ML20198F700
| 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: |
| 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
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July 22, 1997
EA 97 200
7
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:
(NRC INSPECflDR EENflNUI '$4/97005(DRP); 50-455/97005(DRP))
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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
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. 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
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it did not reflect this change. Subsequently you completed an operability determination
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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
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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
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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
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K. Graesser
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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 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
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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Resident inspector, Byron
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