ML20214F323

Responds to NRC Re Violations Noted in Insp Rept 50-455/86-46.Corrective Actions:Complete & Thorough Walkdown Conducted of Piping Sys Assoc W/Unit 1 & Unit 2 Flow Transmitters FT-RH001 & FT-RH002

ML20214F323
Person / Time
Site:	Byron
Issue date:	02/20/1987
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
2749K, NUDOCS 8705260027
Download: ML20214F323 (3)

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'N Commonwealth Edison

-( 1- One First National Plaza Chicago, Illinois Q*3

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j Address Reply to: Post Omce Box 767

\/ Chicago, Illinois 60690 - 0767 -

February 20, 1987

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Mr. James G. Keppler.

Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

-Byron Station Unit 2 IGE Inspection Report 50-455/86046 NRC Docket No.'50-455 Reference (a): January _14, 1987 letter from R.F. Warnick to Cordell Reed

Dear Mr. Keppler:

Reference (a) provided the results of an inspection at Byron Station on December 2-31, 1986. During this inspection, certain activities appeared to be in violation of NRC requirements. Attachment A of this letter contains Commonwealth Edison's response to the Notice of Violation enclosed with reference (a). On February 13, 1987, a one-week extension was granted on the due date for the response to the Notice of Violation, please direct any questions regarding this matter to this office.

Very t uly yours

. _ zv::a

. L. Farrar Director of Nuclear Licensing Im j 1

Attcchment  !

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8705260027 DR 870220 ADOCK 05000455 PDR a gt O l

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JATTACHMENT i

VIOLATION 10 CFR 50, Appendix'B, Crite'rion V, as implemented by the Commonwealth Edison Company's. Quality Assurance: Manual,' Quality Requirement 5.0,2 requires'that activities affecting quality shall be prescribed by' documented instructions,-procedures, or drawings.

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10 CPR 50,~ Appendix B,-Criterion VI, as. implemented by the- -

Commonwea1th Edison Company *s Quality Assurance Manua1, Quality Requirement 6.0, requires that measures shall be established.to control the issuance of; documents,.such as instructions, procedures,:or drawings,' including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents,. including _ changes; are reviewed for adequacy.

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Contro'l'and Instrumentation Drawing.C&ID M-2137, Sheet 1, " Residual-Heat Removal," shows the piping arrangement and identifies the isolation valves for flow transmitters 2FT-RH001 and 2FT-RH002 and flow indicating-

. switches 2FIS-610 and 2FIS-611.

Byron Operating Procedure BOP RH-M2, " Residual Heat Removal (RHR)

Valve Lineup ' Unit 2", lists all of the valves for Unit 2 RHR system.

Contrary to the above:

a. Installed valves-2RH018C, 2RH018D,-2RH019C, and'2RH019D were not indicated on drawing M-2137, Sheet 1.

b. The piping arrangement for flow transmitter 2FT-RH002 and flow indicating switch 2FIS-611 does not; agree with that indicated on drawing M-2137, Sheet 1.

.c. Valves 2RH018C, 2RH018D, 2RH019C, and 2RH019'D were not included on 3

the system valve lineup BOP RH-M2.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A complete.and thorough walkdwn was conducted of the piping

-systems' associated with the Unit I and Unit 2 flow transmitters FT-RH001 and FT-RH002 and flow indicating switches FIS-610 and FIS-61.l' Installed valves 2tH018C,'2RH018D, 2RH019C, and 2RH019D are' instrument isolation valves and, therefore, these valves are not required to be delineated in the Byron

~ Operating Procedures BOP RH-M2, " Residual Heat Removal (RHR): valve' lineup -

Unit 2" or on drawing M-2137,' Sheet 1.

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- The piping arrangemer.t:for flow transmitter 2FT-RH002 and-flow

- indicating switch 2FIS-611 does not agree with-the; arrangement ~on drawing 1 H-2137, Sheet'1. However, note 34 on drawing'M-819 specifies that the-set,ondary root" valve may be deleted if the exposed instrument line .is short.

(L40'-) and if two isolation ~ valves are provided near'the instrument.

2FIS-611 and 2FT-RH002 meet:this requirement. Thus, the piping arrangement is correct and the drawing note provides the reason that the arrangement differs from the' drawing.,

Based on the violation as stated Byron procedures and drawings are correct as delineated.

CORRECTIVE ACTION TAKEN TO AVOID'FURTHER VIOLATION In pursuing the alleged violation, it was determined that a complete valve lineup was not performed on the flow transmitter and flow switch. The Operating Department was responsible for the primary' root valves and secondary root valves and the instrument mechanics were responsible for-the five valve manifold and instrument isolation valves located adjacent to the manifold. These valves are verified to be in their correct position during valve lineups. However, some manifold isolation valves are not located adjacent to the manifold. These valves were not. verified to be open. These. valves provide. isolation for non-safety related instrumentation, for example, 2FT-RH002. Since the transmitter provided proper output'to the I process computer, the isolation valves had to be positioned' correctly even'

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l though they were not specifically checked. These instrument isolation i i

valves are not notated on the drawings but identified by " note".

Byron Station is currently assessing the number of instrument isolation valves which are located romotely from theLvalve manifold and will take action to assure these valves are properly aligned. A supplemental response to this inspection report will be provided in thirty days which will describe our action plan and schedule to assure the valves are properly 'i aligned.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED February 19, 1987 for items discussed in the violation.

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