ML20199B881
| ML20199B881 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/07/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | 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-97-0266, BYRON-97-266, NUDOCS 9711190140 | |
| Download: ML20199B881 (2) | |
Text
Gimmonweahh Idevm Compny e flyron Generatmg f.tation
- 4150 North German Churt.h Road It) run,11. 610109791 1rI8142346641 Aovember7, 1997 LTR:
BYRON 97-0266 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 7TTENTION:
Document Control Desk
SUBJECT:
Byron Nuclear Power Station Units 1 and 2 Correction to Reply to a Notice of Violation Inspection Report No. 50-454/97009; 50-455/97009 NRC Docket Numbers 50-454, 50-455
REFERENCE:
1.
K.
L. Graesset letter to Director, Office of Enforcement dated November 3, 1997, transmitting Reply to a Notice of Violation and Imposition of Civil Penalties 50-454/97009; 50-455/97009
- 2. A.
B. Beach letter to Mr. Graesser dated October 3, 1997, transmitting Notice of Violat!Jn and Imposition of Civil Penalties 50-454/97009; 50-455/97009 Byron Station is reissuing Commonwealth Edison company's response (Reference 1) to the Notice of Violation (NOV) which was transmitted with the referenced letter (Reference 2).
This is being done in order to correct the error involving missing Pages 7 and 8.
I regret any inconvenience this situation may have caused you.
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.
Respectfully,-
$$4df/
K. L. Graeeser Site Vice President Byron Nuclear Power Station KLG/DB/rp g
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Attachment (s) cc:
A. B. Beach, NRC Regional Adrdnistrator - RIII G.
F. Dick Jr., Byron Project Manager - NRR
- enior Resident Inspector, Byron R. D. Lanksbury, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS
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BYRON 97-0241l FILE s,
1.10.0101 1 Director
- Office,of Enforcementc
.f :l U.S. Nuclear' Regulatory Commission..
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Washington,DC20555?(
I ATTENTION:
Document Control Desk-
..,oSUBJENT:
Byron Nuclear Power Station Units 1 and 2
. Reply to a'Noticefof Violation -
Inspection = Report No,'-50-454/97009; 50-455/97009 NRC Docket Numbers 50-454,'50-455 4
t
REFERENCE:
- A. B. Beach letter to Mr. Gracsser 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 violation-(NOV) which was' transmitted with the referenced letter. The NOV cited one (1) l Severity: Level III violation and one (1) Severity Level IV violation requiring a wntten response. Comed's response is provided in the attachment.
We appreciate'the need to comply precisely-with Technical Specifications. At Byron, we strive to conply with Technical Specifications and all other y
licensing requiren.ents. 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 attention promptly and resolved appropriately.
This-letter contains1th'e-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 question-.
This--
redundant review will-be.condtteted for approximately.a one year period, at which time a determination will be made whether this process should'be continued.
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-Id approximately 12 months, the site will perform an effectiveness review with respect to the corrective actions relative to ECCS
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Byron Ltry 97-0241 November 3, 199.7 Page 2 A review of all slave relay surveillance prg*cedures to compare 3.
electrical schematics and surveillances to verify all Technical Specification requirements are met is being conducted.
A modification is being evaluated to resolve thermal transients 4.
caused by cycli,np of'the letiown line containment isolation valves.
of my knowledge and belief, the stawenents contained in' this To the best document are true and correct.
In some respects these statements are not based on my personal knowledge, but on the information furnished by other Such information Comed employees, contractor employees, and/or consultants.
and I believe it to be has been reviewed in accordance with company practice, reliable.
If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (8151234-5441 ext. 2280.
Respectfully,
/
- h. L.
u L. G a ~ser Site Vir.e-resident Byron Nuclear Power Station State of Illinois SS County of ogle i
Subscribed and sworn to before me this 28th Day of October 1997 m.::_- - - :: v::_ :--
" OFFICIAL SEAL" Petnce Havenge i
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Notary Public KLG/DB/rp Attachment (s) cc:
A. B. Beach, NRC Regional Administrator - RIII G. F. Dick Jr., Byron Project Manager - NRR Senior Resident Inspector, Byron R. D. Lanksbury, Reactor Projects Chief - RIII F. Ni::iolek, Divisien of Engineering - IDNS (p:$7byttrsG70241 won
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A "*C " I VIOLATION ASSES' SED A CIVIL PDIALTY
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A. Compliance with Technical ~. Specifications 1.-
Technical Specification 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems be operableLwith the-units >in Modes 1,.2, and,3 with each subsystem comprised oft __
'a) one operable centrifugal charging pump; b)-one operable safety injection pumpt.,c) one operable Residual Heat Removal- (RHR)Lheat --
j exchanger; d) one operable RHR pump;_and e).'an operable _ flow path
--capablejof taking suction from the' refueling water storage tank on a safety
- injection signal and. automatic opening of the contain.it sump suction valves.
Technical Specification Surveillance 4.5.2.b(1) requires that each ECCS subsystem be demonstrated opetable at least once per 31 days by ver. ting the ECCS pump casings and discharge piping high points
-outside of containment.
contrary to the above:
Since commercial operation began in 1985 and 1986, u
a.
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 1 high point vent, 1RH027, on the discharge piping of the RHR heat 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 (ESFAS) instrumentatioa channels and
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interlocks shown 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 ESFAS instrumentation channel and interlock and the' automatic actuation logic and relays.be demonstrated operable by the performance of the ESFAS
. instrumentation surveillance requirements specified in Table 4.3-2.
Technical-Specification Table 4.3-2,-Functional Unit 3.a(2),
' Containment Isolation,' Phase A Isolation," requires that automatic
-actaation' logic and-actuation relays receive a slave relay test on a quarterly basis.-
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'4 Technical Specification Definition-1.31 states,Lin part, that a " lave rel&y test. shall include a-continuity check, as a minimum, of a.
- ciated
,-testable ^ actuation devices.
4 Contrary to the above:
i 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 10V8149A/B/C and 2CV8149A/B/C, (Containment Phase A Isolation Valves) was nog, performed on a quarterly basis since April 29, 1991.
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b.
As of May,27, 1991, the continuity test for the slave relay contacts that actuate the CV letdown isolation _ valves ICV 8152, ICV 8160, 2CVB152, and 2CVB160, (Containment Phase A Isolation 3-valves) was not performed on a quarterly basis since June 13, 1991.
These violations represent a Severity Level III problem.(Supplement I)-
$55,000.
REASON FoR THE VIOLATION 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 PIF 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 suction 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 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.
Ib. Failure to vent 1RH027 per Technical specifications The root cause is a deficient ~ surveillance procedure, which did not include IRH027 highpoint vent. Unit 2 piping routing is different, with no equivalent valve.
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4 2a. Failure to perform cv letdown orifice isolation valve slave relay test per Technical
- Specification
-and-2b. Failure to perform.CV letdown isolation valve slave relay test per Technical Specification Prior to 1990, all valves were stroked in compliance with Technical Specifications.
In 1990, Westinghouse advised Byron not to stroke the valves (only CV8152/8160) 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.
I Jumpers were used to prevent stroking the letdown' isolation valves and still be able to perform the surveillance test.
Fuces were pulled for the letdown orifice isolation valves. The use of jumpers permanently was not a desirable choice. Therefore, other permanent actions were considered: 1) install a modification on the letdown isolation valve control circuit to prevent the valveh 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 Specification compliance until a Technical Specification change could be obtained. We chose to follow industry activities via a " lead plant" concept
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to increase frequencies from quarterly to 18 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 surveillance fell off and caused a letdown isolation (LER 96-001).
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 actions.
Upon completion of the review of the Technical Specification SLAVE RELAY TEST definition, it was determined the jumper ins'allation and fuse removal did not meet the Technical Specification surveillance requirement and the slave relays were decrared incperable. The slave relay surveillances were changed to stroke the valves and then performed to meet the Technical Specification requirements.
In summary, there were two root causes: 1) the Onsite Reviews (1990 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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- o CORRECTIVE
- STEFS TAKEN AND RESULTS ACHIEVED
= 1a. Failurs to ' vent cv f system according'to Technical specification (TS) requirement 4.5.2.b.1
-1)
An NOED was granted on May 24,-1997, an emergency Technical-Specification change-was granted for Unit 1 cnt June 1, 1997 and an-exigent-Technical Specification change was ' approved for : Unit 2 -on August 13,-1997.
2)
For the speciff# CV system Technical Specification surveillance requirements, Ultrase ic Testing inspection of vulnerable areas was perf'o'rmed and continues. To date, results have been-
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acceptabl#.
.3)
The "ECCS Venting and Valve Alignment Monthly" surveillance (1/2BOS 5.2.b-1) has been revised to include better acceptance criteria 'and actions to satisfy the surveillance requirements.
i 4)
Byron has. performed an independent review of selected Technical.
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.
Ib. Failure to vent 1RH027 per Technical Specifiestions 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 surveillance procedures.
On 10/23/97, while investigating some questions for the pending vent valve modification, it was discovered,that there were additionel vent valves (Unit 1 only) on these lines.that should be incluBed in the
. monthly ECCS venting procedure. Subsequently, a walkdown of safety injection cold leg injection piping by two independent 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 reviseo. A temporary procedure change was made and venting performed. An LER is being written, (p397byttrt@70241 wpf) r s
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2a. Failure to perform CV letdown orifioe isolation valve' slave relay test por Technical specification
-and-2b.- Failure to perform CV letdown isolation. valve slave ' relay test per_
Technical specificathn-1)
Byron has performed an independent review of selected Technical
-Specification surveillances.- Selected sections were revie.ted based on their highest potential for_having difficulties.
This-review involved a comparison of the Technical Specification words to the actual surv9illances being currently performed.
It.is intended to verify _ literal compliance. There were no identified
-Technical Specification amendments needed.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVC,ID FURTHER VIOLATION la. Failure to vent CV system according to Technical specification (TS)'
requirement 4.5.2.b.1
-1)
Tne 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 item # 454-100-97-SCAQ00010-01.
2)
In approximately 12 months, the site will perform an effectiveness review with respect to the previously mentioned correctivo acti ons. This will be tracked by NTS item # 454-100-97-00901a-ER.
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lb. Failure to vent 1RH027 per Technical specifications t'
1)
None 2a. Failure to perform CV letdown orifice isolation valve slave relay test per Technical specification I
-and-
'l 2b.. Failure to perform CV letdown isolation valve slave relay test per
-l Technical specification
.1)
A review of all slave relay surveillance ^rocedures 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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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 tracked by.NTS item # 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-SCAQ00010-01.
DATE WHEN FULL OcMPLIANCE WILL BE ACHIEVED Full compliance was achieved for ECCS venting when the appropriate license amendm,ents were issued.
Full compliance was achieved for slave relay testing on 5/27/97 and 5/28/97 when appropriate slave relay testing was completed.
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ATTACIOS.NT II VIoLATrow NOT ail 3EssED 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, 19'97, procedures 1BCS 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 VIOLATION The're was an alternate 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,. ths surveillance provided adequate guidance to notify management of the failed surveillance.
The procedure was inadequate as written because it did not identify all possible flow paths.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED l
1.
The "ECCS Venting and Valve Alignment Monthly" surveillance (1/2BOS 5.2.b-1) has been revised to provida guidelines on using either flow path to verify adequate 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' COMPLIANCE NILL BE ACHIEVED Full 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 l
pumps.
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.f bcc: D. L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safe'ty Revi'ew Dept,- c/o Document control Desk, 3rd Floor, Downers Grove
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,DCD-L cens ng, Suite 400, Dowers Grove'.
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