ML20135D091
| ML20135D091 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/27/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Graesser K COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20135D094 | List: |
| References | |
| EA-96-508, NUDOCS 9703050047 | |
| Download: ML20135D091 (6) | |
See also: IR 05000454/1996009
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UNITED STATES
NUCLEAR RE2ULATORY COMMISSION
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REGtON 111
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801 WARRENVILLE ROAD
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USLE. ILUNOIS 60532-4351
February 27, 1997
EA 96-508
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Mr. K. Graesser
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Site Vice President
Byron Station
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Commonwealth Edison Company
4450 N. German Church Road
Byron, Illinois 61010
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTIES - $100,000 (NRC Inspection Report Nos. 50-454/96009;
50-455/96009)
Dear Mr. Graesser:
This refers to the routine inspection conducted from September 27 through December 17,
1996, at the Byron Units 1 and 2 reactor facilities. In addition to other licensed activities,
the inspectors evaluated the licensee's analysis and resolution of excessive silt levels in the
essential service water ultimate heat sink cooling towers basins and the river screen house
intake channel. The report documenting the inspection and transmitting the apparent
violations was sent to you by letter dated January 10,1997. A predecisional enforcement
conference was held on January 24,1997, to discuss the apparent violations, their
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causes, and corrective actions.
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Based on the information developed during the inspection and the information provided
during the conference, the NRC has determined that several violations of NRC requirements
occurred. These violatic,ns are cited in the enclosed Notice of Violation and Proposed
imposition of Civil Penalties and the circumstances surrounding them are described in detail
in the subject inspection report.
On October 15,1996, the Byron Staff identified that excessive sitt levels in the essential
service water cooling tower basins and the river screen house intake canal rendered the
essential service water system inoperable under certain conditions. Inoperability of the
essential service water system would prevent the ultimate heat sink from performing its
design function under postulated accidents. During the NRC inspection, the inspectors
concluded that the initial engineering investigation, analysis, and root cause determination
for the silting problem were slow and narrowly focused. NRC inspections revealed
significant weaknesses in design and test control, work control, and corrective actions
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associated with the Byron station essential service water system. Based on the results of
this inspection, six violations were identified.
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Collectively, the six violations demonstrated: that the licensee's design engineering group
failed to adequately convert the cooling tower basin's design into volumetric requirements;
that system engineering failed to fully understand the essential service water system
design; that the Byron staff failed to fully appreciate the significance of essential service
water degraded conditions that were documented in completed surveillance procedures and
in the work request system; that site surveillance procedures not associated with a
Technical Specification requirement were inadequately developed and had inadequate
acceptance criteria; and that the work request system failed to adequately resolve
degraded conditions associated with the essential service water system. Exacerbating our
concern regarding these issues was that NRC intervention was necessary to identify the
scope and magnitude of the problems and that the Byron staff was ineffective for an
extended period of time at evaluating identified deficiencies. In addition, the June 1996
service wat - event at Commonwealth Edison Company's LaSalle facility (Inspection
Report No.
3-373/374-96009) provided another opportunity for you to identify several of
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these probbms had your operating experience program been more proactive.
The first violation involves the failure of your design engineering group to adequately
translate the design of the ultimate heat sink cooling tower basin into volumetric
requirements. Specifically the calculations did not account for known variables such as the
reduced unusable water volume due to either silt accumulation or the design of the anti-
vortex drainage duct surrounding the essential service water pump suction pipe. The
second violation involves the f ailure to develop appropriate surveillance procedure
acceptance criteria for allowable silt levels in the essential service water cooling tower
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basin to ensure essential service water system operability. These two violations impacted
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your ability to ensure that the essential service water system was able to meet its design
function under certain circumstances and being degraded to the extent that a detailed
evaluation was required to determine its operability. This is significant, because
inoperability of the essential service water system would prevent the ultimate heat sink
from performing its design function under postulated accidents Therefore, these two
violations are classified in the aggregate in accordance with the " General Statements of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600,
as a Severity Level lli problem.
The third and forth violations involve your failure to take appropriate corrective action to
resolve silt accumulation problems and degraded trash racks, both of which had routinely
been identified since 1993. Further, these issues were the subject of maintenance work
orders that had been outstanding for three years. These conditions were adverse to quality
because of two reasons. The first was due to the duration that the failures had existed
and the second was because either the "as-found" silt depth or the degraded trash racks
could have rendered the essential service water system inoperable under certain
conditions. Therefore, these two violations are classified in the aggregate in accordance
with the Enforcement Policy as a Severity Level 111 problem.
)
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K. Graesser
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In accordance with the Enforcement Policy, a base civil penalty of $50,000 is considered
for each Severity Level 111 problem. Since the Byron station has been the subject of
escalated enforcement actions within the last two years,' the NRC considered whether
credit was warranted for /denti// cation and Corrective Action in accordance with the civil
penalty assessment process in Section VI.B.2 of the Enforcement Policy for each of the
Severity Level 111 problems. With respect to the first Severity Level ll1 problem, although
you identified the inadequate service water makeup calculation, it was identified as a result
of continuing questions from the NRC inspectors. In addition, the NRC identified the
inadequate acceptance criteria violation. Further, you missed the opportunity to identify
this issue during the 1991 and 1992 service water design-basis reconstitution that the
Byron staff performed. Lastly, you had several opportunities since 1993 to resolve these
conditions since they were routinely identified during surveillance testing. Therefore, credit
for /dentification was not warranted for the first problem. Credit was not warranted for
/dentification for the second Severity Level 111 problem because the corrective action
failures were identified by the NRC.
Credit was warranted for Corrective Action for both cases. Subsequent to identification of
the issues by NRC inspectors, the Byron staff's root cause determination was sufficiently
rigorous to ensure that corrective actions that have been implemented and are proposed to
Le implemented were comprehensive and should resolve this problem. Several of the
corrective actions included: repairing the known degraded conditions that have existed in
the cooling tower basin; ensuring that management expectations pertaining to design bases
knowledge of the system engineers is clearly and consistently conveyed; revising the
volumetric requirements of water in the cooling towers basins and submitting Technical
Specification change requests (as appropriate); reviewing all open and canceled work
requests to determine if other problems have been properly resolved; and upgrading the
quality and acceptance criteria of surveillance procedures that aie not specifically
associated with a Technical Specification requirement. You stated that the latter corrective
action should identify similar problems associated with the acceptance criteria for other
surveillance procedures that c.o not associated with a Technical Specification requirement
and bring the quality of these procedures up to the quality of the surveillance procedures
associated with a Technical Specification.
Therefore, to emphasize the importance of identification and correction of significant
conditions adverse to quality and for the Byron staff's failure to ensure that the essential
service water system was capable of performing its design function under all
circumstances, I have been authorized, after consultation with the Director, Office of
Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil
Penalties (Notice) in the total amount of $100,000 (a base penalty of $50,000 for each
Severity Level 111 problem).
' A Notice of Violation was issued on December 11.1995. (EA 95-197) for a Severity Level
111 proDiem associated with an inoperable aydrogen monitor.
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K. Graesser
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The fif th and sixth violations include a failure to use adequate test instrumentation to
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measure the depth of silt in the esser.tial servic~ water cooling tower basin and a failure to
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revise the final safety analysis report to correctly reflect the design of the essential service
water system function subsequent to a pre-startup design change. These violations were
categorized as Severity LevelIV.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice wnen preparing your response. The NRC will use your response, in part,
to determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure, and your response will be placed in the NRC Public Documert Room.
Sincerely,
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A. Bill Beach
Regional Administrator
Docket Nos. 50-454; 50-455
Enclosure:
Notice of Violation and Proposed
imposition of Civil Penalty
ec w/ encl:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
K. Kofron, Station Manager
D. Brindle, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
Richard Hubbard
Nathan Schlosa, Economist
Office of the Attorney General
State Liaison Officer, Wisconsin
State Liaison Officer
Chairman, Illinois Commerce Commission
Document Control Desk-Licensing
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K. Grs:ss:r
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The fifth and sixth violations include a failure to use adequate test instrumentation to
measure the depth of silt in the essential service water cooling tower basin and a failure to
revise the final safety analysis raport to correctly reflect the design of the essential service
water system function subsequent to a pre-startup design change. These violations were
categorized as Severity Level IV.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. Tha NRC will use your response, in part,
to determine whether further enforcement action is necessary to ensure compliance with
,
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure, and your response will be placed in the NRC Public Document Room.
Sincerely,
Original signed by A. Bill Beach
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A. Bill Beach
Regional Administrator
Docket Nos. 50-454;50-455
Enclosure:
Notice of Violation and Proposed
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imposition of Civil Penalty
cc w/ encl:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
K. Kofron, Station Manager
D. Brindle, Regulatory Assurance
Supervisor
I. Johnson, Acting Nuclear
Regulatory Services Manager
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
State Liaison Officer, Wisconsin
State Liaison Officer
Chairman, Illinois Commerce Commission
l
Document Control Desk-Licensing
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DOCUMENT NAME: G:\\EICS\\96-508.CP
To receive a copy of this docurnent. indicate in the bos "C" = Copy without attachment / enclosure "E* = Copy with attachment / enclosure
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"N" = No copy
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OFFICE
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DATE
O2/1)D/97 y
02/%/97
02/g97
02/7/97
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OFFICIAL RECOFlD COFY
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DISTRIBUTION:
PUBLIC IE-01
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LCallan, EDO
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EJordan, DEDO
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LChandler, OGC
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JGoldberg, OGC
SCollins, NRR
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RZimmerman, NRR
RCapra, NRR
Enforcement Coordinators
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RI,Riland RIV
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Resident inspector, Byron
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GDick, NRR
JGilliland, OPA
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HBell, OlG
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LTremper, OC
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