ML20087D927
| ML20087D927 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/09/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201170198 | |
| Download: ML20087D927 (3) | |
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Commonwealth Udistn O
1400 Opus Place j
Downers Grove, Illinois 60W January 9, 1992 U.S. Huc! tar Regulatory Commission Attn:
Documeitt Control Desi.
Ha:htngton, DC 20555
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos 50-454/r.0M; 50-455/91026 liRC_Dochet NumbetLft45 Land ' J-A5L_____
Reference:
- 0. Clayton letter to Cordell Reed dattd Der. ember 12, 1991 transinitting NRC Inspection Report 50-454/91026: 50-455/91026 4
Attachment A provides Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report.
The N0V cited one Severity 1.evel IV violation.
The violation concerned the failure to document valve performance data of the 15X1/3 and 2SX169B valve on the it 'nical Specification Data Packege Cover Sheet.
Additional inf' tion that you requested in the reference letter is provided in Attachm4 If your staff ha. iny questions or comments concerning this letter, please refer them to Denise $accomhndo, Compliance Enginee) 6t 008) 515-7285.
Very truly your, m
7.
vach Nuclear Li sing Manager Attachments cc:
A. Bert Davis, NRC Regional Administrator - Rill A. Hsia, Project Henager - NRR H. Kropp. Dr. int Resident int,pector 1
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Attachment A Rf;PONSE ) N011CE Of V10LA110N 454/91026; 455/91026 lochnical Specifttation 6.8.1 reautres that written procedures shall be estabitshed, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Contrary to the above, failure of valva ISX173 on April 17, 1989, and September 26, 1990, and a failure of valve 2SX1698 on April IS, 1991, during Technical Specification surveillances were not documented on the Technical Sp>ctftcation Surveillance Data Packag? Cover Sheet as required by procedure DAP 1400-9, " Technical Specification Data Package Cover Sheet Completion and Use", Revision 10 paragraph 4.b.2.
Valve ISX173 is the essential service water inlet valve to variout coolers for the Unit I diesel driven auxiliary feedwater pump, and valve 2SX1690 is the essential service water inlet valve for the 2B emergency diesel generator jacket water heat exchanger.
BESE0NSE Rea$ondor_theJio.lation There is a lack of understanding by Technical Staff persony11 on the detall of information to-be placed on the Surveillance Data Package Cover Sheet.
- CORRECIIYLSIIESlAIDL6MDJESULISlCHIEED A task force was formed to review the SX173 problem. An action plan was developed.
Those actions were detailed in a letter to the NRC on 12/(/91 in response to the Notice of Violation 454/91024; 455/91024 (provided in Attachment C). Valve 2SX1690 was repaired by replacing the solenoid within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the time the problem was discovered.
On 1/7/92 a memo containing interim instructions has been issued by the Assistant Superintendent of Operating to Department Heads with directions to ensure their personnel understand the intent of documenting actions taken for a degraded or-falled component.
i COBRECIIVLSIIES_Ill&LBILL DE_IAKEtL10E0tDl0AIEERll0LAIl0N The Byron Administrative Procedures (140r, Series) are_being-reviewed to
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determine the clarifications needed to provide appropriate direction on the disposition and docurnentation of degrsded or failed support eautoment discovered during the performance of Technical Specification survelliances.
g These procedures are expected to be revised by 2-1-92._
L DAIE3H E! LEU 1LC0tfilANC LtH1L3LACillEE D full compilance was achieved on 1/7/92 with the issuance of the memo which provided interim _instrLctions on documenting action taken for a degraded or t
failed component.
i ZNLD/1416/2
The following information was requested 'n the Reference letter.
"If failures of the SX supply valve to the EDG 1(2)SX169A(0), occur when these valves are stioked immediately prior to the performance of EDG TS surveillances, would the failures be considered as a EDG failure per 15 table 4.8.l.1" i
RESE0NSE The stroking of the Essential Service Water (SX) supply valves is done to ensure service water is available for cooling of the Emergency Diesel Generators (EDG).
Rcvision 3 of the Dyron/Braidwood UFSAR, Section 6.3.1.2, states " Lack of essential service water flow at the time the diesel generator starts will not prevent accomplishment of its safety function." In the event the valve should fati to open the function would be assessed.
If the valve is not able to be opened, the surveillance would be failed and the EDG declared inoperable.
If the valve can be failed open then tne surveillance would be_ continued and pasted providing that acceptance criteria are met. A work request would be written to repair the degraded SX supply valve.
As directed by BEP.0 " Reactor Trip or Safety injection", step 15, an operator is also dispatched when starting the EDG to verify the EDG operability and that the SX169 valve has opened.
A low cooling flow local alarm would actuate if the valve had not opened and appropriate action would be taken by the operator.
This is an "immediate action" which is expected to be completed within ten minutes.
The B/B UFSAR states, "An engine has been tested under load with the closed cycle cooling system functioning but without service water.
The engine was started from a " Keep Warm" condition and operated for 20 minutes at an average load of 4000 kW without reaching the temperature alarm setpoints."
"The method (s) to be utilized to assess failures identified during surveillance that do not pertain to the Acceptance Criteria identified in the surveillance procedure but clearly aftect operability of a system."
RESP 0BSE A review of-the surveillance results by an SRO wi.11 continue to De the method used to assess failures.
The SRO's are instructed to contact the Operating Engineer if there islany concern regarding plant status.
The information provided to the SRO must be complete and all failures need to be noted on the surveillance package cover sheet.
Methods to improve this-document tion are being reviewed, As vn interim measure, a memo has been issued to all Department Heads instructing them to ensure their personnel understand the intent of documenting actions taken for a degraded or failed component.
ZNLD/1416/3
I Commonwealth Edison 1400 opus Place Downers Grove, litinois C.0515 ATTAcilMENT c Docornbor 0,1991 U.S. Nuclear Regulatory Commission Atto: Document Contr01 Dosh Washington, DC 20555
Subject:
Dyron teJcloar Power Station Units 1 and 2 Responto to Notic9 of Violation Inspect!cn P4 port Nov. 50 454/91024; 50-455/91024 NRC Docket Numbers 50 454 and 50 455 Rotorenco:
E. Groonman letter to Cordell Rood dated November 6,1991 transmitting NRC Inspo0 tion Report 50-454/91024;50-455/91024 Enclosed is Commonwealth Edison Company's (CECO) roc 3onso to the NOV) which was transmittod with the reference loitor and Notico of Violation (The NOV cited ono Soverity Lovel IV violation. Tho violation Inspection Report.
concerned the untimely resolution of failures associated with the estontial service
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water supply valvo. CECO's rosponse is provided in the attachment.
If your stall has any questions or comments concorning this lettor, please refer them to Denise Saccomando. Complianco Enginoor at (708) 515 7285, Very truly your,
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r vi.JA(ovach Nuclear Lic6fising Manager Attachment ec:
A. Bor1 Davis, NRC Regional Administrator Rill A. Hsia, Project Manager - NRR W. Kropp, Senior Ros dont inspector
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ZNLD/1339/1
RESPOl4SE TO IJOTICE OF VIOLATION 454/01024;455/91024 YlOLMION lhd 10 CFR Part 50, Appendix B, Critorion XVI requires that measures shall be estab is e to assure conditions adverso to quality, such as failuros and defectivo oquipment are promptly cortocted and thatihose measures shall assure that the cause of the condition is dotermined and correctivo action taken to procludo repetition.
Contrary to the abovo, repetitivo f ailures of tho essential service water supply valvo (ISX173) to open woro not promptly corrected, Valvo ISX173 suppilos essential service water to the oil cooler, cubicle coolor, fl ht anglo lubo oil coolor and the engino 0
closed cycle hont exchangor for the il! diosol driven auxiliary foodwateraump. The f ailure of valvo 1SX173 to olther open or cines has occurted four tirnos s nco October 1990. Thr90 provlous problems with ISX173 between December 1985 and October 1990 woro identiflod as slow operation.
BESEOttSE Since 1985 occasional porformance anomallos with 1SX173 valve havo occured whilo oorforming surveillance OVS 7.1.2.1.a 2, *Diosol Drivon Auxiliary Feedwater Pump critoria for the surveillance. Thoroforo aorformanco problems f
were not consistently noted by a Dovlaulon Report (DVR) or Discropancy Report (DR).
In March of 1991 a Problem Analysis Data Shoot (PADS) 91010 was generated to ovaluato and correct the noted concerns with 1SX173 valve operation. A delay in This untimely processing resulted in untimely recommendation of corrective act out ined in Maintenanco Momo 40011, " Problem Analysis Processing Guidelinos".
ROBBE01LVESIEPATAKEhtAUD_BESDLIS. ACHIEYER Start up on On 10/25/91, proceduros DOP AF 7,' Auxillary Foodwater Pump 8 (Diosol) ty Pump Rectro", and 1/2 DVS 7.1.2.1.a 2, *Diosol Driven Auxiliary Foodwater Mont1 Survolllance", woro revised to include a requiremont that the 1SX173 is stroked prior to performing the surveillance. This 1SX173 stroking is to ensure protection to the AF pump is maintained. The valvo operation has also tmn added to noted and that nc' mal plant trending / tracking of its performance will tako place.
The station will continue to ovaluato the valvo's performanco, the application, and air configuration. This ovaluation will be completed during the Byron U 2 refuel outage (B2R03). 02U3 is scheduled for completion in May 1992.
In addillon, Byron station and corpo,ato engtneering will evaluate the usos of predictive
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and preventative maintenance for those types of va vos. The evaluation and associated recommendations will bo completed by 12/31/91.
F CDBBEC.TIVE_SIEESlH6T_WILLDEJAKERIQAVQ1R EUBiliEB VJOLAllOH To improve trending of identiflod performanco problems, an onhancement will be made and tho (4uclear Plant to the cross leforencing(of the Total Job Managomont (TJM) Memo 50 Rollability Data System NPRDS) databacos, fdaintenanco Equipment Namo Plato Data Verification" will be intilated to continually collect and verify now and existing equipment nameplato data as part of normal maintenance.
This enhancement is expected to be completed by 6/1/92.
Dyron Station is in the process of rovlowing the DVR threshold and other documentation inillation to f acilitato the trending of equipment problems. This review is expected to be conipleted by G/30/92.
It should be noted that the primary mechanism for resolution of safety related failuros at Dyron continuos to be the DVR program. Por DAP 1000 8 'Malntonanco Problem Analysis Program" section D.6
- PADS are notintended to replace upper tier documents such as DR's, LER's, or DVR's. PADS may be closed out or completed by the up3er tier document." At Dyron, PADS will continuo to be used at the discretion of the s ation to supplomont safety rolated problem analysis. The PADS cited in the notico of violation was generated pro actively by the Assistanco Superintendent of Maintenance to furillet investigato strokin0 problems identified by previous DVR's.
The following long term correctivo actions are being imptomontod:
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Rovised PADS processing guidelines:
Maintenance Memo 400-11 " Problem Analysis Processing Guidelinos" will be I
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revised to incorporato a duo dato extension approval process that takes into account the safety significance of the equipment and the problem identiflod.
At a minimum (for saloty related problems), the extension process will required the approval of an Operating Enginoor or a Licensed Senior Reactor Operator Designoo.
Review current PADS backlog to assure timoly resolutions of important problems:
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All outstanding Problem Analysis Data Sheets (PADS) will be reviewed and a.
those actions not mooting the now guidanco in Maintenanco Memo 40011 will be completed or exlonded as appropriato.
RAIEEJdEREULLflOMEL] NICE _W1LkD EAGBIEEER Full compliance was achloved on 10/25/91 with the issuance of levised surveillruv:e proceduros.
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