ML20214G099

Discusses Insp on 860721-0808 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Violations Considered Significant & Demonstrate Weaknesses in Maint Program

ML20214G099
Person / Time
Site:	Byron
Issue date:	11/18/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconner J COMMONWEALTH EDISON CO.
Shared Package
ML20214G101	List: ML20214G099 ML20214G129
References
EA-86-163, NUDOCS 8611250564
Download: ML20214G099 (4)

Text

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3 D GN NOV f 81986 Docket No. 50-454 License No. NPF-37 EA 86-163 l l

Commonwealth Edison Company ATTN: Mr. James J. O'Connor President Post Jffice Box 767 Chicago, IL 60690 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-454/86029(DRP))

This refers to the NRC inspection conducted during the period July 21 through August 8,1986, at the Byron Nuclear Station, Unit 1 of activities authorized by NRC License No. NPF-37 and the circumstances associated with the installation of an inoperable Pressurizer Code Safety Valve. The incident, which resulted in violations of NRC regulatory requirements, was identified by members of your plant staff and reported to the NP.C. The details are provided in Inspection Report No. 50-454/06029 sent to you by letter dated August 18, 1986. The results of this inspection were discussed on August 25, 1986 during an enforcement conference held in the NRC Region III office between you and others of your staff and Mr. A. B. Davis and others of the NRC staff.

Violations A, B, and C in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) occurred in July 1986 when an inoperable Pressurizer Code Safety Valve was installed, placed into service, and failed to function as required. The violations resulted from inadequate administrative controls and personnel errors in that after a Code Safety Valve was taken out of service for repair, the valve disc was removed and only partial maintenance was performed. Subsequently, because of improper segregation, identification, and test documentation, tne valve with the missing valve disc was inadvertently placed back into service without ever being tested. It is fortuitous that the partial maintenance performed on this valve did not prohibit its actuation on July 17, 1986. In fact, it was only after the valve actuated at a lower pressure than intended that plant personnel became aware of problems with the

! valve. The root cause of these violations was personnel errors by a mechanical i maintenance technician, a mechanical maintenance supervisor and a QC inspector.

As a result a valve was returned to service without positive identitication being made to verify the serial number of the valve and without ensuring that the valve had passed all required tests to demonstrate operability.

Violation D in the Notice is associated with the licensee's review of test data which revealed that after the July 17, 1986 incident, the replacement Pressurizer Code Safety Valves were tested and accepted based on a lift setting of 2485 psig CERTIFIED MAIL 8611250564 e6111e RETURN RECEIPT REQUESTED PDR ADOCK 05000454 G PDR s

Commonwealth Edison Company 2 NOV i 81986

i 3 percent rather than i 1 percent as required by the Technical Specifications.

One of the replacement valves was actually set outside the il percent Technical Specification limit.

These violations are considered significant and demonstrate weaknesses in the maintenance program. However, the NRC staff acknowledges that once licensee management became aware of the Pressurizer Code Safety Valve problem, it took prompt and extensive corrective action at both the station and corporate levels.

The immediate corrective actions included, among other things, meeting with appropriate departments and stressing that test documentation must match equipment being tested; revising test procedures to clearly identify equipment; installing segregation cages for defective components; and requiring QA to independently verify proper disposition of nonconforming conditions. The long term corrective actions include a broad look at all maintenance activities by licensee management as well as requesting INP0 participation in this effort. A task force has been assigned to perform a maintenance review and to develop a maintenance review program.

1 To e:nphasize the need for a disciplined control of maintenance activities through proper administrative controls, identification of materials and components, and adequate segregation of components in a nonconforming status, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-five Thousand Dollars ($25,000) for the violations described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy),

the violations have been classified in the aggregate as a Severity Level III problem. The base civil penalty for a Severity Level III violation or problem is $50,000. However, in this case, the base civil penalty is being reduced by

50 percent because of your unusually prompt and extensive corrective actions as described above. Further mitigation of the civil penalty based on prompt identification and reporting was not considered appropriate because only after

the valve actuated did licensee personnel become aware of the problem.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC i

regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

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Commonwealth Edison Company 3 NOV 181986 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Original signed by C. E. Norelius James G. Keppler Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr. , Esq.

Diane Chavez, DAARE/ SAFE Steve Lewis, OGC L. 01shan, 'F:a PM H. S. Tay' ar, Quality Assurance Divisio*

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Commonwealth Edison Company NOV 1 8 1986 4

1 Distribution PDR SECY CA ACRS JTaylor, IE

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. ABBeach, IE HWong, IE JLieberman, 0GC FIngram, PA Enforcement Coordinator RI, RII, RIII, RIV, RV BHayes, 01 SConnelly, 01A JCrooks, AE00 HDenton, NRR EA File ES File EDO Rdg File

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