ML20096E013

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Responds to NRC Re Violations Noted in Insp Repts 50-454/92-07 & 50-455/92-07 on 920309-13.Corrective Actions: Fire Marshalls Ofc Issued Memo Re Requirements for Ensuring Fire Watches Properly Positioned to Cover Assigned Jobs
ML20096E013
Person / Time
Site: Byron  Constellation icon.png
Issue date: 05/08/1992
From: Kovach T
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9205190016
Download: ML20096E013 (3)


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- [ \\ Commonwcalth Edison

/ 1400 Opus Place oowners Grove, Illinois 60515 -

May 8,1992 U.S. Nuclear Regulatory Commission Washing;on, D.C. 20555 ATTN: Document Control Desk

Subject:

Byron Station Units 1 and 2 Response to Notice of Violation Inspection Report 50-454/32007; 50-455/92007 NBC_D_ochalNoaJiG-4514mdED-A53 L

Reference:

M. Ring letter to Cordell Rced dated April 9,1952, transmitting NRC Inspection Report 50-454/92007; 50-455/92007 Enclosed is Comraonwealth Edison Company's response to the subject Notice of Violation (NOV) wt 'ch was transmitted with the reference letter and Inspection Report. The NOV cited one Severity Level IV violation requiring a response. The violation is related to placement of fire watches.

Our response to the violation is p vided in the attachment, if your staff has i

any questions or comments regarding this response, please refer them to Sara P

Reece-Koenig, Compliance Engineer, at (708) 515-7250.

Sincerely, ke y. Y b

T.J. Kovach Nuclear Licensing Manager cc:

A. Bert Davis, Regional Adm'11strator - Region ill meo.

W. Kropp, Senior Resident ins 3ector 88' A. Hsia, Project Manager - NR R ST

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RESPONSE TO NOTICE OF VIOLATION INSEECIlotLBEEQBT 454/9200lL45519200Z Molatloaf45E455)l92007-02)

During an NRC inspection conducted on March 9-13,1992 a violation of NRC requirements was identified.- In accordance with the " General Statement of Policy and Procurement for NRC Enforcement Actions" 10 CFR Part 2, Appendix C (1991), the violation is listed below:

Tchnical Specification 6.8.1.h required that written procedures be established, implemented, and maintained for the fire protection program.

Byron Administrative Procedure 1100 20, " Fire Prevention When Welding, Cutting and

' Grinding", Revision 6, reau! red that one or more individuals be designated ta watch for potential fire or smolde, ring _during each welding, cutting and grinding operation.

C:ontrary to the above, on March 10,1992, the inspector observed two cutting / welding operations in the turbine building on elevation 380 feet nehr column H-31 th at utilized only one fire watch. The fire watch was located beyond a reasonable distance to provide adequate coverage for one of the two cutting and welding operations.

BenonioLtbe.NioLalloR Byron Admin (strative Procedure 1100-20, " Fire Prevention When Welding, Cutting, and Grinding,".does allow more than one cutting / welding / grinding operation to use a single fire watch. Ste 3.a. of the procedure states,"One or more mdividuals in each wekin cutting and gri ding area shall be designated to watch for x)tential fire or sn:oldering.g,

- This refers to a given area where the work activities are ta <ing place and not to each operation thus allowing for one fire watch to perform fire watch activities for more than one operation. Placement of the fire watch es) is determined by the Fire Marshall's ofilce after conferring with the Supervisor i charge of the work. This process ensures proper positioning of the fire watch in order for the watch to be alert in observing more than one operation.

~ On March 10,1992, the NRC Inspector observed two cutting / welding operations in the Turbine building that were using only one fire watch and the fire watch was located -

beyond a reasonable distance to provide adequate coverage for one of the two cutting and welding operations. The Fire Marshall and the Supennsor in charge of the work had discussed both operations and a location had been identified to place one fire watch to cover both jobs. The fire watch person failed to stay in the area where -

adequate coverage could be provided for both jobs.

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CorrecilveEleps_Taken and ResultaAchlaySd.

^ 'b 1The work in progress was immediately stopped.- A fire watch was then established at both work ;ocations.---

ye The fire'watedwho was beyond a reasonable distance was made aware of the -

T importance of his location relative to both work locations and that this must remain in L

.effect for 30 minutes after work has been completed.

1 Coriacilvejlepa_That Will Be Takaalolyolci Fu:ther Violailpa

The Fire Marshall's office has issued a memo to all Department Heads on the rec!uiremente for ensuring fire watches are properly positioned to cover assigne pbs.

- Th's will also be included in Fire Watch training by July 1,1992.

Date When F.ulLGQmp]lanc1YMllBeAchlRYed

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Full compliance was achieved on March.10,1992, with the proper placement of fire watches for ongoing operations.-

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