ML20155A314
| ML20155A314 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/19/1988 |
| From: | Bliss H COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 5137K, NUDOCS 8810050278 | |
| Download: ML20155A314 (4) | |
Text
i o
i b
gg
/ One First Nabonel Piara Checa0o, lAros O ) Address Reply to. Post omce Box 76F
.p I
e,'
. sj CNeago,inros 60600 0767 September 19, 1988
\\ MIC2ITY PC1T1%
w wuv CfI['
tit e
"nt-y
~
Mr. A. Bert Davis
?l C Regional Administrator W
h U.S. Nuclear Regulatory Comission Region !!!
799 Roosevelt Road Glen Ellyn, IL. 60137 i
Subjects Byron Station Units 1 and 2 NRC Inspection Report Hos.
l 50-454/88-011 and 50-455/88-011 i
NRC.Dorhet.Non d Q-til_and__50-455 i
Reference (a): August 19, 1988 letter from E.G. Greenman to Cordell Reed t
Dear Mr. Davis:
i Reference (a) provided the results of an inspection by Mr. P.G.
i Brochman and Ms. N.V. Gilles of your of fice on July 1 through August it.1988, of activities at Byron Station Units 1 and 2.
During this inspection, certain activities were found in violation of NRC requirements.
Attachment A of this
[
1etter contains Commonwealth Edison's response to the Notice of Violation.
t Reference (a) also expressed a concern regarding the implementation of the modification program at Byron Station.
Attachment B contains the actions that t
have been tak*n and will be take.. to permanently improve the modification program and ensure that documents are properly updated during the modificatioL process.
Please direct any questions regarding this matter to this office.
Very truly yours, l
l* d W
l Henry B Bliss
[
Nuclear Licensing Manager RAC/k13 att.
p 0\\
cet Byron Resident Inspector g
$137K MP t 0 Wil 8910050278 880919 PDR ADOCK 05000454 O
PDC a
ATTACHMENT A Violation 494/880-11-01 455/88011-01 Technical Specification 3.7.5 requires that two independent ultimate 1
heat sink (UHS) cooling towers shall be operable in Modes 1 to 4 with one operable essential service water makeup pump per train. With one essential l
service water makeup pump inoperable, action statement c requires the licensee to restore the af fected pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in Mode 3 within the nest 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Final Safety Analysis Report paragraph 9.2.5.5 specifies that each basin in the cooling tower have a category I level switch and that, in the event of low water level in the basin, the corresponding essential service water makeup pump be automatically started.
Contrary to the above, from June 10 through June 16, 1988, with Units 1 and 2 in Mode 1, level switch OLS-SXO97 for the OB basin was deenergised, thereby rendering the OB essential service water makeup pump incapable of starting automatically on low (UHS) basin water level for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and Units 1 and 2 were not shutdown and placed in Mode 5 within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, j
C o r r e ctivt._Act ion _Ta ke n_a nd_ Result a_Achitved l
The OB SK Makeup pump was returned to operable state at 2001 on June 16, 1988, when the breaker MCC13221 Cub D2-04 was placed in the ON position as documented in LER 88-003.
l C o r r e c tiv e_Ac tio n_to_h e_Tak e n_to_ Avni d_fsrth e r_Yiola tion 1.
An initial review of the Electrical Distribution Book (EDB) was performed to determine accuracy.
Results indicated the followings a.
The 6. 9KV. 4KV and 480V distribution information reflects as-built status of Byron and can be used for DOS information.
j h.
Saveral discrepancies were found in the 120V distribution information contained in the EDB.
Because of these discrepancies the station implemented the following immediate actionst 1)
A caution statement has been placed on the EDB copies to ensure that prints are used instead of the EDB for 120V feed 005 information.
2)
Because the Outage Editor data base is constructed from the EDB, a Special Operating Order 150-57-0048 was issued to ensure that prints were used instead of the Outage Editor for 120V feed information for DOS.
t i
l l
2.
The EDB is under a 100% validated review at this time and will not be used for determining OOS for 120V feeds until the validation is complete.
3.
Procedural controls are being revised to ensure control of the EDB (BAP 500-13 is being written to replace BVP 600-02).
4.
The pertinent sections of Inspection Report 454/88011 were reviewed in depth by Tech Spec System Engineers involved in the modification process in order to raise sensitivities regarding procedural compliance.
Tull_Complianct_RAtt 1.
Initial review of the EDB was completed on August 25, 1988.
A caution statement was placed on the EDB on August 25, 1988.
Special Operating Order 80-ST-0048 was issued on September 9, 1988.
2.
100% validation of the EDB will be completed by June 1, 1989.
3.
BAP 500-13 will be approved for use by October 1, 1988.
(
4.
The Tech Staff review of the inspection report was completed on September 8,
1988.
ATTACRMENT B Violation 494/880-11-01
. s 455/88011-01 Modification _EregranLReview The following discussion addresses concerns regarding the less than adequate performance of the modification program to ensure that the procedures and instructions which are utilised by the control room operators to determine system status, to take equipment out-of-service and to ensure compliance with the operability requirements of the Technical Specifications are up-to-date and correct.
The lessono lentned from events at Zion and Dresden Stations prompted a review of the Byron Station Modification Program in January 1980.
The review resulted in rewriting the Station Hodification Program (BAP 1610-series).
This was completed and approved for use on June 9, 1988.
Byron Station has every confidence that these changes will ensure various documents are properly updated during the modification process. The vlotation identified during this inspection was the result of a modification performed prior to the rewrite of the Station Modification Program.
One of the major enhancements to the modification program was a revision to the modification station check list (BAP 1610-871) that specifically addresses updating the electrical distribution book, valve lineups, procedures, and other items utillmed by the control room operators.
Problems may esist, however, with modifications completed prior to this revision, such as those identified in Notices of Violation 454/88007-02 and 454/88011-01.
Byron Station will compare a selected number of completed safety related modification packages to the new modification program to ensure all necessary documents were properly updated. The program to perform this review will be developed by October 15, 1988.
An initial sample slae of 20% for modifications which were operation authorised between August 1, 1987 and September 1, 1988, will be reviewed by December 31, 1988 The sample slae will be increased by 20% if any discrepancies are found.
Additionally, the station is backfitting modifications being performed during the Unit I refueling outage with the modification station checklist (BAP 1610-871). This backfit will ensure critical documents required for operation are updated.
The new modification program and planned actions were discussed with the Byron Station Senior Resident inspector on September 13, 1988.
5137K