ML20236J616

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-454/87-32,50-455/87-30 & 50-456/87-28.Corrective Actions: Util Conducted Step by Step Comparison of Byron & Braidwood Emergency Procedures Including Emergency Procedures

ML20236J616
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	10/15/1987
From:	Butterfield L COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20236J600	List: IR 05000454/1987032 ML20236J616
References
3714K, NUDOCS 8711060195
Download: ML20236J616 (5)

Text

--312 294139s01 K 1* f-LM:40 CE:0-rU:LE4 ~ L10Eu!!rG 0:-a go.:

. u;, ~g,

pg,; cp, O Cheepo,knose 40000 0767 CommonwesNh Edison one Fas Notonal Maas Cheogo.be.

Ad*ese Revr to Pog perce son 7,7

-l

. October 15, 1987 I

4 l

Mr. h. Bert Davis tegional. Administrator:

U. S. Wuclear' Regulatory Commission Region III

'F99 Roosevelt Road.

Olen Ellyn, IL 60137 3

subject: Byron station Units'1 and 2 braidwood Station Unit 2 Response to Inspection: Reports Nos.

50-454/87-032, 50-455/87-030 and 53-456/87-028 gg. pocket Wos. 50-454,'50-455, and 50-456 Reference (a): Hubert J. Miller. letter.to C. Reed dated September 16, 1987

Dear Mr. Davis:

This letter is in. response to the inspection conducted.by. Messrs.

Hasse and Hopkins and Ms. Reschenke on Augurt 10-17, 1987 of activities at the.

Byron and Braidwood Stations. Reference (a) indicated that certain. activities appeared to be in violation of NRC requirements. The commonwealth Edison Company response to the Notice of violation and the Unresolved Item is provide 6 in the enclosure.

Upon review of the violation, Connonwealth Edison Company believes that the severity' level may not be appropriate for the. significance of the item. As described in the inspection report and as assessed herein, the severity of the two (2) exartples cited appear to be of a minor safety.

~

concern. As.such, commonwealth Edison requests the NRC to re-evaluate the violation's classification with a resulting change being made' from Level IV to -

Level v.

If you have any further questions on this matter, please direct them to this office.

)

Very truly yours, L .f 8711060175 871030 PDR ADOCK 05000454

[Q h t. D. Butterfield' Wuclear Licensing Manager OCT 19N981 Enclosure i

cc! MRC Resident inspect r Byron:.

MRC Resident Inspeepr -

Braidwood-MRC Docweent Ocntrof sk.

.L V1bCu.

J

_.______._L.__,__i_,________

u..., ~.w

' ile II E-

'.16 M1' CECCWU:LE% LICDimG 2N 7 N

' J O. T P0.:u CW j

-2.

1 Upon review of the new step by the procedure Writer and members of.the.

i Byron and Braidwood Operating Departments, it was decided that the new step would be placed in the procedure before step'4 which addressed

.)

initiation of emergency boration of the RCS.

The new step would allow 4

exiting thel procedure when an ATVS event had been corrected, without having to initiate' emergency.boration and continuing through the remaining steps to check for an unexplained increase'in reactivity addition to the' RCS.

j i<

In a follow-up review of the emergency procedures by.the commonwealth-Edison Production Training Center simulator instructors, a concern ~ was-expressed over-placement of the new high level. step before.the step requiring initiation of emergency boration of.the RCS.

Their. concern was-over whether the reactor would be subetitical at-this time without.

initiating emergency boration of the RCs.

Upon further: review by th'e members of the Verification and Validation Team and prior to final on-site review of the procedure by.both Byron and Braidwood, the writer was instructed to change the procedure a second time..This change placed'the-

~

new high level step af ter step' 4 calling -for initiation'of' emergency boration. This change'did not alter the intent of theiprocedure'and improved the operational. correctness of the' procedure.

While incorporating the new change, a misunderstanding resulted.in, the Response '

Not obtained Column step 14 referencing step 6 vice step. 4..

CORRBCTIVE ACTION TAKEN AND RESULTS ACHIEVED commonwealth Edison conducted a step byistep comparison of, Byron.and:

Braidwood Emergency Procedures including Emergency Procedures,. Event Specific, Contingency Action, Functional Restoration and Status. Trees to verify administrative correctness.and to ensure'any deviations.between the:two~

stations were identified and adequately addressed < 'Eight areas of concern resulted from this review, four addressed ' Byron and four ' addressed Braidwood.

These areas were corrected imediately by typo changes t(Byron) Land temporary procedure changes (Braidwood) and permanent changes have been completed.

CORRBCTIVE ACTION TO AVOID WRTHER VIOLA.TICH Although Byron and Braidwool Stations consider the emergency procedure prograrn checks and balances contained in the Procedure Generation Package (PGP) as adequate to ensure the quality of the emergericy procedure.

revisions ~, a requirement will be. added to the PGP. Verification program ' '

checklist to perform a step by step comparison of Byron /Braidwood Unit I and-22 emergency procedures in revision prior.to final review by the on-s$te review t

committee.

DATE WHEN FULL COMPLI ANcE WILL BE ACHIEVED Revision of the Byron and Braidwood PGP's are expected to'be ccupleted by January 31,19BB.

I i

l

,/(

R KQ"5 C7 16:4:

CECD-tU:LE # L1CEd51id _W 3C 4 iO."O3 P005 0;g i

1 3-UNRESOLNED ITEM (456/8'l-028-02) i RESPONSB Byron's and Braidwood's initial Emergency operating Procedures-(sop's) Rev. 1. WOG-1, were written in 1984 ut111 tin 9 the Westinghouse owners oroup (WOG) 8mergency Response Guidelines (ERG's) as a technical basis; Every effort was made to insure the 80p's followed the RRG's in written and Procedure Generation Package (PGP).

')

technical content. Deviations from the ERG's were documented per the BOP j

j Upon the completion of writing of the 30P's, each procedure was '

.I verified for written and technical accuracy per the PGP by a team of' senior d

operators from both stations. The EOP's were also validated for usage and operational correctness per the. PGP by teams of observers-and operators from each station. However, due to limited availability of-the Byron /Braidwood.

simulator, all BOP's were not validated using the simulator method..Some procedures were validated using a desk top review in the simulator control roce in conjunction with a consideration that utilities.could use the woG -

validation program of the ERG's as part of their validation effort. Thisi j

information was provided per a letter from D. M. Crutchfield, NRC, to J. J.

1 Shepperd, WOG, on 9/12/83.

1 The listing of the method used to validate each ROP is shown in the Attachment.

It must be mentioned that although documentation of thc' simulator

'l 1

scenarios used and procedures affected by those scenarios exist, individual documentation of each BOP does not exist for the original BOP's.. The PGP has recently been revised per the NRC's request, to expand the. requirements'of the j

validation program. part of this improved validation program has been the.

.i inclusion of an individual EOF validation form.

]

procedures BwES 3.2 and swrR C.1 were not validated usirig the simulator method. Each procedure was originally validated'by a desk top review method and referenced to the ERG validation program as' stated previously, subsequent revisions referred to this initial validation method.

Each procedure, although not used during particular simulator scenarios,,was discussed if related to the scenario.

For example, during the simulator 1

scenario for Stear. Generator Tube Ruptures (SGTR) procedure DwtS 3.3 was used for cooling down the ruptured steam generator, however, the use of procedure Dwas 3.2 was also discussed.

In conclusion, adequate verification and validation documentation exist for the emergency procedures. Although individual documentation did not exist for the original emergency procedurer. Rev.1, WoG-1, the present requirements of the PGp Validation Program will insure each procedure and subsequent revisions will be adequately documented.

I 3*ll4K

.p

__ y\\_

l 10 m ET 16:J1

' (d.O-id:LEF LICEtGitG IN ?*74 fC."0?

F00P00 rf

\\ u i n.

(.

r

(

('

(

ECllLSURB Coret.WWEAL,TH EDIGON COMPANY RBSPONSE TO INSPECTION REPORTS 154/8'l-032, 455/8'l-030 and_456/87-028 YIOLATIoW (45I /87-t 2-01: 455/8"l-030-01;.;45N67-0 28-01)

I s,7

~

'1(i CFR 50, Appendix B, Criterion II, requires a ddlity ahma'nce.

\\q program be'laplemynted to provide control over activit?pa affec )1ng' thy. ',

l quality"of eystems\\ (i.e. Bmergency Oppeting Procedures; consis) tent with.,their -

)

'f-V importance to safety.

3, j

x Q'

' U,:;;i l3 contrary to the above, the licensee'f ailed to apply',t CA progt'd t,o

)

f provide control over activities affecting'the quality of systems (i.e4 Emergency Opntting Procedures) consistent with their importanes h safety.

1 The Byron cnd Braidwood, Generating Stations failled to ensure that the final

.j printed revision of the EOps matched the appr p d dreft-document and that ala of the consequences of adding and, deleting stegry in the BCPs had been fully examined. Specific examples are as follows j'/

1.

In IBwFR-S.1, "Resportse to Nuclear Powe'r Generati.

y

/ATWs," pages 9 an& lD-were duplicates of pages 7 and 8.

(Braidwood) n c

2.

In spp 14 of IBwFR-S.1 and SFR-S.1, the Response Not Obtainecil column j

returnt the operntor to step 6 (Steam Dump Isolation)' Vide step 4 (Initiate Emergency Boration of RCS) as required by the Westinghouse Emergency Response cuidelines.

(ByronandBraidwoodp L

1 RESPoWSE commor.veMth Edison ccupany acknowledoeti that the identified procedural discrepancies occurred.

The, circumstances leading to these i

discrepaneles are as follows:

4 1.

Procedure IBwFR S.1, orig %allyc fourteen pages, w!.s 'Jub'nitted to word processing for Y1nor ' typo' corrections prior to implementation. -Due to the concentrating of steps oh the Mrd processor ittto.two pages (which originally took four pages), the procedure was condensed into twelve pages. During printing of the procedure two extra pages were printed containing duplicate steps 9 to.12.

The procedure was returned to the procedure writer who reviewed the marked pages for accuracy and pagr checked it for the correct nurrJ)er of pages. The extra two pages kitre net identified during this review.

2.

This discrepancy occurred during the writing of the revision to the '

procedure.

It was caused by the inclusion of a new higbl19 vel,stepito allow exiting of the procedure when it'Md.been determined'thE reactor war.

suberitical. This new step was suggested by the Westinghouse vendor review of Braidwood's Unit 1 Emergency Procedures, Revision 1 WOG-1.

/

/

/- I b !

312"2%.e.y3960.:..

y

~ W-.fW

')

- '- 10 P. ET.

E:C CECO-tU1EM LlCEf 6 IIE B1 397% ( to.."03.

' ppfgg3 -

i e

-'i ATTADOEllT Li-,Vz

.l -l p

)

Minunnn E0P IEV I terr I VAL 1047[qE Pgrp)g,

}/

1 / /X 9..

s 4

n

1 y

,t

. /:~,.,

g.

9.

510 Sll, $12 %l g,l.

SCEllARIOS -$l$5JLATOR 51 52 $3-54 $5 $6 $7 $6. 89

<o 3

'y Si

[ftsactorTrip

' E t,J j

s g

gP0 X'R-X X.

l' ? X. X X.;X X

'X lX:

"y

'J pY 22, ATws-m stP ts 'o.0 -

t X

e SEP IS 0.1 X

X 3X t d.1 X

l

= 53. Loss hf eli Ac [Po,.r/1

' i

~/

.fd 1

E 80C Cooldown > #-

l N P ES 0.2 X/ '.

N EP ES 0.3

,Ml 0 f X

S4 -

Loss of, Seconde,ry Q'

' Neat;$1 W a

gEP Es 0.4 X

\\d

.X' X

YG

$5 UncontrollsdDepresssl/

EPI

,!X

' of All syss.

"t MP ES-l.1 X

X X

,X. f.

1$60 ' SGTR)(700 GP90 !

DJ

.X g[P ES l.2.

X S7 SSTR$/oParPrets e

SEP Es.l.3

'T d

J X: ;q Con + rot-M P ES-0 a X

$8.

Large'Leca/ Loss'ofJ DEP-2 Emerg Coolent Rectre l

X J,Y' I

. i. 94eln Steen Lins Break. i j

SEP.)

j..

~$9

~

X BCP E$.3.1 g

4EP ES.3.2

.n X

Downstroas MSly's -

4 f

$10 Lors,.y Al[ g;.pa e-J stP ES-3.3 S I,l. 3sjs) La.;a (4000 W )

L 9

'X-

. )6 )/ -

j,-.e d DCA 0.X it. 512..laae k w t

Safets..

8CA 0.1

,i

'W2 laject.la - ' ' L X

BCA 0.2

/5

g (d

/

i' X

scA s.1 J '\\

X.

D.-' Desk Top Astlowf 8*' J. 2

'[

SCA 2.1 X

'.. 33

-l

'E i

BCA 3.1

!% /

X 4 Velldetton 14sthod 3

+ m%

]

j.

'i.

,?' (J.(

X SCA 3.2 b

V g

ocA 3.3

.x..

f

.m s.i X

j r-ap x-

.tc

1. 4 s..

WR s.2 a

pC,[

p em c.1 X

i:

X

= ['p~

X s.

l vR c.2 SFR C.3 9FR H.I X

t a

l era H.2 f

X j.I c #;

y C R H.3 a

A e

y R n.<

(

< s.

y I

i.

y g,g g,$

1 BFR P.i j

X

'}I p#

o'E vi

'4 l.

1 x

. ;< }

i y R P.2 t

s p,

ty

//J-

,1 7

3FR 1 l g

4- - 'j l( },

[< # f ' "p'

<, n c.

j 8FR Z.I V "

1 x

l' SFR Z,7

/1 Q

l

.WR 2.3 x

-( 0 t f

[.

SFR I.2 -

R s

'I

+

l l

8FR 4.3 l,e' x

y

's

~

(t

. j

.i a

?f 4:

3 <s s

l

, e

+.,_ : i,

'A' s

...)N' h.'d 5

I

'j y,

<, [,

a.

1. -

. b;,

(,y

-.+. %,

- -- a ~ a p%w

_g

>[

a-,

]'

i,)_

t NA. s '

); ';