ML20235T836
| ML20235T836 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/18/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3601K, NUDOCS 8710130242 | |
| Download: ML20235T836 (4) | |
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['N Commonwealth Edison.
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J Address Reply to: Post Office Box 767 (j
Chicago, Illinois 60690 0767 ~
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.J September 18, 1987 l
Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road' Glen Ellyn, IL 60137 i
Subject:
Byron Station Units 1 and 2 NRC Inspection Report No. 50-454/87-028; 50-455/87-026 NRC Docket Nos. 50-454 and 50-455 Reference (a): August 20, 1987 letter from W.L. Forney to Cordell Reed i
Dear Mr. Davis:
Reference (a) provided the results of an inspection by Messrs.
Brochman and Olshan on July 1 - 31, 1987 at Byron Station..During.this inspection, 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 (a). Attachment B contains the response to an unresolved item regarding Byron's policy for temporarily lifting out-of-service cards, please direct any questions regarding'this matter to this office.
Very truly yours,-
Or L. D. Butterfield Nuclear Licensing Manager Attachments cc: Byron Resident Inspector 8710130242 870918 ADOCK 0 % 4[
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ATTACHMENT A I
VIOLATION 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 5.0, requires that activities affecting quality shall be accomplished in accordance with approved instructions, procedures, and drawings. Control of the status of plant equipment is an activity affecting quality.
Byron Administrative Procedure (BAP) 330-1, " Station Equipment Out-of-Fervice (003) Procedure," implemented this requirement. Paragraph C 6.a(2) required that prior to temporarily lifting an OOS card, concurrence be obtained from the individual (or his supervisor) who requested the original OOS: otherwise, the temporary lift may not be authorized.
Paragraph C.6.b(2) required that the Shift Engineer or the Shift Foreman (licensed SRO) shall authorize the temporary lift only after he is satisfied that plant conditions allow this activity, that no OOS holder restrictions have been violated, and that all concurrences have been made.
Contrary to the above:
I a.
On April 8, 9, 25 and 30, 1987, seven temporary lifts of OOS cards were performed without the required concurrences having been obtained on the temporary lift record sheets.
b.
On March 31 and on April 7, 9, 13 and 30, 1987, eight temporary lifts of OOS cards were performed without obtaining the required SRO approvals.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Byron Station has conducted an in-depth review of the Temporary Lift Program.
It has become apparent that there is a lack of attention to detail regarding implementation of the Temporary Lift Program by the operating Department. The control room supervisors and unit operators should have ensured proper concurrences were documented prior to authorizing the temporary lifts cited in the violation.
The missing signature problems observed by the Quality Assurance Department were considered to be isolated incidents due to the amount of temporary lifts being correctly processed at that time. Those signature problems were corrected at the time of the quality assurance surveillance.
Shortly after this violation was identified, all " Temporary Lift / Equipment in Test" record sheets currently in effect were reviewed.
It was verified that all proper signatures were documented on these forms.
Additionally, throughout July of 1987, the Assistant Superintendent of Operating held informal discussions with shift personnel emphasizing procedure adherence and attention to detail regarding the Temporary Lift Program.
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CORRECTIVE ACTION TO AVOID FURTHER VIOLATION I
Since July of 1987, the Assistant Superintendent of Operating has I
been performing informal periodic reviews to ensure proper adherence to the j
Temporary Lift Program requirements. These reviews are still being l
performed and no additional deficiencies have been identified.
The Temporary Lift Program is being revised. The governing administrative procedure, BAP 331-1 " Administrative Requirements for Temporarily Lifting OOS Cards and/or Placing Equipment in Test", will be revised to clarify the program requirements and more clearly define signature requirements. Additional training will be given to all licensed on-shift personnel when the revision to BAP 331-1 is complete.
i A daily order was issued to on-shift personnel that clarifies signature requirements. The daily order also requires the Shift Engineer on the first shift to review all outstanding temporary lifts on a daily basis.
This daily order will be reinforced by an item in the Required Reading l
Program for all licensed on-shif t personnel.
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1 The Quality Assurance Department will conduct an implementation l
I audit of temporary lifts after the corrective actions discussed above are i
completed.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Byron Administrative Procedure BAP 331-1 will be revised by October 30, 1987 and additional training on this program revision will be completed for all licensed on-shift personnel by November 30, 1987. The daily order discussed above was issued September 14, 1987 and reinforcement of this order will be completed through the Required Reading Program by September 30, 1987.
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e ATTACHMENT B Response to Unresolved Item The inspection report documented an unresolved item concerning Byron's policy for review of temporary lifts of out-of-service (OOS) tags and whether that policy requires consideration of the consequences on the plant when temporary lifts are authorized.
Temporary lifts are authorized by senior reactor operators (SRO).
The SRo's instructions for this matter are found in Byron Administrative Procedure BAP 331-1, " Administrative Requirements for Temporary Lifting of OOS Cards and/or Placing Equipment in Test".
Step C.b.2 of this procedure states:
The Shift Engineer (or designee)/ Shift Foreman shall authorize the Temporary Lift / Equipment in Test only after he is satisfied plant conditions allow this activity, no 00S holder's restrictions have been violated, and all concurrences have been made.
We believe the instructions quoted above implicitly require consideration of the consequences on the plant when authorizing a temporary lift. However, this implicit review function is confined to the deliberate action being authorized by the temporary lift and does not consider unauthorized or inadvertent actions.
It would be virtually impossible to postulate all potential inadvertent actions and encompass their consequences in this review.
The inspection report also stated that Byron's policy on performing work on components which are being used as physical isolation points for other work activities is not clear.
As a matter of routine, the SRO does consider isolation points when authorizing a temporary lift.
It is not a normal practice to allow work on a valve ort component that is an isolation point unless that particular valve or component is out of service for maintenance.
i To strengthen the need for consideration of isolation points when authorizing temporary lifts, a daily order is being issued today that requires a review to assure the loss of the isolation point affected by the temporary lift can be tolerated. This extra review requirement will be included in the next revision to BAP 331-1 due October 30, 1987.
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