ML20153F164

Responds to NRC Re Violations Noted in Fire Protection Insp Repts 50-454/85-49 & 50-455/85-34.Corrective Actions:Procedures Bmp 3103-5 & Bsi 104-5 Revised & Welding, Cutting & Grinding Permits Will Include Checklist

ML20153F164
Person / Time
Site:	Byron
Issue date:	02/13/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1297K, NUDOCS 8602250326
Download: ML20153F164 (2)

Text

.

- M"

, Commonwealth Edison

-  ?. One First National Plaza. Chicago, Ilhnois

[

( ^ ] Address Reply to. Post Othee Box 767 y / Chicago, lilinois 60690 February 13, 1986 I

Mr. James G. Keppler Regional Administrator i U.S. Nuclear Regulatory Commission l Region III 799 Roosevelt Road l Glen Ellyn, IL 60137 I

Subject:

Byron Station Units 1 and 2 l I&E Inspection Report Nos.

50-454/85-049 and 50-455/85-034 Reference (a): January 16, 1986 letter from C. J. Paperiello  ;

to Cordell Reed j 1

I

Dear Mr. Keppler:

Reference (a) provided the results of a fire protection inspection at Byron Station by Mr. Ramsey in November, 1985 through January, 1986.

During this inspection, an unresolved item was identified concerning the control of welding and cutting activities. Attachment A to this letter contains Commonwealth Edison's response to this unresolved item.

Please direct any questions regarding this matter to this office.  !

Very truly yours,

/ 1 Qvzm l l

D. L. Farrar Director of Nuclear Licensing im Attachmen ec: Byron Resident Inspector g2250326860213 1297K G ADOCK 05000454 pDR 1

FEB 18 1986 dEc/

ATTACHMENT A RESPONSE TO UNRESOLVED ITEM During this inspection, the control of welding and cutting activities was reviewed by the NRC inspector. As noted in paragraph 3a of the inspection report, Byron Station has a commitment to comply with NFPA Standard 51B regarding welding, cutting and grinding activities.

+ This commitment has been addressed by administrative controls implemented by the Project Construction Department and Byron Station t Maintenance Department. For the Project Construction Department, Byron Site Instruction (BSI) No. 104-5 has been developed. For the Byron Station Maintenance Department Byron Maintenance' Procedure BNP 3101-5 has been developed. We believe these procedures meet the requirements of NFPA-51B.

As allowed by NFPA-51B, Commonwealth Edison management has delegated the authority to issue cutting, welding and burning permits to the Station /

Contractor Supervisors in charge of the work. In addition, for certain l

designated areas defined in the aforementioned procedures.-the supervisor i authorizing the work must also obtain the Shift Ergineer's (or his designees)

signature of notification and concurrence before proceeding with the work.

Nevertheless, Byron Station and the Project Construction Department have reviewed procedures BNP 3103-5 and BSI 104-5 and concluded that some l' enhancements can be made to these administrative controls. In addition to the ten areas that are presently identified in procedures BMP 3101-5 and BSI 104-5 as requiring the Shift Engineer's (or his designees) notification and concurrence prior to the work being performed, three other areas are being i added to this list. These areas are the ESF switchgear rooms, the remote

, shutdown panel rooms and the fire protection diesel and day tank room, i In addition, the welding, cutting and grinding permits used in the 4

current procedures will be revised to include a checklist to address the -

specific precautions that must be taken to prevent fires. Station / Contractor Supervisors will assure compliance with these precautions prior to starting the work, i The revisions to procedures BNP 3101-5 and BSI 104-5 will be completed by March 7,'1986.

! The contractor personnel involved in the specific incident discussed in the inspection report have been reinstructed concerning the administrative controls for welding and grinding activities. The requirements for a fire l

watch to be present during welding / grinding activities as well as the

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responsibilities of the individual designated as the." fire watch" were re-emphasized.

l l

} 1297K i e

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