ML20082F214
| ML20082F214 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/14/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082F209 | List: |
| References | |
| 7613N, NUDOCS 8311280474 | |
| Download: ML20082F214 (3) | |
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J Address Reply to: Post Offica Box 767
) one First National Pla22, Chicago, Ilknois i(,s Chicago. Illinois 60690 November 14, 1983 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station Units 1 and 2 I&E Inspection Report Nos. 50-454/83-40 and 50-455/83-30 Reference (a):
October 11, 1983, letter from J. F.
Streeter to Cordell Reed.
Deer Mr. Keppler:
Reference (a) provided the results of an inspection con-ducted by Mr. M.
Ring and C. Vandenburgh during August and Septembcs, 1983 at Byron Generating Station.
During that inspection certain activities were found to be in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to in reference (a).
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects tPese statements are not based on my personal know-ledge but upon 11 formation furnished by otner Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address further questions regarding this matter to this office.
Very truly yours, e
_/t g/LA4" sse D. L. Farrar Director of Nuclear Licensing TRT/lm
-7613N 8311280474 831121 PDR ADOCK 05000454 G
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION Violation 10 CFR 50, Appendix B, Criterion Y states in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings...".
10 CFR 50, Appendix B, Criterion XIV states in part, that..." Measures shall also be established for indicating the operating status of structures, systems and components of the nuclear power plant...such as by tagging valves and switches, to prevent inadvertant operation."
Byron Administrative Procedure 300-18 states in part
..."The operator (s) performing the OOS... initials the Equipment Outage Form in the column '005 by' after performing the 00S task."
The procedure also states that " Work on safety-related or other important systems require an independent verification of the tagging and alignment by a second qualified. individual...and shall be documented on the Outage Form...".
Production Instruction No. 1-3-A-1 states in part, that... Equipment with...an OUT-0F-SERVICE CARD attached shall not be operated under any circumstance." and ".. 0UT-OF-SERVICE CARDS must be removed before energizing or operating equipment and the same or other cards must be placed on the equipment before resuming work."
Contrary to the above, Production Instruction No. 1-3-A-1 was not followed in two instances.
On September 7, 1983, during the performance of VE 128.10, an operator positioned a handswitch without removing the Out-of-Service (005) that was attached to the handswitch.
On September 8, during the Structural Integrity Test. an operator started to position a valve with an 00S tag still attached.
When questioned by the Test Engineer, the operator correctly removed the tag under temporary lift and with Shift Engineer permission.
The operator completed positioning the valve and then incorrectly rehung the tag with the valve in a position different from that specified by the 00S.
Byron Administrative Procedure (BAP) 300-18 was not followed in that on September 2, 1983, during the line-up for PC 58.11, an operator placed a series of 00S cards on valve handwheels and breaker panels without initialing the Equipment Outage Form as each task was completed.
The required independent verification and subsequent documentation on the Equipment Outage Form was not performed for this line-up.
i Further, none of the approximately one thousand Equipment Outage Forms processed under the current (as of September 2) revision of the BAP contained independent verification.
. e,*
l s.* Corrective Action Taken and Results Achieved The operator who rehung the out-of-service card after reposi-tioning the valve during the temporary lift was immediately reprimanded by the Shift Engineer.
The proper =cthod of card control during a temporary lift was reviewed with him and reinforced to all operators by the Shift Supervisors through daily-orders, Shift Engineers notes, and briefings.
Independent verification will be implemented by a change to BAP 300-18, " Removing and Returning Equipment Out-of-Service."
For Out-of-Services that took place prior to' implementation of the pending revision, verification will be accomplished in a variety of ways.
First, they will undergo independent verification on the Return-to-Service after the revision to BAP 300-18 becomes effective.
Second, as part of our normal method of business, after systems are turned over to the Operations Department, Mechanical and Electrical line-ups will be performed to insure the proper position of equipment and establish Operating Department Control.
Third, prior to Core Load all Out-of-Services on the unit must be " field" verified as accurate, applicable and necessary.
Finally, all surveillances required for a particular mode of unit operation must be satisfactorily performed prior to entry into that mode.
This series of events will preclude any possibility of system misalignment.
Operators will be required to hand carry a field copy of the outage form.on out-of-service and return to service jobs.
They will initial this field copy.after each card is hung or removed unless instructed otherwise by Shift Supervision.
Action Taken to Prevent Recurrence The proper method of performing Out-of-Service jobs were reinforced to all shift personnel through daily orders, Shift Engineer Notes and shift briefings.
BAP 300-18 will be revised to clarify proper out-of-service operations.
Date When Full Compliance Will Be Achieved December 15, 1983.
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