ML20133C837
| ML20133C837 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/10/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0343K, 343K, NUDOCS 8508070154 | |
| Download: ML20133C837 (9) | |
Text
I 3
p Commonwealth Edison N
One First National Plaza. Chicgo. Illinois A
Address Reply to: Post Office Box 767 Chicago, Illinois 60690 July 10, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 1.E. Inspection Report Nos.
50-454/85-002 and 50-455/85-001 NRC Docket Nos. 50-454 and 50-455 Reference (a): June 3, 1985 letter from J. G. Keppler to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided the results of inspection at Byron Station from January 1 through March 26, April 6, 9, 10 and 12, 1985. During these j
inspections, certain activities were found to be in violation of NRC 1
requirements. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a). On July 1, 1985, Commonwealtn Edison was granted a seven day extension on the due date for the response to the tbtice of Violation.
Attachment B addresses the additional concerns expressed in reference (a) regarding prevention of operator errors and the review of tests during the startup program.
Please direct any questions regarding this matter to this office.
Very truly yours, D. L. Farrar irector of Nuclear Licensing 1m Attachments gdf cc: Byron Resident Inspector JUL111985 h B508070154 850710 PDR ADOCK 05000454 0343K PDR G
e ATTACHNENT A VIOLATION 1 10 CFR 50 Appenoix B, Criterion XI, states, in part, "A test program
~
shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed... Test results shall be documented and evaluated to assure that test requirements have been satisfied."
The Byron FSAR, Chapter 14, Table 14.2-11, " Auxiliary Power System (Preoperational Test)," indicates that prior to fuel load electrical distribution system voltage readings will be taken and analyses conducted to verify voltage levels at the vital busses are acceptable for the expected full load and minimum load conditions throughout the anticipated range of voltage variations of the offsite power source.
Contrary to the above, prior to fuel load the licensee had not conducted analyses necessary to verify acceptable vital bus voltages for the expected full load and minimum load conditions at offsite power source voltages other than the near nominal values obtained from field measurements.
CORRECTIVE ACTION TN<EN AND RESULTS ACHIEVED The analyses to verify acceptable electrical distribution system voltage levels were performed, evaluated, ano found acceptable.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIAM'E The required analyses are performed by Commonwealth Edison departments not normally involved in the preoperational test program. The cognizant Project Engineering Department personnel, who are normally involved
_in the preoperational test program, have been made aware of the need for closer coordination with other departments to assure this testing commitment will be fulfilled for Byron Unit 2 and the Braiowood Units.
DATE WHEN FULL CO WLIANCE WILL BE ACHIEVED Full compliance was achieved on January 26, 1985 when the required analyses were completed and evaluated.
0343K
4
. VIOLATION 2 10 CFR 50 Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...and shall be accomplished in accordance with these instructions, procedures or drawings."
Byron Operating Procedure (BOP) SI-9, " Raising Accumulator Level With SI Pumps at All RCS Pressures" provided for isolating one of the two safety injection pumps from the RCS cold leg injection header to provide a charging flow path to the SI accumulators.
Contrary to the aoove, on January 11, 1985, while in Mode 3 charging to the SI accum.lators was not accomplished in accoroance with BOP SI-9 in that the operator isolated both of the safety injection pumps from the RCS cold leg injection header. This occurrence was identified and corrected by the licensee within fifteen minutes fc11owing the operator error.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
The 18 SI pump discharge isolation valve was opened to restore the 18 SI train to operable status.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONC0!43LIAICE A temporary Procedure Change Request was immediately initiated to change procedure BOP SI-9 to provide awarencss of Technical Specifications Limiting Conditions for Operation (LCO) violations. Subsequently, this procedure was permanently revised to allow the use of either SI pump depending on plant conditions. The procedure states under what conditions each pump can and/or must be used to prevent an LCO violation.
In addition, the control board mimic of the SI system was reviewed and verified to be correct.
i A Daily Orders Memo was written reminding shift personnel of the importance of procedural adherence.
It was also noted, in another Daily Orders Memo, that any change to a procedure must be documented by a Temporary Change Request or a permanent procedure revision. This includes adding steps in an effort to make the procedure safer.
The importance of procedure changes and adherence to procedures was re-emphasized to all department heads during station meetings held on January 17 and 38,1985.
T l
- , - Station personnel licensed at the Senior Reactor Operator level conducted a review of.all operating procedures involving ECCS systems, even as'a support system, to determine those procedures that could impact Technical Specifications LCO's. As a result of this review, affected operating procedures were revised.
DATE ^ WHEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on January 11, 1985 when the 1B SI
. train was restored to operable status.
e 0343K
i VIOLATION 3 10 CFR 50.59 requires, in part, that written safety evaluations be completed for changes in the facility as described in the safety analysis report to determine if the changes iniolve unreviewed safety questions. 10 CFR 50.59(c)(2) requires changes that involve unreviewed safety questions be submitted to the NRC for approval as amendments to the operating license. 10 CFR 50.59(a)(2)(1) indicates that changes in the facility that increase the probability of malfunction of equipment important to safety previously evaluated in the safety analysis report are unreviewed safety questions.
General Design Criterion (GDC) 2 of 10 CFR 50 Appendix A requires that components important to safety be designed to withstand the effects of natural phenomena suci, as earthquakes. The NTC (temperature channel test) cards in the Overpower delta T and Overtemperature delta T reactor protec-tion system channels are instruments in the calid-state protection system cabinets and are important to safety.. FSAR Section 7.2.1.1.11 indicates that the seismic design information in Section 3.10.1.1 demonstrates conformance with GDC 2 and Section 3.10.1.1 indicates that instrumentation included in
~the solid-state protection system cabinets was seismically qualified.
Additional seismic testing later revealed that the relays on the NTC cards may not be seismically qualified. Consequently, Paragraph D of Operating License NPF-23 provided a temporary exemption from GDC 2 for the NTC cards based on a licensee justification for interim operation which indicated that the relays on the NTC cards would be bypassed during normal operation.
Contrary to the above:
a.
A written safety evaluation was not completed for allowing NTC cards not having bypassed relays to remain installed during Mode 2 operations from the time of initial criticality on February 2,1985, until the relays were replaced with cards having bypassed relays on February 5, 1985.
(During this time period power level did not exceed 1%.)
b.
GDC 2 was not satisfied during the above described Mode 2 operations.
c.
An amendment to Operating License NPF-23 was not submitted to the NRC for approval for the use of NTC cards not having bypassed relays during Mode 2 operations.
(NRC approval was required because an unreviewed safety question was involved since the probability of malfunction of equipment important to safety (i.e., reactor trip system instrumentation) previously evaluated in the safety analysis report was increased (i.e., during a transient with a seismic event, the Overpower delta T and Overtemperature delta T channels were less likely to trip, if required, due to NTC card relay contact bounce)).
}
w l
. RESPONSE A safety evaluation was performed in accordance with 10 CFR 50.59 to address the installation of the unmodified NTC cards for testing purposes.
This safety evaluation was performed in the context of a change in a procedure, not a change in the facility, as described in the safety analysis report.
When the plant entered mode 2 with the unmodified NTC cards installed, a second safety evaluation, per 10 CFR 50.59, was not required to address a change in the facility because of our interpretation of the justification for interim operation (JIO) concerning the seismic qualification of the NTC cards. Our interpretation of the JIO was that it
. included the flexibility to use either the modified or unmodified NTC cards until the startup test program was completed. Upon completion of the startup test program,'the plant would enter " normal operation" and the modified cards would be required to be installed in accordance with the JIO. As a result of our interpretation of the JIO, we believed NRC acceptance of the JIO consti-tuted prior Commission approval to use modified or unmodified NTC cards, as needed,'until the plant reached " normal operation".
Given our interpretation of the JIO, we understood General Design Criterion (GDC) 2 to be properly addressed by the temporary exemption that was included in Operating License WF-23.
We believed this exemption from GDC-2 covered the use of the unmodified NTC cards during startup testing because the exemption was based on the JIO.
An application for an amendment to Operating License NPF-23 was not submitted because NRC acceptance of the JIO, with our interpretation of its
_ provisions, constituted prior Commission approval to use unmodified NTC cards during startup testing. No unreviewed safety question existed because the JIO was reviewed by the NRC and approved.
- We continue to believe our interpretation of the JIO was valid, however we agreed that the NRC interpretation is more conservative. When we were informed of the NRC position with respect to the JIO, this more conservative interpretation was promptly adopted. Subsequently, a revision to the JIO that clarified the use of unmodified NTC cards curing testing was submitted to the EC.
Assuming the more conservative NRC interpretation of the JIO, a safety evaluation should have been performed in accordance with 10 CFR 50.59 to address a change in the facility related to the use of the unmodified NTC cards during startup testing. GDC-2 would have been addressed as well the need to apply for an amendment to the Operating License.
b
=.
. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED
. On February 5,1985, the unmodified NTC cards were removed and replaced with modified cards. This was done because the unmodified cards were_no longer needed for testing at the time and also to alleviate the NRC's
. concern regarding the use of the unmodified cards.
Since the more conservative interpretation of the JIO was adopted by
-Commonwealth Edison, the JIO was revised on March 5, 1985 to explain the temporary use of the unmodified NTC cards during startup testing. This revision was approved by the NRC on March 8, 1985.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIAtCE Station personnel who review and approve safety evaluations per 10 CFR 50.59 received a listing of current JIO's with a short description of their content. In addition, these personnel were familiarized with the process of JIO review and approval. This action was completed as of March 1, 1985.
A checklist was implemented to include a review of JIO's against Test Change Requests (TCR's) during the Post Test Review Board to determine any potential impact or conflict that a TCR may create with conditions or requirements of a JIO. This checklist was developed and implemented as of March 1, 1985.
An additional administrative control was developed and implemented in the form of a checklist attached to the 10 CFR 50.59 review document to ensure the author and the reviewer / approver of the safety evaluation consider the FSAR, Technical Specifications, license conditions, JIO's, fire protection requirements, and other applicable issues when evaluatlig a proposed change. This checklist was developed and implemented as of March 1, 1985.
A letter was issued to all station personnel involved in the 10 CFR 50.59 review process that provided guidance on how to perform a safety evalua-tion per-10 CFR 50.59. A station procedure providing specific requirements for a 50.59 review was also issued. These actions were completed as of May 1,
'1985.
DATE WHEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on February 5,1985 when the unmodified NTC cards were removed and replaced with modified cards.
l 0343K L
r-
. VIOLATION 4 Technical Specification 3.3.1 requires, in part, that the Overtemperature delta T and Overpower delta T channels of the reactor trip system be operable in Mode 2.
In order for the channels to be operable they must satisfy GDC 2 which demonstrates they are capable of performing their trip function during a seismic event.
Contrary to the above, the Overtemperature delta T and Overpower delta T channels were inoperable during Mode 2 operations between February 2 and 5, 19o5, due to NTC cards being installed in the channels that did not satisfy GDC 2.
RESPONSE
Since the unmodified NTC cards were not fully seismically qualified, the operability of the Overtemperature delta T and Overpower delta T channels under Technical Specification requirements was questioned. However, given our interpretation of the JIO discussed in the response to Violation 3, we believed the provisions of the JIO. and the temporary exemption from GDC-2 included in the Operating License superceded the Technical Specification operability requirement during startup testing. Consequently, it was and continues to be our position that Technical Specification 3.3.1 was not violated.
Assuming the NRC interpretation of the JIO, the affected reactor protection channels could not have been considered operable under the Technical Specification requirements for Mode 2 operation.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED As noted in the response to Violation 3, the unmodified NTC cards were removed and replaced with modified cards. The Overtemperature delta T and Overpower delta T channels were operable under Technical Specification 3.3.1 requirements with the modified cards installed.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The revised JIO dated March 5, 1985 more clearly defined the temporary use of the unmodified NTC cards for startup testing. During the short periods when the unmodified NTC cards will be used for startup testing, the provisions of the revised JIO supercede the Technical Specification operability requirements.
DATE WHEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on February 5, 1985 when the unmodified NTC cards were removed and replaced with modified cards.
0343K
4 ATTACHMENT B OPERATOR ERROR
'The operator error, which is the subject of Violation 2, has received considerable' corporate and station management attention. Emphasis on reduction of personnel errors has been and continues to be a feature of Commonwealth Edison's Regulatory Performance Improvement Plant (RPIP) at the station and corporate level. This specific event was classified as a Potentially Significant Event in accordance with directives from the RPIP. A description of the event was verbally transmitted to our other nuclear stations by corporate personnel shortly after the occurrence. Following investigation by the Station, a written report was transmitted to the other nuclear stations. This event was additionally discussed at meetings of the Station Superintendents.and Assistant Superintendents - Operations. These discussions were aimed at promulgating lessons learned from Byron to prevent this type of error at our other nuclear stations. Additional remedial measures taken by the station to preclude recurrence of this type of event are discussed in the response to Violation 2.
TEST REVIEWS As noted in the response to Violation 3, corrective actions have been taken by the station to make personnel involved in the review of test results and test changes aware of the necessity for a comprehensive review.
The review requirements have been enhanced and administrative actions have been taken to promote rigorous-reviews.
Corporate personnel involved in the review of test results (the Project Engineering Department) have also been sensitized to the need for a rigorous, documented review. The following steps have been taken to heighten the awareness of cognizant individuals in this area:
The Byron Startup Manual was revised to explicitly require a specific documented resolution of data that does not meet acceptance criteria jr3 when approving test results. In addition, all Project Engineering Department (PED) personnel involved in -test reviews have received a copy of existing justifications for interim operation (JIO's) with a memo instructing them to become familiar with JIO's and to consider them in test reviews.
Finally, a temporary PED procedure has been put in place to require a second internal review of tests, project documentation, and acceptance /
rejection letters from PED to the Station on executed tests. This second review covers specific, key aspects of test review. The procedure provides a means for identifying shortcomings in documentation of test evaluations that might otherwise have gone unnoticed. The temporary procedure will remain in force until, in our judgment, we have achieved a satisfactory level of test review awareness.
0343K w