ML20086H941

Responds to NRC Re Violations Noted in Insp Repts 50-454/91-24 & 50-455/91-24.Corrective Actions:Procedures BOP AF-7, AFW Pump B (Diesel) Startup On... & 1/2 Bvs 7.1.2.1.a-2, Diesel Driven AFW Monthy... Revised

ML20086H941
Person / Time
Site:	Byron
Issue date:	12/06/1991
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9112100198
Download: ML20086H941 (3)

Text

y . - . _ _ _ _ . . . _ . . . - _, _

'\L 'Cemmon'wtalth Edison

1. 1400 opus Place :

-=

-l V Downers Gove, Illinois 60515 f

December 6,1991 o

l U.S. Nuclear Regulatory Commission Attn:- Document Control Desk Washington, DC - 20555 -

- 1

Subject:

Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation

- Inspection Report Nos. 50 454/91024; 50-455/91024

- NRC Docket Numbers 50-454 and 50-455

~

Reference:

- E. Greenman letter to Cordell Reed dated November 6,1991

transmitting NRC Inspection Report 454/91024;50-455/91024.

Enclosed is Commonwealth Edison Company's (CECO) res mnse to the Notice of Violation (NOV) which was transmitted with the reference lelter and

Inspection Report. The NOV cited one Severity Level IV violation. The violation -

- concerned the untimely resolution of failures associated with the essential service water supply valve. CECO's response is provided in the attachment.

if your staff has any questions or coinments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at (708) 515-7285.

Very truly your,

, M

.J evach Nuclear Lic sing Manager ' .

- Attachment' -

cc: A. Bert Davis, NRC Regional Administrator - Rlli A. Hsia, Project Manager - NRR

. W. Kropp, Senior Resident inspector 9112i00193 - 9 fl206 .

PDR- ADOCK oGOso454 g Q oGR ZNLD/1339/1 1

, , , . . ., - ,~ ,

4 RESPONSE TO NOTICE OF VIOLATION 454/91024;455/91024 VIOLATION 10 CFR Part 50, Appendix 0. Criterion XVI requires that measures shall be established to assure conditions adverse to quality, such as failures and defective equipment are prompti' corrected and that these measures shall assure that the cause of the conditiv lo determined and corrective action taken to preclude repetition.

Contr% to the above, repetitive failures of the essential service water supply valve (ISX173) to open were not prompdy corrected. Valve ISX173 supplies essential  ;

service water to the oil cooler, cubicle cooler, right angle lube oil cooler and the engine closed cycle heat exchanger for the 1B diesel driven auxillary fondwater aump. The f ailure of valve 1SX173 to either opon or close han cccurred four times s r,ce October 1990. T hree previous problems with ISX173 between December 1985 and October 1990 were identified as slow operation.

REGRONSE Since 1985 occasional performance anomalies with ISX173 vaive have occured while performing surteillance BVS 7.1.2.1.a-2," Diesel Driven Auxillaty Feedwater Pump Monthly Surveillance". The valve operation was not included as part of the acceptance critoria for the surveillance. Therefore 3erformance problems with the ISX173 valve woro not consistently noted by a Devlaulon Report (DVR) or Discrepancy Report (DR).

In Mar 1 of 1991 a Problem Ana'ysis Data Sheet (PADS) 91010 was generated to evaluate and correct the noted concerns with ISX173 valve operation. A delay in processing sesulted in untimely recommendation of corrective actions. This untimely res aonse is not consistent with the Station's normal processing timeframe for PADS as out ined in Maintenance Memo 400-11. " Problem Analysis Processing Gulde'ines".

COR D ECIIVESIE PS_TAKEhlAN D_RE SULTRAGHitiV E R On 10/25/91, procedores BOP AF 7, " Auxiliary Feodwater Pump B (Diesel) Start up on Recirc" and 1/2 BVS 7.1.2.1.e 2," Diesel Driven Auxiliary Feedwmer Monthly Pump Survellianc9", were revised to include a requirement that the 1SX173 is stroked prior to performing the surveillance. This ISX173 stroking is to ensure protection to the AF pump is maintained. The valve operation has also been added to the acceptance criteria for the surveillance. This wif. ensure that the as found condillon of this valve is noted and that normet plant trending / tracking of its performance will take place.

T he station will continue to evaluate the valve's performance, the application, and air configuration. This evaluation will be completed during the Byron U 2 refuel outage (B2R03) B2R03 is scheduled for completion in May 1992.

In addition, Byron station and corporate engineering will evaluate the uses of predictive and preventative maintenance for these types of valves. The evaluation and associated recommendations will be completed by 12/31/91.

- ZNLD/1307/1

CORRE011VE STEPS _TilAT WILL DE 1 AKENIO AVOIDIURT HER VIOLATION To improve tmnding of identified performance problems, an enhancement will be made to the cross referencing of the Total Job Mana gement (TJM) and the Nuclear Plant Reliability Data System [NPRDS) databascs. Nialntenance Memo 50010 *Dyron Equipment Name Plate Data Verification

• will be initiated to continually collect and verify new and existing equipment nameplate data as pmt of normal maintenance.

1 his enhancement is expected to be cornpleted by 6/1/92.

Dyron Station is in the process of reviewing the DVR threshold and other ,

documentation initiation to f acilitate the trending of equipment problems. This review is i expected to bn completed by 6/30/92. l lt should be noted that the primary mechanism for resolution of safety isiated f ailures nt Dyron continues to be the DVR program. Por BAP 1000-8 " Maintenance Prvblem Annlysis Program" section D.0 " PADS are not intended to replace upper tier documents l 90clias DR's, LER's, or DVR's. PADS may be closed out or completed by the upper tier document." At Byron, PADS will continue to be used at the discretion of the station to supplement safety-related problem analysis. The PADS cited in the notice of vlolation was generated pro actively by the Assistance Superintendent of Maintenance to further investigate stroldng problems identified by previous DVR's.

The following long term corrective actions are being implemented:

1. Revised PADS processing guidelines:

a. Maintenance Memo 40011 " Problem Analysis Processing Guidelines" will be revised to incorporate a due date extension approval process that takes into account the safety significance of the equipment and the problem ,dentitled.

At a minimum (for safety related problems), the extension process will required the approval of an Operating Engineer or a Licensed Senior Reactor Operator Designee.

2. Review current PADS backlog to assure timely resolutions of important problems:

a. All outstanding Problem Analysis Data Sheets (PADS) will be reviewed and those actions not meeting the new guldance in Mo!ntenance Memo 400-11 will be completed or extended as appropriate.

D ATE.WH E tLEU LLODM PL! AN C E WILL B E. ACHI EVE D Full compliance was achieved on 10/25/91 with the issuance of revised surveillance procedures.

L l

ZNLD/1367/2

_ _ _ _ _ _ _ . _ _ . . ._ . _ _ _ _ _ _ __ - __