ML20199B491
| ML20199B491 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/21/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-22, 50-455-97-22, BYRON-97-0020, BYRON-97-20, NUDOCS 9801280295 | |
| Download: ML20199B491 (5) | |
Text
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O>mmonweakh 1:dison Compan)
. liyron Generating Station K
4 450 North German Church Road
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January 21, 1998 3
LTR:
BYRON 97-0020 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission Washingc'on, DC 20555 l
Attention:
Document Control Desk P
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation
[
Inspection Repo-* No. 50-454/97022; 50-455/97022 NRC Docket Numbers 50-454, 50-455 I
Reference:
Geoffrey E. Grant letter to Mr. Graesser dated i
December 24, 1997, transmitting NRC Inspection Report 50-454/97022; 50-455/97022
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Enclosed is Commonwealth Edison Company's response to the Notice of violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited two (2) Severity Level IV violations requiring a written response. Comed's response is provided in the attachment.
This letter contains the following commitments:
1)
Install suction header vent valves and balance line vent valves on the 2A and 2B CV Pumps prior to entering mode 4 following B2RO7.
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9801280295 900121
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PDR ADOCK 05000454
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A I!nicom Company
Byron Ltr. 97-0020 Tanuary 21, 1998
,Q Page 2 If your staff haa any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully,
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. [3 K. L. Gr es r U
Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc:
A. B. Beach, NRC Regional Administrator - RIII G. F. Dick Jr., Byron Project Manager - NRR E. W. Cobey, Senior Resident Inspector, Byron M. J. Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS (p: \\ 90bylt rs\\ 980020.wp f \\2) l 1
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ATTACHMENT I
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-i VIOLATION (454/455-97022-01) 10 CFR 50 Appendix B, Criterion V, " Instruction, Procedures, and Drawings,"
states. in part, that activities affecting quality shall be prescribed by documented instructions, pr,c"dures, or drawings, of a type appropriate to the circumstances.
Contrary tc the above, as of September 10, 1997, Byron Operating Procedure (BOP) CV-3, " Pilling nd Venting the CV System," Revision S, an activity affecting quality, was not of a type appropriate to the circumstances.
Specifically, BOP CV-3 did not provide appropriate steps to vent the 2B CV pump (50-454/455-97022-01(DRP)).
'his is a Severity Level IV Violation (Supplement I).
REASON FOR THE VIOLATION A procedure was not available to provide instructions for venting the 2B CV Pump af ter maintenance was performed on the pump. The permanent procedure for venting the 2B CV Pump, BOP CV-3, " Filling and Venting the CV System," and the associated valve list BOP CV-3T2, utilized vent flow paths outside the boundaries of the Out of Service placed for the planned maintenance activities on the pump. Using this procedure would have been ineffective in venting the pump in preparation for returning the pump to service.
The type of maintenance performed on the 2B CV Pump was not a routino activity, and as such, a temporary procedure should have been developed for this specific activity. The necessary procedure was not developed prior to completion of maintenance. Not having an appropriate procedure available resulted from a misunderstanding in job planning. Operators involved in planning did not believe the 2B CV Pump would need to be drained to perform the maintenance work. As a result, plans were not made ahead of time to address preparing a procedure for venting the pump upon completion of maintenance activities. This resulted in the pump being vented using craft capability and the pump recirculation line being vented using a temporary procedure change to Station Procedure 2BVS 1.2.3.1-2, " Unit 2 Train B ASME Surveillance Requirements for Centrifugal Charging Pump 2B and Chemical and Volume Control System Valve Stroke Test."
CORRECTIVE STEPS TAKEN AND RFSULTS ACHIEVED The 2B CV Pump was vented utilizing instrument lines as vents and writing a temporary procedure change to Station Procedure 2BVS 1.2.3.1-2 to vent the mini-flow line.
Operating procedure BOP CV-3, Revision 6, was approved for use en December 23, 1997 with guidance on the utilization of installed suction header vent valves and balance line vent valves for venting the CV Pumps.
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C070tRCTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION Mo'ifications have been -installed on the.lA and IB CV Pump casings that d
add suction header-vent valves and balance line vent valves to~ allow easy pump venting. -Modifications are planned to install suction header vent valves-and balance line vent valves on the 2A-and 2B CV Pumps prior to_ entering mode 4
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following B2RO7. This action will be tracked'by NTS itemN 454-100-97-02201-01.
There is no work scheduled on the 2A or 2B CV pumps before the B2R07 outage. If emergent work becomes necessary during operations, prior to installation of the suction header vent -valves and balance line vent valves on-the 2A and 2B CV Pumps, BOP CV-3 will be Temporarily changed to address the equipment as it is currently installed. A Daily order was written informing shift personnel of this expectation.
DATE WHEN FULL CcNPLIANCE WILL BE ACHIEVED Full compliance was achieved on 09/10/97 when the pump was successfully vented.
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ATTACHMENT II
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VIOLATION (454/455-97022-02)
TS 6.0.1.a states-written procedures shall be established, implemented,_and maintained covering the applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, Section 9.e, states general procedures-for the control of maintenance, repair, replacement, and modification-work be prepared before reactor operation is begun.
NSWP-A-03, " Foreign Material Exclusion" (FME), Revision 0, Step 6.4.1, states that all system breeches must be covered where possible except when: the opening ~is attended, and work, inspection, or testing is in progress that requires removal of the FME cover.
Contrary to the above, on November 17, 1997, the inspectors observed two holes not protected.with INE covers in the floor-drain sump cover on the Unit 1 l
containment floor drain sump on the 377 foot level inside the containment missile barrier. At that time, no one was monitoring the FME area and no work or testing was being performed on the floor drain sump (50-454/455-97022-
-02(DRP)).
This is a Severity Level IV violation' (supplement I).
REASON FOR THE VIOLATION
'The cause of this event was due to a lack of any FME cover for the sump to facilitate drain hoses. The drain hoses were just draped into the sump hole.
This made it difficult, if not impossible, to maintain proper FME controls in
-accordance with NSWP-A-03.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Comed management had prev'7usly recognized the inadequacy and was in the process of building special FME covers:for the sump _in question.
This new-sump cover completely covers the sump _and provides mechanically threaded connections.for. drain hoses. This sump cover is now in.use.
A Work-it-Now- (WIN) Team was previously established to review and revise the
'NSWP to: produce an FME procedure that exceeds industry standards. This procedure will clearly define responsibilities, accountabilities and contain the tools to assure that the OME program is being effectively implemented.
This Team is continuing _to meet regularly to establish an appropriate procedure.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATICN Comed considers the new sump covers sufficient to prevent further violations of NSWP-A-03 where this sump is concerned.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on November 19, 1997 when the new sump covers were installed.
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