ML20210Q351
| ML20210Q351 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/25/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-08, 50-454-97-8, 50-455-97-08, 50-455-97-8, BYRON-97-0196, BYRON-97-196, NUDOCS 9708290135 | |
| Download: ML20210Q351 (7) | |
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th ron t ecnonning Station 1450 North Cerrman Church Itoad llyron. II. 61010 9?94 TriH14236%141 August 25,' 1997 LTR:
BYRON 97-0196 FILE:
1.10.0101 U.S. Nuclee Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk I
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97008; 50-455/97008 NRC Docket Numbers 50-454, 50-455
Reference:
Geoffrey E. Grant letter to Mr. Graesser dated July 23, 1997, transmitting NRC Inspection Report 50-454,97008; 50-455/97008 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 three (3) Severity Level IV violations requiring a written response.
Comed's response is provided in the attachment.
This letter contains the following commitments:
1)
The corrective actions group will review procedures /p ocesses for LER preparation to ensure it is clearly stated who hat the responsibility to verify that NTS items are entered into the computer tracking system.
2)
The AF System technical specification surveillance (2BOS 7.1.2.1.b-2) will be scheduled through work control 8
not to be immediately preceded by the ASME surveillance e01 (2BVS 0. 5-3. AF.1-2).
3)
A multi-disciplinary task force will be created to address the issue of pretenditioning on a generic basis.
The task force will iq
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technical specification surveillances does not recur.
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Byron Ltr. 97-0196 August 25', 1997-Page 2 4)
The 28 AF Pump preconditioning event will be presented during Engineering, Operations, Maintent.nce, and Work Control training.
The training will review how the event occurred, why the event occurred, and corrective actions taken to prevent recurrence.
l 5)
Revising the maintenance alteration procedure (BAP 400-9) to incorporate the verbal commitment to the NRC to allow chart l
recorders to be connected for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without a temporary i
alteration and to ensure a person knowledgeable of the recorder and connections would be present onsite during the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
1 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, K. L. Gr e er Site Vice resident 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 S. D. Burgess, Senior Resident Inspector, Byron R.
D. Lanksbury, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS 4
D. L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept, c/o Document Control Desk, 3rd Floor, Downers Grove DCD-Licensing, Suite 400, Downers Grove.
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. ATTACHMENT I
- VIOLATION (454/455-97000-01) 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actiun," requires, in part,.that measures be established to assure that condition adverse to quality are promptly identified and corrected.
1,.
LER 50-454/94014, " Diesel Generator (DG) inoperability in Mode 5 due - to misinterpretation' 'of TS requirements," committed to = a corrective action of developing a technical - specification interpretation (TSI) to clarify the requirements of DG inoperability when its supporting equipment was inoperable.
l Contrary.to the above, the inspectors identified that from October 17, 1994, i
until April 29, 1997, the corrective actions to conditions adverse to quality that were identified in LER 454/94-014 were not pe rformed. Specifically the TSI had not been developed (50-454;455/97008-01(DRP)).
This is a Severity Level IV Violation (Supplement I).
~
REASON FOR THE VIOLATION Although Nuclear Tracking System (NTS) item numbers were assigned to the corrective actions, the data was not submitted or was overlooked that would have j
ensured its inclusion in the computer database.
It is not known for sure how--
this occurred, since this event-is three (3)_ years old.
However, a re'elew of
.the ' procedure governing LER preparation indicates it was not clear who was responsible for easuring ' ) items were entered into the database.
-CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
~The missing NTS - items were entered into the computer database and completed, as appropriate.
2.
- All other corrective actions from LERs, beginning in 1994 to present, were verified to be-in-the computer tracking system.
.. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
.l.
The corrective actions ' group will review procedures / processes for LER
- preparation to ensure it is clearly stated who has the responsibility.to verify that NTS items are entered into the computer tracking system. This
-action will be tracked by NTS item # 454-100-97-00801-01.
DATE WHEN FULL CcMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 5/21/97 when the TSI/G for "DG Operability for Modes-5 & 6" was written and approved.
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. ATTACHMENT II
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VIOLATION-(454/455-97000-02)-
10 CFR Part 50, Appendix B, Criterion II, " Quality Assurance Program," requires, in part, that activities affecting quality shall be accomplished under suitably controlled _ conditions.
Contrary to the above, the _ inspectors identified on May 13, 1997, the 2B diesel driven auxiliary _ feedwater pump ' was not tested under suitably controlled conditions._ Specifically, a manual start of the diesol engine was performed (preconditioning) immediately prior to an engineered safeguard feature start
- (50-4 54; 455/97008-02 (DRP) ).
=This'is a Severity Level IV Violation (Supplement I).
{
-REASON FOR THE VIOLATION i
on 5\\l3\\97 at'0821 Byron station-Unit-2 entered a LOCAR (2BOS 7.1.2-1A) on the 2B diesel driven Auxiliary Feedwater (AF) Pump-to perform an ASME surveillance.
During the performance of 2BVS (0.5-3. AF.1-2),. ASME surveillance requirement for tha'2B AF Pump, the overcrank lockout alarm annunciated during the attempted.
diesel start with the B battery bank selected. The overcrank alarm annunciated correctly at the local' panel (2AF0lJ), after the 2B AF Pump failed-to start within 4 starting cycles per 55 seconds. Per the startup procedure, ' BOP AF-7, if the engine overcrank alarm annunciates the other battery bank can be selected.
lThe A' battery bank was selected, and the 2B AF Pump started on-the first crank.
The ASME surveillance was completed satisfactorily and exited.
Operations - started the 2B AF pump. on the B battery banh-per scheduled surveillance (2BOS 7.1.2.1.B-2) to_ support diagnostic troubleshooting _on the overcrank alarm. The diesel started on the first crank. The start of the 28 AF-Pump per (2B05 7.1.2.1.B-2) was considered to be preconditioned = due to the ASME surveillance preceding it..After the start with the B battery on the " hot" 2B AF Pump, thet2B AF pump was successfully started from an approximately' ambient condition per BOP AF-7 with the B battery bank. Cell voltages on theLB battery bank _were successfully measured per (2BHS AF-1B). On the basis of' successful completion of.the above actions the LOCAR was_ exited on 5/13/97 at 2100.
d.
CORRECTIVE STEPS TAREN AND RESULTS ACHIEVED
'1.
On 5/15/97 the 2B AF diesel was successfully started from an ambient condition.
CORRECTIVE' STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
- The AF System technical specification surveillance (2BOS 7.1.2.1.b-2) will be scheduled through work. control not to be immediately preceded by the ASME surveillance (2BVS 0.5-3. AF.1-2). This action will be tracked by NTS item #454-100-97-00802-01.
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2.
A multi-disciplinary task force will be created to address the issue of
. preconditioning on a generic basis. The task force will develop a program designed to ensure that preconditioning prior to technical specification
-surveillances does not recur.
This action will be tracked by NTS item
- 454-100-97-00802-02, 3.
The 2B AF Pump preconditioning event will be presented during Engineering, operations, Maintenance, 'nd Work control training.
The training will review how the event occurred, why the event occurred, and corrective
-actions taken to prevent recurrence. This action will be tracked by NTS item #454-100-97-00802-03.
DATE WHEN FULL CcMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 5/15/97 when the 2B AF diesel was started from l
an ambient condition.
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y ATTACIOSNT III VIOLATION ~ (454/455-97000-03)
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10 CFR Part 50, Appendix B, Criterion III,: " Design Control," requires, in part,
? that measures be established to assure that applicable regulatory requirements and-_ the design basis are correctly translated into - specifications, drawings, L
proesdures, and instructions. Design changes, including field changes, shall be l subject to design control measures commensurate -with those-applied to the g
original design..
i Contrary to the above, the inspectors identified that from April 13, 1997, until
= April.28,1 1997, the temporary alteration program was' not adequate to ensure design control measures commensurate with those applied to the original design were implemented prior to connecting a strip chart recorder, a temporary system alteration, on the bus 211 battery charger for troubleshooting-(50-454;455/97008-03(DRP)).
-Thislis a-Severity Level IV Violation (Supplement I).-
REASON FOR THE VIOLATION During troubleshooting activities on the Unit 2125V DC ESF Battery Charger (211).
. under the direction of BAP 400-9, " Troubleshooting and Maintenance Alterations,"-'
a strip' chart recorder was installed in order to troubleshoot the low voltage output that was occurring intermittently. During the troubleshooting activities,-
the battery charger was considered operable and the. strip chart recorder was left installed for a period of about fifteen days. While the strip chart recorder was installed, -the - NRC resident raised a question as : to whether - the - BAP 400-9 documentation for the: installation was acceptable.as is or if it should be-a temporary alteration. The resident's question is based on the following under the guidance of BAP 400-9, the installation of the strip chart recorder did not receive an engineering review for seismic and other related.. issues, and a review was not performed to determine the failure modes of the recorder while connected
,to the battery charger. If a temporary alteration had been performed, a detailed engineeridg' review would be required, which would address all the concerns addressed by the NRC inspector.
Upon : review of BAP. 330-2,
" Temporary Alterations," clear guidance on :the.
' installation of strip. chart ' recorders on operable equipment' could not be found.
LAfter contacting other' plants within-the Comed system and the industry, it'was
= determined that there were a variety of methods used, regarding ' strip chart -
recorders and temporary alterations,'within the industry. Therefore, since both procedures did not provide clear guidance and industry contacts revealed some improvements-could be made to Byron's programs, the policy for installation of-
. strip' chart recorders needed to be changed.
CORRECTIVE-STEPS TAKEN AND RESULTS ACHIEVED 1.l The temporary alteration procedure (BAP 330-2) was revised to allow chart recorders to be connected for up to'24 ' hours without a temporary alteration.
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e CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
Revising the naintenance alteration procedure (BAP 400-9) to allow chart recorders to be connected for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without a temporary alteration and to ensure a person knowledgeable of the recorder and connections would be present onsite during the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
Equipment with I
engineering test points will not require a temporary alteration.
NTS Item 454-100-9*l-00803-01 will track completion of this item.
DATE WHEN FULI. CCHPLIANCE WILL BE ACHIEVED Full compliance was achieved on 4/29/97 when the chart recorder monitoring equipment was removed.
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