ML20235H794
| ML20235H794 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/11/1987 |
| From: | Maiman T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3560K, NUDOCS 8710010178 | |
| Download: ML20235H794 (4) | |
Text
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Ccmmenwillth Edison 3,
One First National Plaza, Chicago, Illinois V
Address Reply to: Post Office Box 7FI pg Chicago, Illinois 60@0 Gg((gg,0S M81sEp 30 A 9: Yi'**'***'
Mr. A. Bert Davis-Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Unit 1 NRC Inspection Report No. 50-454/87-022
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NRC Docket No. 50-454 References (a): June 29, 1987 letter from C.E. Norelius to Cordell Reed (b): August 13, 1987 letter from A.B. Davis to 3.J. O'Connor
Dear Mr. Davis:
Reference (a) provided the results of a special NRC inspection at Byron Station on May 26 to June 12, 1987. As a result of this inspection and an Enforcement Conference on July 9, 1987, certain activities were found in violation of NRC requirements. Attachment A of this letter contains Commonwealth Edison's response to the Notice of Violation enclosed with reference (b).
Reference (b) also requested a description of our corrective actions to improve station performance and personnel awareness of the need to safeguard the operability of safety 1 elated equipment. Attachment B of this letter describes our actions to address this concern.
Please direct any questions you may have regarding this matter to the Nuclear Licensing Manager.
Very truly yours,
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Ma iman Vice'Pfesident Attachments cc: Byron Resident Inspector ISEP 141987 f go\\
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ATTACHMENT A VIOLATION:
Technical Specification 3.0.4 requires that entry into an operational mode shall not be made unless the conditions of the Limiting condition for Operation are met.
Technical Specification 3.6.2.2 requires that the spray additive system shall be operable in modes 3 and 4 with a spray additive eductor capable of adding sodium hydroxide (NaOH) to a containment spray system pump flow. With the spray additive system inoperable, restore the system to operable status within the next 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> or else be in Cold Shutdown [ Mode 5]
in the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
For the spray additive system to be operable, valves ICFC16A and ICS018B must be open so that NaOH can flow from the storage tank to each of the spray additive eductors when the containment spray system is actuated.
Centrary to the above:
1.
On May 6 and May 23, 1987, Unit 1 entered Mode 4 with valves 1CS018A and ICS0188 shut; thereby rendering the spray additive system incapable of adding NaOH to the containment spray system pump flow.
2.
From 0900 on May 6, 1987 to 1412 on May 15, 1987, with Unit 1 in Modes 3 and 4, valves ICS018A and ICS018B were shut for greater than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />; thereby rendering the spray additive system incapable of adding NaOH to the containment spray system pump flow, and action was not taken to place the unit in Mode 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon notification of the incorrect position of the valves, the operating department immediately restored valves ICS018A and 1CS018B to the open position.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION a) On May 26, 1987, the Unit 2 containment spray system was reviewed for correct valve positioning. No problems were identified.
b) On May 28, 1987, a special operating order was issued to the operating department. This order requires all valve manipulations performed in addition to those required in a surveillance test to be documented.
c) On May 29, 1987, Byron Administrative Procedure BAP 1310-4, " Temporary Changes to Permanent Procedures", was revised to require listing of other procedures applicable to a temporary procedure change.
,o d) On June 1, 1987, a daily order was issued to the operating department to require the status of locked. valves to be recorded on a temporary status board. Additionally, the status board and associated documentation are to be reviewed on a shiftly basis, e) on July 31, 1987, an evaluation to determine the benefits of a
" package" concept for processing surveillance was completed.
Byron Administrative Procedure BAP 1400-10, " Surveillance Frogram Departmental Responsibilities", will be revised by January 1, 1988 to implement this " package" concept. The " package" concept includes a procedure compatibility review.
f) On August 4, 1987, Byron Administrative Procedure BAP 335-1T1, " Shift Engineer Turnover", was revised to include a checkoff for review of the locked valve status board, g) Byron Administrative procedure BAp 330-3, " Locked Equipment program",
will be revised by October 1, 1987 to include the following caution statement.
"The opposite train of a system must be verified operable prior to changing the position of a locked valve that would render its own train inoperable." An additional change to this program is in progress to require one unique lock per valve. This change will be completed by January 1, 1988.
h) on August 18, 1987, surveillance procedure 1/2 BOS 6.3.2.B-1 was revised to assure sodium hydroxide is isolated, the pertinent section of pipe is drained, and the containment spray system is properly restored upon completion of the surveillance, i) Byron Administrative Procedure BAP 340-2, " Initiation and Use of System Lineups", will be revised by October 1, 1987 to combine the efforts of the locked equipment list and the abnormal lineup list. This will more effectively control non-standard valve alignments. This procedure change will address valves not already covered by the out-of-service program or other procedures, j) Byron surveillance procedures will be revised by July 1, 1988 to ensure I
that system alignment and restoration are controlled by the same document and that all valves required to be manipulated as part of the surveillance are documented in the surveillance.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED valves icS018A and 1cS018B were restored to the open position on May 26, 1987.
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ATTACHMENT B Reference (b) requested Commonwealth Edison to describe our actions to improve station performance and personnel awareness of the need to f
safeguard the operability of safety related equipment.
Byron Station is equally concerned about the number of events which have occurred in the recent past resulting in redundant trains of safety related equipment becoming inadvertently inoperable. As a result, these events have been aggressively investigated to determine what corrective actions are necessary to assure this situation will not recur. Several corrective actions were j
presented at the Enforcement Conference on July 9, 1987 during the
]
discussion of the containment spray additive event.
)
l Following that Enforcement Conference, the Byron Station Manager directed the formation of a task group to assess the potential for impairing redundant components. The overall mission of this task group was to j
evaluate the adequacy of management control over redundant component impairments. The specific charter of this task group was to:
identify all programs that interface with safety related equipment and have a potential to cause inoperability; evaluate the administrative controls in the individual programs and; evaluate the programs' administrative controls when looked at interactively.
The recommendations and findings documented in the task group report resulted in the following actions being implemented at Byron Station:
1.
Implementation of the " package" concept for surveillance to assure procedure compatibility.
[ Item (e), Attachment A]
2.
An operability flow chart and status board were developed to assist personnel in activities affecting redundant components and evaluating plant status prior to executing the activity.
3.
Byron Administrative Procedure BAP 1400-9, Surveillance Data Package Cover Sheet, and BAP 1400-T5, Data Package Cover Sheet, will be revised by October 1, 1987 to require an opposite train operability verification and signoff.
4.
Byron Administrative Procedure BAP 1310-A2, Procedure Review Checklist, will be revised by October 1, 1987 to incorporate the good practices of INPO plus Byron specific requirements to assure redundant component operability.
Parallel with the task group, the Byron Onsite Nuclear Safety Group conducted an independent review of activities at Byron Station that could potentially cause inadvertent impairment of redundant safety trains.
The recommendations from this effort are being reviewed by station management for implementation.
Commonwealth Edison believes that the efforts presented above and in Attachment A provide the procedural and administrative framework required to ensure the proper operability of safety related equipment at Byron Station.
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