ML20217M927
| ML20217M927 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/19/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-05, 50-454-97-5, 50-455-97-05, 50-455-97-5, BYRON-97-0194, BYRON-97-194, NUDOCS 9708250363 | |
| Download: ML20217M927 (4) | |
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omimonwealth Idum Compan) flynm Generaung Station 4 650 North German ('hurch Road ligon,1161010 979 i TelHi% E 44441 Aligust 19, 1997 LTR:
BYRON 97-0194 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 s
Attention:
Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97005; 50-455/97005 NPC Docket Numbers 50-454, 50-455
Reference:
Geoffrey E. Grant letter to Mr. Graesser dated July 22, 1997, transmitting predecisional enforcement conferenco results of NRC Inspection Report 50-454/97005; 50-455/97005 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 one (1) Severity Level IV violation requiring a written response. Comed's response is provided in the attachment.
This.lettor contains the following commitments:
1)
Restore Unit 1 containment floor drain covers to appropriate architectural drawing A-699 details.
2)
Restore Unit 2 containment floor drain covers to appropriate architectural drawing A-699 details.
3)
Perform a periodic engineering review of containment floor drain system flow recorder to verify appropriate weir box response. This action is to be implemented for Unit 1/2 until corrective actions are completed to restore the design
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configuration of the floor drain grates.
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Byron Ltr. 97-0194 Xugust 19, 1997 Page 2 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, W
,K. L. Gra ni Site Vice Prosident 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 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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ATTACEMENT I r
V2OLATION (454/455-97005-03) 10 CFR 50.59, " Changes, tests and experiments," permits the licensee to make changos to the facility and procedures as described in the safety analysis report and conduct tests or expariments not described in the safety analysis report without prior Commission approval provided the change does not involve a change in the technical specifications or an Unreviewed Safety Question (USO).
The licensee shall maintain records of changes in the facility e.nd these records must include a written safety evaluation which provides the bases for the determination that the change does 1.ot involve an USQ.
10 CFR 50.9(a) requi res, in parte that information provided to the NRC by a licensee or information required by regulation to be maintained by a licensee shall be complete and accurate in all material respects.
UFSAR Section 5.2.5.1, " Reactor Cavity and Containment Floor Drain Sumps," Figure 5.2-3 specified that a vendor bar grate of appror.imately 5 inches sas to be installed over each of the cor.tainment floor drains.
Contrary to the above, as of March 14, 1997, the facility was not as described in the UFSAR in that the grates described in the UFSAR Figure 5.2-3 covering the
- containment floor drains leading to the containment floor drain leak detection system were not installed. The drains were either covered with a different grate or screen, or were not covered at all resulting in the potential that foreign material could enter the drain system and adversely affect the leak detection system. A written safety evaluation was not performed to make a determination that the change did not involve an unreviewed safety question. In addition, the updated FSAR was not complete and accurate in all material respects in that it did not reflect this change.
t This is a Severity Level IV Violation (Supplement I).
(50-454/455-97005-03(DRS))
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L REASON FOR THE VIOLATION Byron Station agrees with the violation in that the design drawings documented
. in-UFSAR Figure 5.2-3 do not match the as-built configuration of the plant.
Specifically, all of the floor drain bar grates-are not installed as shown in the drawings. In addition, several of the installed drain grates are of a different type than shown in Figure 5.2-3.
We believe that this condition has existed since original construction. No 50.59 safety evaluation was performed to document the acceptability of the differing plant configuration from the UFSAR.
Byron Station recognizes the significance of ensuring the plant configuration is consistent with the licensing basis as documented in the UFSAR. ' It is important to note _ that this was self-identified, in part, due to the heightened awareness of design basis compliance.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
Operability Assessment was performed to demonstrate that the containment floor drain system is operable pending corrective actions to restore'the design conflguration of the plart.
2.
Unit 2 floor drains were flushed and cleaned to ensure adequate
- communication of the floor drains with the containment floor drain sump.
CORRECTIVE STEPn THAT WILL BE TAKEN TO AVOID FURTHEM VIOLATION 1.
Restore Unit 1 containment floor drain covers to appropriate architectural drawing A-699 details.
This action will be tracked by NTS item
- 454-201-97-0598-01, 2.
Restore Unit 2 containment floor drain covers to appropriate architectural drawing A-699 details.
This action will be tracked by NTS item
- 454-201-9'/-0598-02, 3.
Perform a periodic engineering review-of containment floor drain system-flow recorder to-verify appropriate weir box response. This action is to be implemented for Unit 1/2 until corrective actions are completed to restore the design configuration of the floor drain grates. This action will be tracked by-NTS item # 454-201-97-0598-03.
DATE WHEN FULL COMPLIANCE WILL BC-ACHIEVED Full' compliance will be achieved by 6/01/98, following Unit 1/2 refuel outages,
.when tue containment floor drain covers are restored to appropriate architectural drawing A-699-details, tpr\\94 yltts\\970194.q t)
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