison Company is hereby required to submit a written statement j or explanation to the U. S. Nuclear Regulatory Commission, ATTN: Document i Control Desk, Washington, D. C. 20555 with a copy to the Regional '!

Administrator, Region 111, 799 Roosevelt Road, Glen Ellyn, IL, 60137, and a copy to the NRC Resident' inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting the Notice of 4 Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Viclation" and should include for each violation: (1) the reason .

for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) i the corrective steps that will be taken to avoid further violations, and (4)'

the date when full compliance will be achieved. If an adequate reply. is not received within the time specified in the Notice, an order may be issued to q show cause why the license should not be modified, suspended, or revoked, or wSy such other action as may be proper should not be.taken. Where good cause is shown, consideration wil' be given to extending the response time.

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. Notice of Violation .3' ,

With regard to violation 2, the inspection showed that steps had been taken to I correct the identified violation and to prevent recurrence. Consequently, no.  :;

reply to the violation is retp' red and we have no further questions regarding -i' this matter.

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Dated at Glen Ellyn, Illinois  :

this l # day of November.1993 Y

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