ML20134M866
| ML20134M866 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/15/1996 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-96-0295, BYRON-96-295, NUDOCS 9611260066 | |
| Download: ML20134M866 (4) | |
Text
, Commonwealth Edison Company llyron Generating Station
+
4450 North German Church Road llyron,11.6101n9794 Tel H15-2M5111 November 15, 1996 LTR:
BYRON 96-0295 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk I
SUBJECT:
Byron Nuclear power Station Units 1 and 2 j
Response to Notice of Violation Inspection Report No. 50-454/96007; 50-455/96007 j
NRC Docket Numbers 50-454, 50-455
REFERENCE:
James L. Caldwell letter to Mr. Graesser dated October 18, 1996, transmitting NRC Inspecti..
Report 50-454/96007; 50-455/96007 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report.
The NOV cited one (1) Severity Level IV violation requiring a written response. Comed's response is provided in the attachment.
This letter contains the folloving commitments.
1.
The procedure, 2BVS 1.2.3.1-1, will be revised to include a reference to the applicable operating procedure for starting the CV Pump.
The operating procedure verifies proper system line-up.
2.
Involved Operators will be counselled on their responsibility to verify that conditions and alignments are correct before operating j
equipment.
3.
Procedural guidance will be developed for aligning and running a Chemical and Volume Control System Charging Pump on recirculation.
This procedure will include a verification that applicable lineups are complete as a prerequisite to starting the pump.
9611260066 961115 I
PDR ADOCK 05000454 G
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A l'nicom Company
Byron Ltri 96-0295 November'15, 1996 Page 2 If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext. 2280.
Respectfully, w
K.
L.
Graesser Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc:
A. B.
Beach, NRC Regional Administrator - RIII G.
F.
Dick Jr., Byron Project Manager - NRR S.
D.
Burgess, Senior Resident Inspector, Byron R. D.
Lanksbury, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS D.
L.
Farrar, Nuclear Regulatory Services Manager, Downers Grove j
Safety Review Dept, c/o Document Control Desk, 3rd Floor, Downers Grove 1
DCD-Licensing, Suite 400, Dowers Grove.
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i ATTACHMENT I VIOLATION (454/455-96007-02)
,1 10 CFR Part 50, Apper. dix B, Criterica V, Instructions, Procedures, and Drawings, j
requires in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.
-1 Contrary to the above, on September 14, 1996, procedure 2BVS 1.2.3.1-1, "ASME Surveillance Requirements for Centrifugal Charging Pump 2A a d Chemical and Volume Control System Valve Stroke Test," Revision 12, was inappropriate to the circumstance, in that, it failed to provide adequate steps to ensure that the essential service water system provided cooling to the 2A chemical and volume control pump lube oil cooler (50-455/96007-02 (DRP)).
This is a Severity Level IV violation -(Supplement I).
REASON FOR THE VIOLATION The root cause of the 2A CV Pump being run on 09/14/96 without Essential Service Water cooling being valved into the oil coolers was the operator started the pump per 2BVS 1.2.3.1-1, step 3.6, without first verifying the pump was ready to be run per BOP CV-lb, "Startup of the CV System (Unit 2)".
The normal operating procedure governing the starting of 2A Centrifugal Charging Pump is BOP CV-lb which lists as Prerequisite #11, " Ensure that at least one SX Pump is. running with a flowpath to the 2A CV Pump equipment to ensure adequate cooling to the 2A CV Pump Gear Cooler, Lube Oil Cooler, and Cubicle Cooler".
Since the intent of BOP CV-lb is to start a CV Pump in the normal charging mode of operation, it has been decided that procedural guidance addressing the start j
of a CV Pump in a recirculation mode of operation will be developed.
The periodic ASME surveillance requires the CV pump to be of erating in the recirculation mode.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.'
The immediate corrective action was to complete a verification of the lineup to support the running of the 2A CV Pump, 2.
Station Engineering was consulted to ensure no operational limits had been exceeded.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION h
1.
.T e procedure, 2BVS 1.2.3.1-1, will be revised to include a reference to the applicable operating procedure for starting the CV Pump.
The operating procedure verifies proper system line-up.
NTS Item #455-100-96-00702-01 will track this item to completion.
2.
Procedural guidance will be developed for aligning and running a Chemical and Volume Control System Charging Pump on recirculation.
This procedure.will include a verification that applicable lineups are complete as a prerequisite to starting the pump. NTS Item #455-201 0471-01 will track this item to completion.
3.
Involved Operators will be counselled on their responsibility to verify that conditioas and alignments are correct before operating equipment.
NTS Item #453-201-96-0471-02 will track this item to completion.
4 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance 'ias achieved on 9/14/96 when the SX valves were repositioned, and da*u reviewed to ensure no operational limits had been exceeded.
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