ML20137W829

Responds to NRC Re Violations Noted in Insp Repts 50-454/96-12 & 50-455/96-12.Corrective Actions:Mechanical Maintenance Personnel Involved Were Coached on Importance of Attention to Detail & Procedure Adherence in Work

ML20137W829
Person / Time
Site:	Byron
Issue date:	04/11/1997
From:	Graesser K COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYRON-97-0084, BYRON-97-84, NUDOCS 9704210015
Download: ML20137W829 (8)

Text

i Comnmnwralth likson Comruny l

Ily ron Generating Station

.'t 4 650 Nonh Gennan Church Road i I fly ron. lL 6lO149791 1cl H15 2M5161 l

l April 11, 1997 LTR: BYRON 97-0084 FILE: 1.10.0101 U.S. Nuclear Regulatory Commission i Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation ,

Inspection Report No. 50-454/96012; 50-455/96012 l NRC Docket Numbers 50-454, 50-455

REFERENCE:

J.L.Caldwell letter to Mr. Graesser dated )

March 13, 1997, transmitting NRC Inspection Report 50-454/96012; 50-455/96012 l

l l

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 three (3) Severity Level IV violations requiring a written response. Comed's response is provided in the attachment.

This letter contains the following commitments:

1. Conduct an evaluation of changing the BAP 1100-3 requirements.

2. Refresher training to be given to the Station Laborer personnel on watertight door requirements.

3. Consideration to be given to installing cameras inside the SX pump rooms to monitor the WE and WF pump room doors.

4. An UFSAR update will be submitted to include a statement to provide for alternate monitoring in circumstances where the alarm function on the containment sump is annunciated due to

!!cn-RCS sources.

t 9704210015 970411 DR ADOCK 050004 4 l1D t

ampupppn.upp (p:\97byhrs\970084.wpf\1)

A Unicum Onmpany

l

. Byron Ltr: 97-0084 l April 11, 1997 I Page 2 l l

l 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, l

K. L. Graesser Site Vice President l Byron Nuclear Power Station l

KLG/DB/rp Attachment (s) cc: A. B. Beach, NRC Regional Administrator - RIII )

G. F. Dick Jr., Byron Project Manager - NRR I 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 Safety Review Dept, c/o Document Control Desk, 3rd Floor, Downers Grove DCD-Licensing, Suite 400, Downers Grove.

l l

l l

(p:\97byltrs\970084.wpf\2) 1

ATTACHMENT I VIOLATION (4 54 /4 5 5 - 9 6012 - 03 a/b) 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 as 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 i determined and corrective action taken to preclude repetition. I

a. Contrary to the above, on December 20, 1996, the inspectors I identified that corrective actions taken to preclude repetition of a previously discussed event were ineffective. Specifically, the l SI pump oil cooler end bell misalignment discovered on October 11,  !

1995, was similar to the misalignment of the essential service water room cooler cooling water divider plates on December 20, 1996. Both events involved orientation of flow dividers, either end bells or divider plates, on safety-related equipment (50-4 54 /4 55- 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 appropriate maintenance personnel, to preclude leaving the B train essential service water pump room j watertight door unattended for more than 15 minutes without a '

proper barrier / fire protection system impairment permit j (50-454/455-96012-03b(DRP)), '

l This is a Severity Level IV violation (Supplement I) . i l

l REASON FOR THE VIOLATION

a. The mechanic was aware of the LCOAR situation with the time involved to perform the essential service water (SX) activities. He also had the company photographer and System Technical Expert with a Quality control Inspector examining the components. With these outside distractions the mechanic did not pay attention to detail and follow the procedure to verify the alignment of the matchmarks, and assembled the baffle plates incorrectly. l

b. Past practice associated with watertight doors allowed the doors to remain open when the room was occupied. This action had been in effect since Rev. 8 of BAP 1100-3 " Fire Protection Systems, Fire Rated Assemblies, '

Ventilation Seals, and Flood Seal Impairments" dated September 26, 1990.

The most recent revision to BAP 1100-3, " Fire Protection Systems, Fire Rated Assemblies, Ventilation Seals, and Flood Seal Impairments", is dated December 16, 1996. This revision changed the requirements to "any watertight door that needs to be open for greater than 15 minutes must have a Barrier / Fire Protection System Impairment Permit, BAP 1100-3T1".

Signage that reflects this procedure change was installed on all 10 watertight doors at the Station by October 14, 1996.

(pn97byhrs\970084.wpf\3)

l l

l 1

The Mechanical Maintenance (KM) crew personnel interviewed did not notice any specific signage when performing work on the 1B SX Strainer.

Personnel had not been trained on the procedure which was revised in I December of 1996 and an NTS item was written to review new procedure with Maintenance personnel by March 28, 1997. The incident happened between 2

these two dates.

The cause of the event was inattention to detail and unawareness of a recent procedure change, which required an Fire Protection Impairment  ;

Permit (FPIP) whenever the SX Pump Room door is to remain open for greater j than 15 minutes.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

a. Essential Service Water Room Cooler Cooling Water Divider Plates

1. Mechanical Maintenance personnel involved were coached on the importance of attention to detail, and procedure adherence in their 1 work.

b. Watertight Door for Essential Service Water (SX) Pump Room Found Open

1. A Fire Protection Impairment Permit (FPIP) was written to allow the watertight door to be left open.

2. All Maintenance personnel discussed the event (open watertight door) at departmental safety meetings shortly after the event occurred and addressed the procedure change.

3. An Action Request (AR) #970025192 was written to change door signage to require closing of the door or obtain an FPIP.

4. Operations, Engineering, Radiation Protection, and Security department personnel received a required reading package discussing the event and the procedure change.

(p:\97byltrs\970084.wpfi4)

, . . - . - . . _ . _ . _ . . ~ ~ . _ _ . , ~ . . . ~ _ . _ _ . . - _ . ~ ~ _ _ _ .

c CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION

a. Essential Service Water Room Cooler Cooling Water Divider Plates

1. None

b. Watertight Door for Essential Service Water (SX) Pump Room Found Open

1. An'evaluationofchangingtheprocedurerequirementswilj.be I tracked in NTS by item #454-201-97-0068-01. j

2. Refresher training to be given to the Station Laborer personnel on watertight door requirements. This item will be tracked via NTS #454-201-97-0068-02.

l

3. Consideration to be given to installing cameras inside the S7 ; pump i rooms to monitor the WE and WF pump room doore. The only I additional requirements that have been placed on thesa doort (4 I total) is the signage. One camera in each room would oe j sufficient to monitor both doors contained within that room. There currently is a camera system being evaluated that is monitoring the Diesel Oil Storage Tank Room doors and the A/B Train SX Pump Room doors. This item will be tracked via NTS #454-201-97-0068-05.

- DATE WHEN FULL COMPLIANCE WIT.L BE ACHIEVED

a. Full compliance was achieved on 1/02/97 when the essential service water room cooler cooling water divider plates were reassembled in their correct configuration.

b, Full compliance was also achieved on 1/10/97 when a Fire Protection Impairment Permit (FPIP) was written to allow the B train essential service water pump room watertight door to remain open.

1l i

(p:\97byltrs\970084.wpf\5)

- . . ~ - - . . . . . ~ - . . . _-..~-~..-.-~~..----.,n.~~~ _ . _ - - . + . .

4 ATTACHMENT II VIOLATION (454/455-96012-05) 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings ", requites activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the i circumstances and be accomplished in accordance with these instructions.

Byron Administrative Procedure 390-13, " Degraded Equipment Program", Revision 4, requires entries into the degraded equipment log for " inoperable subsystems or components of technical specification required equipment such that the function l of the corresponding TS equipment is not impaired but increased awareness is i deemed appropriate at the (operators) discretion."

• 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 (50-4 54 /455-96005 (DRP) )

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

REASON FOR THE VIOLATION i

The reason for the violation was a misinterpretation of the intent of BAP 390-13.

The Degraded Equipment Log (DEL) is used as a tool by the Unit Supervisors to assist them in determining if a component is in compliance with a Technical Specification.

A DEL entry should have been made due to the reliance on the 1RF000 recorder and log readings, per the procedure, to substitute for the alarm function. Failure  ;

of this recorder would have resulted in a LCOAR entry, and should have been identified, via the DEL, as a protected item.

Since the contingency action directs the operator to use the 1RF008 recorder, and this action maintained the 1RF008 operable, the Unit Supervisor did not feel additional tracking for 1RF008 was warranted. This action was supported by the

" ope rators discretion" statement in BAP 390-13. However, the BAP also refers to equipment being " impaired". In this case, reliance on a contingency procedure to maintain operability met this criteria, and a DEL entry should have been made.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

1. An entry into the DEL was made for the 1RF008.

2. The history, intent, and future purpose of the DEL was discussed at the March Unit Supervisors meeting.

(p:\97byhrs\970084.wpfi6)

l i

1 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION None DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 2/11/97 when the 1RF008 was entered into the I Degraded Equipment Log.

1 l

l l

1 4

l l

• l s

e 4

i (p:\97byltrs\970084,wpf\7)

- - - . . . - - . - - . . - . . - . . - - - ..-._. - . _ . . - . . ~ . . - -

Y 4 .

ATTACHMENT III VIOLATION (454/455-96012-06) 10 CFR 50. 59 (b) (1) states that "The licensee shall maintain records of changes in the facility. . .to the extent that these changes constitute changes in facility as describe $ in the safety analysis report..." and "these records must include  !

a written satety 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 December 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 (50-4 54 /455-96012-06 (DRP) ) .  ;

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

REASON FOR THE VIOIATION Once the alarm for 1RF008 was annunciated due to an increase in sump input from any source, further automatic warning to indicate a change in leakage from an RCS source is lost although the monitor remains capable of detecting / trending '

increases in containment sump input. By initiating procedure 1BOS RF-1, "ContalPhent Floor Drain Monitoring System Non-Routine Surveillance", the functiatul equivalent of an automatic alarm is restored such that the control i room operators will be alerted to an increase in leakage.

A 10 CFR 50.59 safety evaluation screening was performed on procedure 1BOS RF-1 with no discernable impact on the UFSAR. This was due to a misinterpretation of the alarm requirements as stated in the UFSAR.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

1. A 50.59 safety evaluation was completed on 1/16/97 for 1BOS RF-1.

2. A copy of the 50.59 safety evaluation was forwarded to the appropriate Braidwood system engineer.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION

1. An UFSAR update will be submitted to include a statement to say that in addition to the Main Control Rcom Alarm, Station procedures provide for l alternate monitoring in circumstances where the alarm function on the containment sump is annunciated due to Non-RCS sources. This action is tracked via 454-100-96-01206-01.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 1/16/97 when an appropriate 50.59 safety

[ evaluation was completed on 1RF008 and 1BOS RF-1.

4 (p:\97byltrs\970084mpf\8)

_ . - ._