ML20198R015
| ML20198R015 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/03/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-09, 50-454-97-9, 50-455-97-09, 50-455-97-9, BYRON-97-0241, BYRON-97-241, NUDOCS 9711130119 | |
| Download: ML20198R015 (9) | |
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1.10.0101
'trector silice of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUBJECT!
Byron Nuclear Power Station Units 1 and 2 Reply to a Notice of Viole.tior Inspection Report No. 50-454/97009; 50-455/97009 NRC Docket Numbers 50-4 54, $(,-4 55 REFERENCEt A. B. Beach lotter to Mr. Graesser dated October 3, 1997, transmitting Notice of Violation and Imposition of Civil Penalties 50-454/97009; 50-455/97009 Enclosed is Commonwealth Edison Company's response to the Notice of vio.lation (NOV) which was transmitted with the referenced letter.
The NOV cited one (1)
Severity Level III violation and one (1) Severity Level IV violation requiring a written response. Comed's response is provided in the attachment.
We appreciate the need to comply precisely with Technical Specificationr. At Byron, we strive to comply with Technical Specifications and all other licensing requirements. Our approach is to abide by the plain meaning of the requirements. We want to be sure that any questions regarding interpretations of the licensing requirements are brought to management's attenti. promptly and resolved appropriately.
This letter contains the following commitments:
1.
The Plant Operational Review Committee (PORC) at both Braidwood and Byron Stations will review Technical Specification literal compliance issues raised at either station.
This is expected to be a redundant examination of literal compliance questions. This redundant review will be conducted for approximately a one year period, at which time a determination will be made whether this
.prociss should be continued.
2.
In approximately 12 months, the site will perform an effectiveness review with respect to the corrective actions relative to ECCS
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Novembcr*3, 1997 Page 2-3.
A review of all slave relay surveillance procedures to compare electrical schematics and surveillances to verify all Technical Specification requirements are met is being conducted.
4.
A modification is being evaluated to resolve thermal transients caused by cycling of the letdown line containment isolation valves.
To the best of my knowledge and belief, the statements contained in this document are true and correct.
In some respects these statements are not based on rny personal knowledge, but on the information furnished by other CorrEd employees, contractor employees, and/or consultants.
Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext. 2280.
Pespectfully, dL L. G ar ser s.
Site Vict President Byron Nuclear Power Station State of Illinois SS County of Ogle Subscribed and sworn to before me this 28th Day of October 1997
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KLG/DB/rp Attachment (s) cc A. B. Beach, NRC Regional Administrattr - F 'I G. F. Dick Jr., Byron Project Managet - NRR I
Senior Resident Inspector, Byron R.
D. Lanksbury, Reactor Projects chief - RIII F. Niziolek, Division of Engineering - IDNS (p WTbytrs\\970241 wpf) l i-
ATTACHMENT I VIOLATION ASSESSED A CIVIL PENALTY A. Compliance with Technical Specifications 1.
Technical Specification 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems be operable with the units in Modes 1, 2, and 3 with each subsystem comprised of:
a) one operable centrifugal charging pump; b) one operable safety injection pumps c) one operable Residual Heat Removal ( RHR) heat exchanger; d) one operable RHR pump; and e) an operable flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatic opening of the containment sump suction valves.
Technical Specification Surveillance 4.5.2.b(1) requires that each ECCS subsystem be demonstrated operable at least once per 31 days by venting the ECCS pump casings and discharge piping high points outside of containment.
Contrary to the above:
a.
Since commercial operation began in 1985 and 1986, respectively for Unit 1 and Unit 2, and continuing until May 1997, the ECCS subsystem consisting of a Centrifugal Charging (CV) system had not been demonstrated operable at least once per 31 days by venting the pump casing and the CV high points outside containment when the units were in Modes 1, 2, and 3.
b.
A Unit I high point vent, 1RH027, on the discharge piping of the RHR.. eat exchanger outside of containment was not vented at least once per 31 days when the units were in Modes 1, 2, and 3, to demonstrate operability from 1985 through June 2, 1997.
2.
Technical Specification 3.3.2 requires that the Engineered Safety Features Actuation System (ESEAS) instrumentation channels and interlocks shot in Table 3.3-3 shall be operable with their trip setpoints set consistent with the values shown in the trip setpoint column of Table 3.3-4.
Technical Specification Surveillance 4.3.2.1 requires that each ESEAS instrumentation channel and interlock and the automatic actuation logic and relays be demonstrated operable by the performance of the ESEAS instrumentation surveillance requirements specified in Table 4.3-2.
Technical Specification Table 4.3-2, Punctional Unit 3.a(2),
" Containment Isolation, Phase.'. Isolation," requires that automatic actuation logic and actuation relays receive a slave relay test on a quarterly basis.
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- Technical Specification Definition 1.31 states,'in part, that a slave relay test shall include.a continuity check, as a minimum, of associated testable actuation devices.
Contrary to the abover a.
As of May 27, 1997, the continuity test for the slave relay
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contacts that actuate the CV letdown orifice isolation valves ICV 8149A/B/C and 2CV8149A/B/C, (Containment Phase A Isolation
-Valves) was not performed on a quarterly basis since April 29, 1991.
- b..
As of May 27, 1997, the continuity test for the slave-relay contacts that actuate the CV letdown isolation valves ICV 8152, 1CV8160, 2CV8152,cand 2CV8360, (Containment Phase A Isolation Valves) was not performed on a quarterly basis since June 13, 1991.
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I These violations represent a Severity Level III problem (Supplement I)-
$55,000.
i REASON FOR THE VIOLATION j
1a. Failure to vent CV system according to Technical specification (TS) requirement 4.5.2.b.1 In 1996, a Problem Identification Form (PIF) was initiated by a member of our System Engineering Group. An evaluation of the PIP was made in addition to an Operability Assessment. At that time, the design of the system was reviewed.
Specifically,-we looked at three elements: 1) the CV Pump discharge piping being under constant pressure, 2) the physical arrangement of the pump casing, and 3) -the design of the auction and discharge piping. When we internally looked-at the question, we believed we were making good faith, informed decisions on the issue of compliance with Technical Specifications. We had determined that the system was self-venting and the Surveillance Requirements 4
were being satisfied.
In retrospect, the wrong decision was made regarding our determination that the continuous venting feature of the CV design satisfied the Technical-Specification Surveillance Requirement.
It was not consistent with precise compliance. Although there was never any intent to operate the system outside of. Technical Specifications, we were not-sensitive to the issue of literal compliance because of-the CV design features.
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Failure to vent 1RH027 per Technical specifications
.The root 'cause is a deficient surveillance procedure, which did not include
'1RH027 highpoint vent. LUnit 2. piping routing is different, with:no equivalent valve.-
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2a. Failure to perform CV letdown orifice isolation valve slave relay test per
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Toghnical specification
-and-t 2b. Failure to perform CV letdown isolation valve slave relay test per
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Technical specification j
f Prior to 1990, all valves were stroked in compliance with Technical
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Specifications.
In 1990, Westinghouse advised Byron not to stroke the valves F
(only CVB152/8160) because charging nozzle thermal transients could be caused by closing letdown isolation valves during quarterly slave relay surveillance performance.
Byron also applied this issue to the orifice isolation valves because of similar impact on thermal transients.
-f Jumpers were used to prevent stroking the letdown isolation valves and still be able.to perform the surveillance test.
Fuses were pulled for the letdown ori" ice isolation valves.. The use of jumpers permanently was not a dosirable choice..Therefore, other permanent actions were considered: 1) install a
_t modification on the letdown isolation valve control circuit to prevent the valves from closing during the surveillance, or 2) submit a Technical Specification change to increase the surveillance frequency from quarterly to
-18 months.
The choice was made to continue using jumpers / pulling fuses for Technical f
Specification compliance until a Technical Specification change could be obtained. We chose to follow industry activities via a " lead plant" concept to increase frequencies from quarterly to 10 months.- When these efforts stalled, we did not appropriately react to submitting the Technical Specification change or initiating a modification.
'In March 1996, a jumper installed for the performance of a quarterly aurveillance fell off and caused a letdown isolation (LER 06-001).
Subsequent review of this event by the Safety Review Committee questioned the use of jumpers while performing the Technical Specification surveillance.
The Safety Review Committee was told previous Onsite Reviews were written in 1990 and 1993 reaffirming the installation of the jumper.
Engineering was instructed to update the Onsite Review to 1997 standards and review any previously identified corrective actio.
Upon completion of the review of the Technical Specification SLAVE RELAY TEST definition, it was determined the jumper installation and fuse removal did not meet the Technical Specification surveillance requirement and the slave relays were declared inoperable. The slave relay surveillances were changed to stroke the valves and then performed to meet the Technica) Specification requirements.
-In summary, there were two root causess 1) the Onsite Reviews (1950 and 1993) did not recognize that the addition of jumpers did not meet the requirements of the Technical Specifications, and 2) the Onsite reviews were also inappropriately applied to the orifice block valves.
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t CONIECTIVE STEPS TAMEN AND RESULTS ACHIEVED
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1a.' Fail re to vent CV system according to Technical Specification (TS) _
requirement 4.5.2.b.1 1)
_ An NOED was granted on May 24, 1997, an emergency Technical n
Specification change was granted for Unit 1 on June 1, 1997 and an exigent Technical Spec.fication change was approved for Unit 2 on August 13, 1997.
I 2)
For the specific CV system Technical Specification surveillance requirements,-Ultrasonic Testing inspection of vulnerable areas was performed and continues.
To date, results have beon acceptable.
. F 3)
The "ECCS Venting and Valve Alignment Monthly" surveillance (1/200s 5.2.b-1)-has been revised to include better acceptance.
criteria and actions to satisfy the surveillance requirements.
4)
Byron has performed an independei.t review of selected Technical r
-Specification surveillances.
Selected sections were reviewed based on their highest potential for having difficulties. This review involved a comparison of the Technical Specification words to the actual surveillances being currently performed.
It is intended to verify literal compliance.
There were no identified Technical specification amendments needed.
5)
The Station Manager distributed a letter to Site personnel stressing the responsibility of Technical Specification literal compliance.
1b, Failure to vent-1RH027 per Technical specifications I
1)
The "ECCS Venting and valve Alignment Monthly" surveillance (1/2BOS 5.2.b-1) has been revised to include the IRH027 valve.
2)
ECCS isometric drawings were reviewed, verifying all highpoint vent valves are included in cerveillance procedures.
On 10/23/97, while investigating some questions for the pending vent valve modification, it was discovered that there were additional vent 1
valves (Unit 1 only) on these lines that should be included in the
- monthly ECCS venting procedure.
Subsequently, a-walkdown of safety injection cold leg injection piping by two independent
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reviewers was performed, as well as additional reviews of the procedure.
These valves were not identified as high point vents when the procedure was'previously revised. A temporary procedure change was made and' venting performed.
An LER is being written.
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F 2a. Failure to perform CV letdown orifioe isolation valve slave relay test per Technical specification.
-and-2b. Failure to perform CV letdown isolation valve slave relay test per Technical specification 1)
. Byron has perforued an independent riview of selected Technical Specification surveillances.
Select.1 sections were reviewed based on their highest potential for having difficulties.
This review involved a comparison of the Technical Specification words to the actual surveillances being currently performed.
It is intended to verify literal compliance. There were no identified Technical Specification amendments needed.
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_ CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1a. Failure to vent CV system according to Technical specification (TS) requirement 4.5.2.b.1 1)
The Plant Operational Review Committee (PORC) at both Braidwood and Byron Stations will review Technical Specification literal compliance issues raised at either station.
This is expected to be a redundant examination of literal compliance questions. This redundant review will be conducted for approximately one year period, at which time a determination will be made whether this crocess should be continued.
This is tracked by NTS item # 454-100-97-SCAQ00010-01.
2)
In approximately 12 months, the site will perform an effectiveness review with respect to the previously mentioned corrective actions. This will be tracked by NTS item # 454-100-97-00901a-ER.
1b. Failure to vent 1RH027 per Technical specifications 1)
None 2a. Failure to perform CV letdown orifice isolation valve sl3ve relay test per Technical Specification
-and-2b. Failure to perform CV letdown isolation valve slave relay test per Technical specification 1)
A review o2 all slave relay surveillance procedures to compare electrical schematics and surveillances to verify all Technical Specification requirements are met is being conducted.
This is being tracked by NTS item # 454-100-97-00902b-01.
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2)
Upon completion of slave relay surveillance procedure review, evaluate modification to resolve thermal transients caused by cycling of the letdown line containment isolation valves. This is trackad by NTS itemN 454-100-97-00902b-02.
3)
The Plant Operational Review Committee (PORC) at both Braidwood and Byron Stations will review Technical Specification literal compliance issues raised at either station.
This is expected to be a redundant examination of literal compliance questions. This redundant review will be conducted for approximately one year period, at which time a determination will be made whether this process should be continued. This is tracked by NTS itemN 454-180-97-SCA000010-01.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved for ECCS venting when the appropriate license amendments were issued.
Full compliance was achieved for slave relay testing on 5/27/97 and S/28/97 when appropriate slave relay terting was completed.
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g ATTACHMENT II -
VIOLATION NOT ASSESSED A CIVIL PENALTY A.
Written Procedures 1.
10 CFR Part-50, Appendix B, criterion V,
" Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. The procedures shall include appropriate qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
-Contrary to the above as of June 2, 1997, procedures 1BOS 5.2.b-1,
" Unit 1 ECCS Venting and Valve Alignment Monthly Surveillance,"
Revision 5 and 2BOS 5.2.b-1, " Unit 2 ECCS Venting and Valve Alignment Monthly Surveillance," Revision 4, failed to have appropriate steps specified to vent the safety injection pumps.
This is a Severity Level IV violation.
REASON FOR THE VIO1J. TION There was an alternste flowpath for venting the Safety Injection (SI) pump.
The operators had applied craft capability to use an alternate flow path if the primary flow path could not be used.
Either flow path would adequately vent the pump.
If neither flow path could be used, the surveillance provided adequate guidance to notify management of the failed surveillance.
The procedure was inadaquate as written because it did not identify all possible flow paths.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The "ECCS Venting and Valve Alignment Monthly" surveillance (1/2BOS 5.2.b-1) has been revised to provide guidelines on using either flow path tc verify adcquate venting of the SI pumps.
2.
Other ECCS pump configurations were reviewed for pump venting capabilities, with no discrepancies identified.
CORRECTIVE STEPS THAT.WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
None DATE WHEN FULL CcNPLIANCE WILL BE ACHIEVED Pull' compliance was achieved on 06/03/97 when procedure 1/2BOS 5.2.b-1 was revised-and approved to include appropriate steps to vent the safety injection pumps.
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