ML20198F700

Discusses Insp Repts 50-454/97-05 & 50-455/97-05 on 970314- 0501 & Forwards Notice of Violation

ML20198F700
Person / Time
Site:	Byron
Issue date:	07/22/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Graesser K COMMONWEALTH EDISON CO.
Shared Package
ML20198F705	List: ML20198F700 ML20198F823
References
50-454-97-05, 50-454-97-5, 50-455-97-05, 50-455-97-5, EA-97-200, NUDOCS 9708130121
Download: ML20198F700 (5)

See also: IR 05000454/1997005

Text

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July 22, 1997

7

EA 97 200

Mr. K. Graesser

Site Vice President

Byron Nuclear Power Station

Commonwealth Edison Company

. 4450 North German Church Road

Byron, IL 61010

97 JL 25 N0:25

SUBJECT: NOTICE OF VIOLATION

(NRC INSPECflDR EENflNUI i '$4/97005(DRP);

4 50-455/97005(DRP))

Dear Mr. Graesser:

This refers to the inspection conducted from March 14,1997, through May 1,1997, at

the Byron Generating Station Units 1 and 2 facility. This inspection included a review of

the containment floor drain leak detection system. The written results of this inspection

were provided to you on_ May 28,1997. Problems with the floor drain system were -

. docketed by Byron Station in Licensee Event Report 50-455/97001, dated April 17,1997.

A predecisional enforcement conference was conducted on June 21,1997.

Based on the information developed during the inspection and the information that you

provided during the conference, the NRC has determined that a violation of NRC

requirements occurred. This violation is cited in the enclosed Notice of Violation and the

circumstances surrounding it are described in detailin the subject inspection report.

Specifically, as of March 14,1997, the facility was not as described in the Updated Final

Safety Analysis Report (UFSAR)in that the grates described in UFSAR Figure 5.2 3

covering the containment floor drains leading to the containment floor drain leak detection

-system were not installed. The drains were either covered with a different grate or screen,

or were not covered at all resulting in the potential that foreign material could enter the

drain system and adversely affect the leak detection system. On March 15,1997, foreign

material was found plugging the leak detection system, rendering it inoperable at that time.

- This violation is of concern because a written safety evaluation was not performed to make

a determination that the change did not involve an unreviewed safety question, in

addition, the updated FSAR was not complete and accurate in all material respects in that j

it did not reflect this change. Subsequently you completed an operability determination f

that concluded the floor grates were not required for the containment floor drain leak-

detection system to be operable. While system operability was not affected, the missing

drain grates did contribute to the degraded condition of the leak detection system.

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K. Greesser 2-

Three other apparent violations regarding the potential inoperability of the containment

floor drain leak detection system, potentially incomplete or inaccurate information in the

LER regarding this event, and the potential failure of operators to identify this event were

identified in the subject inspection report. Based on information presented at the

predecisional enforcement conference, the NRC determined that these apparent violations

were not substantiated. While the containment leak detection system was degraded, it

could not be demonstrated to have been inoperable until the discovery of standing water in

the floor drains on March 15,1997. While we can not demonstrate that the system

became inoperable for greater than the 7 days allowed by your technical specifications we

do believe that it was only marginally capable of performing its design function and that

the additional margin or capabi!ity for the system to detect leaks had been significantly

reduced. At the time that your staff detected the problem with the system the plant was

in a condition in which operebility of the system was not required. Based on the above, a

violation of technical specificvions was not substantiated. A violation of 10 CFR Part 50,

Appendix B, for operators falling to identify a condition adverse to quality, was not

substantiated based on our review of the information that Byron presented during the

predacisional enforcement conference. While the possibility for the operators to detect the

system degradation existed, we consider the circumstances to be sub that not detecting

the system degradation in this case did not constitute a violation. Finally, a 10 CFR 50.9

violation was not substantiated because on final review all of the information in the

licensee event report (LER) 50 455/97001, " Unit 2 Containment Drain System Clogged

Due to Debris," was in fact complete and accurate in all material respects. The apparent

incomplete and inaccurate information discussed in the subject inspection report was

determined to be poor presentation within the LER. However, well developed reports to

the NRC are vital to clear cominunication of issues at your station.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

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K. Graesser 3-

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely,

A. Bill Beach

Regional Administrator

Docket Nos. 50-454; 50-455

Licenses No. NPF 37, NPF-66

Enclosure: Notice of Violation

cc w/ encl: T. J. Maiman, Senior Vice President

Nuclear Operations Division

D. A, Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

K. Kofron, Station Manager

D. Brindle, Regulatory Assurance

Supervisor

I. Johnson, Acting Nuclear

Regulatory Services Manager

Richard Hubbard

Nathan Schloss, Economist

Office of the Attorney General

State Liaison Officer, Wisconsin

State Liaison Officer

Chairman, Illinois Commerce Commission

Document Control Desk Licensing

DOCUMENT NAME: G:\EICS\97-200 WS2

To receive a copy of this document, Indicate in the box "c" = Copy w/o attach /encI *E' = Copy w/ attach /senci *N" = No copy

0FFICE RIII lc RIlK l RIII ,, l RIII\ l

NAME C1ayton (44. Grobe\ Gran . %N Beach \

DATE 7/f g 7 \ n tY()/) \

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OFFICIAL RECORD C031

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K. Graesser .3-

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure, and your responso will be placed in the NRC Public Document Room (PDR).

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos. 50-454;50-455

- Licenses No NPF-37, NPF-66

Enclosure: Notice of Violation

cc w/ encl: T. J. Maiman, Senior Vice President

Nuclear Operations Division

D. A. Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

K. Kofron, Station Manager

D. Brindle, Regulatory Assurance

Supervisor

1. Johnson, Acting Nuclear

Regulatory Services Manager

Richard Hubbard

Nathan Schloss, Economist

Office of the Attorney General

State Liaison Officer, Wisconsin

- State Liaison Officer

Chairman, Illinois Commerce Commission

Document Control Desk-Licensing

SEE PREVIOUS CONCURRENCE

DOCUMENT NAME: G:\EICS\97 200.WS2

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