ML20137K349

Notice of Violation from Insp on 961218-970131.Violations Noted:Corrective Actions Taken to Preclude Repetition of Previously Discussed Event Ineffective,Change in Facility as Described in UFSAR Made W/O Conducting Safety Evaluation

ML20137K349
Person / Time
Site:	Byron
Issue date:	03/13/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137K332	List: ML20137K329 ML20137K349 ML20137K363
References
50-454-96-12, 50-455-96-12, NUDOCS 9704070013
Download: ML20137K349 (3)

Text

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-454; 50-4ti5 Byron Station, Units 1 and 2 License Nos. NPF-37; NPF-66 During an NRC inspection conducted from December 18,1996, through January 31, 1997, three violations of NRC requirenants were identified. In accordance with NUREG-1600, " General Statement of Policy u '5rocedure for NRC Enforcement Actions," the violations are listed below:

1. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality, such 6:

deficiencies, deviations, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

a. Contrary to the above, on December 30,1996, the inspectors identified that .

corrective actions taken to preclude repetition of a previously discussed event were ineffective. Specifically, the Si pump oil cooler end bell misalignment discovered on October 11,1995, was simitsr to the misalignment of the essential service water mom cooler cooling water divider plates on December 30,1996. Both ownts involved orientation of flow dividers, either end bells or divider plates, on cafety-related equipment (50-454/455-96012-03a(DRP)).

b. Contrary to the above, on January 9,1997, the inspectors identified that corrective actions implemented on December 15,1996, in response to NRC identified findings identified on February 22 and July 15,1996, were ineffective. Adequate training was not given to aporopriate maintenance personnel, to preclude leaving the B train essential service water pump room water tight door unattended for more than 15 minutes without a proper barrier / fire protection system impairment permit (50-454/455-96012-03b(DRP)).

This is a Severity Level IV violation (Supplement 1).

2. 10 CFR Part 50, Appandix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires activities affecting quality shall be prescribed by documented instructions,  !

procedures, or drawings, of a type appropriate to the circumstances and be j accomplished in accordance with these instructions. '

Byron Administrative Procedure 390-13, " Degraded Equipment Program,"

Revision 4, requires entries into the degraded equipment tog for " inoperable subsystems or components of technical specification required equipment such that the function of the corresponding TS equipment is not impaired but increased awareness is deemed appropriate at the (operators) discretion."

l 9704070013 9703t3 PDR ADOCK 05000454 O PDR J

Notice of Violation Contrary to the above, the inspectors identified that on December 29,1996, the Unit 1 Containment Floor Drain system was not placed on the Degraded Equipment Log while the alarm was not able to perform its function to identify a reactor coolant system leak as designed, even though the chart recorder was operable and a procedure had been implemented to provide increased awareness (50-454/455-96012-05(DRP)).

This is a Severity Level IV violation (Suppiament 1).

3. 10 CFR 50.59(b)(1) states "The licensee shall maintain records of changes in the facility...to the extent that these changes constitute changes in facility as described ,

in the safety analysis report..." and "these records must include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question."

Contrary to the above, the inspectors identified that from December 29,1996, through Dec:mber 31,1996, a change in the facility as described in the Updated Final Safety Analysis Report was made without conducting a written safety evaluation. Specifically, the alarm function for the Unit 1 Containment Floor Drain (1RF008) was not available as described in the safety analysis report. Operator action to log the flow rate into 1RF008 every one-half hour was implemented through an approved procedure without conducting a safety evaluation (50-454/455-96012-06(DRP)).

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting the Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in the Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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Because your response will be placed in the NRC Public Document Room (PDR), to the j extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desita not to be placed in the PDR, and provide the legal basis to support your  !

request for withholding the information from the public.

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Dated at Lisle, lilinois  !

this Qth day of March 1997 I 1

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