ML20198C030
| ML20198C030 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/31/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-414-97-20, 50-454-97-20, BYRON-97-0313, BYRON-97-313, NUDOCS 9801070156 | |
| Download: ML20198C030 (5) | |
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i December 31, 1997 LTR BYRON 97 0313 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97020; 50-455/97020 NRC Docket Numbers 50-454, 50-455 References Geoffrey E. Grant letter to Mr. Graenser dated December 4, 1997, transmitting NRC Inspection Report 50-454/97020; 50-455/97020 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 one (1) Severity Level IV viointion requiring a written response.
Comed's response is provided in the attachment.
This letter contains the following commitments:
1)
Nuclear Station Procedure NSP-RA-4002, Nuclear Station Processing of Operating License Amendment Requests, will be revised to include the requirement to have the amendment placed in the appropriate location in accordance with the 10CFR19.
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i Hyron Ltr. 97-0313 Dedember 31, 1997 Page 2 If your staff has any questions or comments concerning this letter, please refer them to Don Drindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully,
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t-K. L. Ora e,,>r Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc:
A. B. Beach, NRC Regional Administrator - RIII G.
F. Dick Jr., Byron Project Mana ger - N2R Senior Resident Inspector, Byron M. J. Jordan, Reactor Projects Chief - RIII F. Hizjolek, Division of Engineering - IDNS (p:\\97byltrs\\970313.wpf)
ATTACHMENT I e
VIOLATION (454/455-97020-01) 10 CFR 19.11(a) (2) states that each licensee shall post current copies of the license, license conditions, or documents incorporated into a licenso by reference, at>J amendments thereto.
10 CFR 19.11(b) states that when posting of the current license is not practical, the licensee may post a notice w*ich describes the document and states where it may be examined.
The Byron Station posting indicates tb te current Unit i and Unit 2 licenses can be located in central f-Contrary to the above, as of September.
1997, neither the Unit i nor Unit 2 licenses in central files were current.
Jpecifically, the following eight Technical Specification amendments were not incorporated,
- a. Amendment 84, issued June 26, 1996, to be implemented within 30 days
- b. Amendment 86, issued April 2, 1997, to be implemented within 45 days
- c. Amendment 87, issued April 15, 1997, to be implemented within 30 days
- d. Amendment 88, issued April 16, 1997, to be implemented within 30 days
- e. Amendment 89, issued May 6, 1997, to be implemented within 30 days
- f. Amendment 90 (Unit 1), issued August 13, 1997, to be implemented within 30 days
- g. Amendment 90 (Unit 2), issued July 10, 1997, to be implemented within 30 days
- h. Amendment 91 (Unit 2), issued August 13, 1997, to be implemented within 30 days This is a Severity Level IV Violation (Supplement I).
(50-454/455-97020 01(DRP))
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samanas IOR TME VIO1ATION i
The requirement to post the location where a current copy of the license could l
be viewed ' (Central File) as per 10CFR19.11 was done properly. However, the requirement to keep this copy up to date was not-procedura11:ed, and therefore was overlooked.
.The Regulatory Assurance Supervisor believed that the amendments had been
" implemented" as required by the amendment's cover letter. As each of the referenced amendments were received, it was " implemented" in the sense that the appropriate surveillance procedures were put in place, if necessary.
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since all the referenced emendments, except for #86 and #90(Unit 1)/#91(Unit 2 ) ', were in fact, relaxstions of the Technical Specifications that they replaced, even if-the Operators had followed the previous Technical
'Jpecification in the Techriccl. Specification book, they would have more than ve.t the requirements of the n tw Technical Specification.
4 Amendments #86 and #$0 0 nit 1 /#91(Unit 2) had been requested because of plant problems.that required Iore estrictive Technical Specifications.
In these-two cases, Byron had already revised the required procedures necessary to implement these two amendments, and had been following them for several months. Therefore, the inclusion of the new amendments into the Technical j
Specification book was only a formality with respect to station procedures.
CORh8CTIVE.STIFS TAKEN AND RESULTS ACHIEVED In August of 1997, in order to get the amendments into the Technical Specification books, the Regulatory Assurance Supervisor began the process of obtaining additional resources in the form of Professional Staff Augmentation (PSA). The PSA arrived on site on Sept. 17, 1997 Following N-GET and other i
required training, his first assignment was to begin the On-Site Review process to put'the amendments in the Technical Specification-books.
Before he could complete the task, the NRC Resident Inspector, on Sept. 26, 1997, realized that the amendments had not been incorporated into the-Technical Specification books. On Sept. 29, 1997 the Regulatory Assurance Supervisor i
discussed the issue with the. Resident Inspector and told him that the PSA was onsite and his first assignment was to incorporate the amendments into the Technical Specification book.
It was expected to take several weeks.
The PSA began working on the amendments on Sept. 23, 1997.
The' amendments were On Site Reviewed and then sent to Central File for distribution ~to the' Station copies of the Technical Specifications on Oct. 27, 1997 and Nov.
3, 1997.
The Regulatory Assurance Supervisor has discussed this event and the requirements of'10CFR19 with the other Regulatory Assurance Supervisors at'the other Comed sites'.
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CORRBCTIVE STEPS TMAT WILL BE TAKEN TO AVOID FURTMER VIOLATION Nuclear Station Procedure NSP-RA-4002, Nuclear Statior. Processing of Operating License Amendment Requests, which will be used by all'hix Comed nuclear sites, i
will be revised to include the requirement-to.have the amendment placed in the appropriate location in accordance with the 10CFR19. This action will be tracked by NTS itemN 454-100 97-02001 01).
DATE WMEN FULL CCHPLIANCE WILL BE ACEIEVED Full compliance was achieved on November 3, 1997 when Amendment #91(Unit 2) was issued to Central File for distribution.
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