ML20248C727
| ML20248C727 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/21/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248C725 | List: |
| References | |
| 50-454-98-05, 50-454-98-5, 50-455-98-05, 50-455-98-5, NUDOCS 9806020239 | |
| Download: ML20248C727 (5) | |
Text
ERRATA NOTICE OF VIOL.ATION Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2 License Nos. NPF-37; NPF-66 During an NRC inspection conducted on January 13 through February 23,1998, six violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions, "NUREG-1600, the violations are listed below:
1.
Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
a.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies equipment control, e.g., locking and tagging, as an example of an administrative procedure.
Byron Administrative Procedure 330-1, " Station Equipment Out-of-Service Procedure," Revision 28, Section C.6.c.4, requires, in part, that the equipment listed on the out-of-service (OOS) form be retumed to service.
Out-of Service No. 970006915 required that the Unit i seal water retum filter 1CV02F inlet isolation valve,1CV8396A, the Unit i seal water retum filter 1CV02F bypass valve,1CV8399, the control switch for the reactor coolant pump seal water retum containment isolation valve,1HS-CV057, and the control switch for the reactor coolant pump seal water retum isolation valve,1HS-CV082, be retumed to service.
Contrary to the above, on January 17,1998, Byron Administrative Procedure 330-1, Section C.6.c.4, was not implemented in that OOS No. 97006915 was cleared without retuming to service all equipment listed on the OOS. Specifically, Unit 1 seal water retum filter inlet isolation valve and bypass valve, as well as the control switches for two isolation valves for the reactor coc! ant pump seal water, were not retumed to service before clearing the OOS.
(50-454/98005-01a(DRP); 50-455/98005-01a(DRP) l This is a Severity Level IV violation (Supplement l),
b.
Regulatory Guide 1.33, " Quality Assurance Program Requirements," Revision 2, Appendix A, Paragraph 9.e., states, in part, that general procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun.
Byron Administrative Procedure (BAP) 1610-9, " Engineering Requests,"
Revision 4, Paragraph A, states that the procedure purpose was to explain when Engineering Requests (ERs) were used and describe the process in which ERs I
were submitted, completed, and administratively controlled.
9906020'239 990521 PDR ADOCK 05000454 9
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I Notice of Violation BAP 1610-9, " Engineering Requests," Revision 4, Paragraph C.2.a, states that examples of requested activities included design changes (modifications, minor plant changes, exempt changes) and that the changes shall be processed as ER type code potential design change requests.
Contrary to the above, on July 15,1996, an engineering request was not processed to review a potential design change (modification) to the 1B essential service water pump prior to the actual modification. Specifically, a gasket was installed to stop an oil leak that was not an approved modification.
(50-454/98005-01b(DRP); 50-455/98005-01b(DRP))
This is a Severity Level IV violation (Supplement I).
2.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances.
NSWP-A-03, " Foreign Material Exclusion, " Revision 0, provides controls for preventing foreign material from entering systems.
Contrary to the above, on June 5,1997, NSWP-A-03, " Foreign Material Exclusion,"
Revision 0, was not of a type appropriate to the circumstances in that it failed to prevent the intrusion of foreign material, in the form of a condenser tube cleaning brush, into the containment spray system. (50-454/98005-02(DRP); 50-455/98005-02(DRP))
This is a Severity Level IV violation (Supplement I).
3.
10 CFR Part 50.59(a)(1) states, in part, that the holder of a license may make changes to the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.
10 CFR 50.59(b)(1) states, in part, that the licensee shall maintain records of changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
The Byron Updated Final Safety Analysis Report (UFSAR), Section 11.3.2.1, " Gaseous Waste Management System Design," states, in part, that the gaseous waste processing system (GWPS) processes hydrogen stripped from the reactor coolant and nitrogen from i
the closed cover gas system. The components connected to the GWPS are limited to those which contain no air or aerated liquids in order to prevent the accumulation of oxygen in the system. Further, the GWPS is maintained at a pressure above l
atmospheric to avoid intrusion of air. Hence, the GWPS will normally not contain oxygen and special design precautions are taken in order to avoid unintentional intrusion of oxygen.
l
Notice of Violation Contrary to the above, on September 10,1997, the licensee operated the GWPS different from that described in UFSAR, Section 11.3.2.1, in that a system containing air was vented to the GWPS via the chemical and volume control system. A written safety evaluation had not been performed to determine that the change to the facility as described in the UFSAR did not involve an unreviewed safety question. Specifically, Temporary Change 97-2-156 (Revision 15 dated September 10,1997) to 2BVS 1.2.3.1-2,
" Unit 2 Train B ASME Surveillance Requirements for Centrifugal Charging Pump 28 and Chemical and Volume Control System Valve Stroke Test," allowed portions of the chemical and volume control system piping that had been exposed to air during maintenance activity WR 9700068333, " Seal injection Lines Need to be Cleaned," be vented to the volume control tank which is vented to the GWPS.
(50-454/98005-04(DRP); 50-455/98005-04(DRP))
This is a Severity Level IV violation (Supplement 1).
4.
Technical Specification 6.8.1.g states that written procedures shall be established, implemented, and maintained covering the Fire Protection Program implementation, a.
Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4, Step C.6,
" Cleanup of Flammable / Combustible Liquids," Paragraph a, requires that flammable or combustible liquids which are leaked or spilled shall be promptly cleaned up and not allowed to accumulate. Materials used to clean up the spill should be removed from the building.
Contrary to the above, on February 4,1998, the licensee did not implement Procedure BAP 1100-9, Paragraph C.6.a, in that the inspectors identified a large plastic trash can full of materials that had been used to clean up a spill and not removed from the building. (50-454/98005-05a(DRP); 50-455/98005-05a(DRP))
This is a Severity Level IV violation (Supplement 1).
b.
Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4, Paragraph C.2.b, states, in part, that flammable / combustible liquid containers that do not require prior authorization are: 1) approved / original containers of five gallons or less being transported and used immediately in the plant while in attendance of plant personnel. Paragraph C.2.c states that aerosol containers should be transported and used in quantities not to exceed the amount needed for a specific job. These containers should not be left unattended in the plant at any time. Storage in a Fire Marshal approved Flammable Liquids cabinet per Paragraph C.5 it. acceptable.
Contrary to the above, the licensee did not implement Procedure BAP 1100-9, Paragraph C.2.b, nor Paragraph C.2.c, as evidenced by the following examples (50-454/98005-05b(DRP); 50-455/98005-05b(DRP)):
Notice of Violation Paragraph C.2.b was not met:
On February 4,1998, the inspectors identified two original containers of cleaning solution, less than five gallon containers, marked as combustible, not in attendance of plant personnel at the river screen house.
On January 27,1998, the inspectors identified two original containers of anti-seize lubricant, less than five gallon containers, marked as combustible, near the 1B essential service water pump not in attendance of plant personnel.
On January 30,1998, the inspectors identified an approximately %-gallon can containing oil in the Spent Fuel Pool (SFP) pump room not in attendance of plant personnel.
Paragraph C.2.c was not met:
On February 4,1998, the inspectors identified three aerosol cans in the river screen house unattended and not in a storage cabinet.
On January 27,1998, the inspectors identified two unattended cans of aerosol degreaser, not in a storage cabinet, near the 1B essential service water pump.
This is a Severiy Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy ft de NRC P*Jident inspector at the facility that is the subject of this Notice, within 30 days (.,1ine date oi ine letter transmitting the Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each
' violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in the Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your
Notice of Violation response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial
. information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 21st day of May 1998 I
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