ML20198R362
| 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: |
| 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) | |
See also: IR 05000454/1997009
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USLE. ILUNOIS 80632-4361
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Mr.K Groessor
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PUBL
Site Vice President _
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
Unit i and Unit 2 reactor facilities. An exit meeting was conducted on June 5,1997, and the
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inspection report was issued on July 25,1997. A predecisional enforcement conference was
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conducted on September 11,1997, to discuss the inspection issues related to strict compliance
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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
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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
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(96-007) determined that the intent of the TS was being met based on factors such as the
pressure in the piping and the CV system design and piping configuration. However, this
ol:erability assessment failed to recognize that TS requirements were not being strictly met and
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. 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 -
devices. ' In the first example, the continuity check for the slave relay contacts that actuate the -
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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
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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
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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
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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
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
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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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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
- Enclosure: Notice of Violation and Proposed
impocition of Civil Penalty
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K.- Graessor
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ec w/ encl:
R. J. Manning, Executive
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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.
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l. Johnson, Lloonsing .
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Operations Manager
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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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K. Graesser
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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
Docket File
..