ML20236U674
| ML20236U674 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/19/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3860K, NUDOCS 8712030284 | |
| Download: ML20236U674 (3) | |
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. Address Reply to: Post Office Box 767 Chicago, Illinois 60690 - 0767 November 19, 1987-Mr. A. Bert Davis Regional' Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Fyron Station Units 1 and 2 Response to NRC Inspection Report Nos. 50-454/87-038 and 50-455/87-035 NRC Docket Nos. 50-454 and 50-455 Reference (a): October 20, 1987 letter from W.L. Forney to Cordell Reed
Dear Mr. Davis:
Reference (a) provided the results of a routine safety inspection conducted by Mr. Brochman of your office from September 1 to October 1, 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).
Please direct any questions regarding this matter to this office.
Very truly yours, V
L. D. Butterfield Nuclear Licensing Manager Attachment cc: Byron Resident Inspector
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ATTACHMENT A VIOLATION 10 CFR 50.59(a)(1) requires that the licensee obtain commission approval prior to making changes in the facility as described in the safety analysis report, if the proposed change involves a change in the Technical Specifications or involves an unreviewed safety question.
10 CFR 50.59(b)(1) requires that the licensee maintain records of all changes to the facility made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Byron administrative procedure BAp 330-2, " Temporary Alterations,"
Paragraph A, requires that temporary alterations (changes) to all plant systems be performed in accordance with this procedure. However, as an exception, temporary alterations may be made by other procedures (e.g.,
surveillance tests) that meet certain notification and verification requirements, provided that control of the temporary alteration is transferred to BAP 330-2, if the alteration must stay installed following completion of the procedure.
BAp 330-2T1, " Temporary Alteration Log Sheet," implements the requirements of 10 CFR 50.59(b)(1) and BAP 330-2.
Contrary to the above, on November 11, 1985, a test manifold remained installed in line IVQO2A4B of the containment purge (VQ) system following completion of a surveillance test. No written verification, in accordance with BAP 330-2T1, was made to determine that the continued installation of this test manifold did not constitute an unreviewed safety question.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The test manifold was removed from line IVQO2A4B on October 9, 1987. On November 5,1987, Sargent & Lundy completed a review of the seismic effect of this test manifold installation. Their review concluded the seismic effect of this manifold installation did not create a safety significant concern.
In addition, the Byron Station Technical Staff conducted a 10 CFR 50.59 evaluation and determined that no unreviewed safety question existed with respect to this test manifold installation.
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CORRECTIVE ACTION TO AVOID FURTHER VIOLATION On November 13, 1987, the Byron Station Manager issued a letter to department heads at the station. This letter emphasized the need to remove test equipment when testing is completed on a component or system.
In addition, a generic procedure will be written to outline the steps required to exit a procedure or restore a system in test to normal. This generic procedure will be developed by December 31, 1987.
In order to address whether any other test equipment is
" permanently" installed in any plant system without the required 10 CFR 50.59 review, the following actions are being taken:
Beginning October 30, 1987, Byron Station Technical Staff engineers have been walking down the accessible portions of systems they are performing a surveillance on, looking for any test equipment installed but not authorized by an approved procedure that underwent a 10 CFR 50.59 review. To date, these walkdowns have not identified any test equipment installations that have not undergone the appropriate review. This walkdown effort will continue through January 1, 1988.
A daily order was issued by the Assistant Superintendent for Operating on October 27, 1987, directing operators to look for test equipment which may have been left in the plant after testing was completed. This daily order was in effect until November 2, 1987.
Operators did not identify any test equipment installed in safety related systems in the auxiliary building without the appropriate review being performed. However, a few test equipment installations were identified in non-safety related systems in the turbine building for which the level of review has not yet been determined.
If it is determined these test equipment installations are not in accordance with the requirements of Byron administrative procedure BAP 330-2 or 10 CFR 50.59, the required review will be performed or the test equipment will be removed. The resolution of these items will be completed by December 4, 1987.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Technical Staff walkdowns described above will be completed January 1, 1988.
If any discrepancies are identified, they will be corrected by February 1, 1988.
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