ML20148D008
| ML20148D008 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/23/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-02, 50-454-97-2, 50-455-97-02, 50-455-97-2, BYRON-97-0123, BYRON-97-123, NUDOCS 9705300031 | |
| Download: ML20148D008 (15) | |
Text
Commonweahh I'.dison Company 11)ron Generating Statiot) i a
4450 North Gerrnan Church Road II) ton,11. 61010979 6 j Tel H 15-234-5411 May 23,1997 LTR: BYRON 97-0123 FILE: 1.10.0101 l U.S. Nuclear Regulatory Commission l Washington, DC 20555 l Attention: Document Control Desk 1
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97002; 50-455/97002 NRC Docket Numbers 50-454. 50-455
Reference:
James L. Caldwell letter to Mr. Graesser dated April 23,1997, transmitting NRC Inspection Report 50-454/97002; 50-455/97002 j 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 five (5) Severity Level IV violations requiring a written response. Comed's response is provided in the attachment.
This letter contains the following commitments:
- 1) A Task Force was formed, with the Operations Manager as sponsor, to raise i the standards of in-plant operators to that of the Main Control Room.
- 2) Non-licensed operator training will cover procedure adherence and QW (Qualify, Validate and Verify). This will be done in the third quarter continuing training.
- 3) As mentioned under corrective actions, operators are participating in simulator sets with licensed operators.
- 4) Human Error Reduction training is being provided to non-licensed operators.
- 5) A detailed procedure for installation of motor bearings for the RH pump motors gD l will be developed. y
- 6) The procedures for RH pumps will be re-written to incorporate lessons learned from this event, and all procedures for maintenance on vertical pumps will be i i
reviewed for adequate work instructions.
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- 7) The Maintenance Departments training is being reviewed to assess the need for continuing training or just-in-time training for infrequent, complex tasks. j
- 8) A detailed procedure for installation of motor bearings for the CS pump motors will be developed.
- 9) The procedures for CS pumps will be re-written to incorporate lessons learned from this event, and all procedures for maintenance on vertical pumps will be e reviewed for adequate work instructions. 1 I
- 10) A schedule of management field observations will be initiated for field work !
requiring FME. These observations will continue until the Maintenance !
Superintendent deems compliance to the procedure is appropriate.
implemented between Training and Maintenance departments. l
- 12) 1/2BOS SX-Mi ls being revised to state that prior to opening both flush valves ,
(1/2SX142 and 1/2SX143) the following actions are required: 1) enter the AF ;
LCO 1/2BOS 7.1.2-la, and 2) place the 1A AF pump handswitch in the Main
- Control Room in the pull-to-lock position.
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- 13) The appropriate drawings are being revised and the Unit 1 air supply to the ;
refuel machine is being modified from Service Air to Instrument Air to match ;
the Unit 2 installation. !
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.
Respectf ly, i i
K. L. Graesser i Site Vice President i Byron Nuclear Power Station j KLG/DB/ld i
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 l D. L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept, c/o Document Control Desk,3rd Floor, Downers Grove i DCD-Licensing, Suite 400, Downers Grove. j (p:\97byltrs\970123.wpf-2) i
l ATTACHMENT I ylOLATION f454/455-97002-01)
Technical Specification 6.8.1.a requires that procedures be established, implemented, and maintained for activities covered in Appendix A of Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix A, Section 7.a.(1) recommends the use of procedures for water co'lection in liquid radioactive waste systems. '
Procedure BOP WX-121, " Release Tank Transfer to 22,000 Gallon Regen Waste Drain Tank," Revision 3, step 15, required that the radwaste operator monitor the release ,
tank level recorder and the regen waste drain tank level recorder during the liquid radioactive waste transfers.
Contrary to the above, on February 17, 1997, the inspectors identified that the radwaste operator did not monitor the releas e tank and the regen waste drain tank level recorders during the transfer of liquid radioactive waste from the release tank to the regen waste drain tank. (50-454/455-97002-01(DRP)).
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION The procedure was not followed or placekept to ensure all steps were properly performed. Furthermore, during the Radwaste Panel stand-down it was recognized that lower standards existed for local panel monitoring than for Main Control Room panel monitoring. Operators at the Radwaste Panel were allowed to rely on alarms to take action rather than closely watching indicators and chart recorders.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
-1. Stand-downs were held at the Radwaste Control Panel with the panel operators, Operations Manager, and Shift Operations Supervisor, (SOS). At this meeting,' ,
the Operations Manager and SOS specifically discussed the requirement for !
procedure compliance.
- 2. The process of place keeping, where an operator always has the technical procedure in hand and initials steps as they are done, was formalized in BAP 340-1, "Use of Procedures for the Operating Department" on 3/14/97. An increase in procedure compliance can be inferred from the increase in procedure changes submitted to the Operations Staff.
- 3. To raise the standards in tne area of procedure compliance, the following actions have been taken:
Over half of the Radwaste Supervisors, are now qualified to perform 50.59s. This allows persons knowledgeable in the operation of Radwaste systems to initiate and review procedure changes.
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. j An additional 20 in-plant locations now have procedures to remove the physical barrier of unasallability from the operators.
The procedure revision has been shortened by increasing resources for j revisions. This allows procedure problems noted by operators to be corrected more quickly than in the past.
The Site Policy on Craft Capability, which allowed minor evolutions to be performed without a procedure, has been deleted.
The above actions will improve procedure compliance by providing higher oiq" procedures based on operator input.
To raise the standards in the area of formality, on an as available basis, non-licensed operators are participating in simulator sets with licensed ROs and SROs. Emphasis is placed on procedure adherence and proper communications.
CORRECTIVE SirEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION To address the longer term cultural issues related to standards differences, a Task Force was formed under station administrative procedures with the Operations Manager as the sponsor. The charter of the task force is to raise the standards of in-plant operators to that of the Main Control Room. To date, other utilities standards for operations outside the control room along with relevant INPO documents, have been collected and are under review by the Task Force. The results of this review will form the basis for the action plan to improve operator performance outside the conti ol room.
The members of the Task Force are responsible for most of the items listed under
- orrective actions. An action plan based on reviews and benchmarking will be completed by 12/31/97. NTS Item # 454-201-97-CAQD00782-01 will track this action.
Training will be used to assist with the resolution of the difference in standards. It is not a function of training to impose standards; part of the difference in standards was due to differences in training. The following are some of the items being done to eliminate these differences in training.
Non-licensed operator training will cover procedure adherence and QW (Qualify, Validate and Verify). This will be done in the 3rd quarter continuing training. NTS# 4541009700201-01 will track this action.
As mentioned under corrective actions, operators are participating in simulator sets with licensed operators. NTS# 4541009700201-02 will track this action.
Human Error Reduction training is being provided to non-licensed operators. NTS# 4541009700201-03 will track this action.
Previously, training for Radwaste Supervisors was informal on-the-job training. A c"Ofication guide and continuing training matrix are now in place for Raowaste Supervisors.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 2/17/97 when procedure BOP WX-121 was exited.
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ATTACHMENT II VIOLATION f454/455-97002-04)
Technical Specification 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems shall be operable, with each subsystem including one operable residual heat removal pump, in Modes 1,2, and 3. Technical Specification , 3.5.2, Action statement a. requires that with one ECCS subsystem inoperable, the licensee must restore the inoperable spray system to operable within 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, the licensee identified that since December,1965, with Unit 1 in Modes 1,2, and 3, the 1A residual heat removal pump was inoperabe and action j was not taken to restore the inoperable subsystem to operable within i 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. (50-454/97002 04(DRP))
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION .
l During seal replacement for a leak and motor disassembly to determine the cause of excessive shaft end play, it was determined that the lower thrust bearing was installed wrong during motor work performed in December,1985.
Work was performed under 1985/1986 maintenance work request travelers.
Information in the work request traveler was too generic, in that, specific instructions were needed for correct installation of 1) the lower motor bearings, and 2) verification of axial end play dimensions.
It should be noted that based upon operating history, over 11 years of ASME pump run surveillances and required operation, the pump was considered available.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVEQ
- 1. An extensive review of work history was performed for the other RH trains and determined that the Unit 2A/B RH pump lower motor bearings installations and axial shaft end play measurements were acceptable.
- 2. The 1B RH pump motor shaft end play was checked for correct axial movement and found to be acceptable.
- 3. In response to concerns with the 1A RH pump, an On-Site Review was '
performed and it was concluded that pumps of similar design should be checked for proper installation of bearings and correct axial shaft movement.
- 4. A standdown was held with all maintenance personnel to reinforce expectations for procedure usage, and the utilization of vendors for technical assistance only.
The proceedings were recorded for future reference.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
- 1. A detailed procedure for installation of motor bearings for the RH pump motors will be developed. NTS item # 454-201-97-0387-03 will track this action.
- 2. 10 procedures for RH pumps will be re-written to incorporate lessons learned fr a this event, and all procedures for maintenance on vertical pumps will be n- :3d for adequate work instructions. NTS item # 454-512-97-PMC-001 will t u this action.
- 3. The Maintenance Departments training is being reviewed to assess the need for continuing training or just-in-time training for infrequent, complex tasks. NTS item # 454-512-97-PMC-012 will track this action.
1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED )
Full compliance was achieved on 2/25/97 at 0256 hours0.00296 days <br />0.0711 hours <br />4.232804e-4 weeks <br />9.7408e-5 months <br /> when the 1A RH pump impeller replacement was determined acceptable.
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ATTACHMENT III l
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Technical Specification 3.6.2.1 requires that two independent containment spray 1 systems shall be operable in Modes 1,2,3, and 4. Technical Specification 3.6.2.1, j Action statement requires that with one containment spray system inoperable, the i licensee must restore the inoperable spray system to operable within 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, the licensee identified that since 1986, with Unit i ln Modes 1, 2,3, and 4, the 1B containment spray pump was inoperable and action was not taken to restore the inoperable subsystem to operable within 7 days or be in at least hot ,
standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. (50-454/97002/05(DRP))
This is a Severity Level IV violation (Supplement I).
I REASON FOR THE VIOLATION In response to concerns with the 1A RH pump, the CS pumps were checked for correct axial shaft movement. The shaft end play for the 1B CS pump was found to be excessive. The motor was disassembled and the lower thrust bearings were found to be installed incorrectly.
Work was performed under 1985/1986 maintenance work request travelers.
Information in the work request traveler was too generic. Specific instructions were needed in the travelers for correct installation of the lower motor bearings, and verification of axial end play dimensions. However, based upon operating history, over 11 years of ASME pump run surveillances and required operation, the pump was considered available.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
- 1. An extensive review of work history was performed for the other CS trains and determined that the Unit 2B CS pump lower motor bearings installations and axial shaft end play measurements were acceptable.
- 2. The 1A CS pump was inspected and lower motor bearings re-installed correctly with axial end play verified.
- 3. The 2A CS pump bearing installation and axial end play was verified acceptable.
- 4. A standdown was held with all maintenance personnel to reinforce expectations for procedure usage, and the utilization of vendors for technical assistance only.
The proceedings were recorded for future reference.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
- 1. A detailed procedure for installation of motor bearings for the CS pump motors will be developed. NTS item # 454-201-97-0387-03 will track this action.
- 2. The procedures for CS pumps will be re-written to incorporate lessons learned ;
from tht , cient, and all procedures for maintenance on vertical pumps will be reviewed for acquate work instructions. NTS item # 454-512-97-PMC-001 will track this action.
- 3. The Maintenance Departments training is being reviewed to assess the need for continuing training or just-in-time training for infrequent, complex tasks. NTS i item # 454-512-97-PMC-012 will track this action, i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1
Full compliance was achieved on 2/16/97 at 0455 when Unit 1 entered Mode 5 and the j CS pumps were no longer required.
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ATTACHMENT IV VIOLATION (454/455-97002-06a. b) 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
- a. Contrary to the above, two events identified that procedure SMP-M-4, " Foreign Material Control," Revision 0, was not of a type appropriate to the circumstances in that implementation of the procedure did not prevent foreign material from entering the containment spray system. Specifically, on February 28,1997, foreign material was identified between the thrust bearing seating surfaces of the thrust bearing housing of the 1B containment spray pump. Additionally, on Match 2,1997, foreign material was identified between the mechanical seal seating surfaces of the 1A containment spray pump (50-454/455-97002-06a(DRP)).
- b. Contrary to the abcVe, on March 5,1997, due to an event, the inspector identified that the troubleshooting procedure for Unit 2 pressurizer spray valves, 2RY455B and C, was not of a type appropriate to the circumstances.
Specifically, Work Request 970025538, " Pressurizer Pressure Control Appears to be Drifting," Revision 1, failed to identify that circuit troubleshooting the spray valves could affect and resulted in an inadvertent opening of 2RY455A, pressurizer power operated relief valve (50-454/455-97002-06b(DRP)).
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION
- a. FME Controls Procedure The installation of the mechanical seal requires the seal to be passed through the housing in two pieces with the seal face exposed. The seal was rebuilt in the Mechanical Maintenance hot shop with the seal face being inspected prior to assembly and found free of foreign materiel. The seal was then transported to the pump split in two pieces and placed on the pump shaft. A paint chip was picked up as the seal was installed on the shaft through the pump housing.
The seal face cannot be examined once the process is started.
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The fai!ure to adequately control debris disturbed by frequent floor plug removal and installation is the root cause for debris that effectively caused the damaged motor bearings. The work area was not " swept" for debris continuously even though floor plugs were being manipulated to allow access to the different pump / motors. This movement caused debris, lncluding paint chips from components disturbed during movement, to come loose and infiltrate the area. The Nuclear Station Work Procedure (NSWP) for Foreign Materiel i Exclusion (FME) clearly tasks thejob supervisor with identifying FME measures r commensurate with changing conditions.
- b. Troubleshooting Procedure The repairs that were required had never been attempted while the unit was at NOT/NOP prior to this event, therefore no previous experience could be used '
as a base for precautions. The calibration procedure stated that the procedure ;
could be performed in any mode with one small exception. This established a !
comfort margin with the Instrument personnel that there were no adverse affects to pulling the circuit card (lead / lag unit). The test report package does not contain any precautions concerning backup heater, variable heater or PORV actuations. The weaknesses described lead the work crew and shift personnel to the conclusion that all precautions were in place prior to commencing maintenance.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
- a. FME Controls Procedure i
- 1. A standdown was held with all maintenance personnel in attendance.
FME, housekeeping, and other identified problems were discussed.
Expectations were clearly defined with the proceedings recorded for ,
future reference.
- 2. FME deficiencies identified in the maintenance critique, of RH/CS pump work, were reviewed to ensure full compliance with the FME NSWP.
The FME NSWP was reviewed to determine improvements necessary to ;
prevent recurrence of the problems noted in the critique.
- 3. The use of a cartridge seal, to remove the need to install the seal in two pieces, has been approved for use in future applications. !
- b. Troubleshooting Procedure l 1. Immediate Actions:
- The work was stopped. I Pressurizer status was determined.
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- The Pressurizer Relief Tank was returned to normal pressure.
Pressurizer pressure was returned to normal.
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- All alarms were reset.
Pressurizer pressure controllers were returned to automatic.
- A post transient discussion was held.
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- 2. BIS 3.1.1-206 Surveillance Calibration of Pressurizer Protection ChannelI (Loop 455) was revised to include a mode applicability statement for control cabinet components. This statement will incorporate the requirements to adequately protect the control signals from perturbation during normal operations.
- 3. A review of other instrument circuits and procedures was conducted to check for similar configuration. This loop was found to be unique in its i
operation. '
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- 3. Work Package 970025538 01 was revised to include proper precautions ,
prior to completing repairs. ;
, 4. Operations personnel and the maintenance crew conducted an extensive pre-job brief to align heater controls, the PORV block valve and to j
, establish a solid communication link prior to removing any circuit card i or starting the calibration again.
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- 5. Chart recordings were made of the control signal after completing repairs to measure effectiveness of the repair.
., 6. The Pressurizer pressure troubleshooting event was discussed with Instrument Maintenance Department personnel during a departmental
- safety meeting, i
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
- a. FME Controls Procedure
- 1. A schedule of management field observations will be initiated for field i work requiring FME. These observations will continue until the Maintenance Superintendent deems compliance to the procedure is
- appropriate. NTS item # 454-512-97-PMC-009 will track this action.
- 2. On-job-training (OJT) and realistic " mock-up" training will be r implemented between Training and Maintenance departments. NTS item # 454-100-97-00206a-01 will track this action.
- b. Troubleshooting Procedure
- 1. Due to the uniqueness of this instrument loop, no further actions are necessary.
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. ,' l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
- a. FME Controls Procedure Full compliance was achieved on 3/2/97 when foreign materiel was removed from equipment. j l
- b. Troubleshooting Procedure l
Full compliance was achieved on 3/6/97 when work was appropriately executed, followl.1g the development of detailed work instructions, without significant incident. c i
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ATTACHMENT V VIOLATION (454/455 97002-07a, b) 1 10 CFR Part 50, Appendix B, Criterion III, " Design Control," requires, in part, that measures be established to assure that applicable regulatory requirements and the 1
- design basis are correctly translated into specifications, drawings, procedures, and '
instructions. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
- a. Contrary to the above, on February 28, 1997, the inspectors identified that since initial fuel loading, a field change made to the Unit 1 service air system downstream of valve 1SA038A, was not subject to a seismic evaluation, which is a design control measure commensurate with those applied to the original design (50-454/455-97002-07a(DRP)).
- b. Contrary to the above, the inspectors identified that as of December 1,1996, the requirements of the safety evaluation to enter a limiting condition for operation action requirement for modification M6-1-88-060 were not translated into Byron Operating Surveillance SX-M1 "1A AF Pump SX Suction Line Monthly Flushing Surveillance," Revision 1 which is a design control measure commensurate with those applied to the original design (50-454;455-97002-07b(DRP)).
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION
- a. Unauthorized Temporary Alteration The equipment configuration for 1SA038A was installed during initial construction to supply air to the air operated components of the refuel machine and, as such, was never questioned.
- b. Failure to Translate Safety Evaluation Requirements The root cause for not addressing the requirements of the MAL letter is that the intent of the MAL letter was not clear with respect to the basis behind entering the SX limiting condition for operation (LCO). Based on perspective, either the flushing line modification impacted the 1000 gpm SX supply to AF and the AF LCO (1/2BOS 7.1.2-la) should be entered or when flushing at 1000 gpm coincident with an AF pump start, SX injection into the Steam Generators adds an additional 1000 gpm and the A train SX flows are now impacted, requiring the SX LCO to be entered (1/2BOS 7.4-la). The overall impact of the
, modification, was that both system are impacted and needed to be clearly evaluated per the 50.59 process.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED l
- a. Unauthorized Temporary Alteration 1
- 1. The equipment configuration for 1SA038A was removed. 1
- 2. The completion of Fuel Handling system walkdowns for configuration management concerns, did not identify any additional problems in Unit 1 or Unit 2. l
- b. Failure to Translate Safety Evaluation Requirements i
- 1. Immediate corrective actions were to implement a temporary procedure change to 1/2 BOS SX-M1 to enter both the A train AF LCO and the A train SX LCO.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
- a. Unauthorized Temporary Alteration
- 1. The appropriate drawings are being revised and the Unit 1 air supply to the refuel machine is being modified from Service Air to Instrument Air to match the Unit 2 installation. NTS item # 454-315-97-031F-01 will track this action.
- b. Failure to Translate Safety Evaluation Requirements
- 1. Change 1/2BOS SX-M1 to state that prior to opening both flush valves (1/2SX142 and 1/2SX143) the following actions are required: 1) enter the AF LCO 1/2BOS 7.1.2-la, and 2) place the 1A AF pump handswitch in the Main Control Room in the pull-to-lock position. This will be tracked by NTS item # 454-200-97-CAQS00032-01.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
- a. Unauthorized Temporary Alteration Full compliance was achieved on 3/5/97 when the equipment configuration for 1SA038A was removed.
l b. Failure to Translate Safety Evaluation Requirements l
l Full compliance was achieved on 4/7/97 when Temporary procedure was
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