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Discusses Insp Repts 50-454/97-09 & 50-455/97-09 on 970527- 0605 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000
	ML20198R362
Person / Time
Site:	Byron
Issue date:	10/03/1997
From:	Beach A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Graesser K; COMMONWEALTH EDISON CO.
Shared Package
ML20198R368	List: ML20198R362; ML20198R381;
References
	50-454-97-09, 50-454-97-9, 50-455-97-09, 50-455-97-9, EA-97-264, NUDOCS 9711130248
	Download: ML20198R362 (6)
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Mr.K Groessor -

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Site Vice President _ PUBL IC DOCUMI.K1 N M-

Byron Stklon -

Commonwealth Edison Company

4450 N. ' German Church Road -

Byron, IL 61010

SUBJECTi NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -

. $55.000 (NRC Special Inspection Report No. 50-454/97009; 50-455/97009)

Dear Mr. Graesser:

' This revers to the special inspection conducted from May 27 through June 5,1997, at the Byron

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Unit i and Unit 2 reactor facilities. An exit meeting was conducted on June 5,1997, and the

inspection report was issued on July 25,1997. A predecisional enforcement conference was

l conducted on September 11,1997, to discuss the inspection issues related to strict compliance

l. with Technical Specifications (TS) for the Centrbgal Charging (CV) system and cont innment

= isoistion valvoc and issues related to Emergency Core Conting System (ECCS)_wrt; ten

procriuies.

Based on the iriformation developed during the inspectidn and the information that you provided

du ing the conference, the NRC has determined that violations of NRC requirements occurred.

The violations are cited in the enclosed Notice of Violation (Notice) and Proposed Imposition of

Civil Penalty and the circumstances surrounding them are described in detail in the subject i

inspection report.1

Section i.A.1 of the Notice addresses two examples of falling to strictly comply with TS

surveillance test requirement 4.5.2.b(1) which requires the ECCS pump casings and discharge:

piping high points outside of containment be vented at least once every 31 days. _In the first '

example, on February 16,1996, a Braidwood Station syatem engineer discovered that the CV

pump casing'and high point vents were not being vented every 31 days as required. The

decielon to not strictly comply with the TS was partially based by the Byron Station staff on the

fact that the CV pump casings did not have vents.- A subsequent operability assessment

(96-007) determined that the intent of the TS was being met based on factors such as the

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pressure in the piping and the CV system design and piping configuration. However, this

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ol:erability assessment failed to recognize that TS requirements were not being strictly met and

. that a TS change was needed. The failure to recognize that the TS requirements were not

, being strictly met and to sock a TS change.was identified by ihe NRC.

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The secend example addresses the failure to include a high point vent valve (1RH027) in

- residual heat removal (RH) system surveillance test procedure 1/2 BOS 5.2.b-1. This

procoure is used to meet the requirements of TS surveillance test 4.5.2.b(1). The failure to

include this valve in the_ surveillance test proceduru was identified by the NRC,

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The potential safety consequence of this violation was low. Venting of the ECCS is required to

ensure that no air is entrained in the ECCS that could result in water hammer or air binding that

could prevent proper pump / system performance. Due to the pressure in the CV system piping

and the system configuration, this was not likely to occur in the RH system, high points that

were adjacent to 1RH027 were vented on a quarterly basis. In addition, the ultrasonic testing,

performed by the Byron Station staff, of selected CV high points and the venting of 1RH027

found no entrained air.

Section I.A.2 of the Notice addresses two examples of failing to comply with TS Table 4.3-2,

- Functional Unit 3.a.(2), which requires that Containment isolation Phase A isolation automatic

actuation logic and actcation relays receive a slave relay test on a quarteriy basis. The slave

relay test shall include a continuity check, as a minimum, of associated testable actuation -

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devices. ' In the first example, the continuity check for the slave relay contacts that actuate the -

CV letdown orifice isolation valves had not been performed since April 2gl1ggi, in the second

example, the continuity check for the slave relay contacts that actuate the CV letdown isolation

' valves had not been_ poiformed since Juno 13,1991. Prior to these time frames, actual stroking

j of the valver was performed, which provided the continuity check.

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On September 25,1990, Westinghouse Corporation notified Byron Station that stroking the CV

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. letdown line valves,1/2CV8152 and 1/2CV8160, which was done when performing the quarterly

slave relay containment isolation tests, could result in thermal transients on the CV piping and

nozzles and a high fatigue usage factor. To minimize this effect, Westinghouse recommended

a visual verification and/or electrical continuity test of the slave relay contact actuation instead

of stroking the valve. Although not specifically identified by Westinghouse, Byron Station

determined that the letdown orifloo isolation valve (1/2CV8149A/B/C) slave relay test should

also bs changed in the same manner for thermal transient conoems. - To accomplish the test

without strolong the valves, jumpers were installed across the letdown valve contacts and fuses

were pulled on the letdown ortfice isolation valves to prevent valve actuation when performing

the TS required quarterly surveillance test. Vertfication of the slave relay contact actuation was

. not performed as part of this new testing methodology. -

The potential safety consequence of this violation is low.L Other contacts on the relay were -

vertfled to be operable by observing the actuation of other equipment and the valves were

actually stroked using these contacts approximately every 18 ' months (every refueling outage)

to_ satisfy other TS surveillance test requirements in addition, had these valves failed to close

during an accident, the' emergency operating procedure would have instructed the operators to

close the valveu manually, which could be done without reliance on these contacts,

t While the potential safety consequences of these violations is low, the regulatory significance is

high.iln the case 'of the CV system venting, the Byron Station's staff continued to operate

outside of TS requirements even after discovering that the TS were not being strictly complied

with and did not seek a TS change from the NRC in order to comply. NRC involvement was

necessary in order to ensure that strict compliance with the TS requirements and the necessary

.TS changes were made. The failure to request the necessary TS changes denied the NRC the

opportunity to determine whether safety issues were involvedi in the case of the failure to

perform the required continuity checks on Containment Isolation Phase A isolation relays,

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K. Graessor - 3-

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Byron Station's staff believed that the intent of the TS requirements were being met, Again,

they did not realize the importance of sirictly complying with TS requirements.

Based on the foregoing, these violations have been classified in the aggregate in accordance

with the ' General Statement of Policy and Procedures for NRC Enfomement Actions *

(Enforcement Policy), NUREG-1600 as a Severity Levelill problem. In accordance with the

Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity

Levelill problem, Because your facility has been the subject of escalated enforcement actions

within the last 2 years', the NRC considered whether credit was warranted for Identrication and

Corrective Acticon accordance with the civil penalty assessment in Section VI.B.2 of the

Enforcement Policy.

Identification credit _was not warranted because the Byron Station staff had an opportunity to

- correct the violation in February 1996 when the TS noncomplian ,e was identified for the CV

pump venting.' The NRC identified the continued violation of the TS survelPance testing

requirements during the 1997 inspection. In addition, it was the NRC that identified the failure

to perform the venting of the Unit 1 RHR heat exchanger high point vent valve - The NRC

recognizes that the Byron Station staff identified the failure to perform quarterly continuity tests

for the slave relay contacts. However, this occurred after the NRC identified the ECCS TS

issues.

Corrective Action credit was warranted based on the corrective actions implemented and

discussed at the enforcement conference. The corrective actions included: (1) ultrasonic

testing .nspection of vulnerable areas in the CV system; (2) review of selected TS surveillance

tests to verify strict compliance; (3) submittal of appropriate license amendment requests;

(4) revision of affected procedures; (5) distribution of a Station Manager letter which stress's

strict compliance with TS requirements; (6) revision of Unit 1 monthly surveillance test

procedure to incorporate the 1RH027 vent valve; (7) review of ECCS isometric drawings to

verify all high point vent valves are included in the surveillance test procedures; (8) review of all

slave relay surveillance test procedures (to be completed by November 7,1997); and (9)

evaluation of a slave relay test modification (to be completed by December 5,1997).

Therefore, to emphasize the importance of strict compliance with Technical Specifications, I

have been authedzed, after consultation with the Director, Office of Enfc.coment, to issue the

enclosed Notice of Viciation and Proposed imposition of Civil Penalty (Notice) in the amount of

$55,000 for the Severity Level 111 problem.

The violation described in Section ll of the Notice discusses one Severity Level IV violation that

war not assessed a civil penalty. This violation addresses a failure in provide adequate

instructions to ensure the safety injection (SI) pump casings were vented. Specifically,

procedure 1/2BOS 5.2.b-1 provided no speci'ic direction to the operator as to what valves were

' A Notice of Violation for a Severity Level ill problem was issued on December 11,1995

(EA95-197) and a 3100,000 proposed civil penalty arv. a Notice of Volation was issued

- on February 27,1997 (EA 97-508) for Severity Level all problems.

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K. Graesser . -4-

to be open to vent the Si pumps. Since operators routinely had to pstform additional steps not

- included in the procedure in order to vent the SI systen', numerous opportunities existed for the

inadequate procedure to be identified. This violation is classifed in accordance with the

Enforcement Policy as a Severity Level IV violation.

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

encioned 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.

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

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

Sincerely,

aL.

A. BillBeach

Regional Administrator -

Docket No. 50-454 & 50-455

License No. NPF-37 & NPF-66

- Enclosure: Notice of Violation and Proposed

impocition of Civil Penalty

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K.- Graessor 5-

ec w/ encl: R. J. Manning, Executive -

Vice President, Generation

M. Wallace, Senior Vice

President, Corporate Services

H. G. Stanley, Vice President

PWR Operations

Liaisnn Officer, NOC-BOD

D. A. Sager, Vice President,

Generation Sup'ott

D. Farrer, Nuclear Regulatory

, . Services Manager.

!; l. Johnson, Lloonsing .

'-

Operations Manager _

Document Control Desk-Licensing

K. Kofron, Station Manager.

D. Brindle, Regulatory Assurance

Supervisor-

Richard Hubbard

Nathan Schloss, Economist

_ Office of the Attomey General -

State Liaison Officer'

State Liaison Officer, Wisconsin

Chairman, Illinois Commerce

Commission

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_ _ _ _

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K. Graesser 6-

DISTRIBl1 TION:

PUBLIC pi -

SECY /

CA I

LCallan, EDO

AThadani, DEDE

LChandler, OGC

JGoldberg, OGC

SCollins, NRR

RZimmerman, NRR

Enforcement Coordinators

Rl, Ril and RIV

Resident inspector, Byron

RCapra, NRR

GDick, NRR -

JGil!!!and, OPA

HBell, OlG

l GCaputo, Ol

! LTromper, OC

TMartin, AEOD

OE:ES

OE:EA (2)

GJohnson, OC/DAF

RAO: Rill

SLO: Rill

PAO;Rlli

OC/LFDCB

DRP

Docket File

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ML20198R362

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