ML20091B945
| ML20091B945 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/27/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9204020162 | |
| Download: ML20091B945 (3) | |
Text
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Downste Grove, Illinois 00515 March 27,1992 U.S. Nuclear Regulatory Commission Washin0 ton, D. C. 20555 Attn: Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Associated with Inspection Report 50-454/92004; 50-455/92004 NRC Docket Numbers 50 454 and 50-455 Referonces:
L. R. Gre0er letter to Cordell Reed dated February 28,1992 transmitting NRC Inspection Report 50-454/92004; 50-455/92004 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) transmitted by the referenced report.
The violation dealt with untimely revisions of Emergency Plan implementing Procedures following revision to the Byron Annex to the Generating Station Emergency Plan.
If there are any questions or comments regardleig this response, please contact Perry Barnes, Compliance Supervisor, at 708/515 7278.
Sinceroly, wg $
Yg T.J.Kovach Nuclear Licensing Manager Attachmem cc:
A. Bert Davis, Regional Administrator - Region ll1 A. H. Hsia, Project Manager, NRR W. J. Kropp, Senior Resident inspector G2000G i
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{DR ADOCK 05o00454 PDR
/l ZNLD/1648/1
i ATTACHMENT Response.tollotice.ofNiolation Inspection ReporL454/92004L455/92004 VIOLATION {454/920040h455/9200400 10 CFR Par 150.54(o) requires that a licensee authorized to possess and operate a nuclear power reactor shail follow and maintain in effect emergency plans which meet the standards in 10 CFR Part 50.47(b) and the requirements to Appendix E to 10 CFR Part 50. The Generating Station Emergency Plan (GSEP), Section 8.5.7, states that Emergency Plan implementing Procedures (HPIP) and corresponding lesson plans shall be developed consistent with the GSEP within 4 months of any GSEP revision.
Contrary to the above, Byron EPIP, BZP 200 A1 Revision 2," Byron Emergency Action Levels" had not been updated as of February 14,1992, to be consistent with Revision 4 of the Byron Annex to the GSEP which had an effectivo date of July 15,1991, oxceeding the 4 month period.
REASON EOR _THE VIOLATION -
Severalinconsistencies were noted between Emergency Action Levels (EALs)in the Byron Annex and those in EPIP BZP 200 A1," Byron Emergency Action Levels".
These inconsistencies resulted from a lack of administrative control over revisions to the Byron Annex.
Six EALs under Condition 6 " Natural and Destructive Phenomena", relating to the river level, were iriadvertently transposed to a su 3erceded version. The suporcoded version was introduced when the word processing c ocument file was copied for the annex update. The word processing file used represented the last revision when all pages of the EAL Section (5.1) were revised (Revision 3b) Management reviews failed to identify that pages which were revised by Revisions 3c and 3d were not the same document files. This resulted in an error being introduced into the Byron Annex EAls (Rev 4). This error was not carrlod into the station EAL implementing proceduto (EPIP BZP 200 A1).
Two EALs under Condition 8," Security Threat", were u raded in the Byron Annex; however, they were not upgraded in the EPIP BZP 200
- 1. The EAL associated with protected area intrusion was upgraded from an Unusual Event to an Aleri, and the EAL assoc!ated with vital area intrusion was upgraded from an Alert to a Site Emergency.
Also, an additional EAL was added to Condition 8 EAls that a bomb device discovarod in a vital area should be declared as an Alert.
i These changes were included during the draf t of Revision 4 to the Byron Annex in response to an annual annex review, which identified the need to upgrade the Byron l
Security EALs to address issues brought up during a Quad Cities Exercise (those changes had previously been mndo to Quad Cities and Dresden EALs). Subsequent to l-the draft, these changes were not highlighted durin0 the revision process and were not -
included in the change summary for Revision 4.
The Byron Station Security Plan, procedures, and contingency actions operate independently of EPIP BZP 200-A1 and of the Byron Annex. Regardless of how the station classified the event, Station Security would have responded according to their own plan and procedures to a posed threat. At no time was the public safety, nor the security of the Station, compromleed by these inconsistencies.
ZNLD/1648/2 I
o CORRECIIVE SIEES_TAKEN AND.RESULTS ACHIEVED The inconsistencies were identifled, by Byron Station and Nuclear Services Emergency Preparedness NSEP) personnel, on January 23,1992 during a review of EAls, lhls review was bei(ng conducted to incorporate improvements to L:mergency Actio (EALs) and Philosophy statements. The conect EALs were identified and appropriate revisions to station procedures and the GSEP Annex were initiated. The affected Byron Station procedures were approvod for use on February 6,1992.
Revision 4a to the Byron Annex was onsite revimved on February 22,1992, to correct the Condition 6 EAL inconsistencies. The offsite review was completed on March 6, 1992. The Byron Station GSEP Annex Phl!osophy document was also updated to reflect the EAL changes.
All revisions to EALs in progress were stopped on January 27,1992 to determine the extent of the problem and ensure errors were not introduced into the newly written l
EALs. Efforts were redirected to perform a line by line comparison of the EAls in all six Station Annexes and relevant Station EPIPs. The comparison was completed on February 25,1992 and revealed that there were no technicalinconsistenclos at the other five stations.
CORRECIIVE SIEESlHAT_WILLBE TAKEN.TO AVOID EURTHER_ VIOLATION The GSEP establishes the policy by which revisions to the station specific annexes are controlled. This policy is generalin nature and a need was identified by NSEP personnel to provide more detailed information in the form of a procedure. Such a 3rocedure was in conceptual development at the time of the Byron Station inspection.
9SEP has accelerated development of administrative procedure, CEPIP 1000 4, to t
provide guidance for the control of GSEP Annex revisions. The procedure is to include the following:
A change log system for development and approval of draft chan908 tracked by a designated NSEP Individual.
The unique numbering sequence for tracking of draft changes.
The process for reviewing and identifying changes made to draft changes will include management verification that the correct document files are used.
A detailed change summary required with each revision and revision bars i
j indicating the items that have been changed from the previous revision.
The Corporate Emerb,ency Plan Implementing Procedure, CEPIP 1000-4, will be completed by April 3 1992.
i RATE _WHEREULLCQMPLIANCE_WJLLBEACHIEVED
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Full compilance will be achieved on April 30,1992.
ZNLD/1648/3
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