ML20210E063
| ML20210E063 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/21/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1456K, NUDOCS 8603270178 | |
| Download: ML20210E063 (8) | |
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'N Commonwrith Edison h
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t ) One First National Plaza. Chicago, lilinois O
Address Reply to: Post Office Box 767 Chicago Illinois 60690 -
March 21, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III' 799 Roosevelt Road Glen Ellyn, IL 60137 Subj ect: Byron Station Unit 1 IE Inspection Report No. 50-454/86-002 NRC Docket No. 50-454 Reference (a):
February 20, 1986 letter from R. F.
Warnick to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of an inspection by Messrs.
Hinds Jr., Brochman, and Ms. Malloy on January 1-31, 1986 at Byron Station.
During this inspection, certain activities were found in violation of NRC requirements. Attachment A to this letter contains Commonwealth Edison's response to items 2, 3 and 4 discussed in the Notice of Violation appended to reference (a).
Based on our review of the. inspection report, we have not concluded that the violations were classified consistent with their safety significance discussed in the report. It appears that violations 1 and 4 would be more appropriately classified as Severity Level V since they were found to have minor safety significance.
In light of this, we request the NRC to reconsider the classification of violations 1 and 4.
Please direct any questions you may have regarding this matter to this office.
Very truly yours, br D. L. Farrar Director of Nuclear Licensing im Attachment cc: Byron Resident Inspector 8603270178 B60321 I (
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ATTACHMENT A VIOLATION 2 10 CFR 50, Appendix B, Criterion V states, in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Byron Operating Surveillance 1BOS 3.1.1-20
" Train A Solid State Protection System Bi-Monthly Surveillance", Paragraph F.45 states:
"At the logic test panel, PLACE the INPUT ERROR INHIBIT switch to the INHIBIT position", and requires " INDEPENDENT VERIFICATION" of this step.
Byron Administrative Procedure BAP 100-13. " Guidelines for Performance of Independent Verification of Proper Equipment Alignment",
Paragraph C.1 states, in part:
"All Components that provide a safety function should be independently verified when alignment changes have been made."
BAP 100-13, Paragraph C.9 states: " Independent verification may also be satisfied by visual verification, apart in time, and documentation of equipment alignment by a second qualified person."
Contrary to the above:
a) On December 8,1985, while in Mode 5, a licensed operator performing surveillance 1BOS 3.1.1-20 failed to place the INPUT ERROR INHIBIT switch in the INHIBIT position, resulting in a Safety Injection.
b) During the performance of IBOS 3.1.1-200, on December 8, 1985, the licensee failed to ensure that the Independent Verification Program was effectively implemented.
RESPONSE
We acknowledge an error in the execution of Byron Operating Surveillance 1BOS 3.1.1-20 resulted in an inadvertent safety injection.
However, we have not concluded that the Independent Verification Program was not effectively implemented.
The purpose of Byron's Independent Verification Program is to assure
... plant integrity following equipment alignments, routine maintenance, surveillance testing, special testing and return to service...". This program is consistent with guidelines from NUREG-0737.
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i As mentioned in the violation. Paragraph C.1 of this procedure states that alignment changes to components that provide a safety function should receive an independent verification. This same paragraph goes on to
'say "...this independent verification should occur prior to entering a mode j.
in which the system or component is required". Train A of the Solid State j
Protection System (SSPS) was properly removed from service to perform the j
surveillance. The inadvertent safety injection occurred during the execution of the surveillance when Train A of the SSPS was not required to j
be operable.
l The Operating Department's policy of performing independent verification in a block of steps is consistent with the Station's program, i
To assure an unbiased visual verification, BAP 100-3 Paragraph C.9 indicates I
that'it should be performed " apart in time".
Administrative Procedure BAP 300-1 " Conduct of Operation" further defines this by stating "the independent verification shall be performed apart in time from the initial activity or I
status review. However, it is recognized that on rare occasion the independent verification may be conducted at the same time independently".
This guidance ~was provided because of the difficulty of maintaining true independence when performing the verification after execution of each step.
Performing the independent verification subsequent to each step, or after a block of steps, is consistent with the Station's program as long as it is
" apart.in time" and prior to declaring the system or component operable.
Generally, for procedural accuracy and administrative convenience, the required signoff for each verification step is placed with the step being i
verified. Performing the independent verification steps in blocks of steps is permissible and in most cases preferred in order to assure strict independence.
For the reasons discussed above,'the Independent Verification Program was not intended to assure that each step of a procedure is j-performed correctly as it is being performed and should not have been i
expected to prevent this inadvertent safety injection.
Ensuring correct j
initial performance of a step in a procedure is' more appropriately handled via a procedure NOTE or PRECAUTION alerting.the operator to the possible 9
consequences and..if necessary, requiring dual concurrence that the step was performed coirectly.
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CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
The station management has found this inadvertent safety injection to be an isolated personnel error and not indicative of any programmatic j
Disciplinary action was taken against the operator involved with-concerns.
i this event.
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CORRECTIVE ACTION TO AVOID FURTHER VIOLATION The station will review operating surveillance procedures and attempt to identify other potential steps that may have an adverse safety significance if performed incorrectly.
s DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of operating surveillance procedures will be completed by October 31, 1986.
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VIOLATION 3 j
10 CFR 50, Appendix B, Criterion IVI states, in part: " Measures j
shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditicns adverse to quality, the measures shall 4
assure that the cause of the condition is determined and corrective' action taken to preclude repetition...."
j Aks! "18.7-1976/ANS-3.2, is endorsed by Regulatory Guide 1.33, i
Revision 2.
Regula6J v Guide 1.33, Revision 2 is. committed to in the Byron FSAR, Appendix A.
ANSI N18.7-1976/ANS-3.2, Section 5.2.11 states, in part:
"...In l
the case 'f significant conditions ~aJuerse to safety, the measures shall assure that the cause of the condition la determined and corrective action i
taken shall be documented..."
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On June 26, 1985 a surveillance was pet'ormed on Steam Flow Channel j
522 for the IB Steam Generator Feedwater Regulatins Valve (FRV) control i
circuit using Byron Instrument Surveillance 1 BIS 3.2.'-200, " Surveillance Calibration of the Steam Generator Steam Flow / Feed Flow Mismatch protection 1
Set I".
During the performance of this surveillance Channel 522 was placed in test while it was still selected to control the FRV; the licensed operator 1
was forced to take manual control of the FRV to prevent a reactor trip. The j
placing in test of a channel used to control an important plant parameter was a significant condition which was adverse to safety. This fact was documented and corrective actions defined in Deviation Report (DVR) 6-1-85-194.
contrary to the above, the Licensee failed to complete the 4
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corrective actions identified in DVR 6-1-85-194 in June 1985, prior to i
performance of maintenance on channel 522 on December 27, 1985.
Fail're to u
perform the required corrective actions resulted in e. reactor trip.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
Immediately after the December 27th event. instrument calibration l
procedures involving control switch positione on the main control board were I
affixed with caution cover sheets specificelly listing the control switches j
and their positions. This corrective action supercedes the corrective
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action-discussed'in DVR 6-1-85-194.
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CORRECTIVE ACTION TO AVOID FURTHER VIOLATION Action Item Records (AIR's) which are written to track the l
completion of corrective action commitments on Deviation Reports (DVR's) and Licensee Event Reports (LER's) will be assigned reasonable due dates and will require upper station management approval to exceed this assigned completion.date.
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. In addition Byron Station has implemented a program to improve the content and thoroughness of DVR's and LER's.
This program has also improved the review and approval of reports by involving more upper management and interdepartmental comunication during the review process. The active participation of all departments involved in a particular event during the review process will help to assure the appropriate corrective action has
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been identified and implemented in a time frame commensurate with its significance.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The cover sheets listing the control switen positions were implemented by December 30, 1985.
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VIOLATION 4
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Technical' Specification 4.6.'3.1 states:
"The isolation valves specified in Table 3.6-1 shall be demonstrated OPERABLE prior to retu'ning e
the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isolation time."
Table 3.6-1, Section 7, lists IFWO39D as a Feedwater Containment Isolation valve.
Technical' Specification 3.6.3 states, in part:
"The containment irolation valves specified in Table 3.6-1 shall be OPERABLE...", while in Modes 1, 2, 3 and 4.
Technical Specification 3.6.3.a states, in part:
"With one or more of the isolation valve (s) specified in Table-3.6-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within four hours... Restore the inoperable valve (s) to OPERABLE status, or isalate each affected penetration by the use of at least one deactivated automatic valve secured in the isolation position.. 0therwise, be in at least HOT STANDBY within the next six hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />...."
Contrary to the above:
a) On December 13, 1985, while in Mode 5, containment isolation valve
'1FWO39D was returned' to service prior to performance of an isolation time test, required to verify valve operability.
b) During the period of December 13 tc 31, 1985, while in Modes 1, 2,.3, and 4, with IFWO3oD inoperable for greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and not deactivated, action was not taken to place the unit in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery of the missed isolation time test, valve 1FWO39D was y
declared inoperable and the appropriate Technical Specification action statement was entered. The valve was successfully tested and returned to service.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION All outage work will be in'corporated into the computerized outage tracking program. Also, a revision to Byron Administrative Procedure 300-18. " Removing and Returning Equipment Out-of-Service", will be processed to assure that even under a blanket out-of-service, no work can be performed on safety related equipment unless it has been specifically taken out-of-service. This will require that the equipment cannot be returned to service unless its work package is complete, including appropriate testing.
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1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j
Byron Administrative Procedure 300-18 will be revised by March 31,
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