ML20106H423

Forwards Response to NRC Re Violation Noted in Insp Rept 50-454/84-82.Corrective Actions:Retraining Sessions Held for Operators.Emergency Lighting Unit at Remote Shutdown Panel Relocated & Tested

ML20106H423
Person / Time
Site:	Byron
Issue date:	02/05/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9730N, NUDOCS 8502150301
Download: ML20106H423 (4)

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's Commonwealth Edison

/ One First Nationst Plu3, Chicago, filinois O Addr;ss R;pty to: Post Offica Box 767

\ Chicago, lilinois 60690

. February 5, 1985

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Mr'. James G. Keppler

--Regional Administrator U.S. Nuclear Regulatory Commi_ssion 799 Roosevelt Road Glen _Ellyn,-IL 60137

Subject:

Byron Generating Station Units 1 and 2 I&E Inspection Report No. 50-454/84-82 Reference (a): Drcember 21, 1984 letter from R. L.

Spessard to Cordell Reed.

Dear Mr'. Keppler:

Reference (a) provided the results of inspections of fire protection ~ activities at Byron Station by Messrs. Ramsey, Coppola, Thomas, Mendez, and Ulie on November 13-14 and December 10, 1984.

. 'Durino that inspection certain activities were found to be not in comp 1Iance with NRC requirements. Attachment A to this letter contains Commonwealth Edison's request to the Notice of Violation

.fappended to reference (a).

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Please direct questions regarding these' matters to this office.

Very truly yours,

, f{$ g (Mm -

e-0 D. L. Farrar

, Director of Nuclear Licensing

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Attachment M b ohjj4 ~;

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, ATTACHMENT-A

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-RESPONSE T0-NOTICE-OF VIOLATION c '

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$3 lh10LATION-

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xSection 2.c(6) of facility operating license No. NPF-23 (is ,

requiresfthat the licensee maintain in effect all provisions of the

-approved-firefprotection program as-described in the fire protection

,-~ Treportifor:the. facility through Amendment 4 and the licensee's.

letters dated August 20, 1984, October'll, *~.4, and October.15,-

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+ <1984,;and asLapproved.in the SER through Se,plement 5.

7 . . . Contrary to'the'above,-the-licensee failed to provide and maintain the following aspects of the. approved fire protection

. program;.

W , .a.:10perator Trainina - Training 'of all' operations personnel 5 < required to implementfthe post fire safe shutdown method and

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,o supplemental procedures had'not been' accomplished as required by i'LSections'3.1.b.(7),-3.2.D.(10)., 3.3;a and 3.4.b. of the Byron' Fire. Protection Report.

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b .- -Communications'- Suitable portable radio communicationstwere not.

provided to support safe shutdown as required by=Section 3.5.G.

of:the ~ fire protection report and Secti,on 9.5.1.4' of thef SER

_ Supplement No. 5.

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, = .c.. Emercency:Lightina --Adequa'te emergency lighting to" support safe

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.shutclown.was:not providedias--required by Section 3.5.G. ofothe'

- fire! protection report and Section. 9.5.1.41of thetSER Suppl' ement

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, (Response to-Items of Violation? ^

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, a... Operator? Training: 'The safeEshutdown~ procedures wererinitially?

%> approved'in October,fl984-and were scheduled to be " walked

through" during?the special safety inspection. . Based

upon the

"> iresults of this walRLthrough,.any problems-identified with'these It'was our: intention:to then!-

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v, J- procedures would be scorrected. '

P , implement?thefrequired' operator; training program and to have.all-

_ 'affected operating personnel' trained on:these procedures' prior

to?55 power.

Training on, future procedure revisions-was to be-

. conducted withithe' regularly scheduled' retraining: program.

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.b;

. Communications: 'A follow-up investigation was conducted to

' determine 1where radio " dead spots" existed from the remote i

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. shutdown: pane 11to either the division II 4KV.switchgear room or

?theJ1A diesel generator room.- The results of this investigation

c ~ hi = revealed no'" dead spots" exist.

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After discussions with hc s - operating personnel involved.with the inspection, it is our belief..that the inability of the person at-the remote shutdown

. pane 11to communicate with'other operator was in part due to these.. operators responding to the NRC inspector's concerns and comments coupled with 'a high level of norinal plant'-radio communication during the inspection.

=c. ' Emergency Lighting: The installed emergency lighting fixtures-awere' obstructed from; fully illuminating the remote shutdown

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- panel.-LAs mentioned during the inspecticn, portable lanterns were/available at the remote shutdown panel and could have been used by an operator'to supplement the existing lighting..

Corrective'Astion Taken'and'Results Achieved a.'LGperator. Training: Special retraining sessions have been held 1-BOA-ELEC-3'and 1-BOA-ELEC-5.. At

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for this procedures 1-BOA-PRJ.-5all time .. retraining o Equipment Attendants on these-procedures has been completed, with the exception of the steps.

Lin procedure 1 BOA-PRI-5 which requirefthe jumpering of motor controlicenters. Completion of training for the Equipment--

. Attendants on-1-BOA-PRI-5 is scheduled.- Special retraining-sessions are currently.1being held for.the. remaining.on-shift

. operations personnel but-are not yet.' completed.

' b ~. Communications: -A-walkdown of the two identified areas:was

_ conducted _.following the-safe shutdown. demonstration. 'The ch walkdown; determined that radio " dead spots" did not exist.- We

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believe;that'the inabilityjto' establish communications was caused byithe'hightlevelJofEradio~transmissionsfassociated1with

.r' Ethe. normal. activities of'the plant-which'were occurring at._the

! time of<the demonstration,oand: distractions:whichimay have occurred =inian attempt tolrespon.d-to inspector'qu.estions'and ~

' concerns duringEthe' demonstration. lNeither?of these factors- .

twould-beipresant/during;an'~ actual. remote! shutdown.;

c. Emergency. Lighting: ;The-emergency lighting unit at,the= remote-tshutdowncpanel has been relocated and tested. :The emergency

lighting levelsJ at L the 4 remote" shutdown. panel 'are now uniform ,

cover.theLentire panel..

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~ Corrective Action to Prevent-Further-Noncompliance 2

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'a; . Operator;Tra'ining: LI nitial training and regularly scheduled Lretrainingiwill be1 sufficient to maintain levels _of training on Ethe' remote shutdown' procedures. During the time periods between

regularly' scheduled retraining, operating personnel will be

alerted to changes in the. safe shutdown procedures through-the -

required reading program.

, Communications: 'The current communications system is adequate

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forrsupporting/ safe shutdown from the remote shutdown panel and

< satisfies thescommitments-made in the Byron Fire Protection

' Report.and1the~ Byron Safety Evaluation Report on the suitability

'of theucommunications system to support safe shutdown. ,

c.;-Emergency Lighting: Relocation of the emergency lighting at the remote' shutdown panel and assurance of adequate lighting. levels Lat~the remote shutdown panel satisfies the commitments made in

' the ~ Byron' Fire Protection Report.

- .Date'When" Full Compliance Will Be Achieved Operator Training:- Retraining of.all equipment attendants and on-m shiftioperatin al-80A-PRI-5,=-1g. personnel on'all aspects safe shutdown procedures-BOA-ELEC-3 and 1-BOA-ELEC-5 will be completed. prior.

ftoTachieving 5%' power.

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.. Communication: 'The co.nmunications' system is currently in compliance.

with* commitments"made-to'the.NRC'regarding. adequacy of.the system:toi support safe shutdown.

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! Emergency? Lighting:4'The1 emergency lighting system-is-currentlyfin*

, ' compliance:with commitments'made to'the NRCDregarding adequate ^

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. f sillu'mination of1thebremote shutdown ^ panel to support safe = shutdown.

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