ML20217Q047
| ML20217Q047 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/05/1998 |
| From: | Grasesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-24, 50-455-97-24, BYRON-97-0073, BYRON-97-73, NUDOCS 9803110331 | |
| Download: ML20217Q047 (6) | |
Text
1 Commonwezith Djimn Company j
flyron Generating Station j
I 650 North German Church Road
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!!yron,11.610149794
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l Tel H15-23 4 54 iI March 5, 1998 L'I R :
BYRON 97-0073 FILE:
1.10.0101 1
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U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97024; 50-455/97024 j
NRC Docket Numbers 50-454. 50-455 j
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REFERENCE:
Geoffrey E. Grant letter to Mr. Graesser dated February 3, 1998, transmitting NRC Inspection Report 50-454/97024; 50-455/97024 1
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Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) 'ehich was transmitted with the referenced letter and Inspection Report. The NOV cited two (2) Severity Level IV violations
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requiring a written response.
Comed's response is provided in the attachment.
h' This letter contains the following commitments:
1)
BAP 1100-9, " Control, Use, and Storage of Flammable and
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Combustible Liquids and Aerosols," is being revised to I
clarify wording, intent of the directed actions, and accountability.
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2)
Following the approval of the BAP 1100-9 revision, traini%
on the procedure will be provided to appropriate station personnel.
9G03110331 900305 PDR ADOCK 05000454 G
PDR 111.111.111.E.l111.11 (p:\\98byltrs\\980073.wpf)
A linicom Company
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Byron Ltr. 97-0073 March 5, 1998 hage 2
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If your staff has any questiens or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully, i
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K. L. Gr e,er Site Vice resident Byron Nuclear Power Station l
KLG/DB/rp l
Attachment (s) cc:
A.
B. Beach, NRC Regional Administrator - RIII
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G.
F. Dick Jr., Byron Project Manager - NRR E. W.
Cobey, Senior Resident Inspector, Byron M.
J.
Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS i
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-e ATTACHMENT I t
VIOLATION (454/455-97024-01)
Technical Specification 6.8.1.g states that written procedures shall be established, implemented, and maintained coverins the Fire Protection Program implementation.
Byron Administrative Procedure fBAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4, paragraph C.6.c, requires, in part, that flammable / combustible liquid soaked rags....shall be properly disposed of by using an approved waste can with a self closing lid...
Contrary to the above, on December 3, 1997, the licensee did not implement Procedure BAP 1100-9, paragraph C.6.c, in that. oil soaked rags were found in a 55-gallon barrel without a self closing lid outside the 1A chemical and volume control system (CV) pump room (50-454/455-97024-01(DRP) ).
.This is a Severity Level IV Violation (Supplement I).
REASON FoR THE VIOLATION During work on the 1A Chemical and Volume control (CV) Pump, a large number of oily rigs were accumulating from the cleanup effort. A-55-gallon drum was staged by a flammable cabinet near the work area.
The drum top was labeled
" Oily Rags Only," and to " Replace Lid After Rags Are Put In."
The reason for the violation was a lack of awareness due to lack of training; on the part of the individual placing the drum, of the BAP 1100-5, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols,"
requirements for disposal of oil soaked rags in an approved waste can with a self-closing lid.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The unapproved container and its contents were removed.
2.
An approved waste can with a'self-closing lid was placed at the work site.
3.
New approved containers with self-closing lids were purchased and staged in the Auxiliary Building.
4.
Training, via departmental meetings, was given to maintenance personnel concerning the disposal of flammable / combustible liquid soaked rags in a waste can with a self-closing lid.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
$AP 1100-9 is being revised to clarify wording, intent of the directed actions, and accountability. This action is tracked by NTS# 454-100 02401-01.
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2.
Following the approval of the BAP '1100-9 revision, training on the l
procedure will be provided to appropriate station personnel. This action l
is tracked by NTS# 454-10-97-02401-02.
j DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 12/3/97 when the inappropriate container was removed and replaced with an approved container with a self-closing lid.
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J ATTACHMENT II VIOLATION (454/455-97024-02)
Byron Administrative Procedure (BAP) 1100-9," Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4, paragraph C.2.a.
requires that all flammable and combustible liquid containers transported into plant areas, which will be left unattended, shall have prior authorization by the Station Fire Marshall / designee.
Authorization shall Le accomplished by completing a Transient Fire Load Permit and cubmitting it to the Station Fire Marshall / designee for approval. An approved Transient Fire Load tag will then be issued upon Fire Marshall approval.
Contrary to the above, on December 8, 1997, the licensee did not implement Procedure BAP 1100-9, paragraph C.2.a, in that the inspectors identified 13 containers of flammable liquid staged near the Unit 2 fuel transfer canal control panel and left unattended without a Transieat Fire Load Permit (50-454/455-97024-0?'DRP)).
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION The material identified was a strippable coating to be used during BIR08.
The material was not flammable below 120 degrees Fah.cnheit, and since the area it was to be staged would_not achieve that temperature, the decision was made not to tag the material.
The rekson for the violation was due to a misunderstanding of the procedure in that any material designated as flammable when left unattended shall have a Transient Fire Load Permit and associated Transient Fire Load Tag attached.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
A Transient Fire Load Permit was obtained and appropriate Transient Fire Load Tags attached to the material.
2.
Training was conducted with the involved department personnel and with the contractor who was using the coating material on the procedural requirements for Transient Fire Load Permits and Tags.
3.
Training, via departmental meetings, was given to maintenance personnel concerning the procedural requirements for Transient Fire Load Permits and Tags.
4.
The strippable coating Material Safety Data Sheets (MSDS) and product data sheets were obtained to update station records.
CORRECTIVE STEPS THAT WILL RE TAKEN TO AVOID FURTHER VIOLATION 1.
BAP 1100-9 is being revised to clarify wording, intent of the directed actions, and accountability. This action is tracked by NTS# 454-100 02401-01.
2.
Following the approval of the BAP 1100-9 revision, training on the procedure will be provided to appropriate station personnel. This action is tracked by NTS# 454-10-97-02401-02.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full dbmpliance was achieved on 12/8/97 when a Transient Fire Load Permit was obtained and the material was marked with a Transient Fire Load Tag.
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