ML20099C969

Responds to NRC Re Open Item Noted in Insp Repts 50-454/92-09,50-455/92-09,50-456/92-09 & 50-457/92-09. Corrective Actions:Open Items Will Continue to Be Reviewed as Part of 2-yr Review Program & AOPs Deleted from Program

ML20099C969
Person / Time
Site:	Byron, Braidwood
Issue date:	07/31/1992
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9208050008
Download: ML20099C969 (3)

Text

_

Commonwosith Edison

_Ai 1400 Opus Place i

v Downers Grove, Illinois 6n515 July 31, 1992 U.S. Nuclear Regulatory Commission Washington, D. C, 20555 Attnf Document Control Desk

Subject:

Braidwood Nuclear Power Station Unit I and 2 Byron Nuclear Power Station Unit 1 and 2 Response to Open Item Associated with

_ Inspection Report 50-454(455)/92009; 50-456(457)/92009 NRC Docket Numbers 50-454, 50-455, 50-456, and 50-457

-Raference:

G.--C. Wright letter to Cordell. Reed dated

~

July 1, 1992, transmitting Inspection Report 50-454(455)/92009; 50-456(457)/92009 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Open Item which was transmitted with the referenced letter.

.The Open Item concerned the completion of revisions to the operating abnormal procedures which support'the E0P's, and the performance of a L

complete verification and validation for the revisions.

If there are any questions or_ comments regarding this response, please

. contact Sara Reece-Koenig Compilance Engineer, at 708/515-7250.

Very truly_yours, kbk&Wg L

T.J. Kovach Nuclear Licens',1g Manager Attachments jbc: A, Bert-Davis, Regional Administrator - Region III

-)

H.EJ. Kropp, Senior Resident Inspector, Byron S. DuPont,-Senior-Resident-Inspector, Braldwood

' A.~ 11 Hsia, Project Manager, NRR R 2Pulsifer, Project Manager, NRR 9208050000.920731 PDR ADOCK 0500o454 p /.-

PDR.

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.:2NLD/2060/1

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_1&IACIR1RILA.

Pesponse_to.Open. item 454,_4%,_4 %,.457L92009-01 1.

Provide a schedule for completion of revisions to the OAs and the pet formarice of a complete V&V.

The Schedule for completion of the OAn consists of 2 Parts.

PART 1:

Par t one will eliminate the exitit.ing tempora - procedure changes (TPCs) common to both stations by incorporat.ng them into perinanent revisions. Validations and verifications will be performed only on the parts of the procedurer. that are changed.

These procedures will be assigned alphanumeric revision designators to indicate that the procedures still require complete revisions. The procedure revisions incorporating the common TPCs will be done by September 30, 1992.

PART 2:

The OAs requiro major revisions. Ther.e OA revisions will be written following the standards in the Pcocedure Generation Package Writets Guide (PGP). This effort will include the incorporation of the problem files that have been accumulated, plant specific TPCs, and V&V comment s.

The revisions are being done concurrently with the alphanumeric revisions mentioned in Part 1.

These pt;cedures will be oxercised on the simulator or " table topped" per the PGP.

<11 local actions within the plant will undergo a walkthrough validatio..

)

to verify the local actions can be perforrned as written.

The major revisions, including V & V and supporting documentation, will be completed by July 31, 1994.

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ATIAClaiEliLA._LContinuedi 2.

Address failure to incorporate the V&V of the OAs (specifically procedure walkthroughs) into the normal 2-year procedure review cycle. The 2-year review of DAs had been deleted at Braldwood.

Procedare walkthroughs did not appear to be part of the existing review effort.

At Byron, the OAs have been and will continuo to be reviewed as part of the 2-year review program.

If, during the 2-year review process, a review of problem file entries indicates that a revision is seguited, theu the r evision will be done with its associated V&V as directed by tbo applicable administrative procedures.

Braidwood Station had removed the Abnormal Operating Proceduren from the 2-year review program because the procedures were used frequently for operator training.

Operating Procedure Revision Request forms were routinely generated during the training and were int.orporated into the procedures as TPCc or maintained in the problem flies for future incorporation.

Braidwood will again luclude the Abnormal Operating Procedures in the Station's existing 2-year review program after the proceduros are revised and approved as dascribed in Part 2 above.

If, during the 2-year review process, a review of problem filo entrica indicate. that a revision is required, then the revision will be done with its associated V&V as directed by the applicable administrative procedures.

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