ML20248K116
| ML20248K116 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/03/1998 |
| From: | Greasser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-98-09, 50-454-98-9, 50-455-98-09, 50-455-98-9, BYRON-98-0168, BYRON-98-168, NUDOCS 9806090434 | |
| Download: ML20248K116 (10) | |
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Onnmonwes!A hihon Compan>'
ll> re.i Generating Station f
4 450 North German Church Romi ll) ron,11. 61010 979 i Tel H15-234 5411 June 3, 1998 LTR:
BYRON 98-0168 FILE:
1.10.0101 U.S. Nuclear Regula'wory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/98009; 50-455/98009 NRC Docket Numbers 50-454. 50-455
REFERENCE:
John A. Grobe letter to Mr. Graesser dated May 5, 1998, transmitting NRC Inspection Report 50-454/98009; 50-455/94009 Enclosed is Commonwealth Edison Company's response to the Notice of I
violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited three (3) Severity Level IV violations requiring a written response.
Comed's response is provided in the attachment.
This letter contains the following commitments:
1)
System Engineering will develop a method, for Unit 1, to verify flow through the containment floor drains after hydro-lazing activities are performec'.
2)
Engineering performed an eveluation for the permanent repair of the Unit-1 Seal Table Room Floor Drain. Design changa package (DCP) 9800205 is acheduled to remove temporary alteration 98-1-017 and install the permanent drain cover
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prior to start-up fram Refuel Outage BIR09.
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A linkom um:pany
Byron Ltr. 98-0168 June 3,
,1998 l
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If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully, K.
L. Graesser Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc:
A. B.
Beach, NRC Regional Administrator - RIII J. B. Hickman, Byron Project Manager - NRR E.
W.
Cobey, Senior Resident Inspector, Byron M.
J.
Jordan, Reactor Projects Chief - RIII P.
Niziolek, Division of Engineering - IDNS l
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l ATTACKMENT I j
1 VIOLATION (454/455-98009-01)
Technical Specification 3.0.4 required that entry into an operational mode shall not be made when the conditions for the Limiting Condition for Operation (LCO) are not met and the associated action required a shutdown if they are not met within a specified time interval.
'l Technical Specification 3.4.6.1.b requires that the containment floor drain and reactor cavity flow monitoring systems shall be operable in Modes 1, 2,
3, and 4.
With the required leakage detection systems inoperable, restore to operable status within 7 days; otherwise be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on February 27, 1998, Unit 1 changed operational mode from Mode 5 to Mode 4 when the conditions for the LCO of TS 3.4.6.1.b were not met and the associated action required a shutdown if they were not met within a specified time interval.
Specifically, the floor drain in the Unit 1 seal table room was plugged causing the containment floor drain system to be inoperable.
This is a Severity Level IV violation (Supplement I).
(50-4 54 / 98 009- 01 (DRP) )
REASON FOR THE VIOLATION We agree with the violation.
Inadequate written and oral communications within and between the various station departments was the root cause of the failure to unplug the floor drain.
Station personnel did not initially realize the need for the Seal Table Room drain to communicate with the Containment Unidentified Leak Detection S/ stem.
A lack of monitoring human performance expectations and weak accountability on the part of maintenance and system engineering significantly contributed to the poor work package quality at.d the failure to effectively implement the Reactor Containment Floor Drain (RF) system Preventive Maintenance (PM) requirements.
Previous opportunities _to clean out the Seal Table Room drain were poorly communicated. Work requests from previous outages did not clearly dccument attempts to clean the clogged drain. The importance of the containment floor drains in relation to the Containment Unidentified Leak Detection System was not adequately communicated or understood by various station personnel.
RF system preventive maintenance requirements from LER 97-001 were :ot adequately communicated to the Maintenance Department.
Communication between system engineering and mechanical maintenance on 6/25/97, did not clearly define expectations, roles and responsibilities, or the PM requirements for cleaning the floor drains. Consequently, NR 970032868-01 did not have a complete work scope or clear direction for which containment floor drains were to be cleaned. Also, the work request did not have contingencies in the event 3
a floor drain "as determined to be plugged.
Work activities were not well documented on the completed work request.
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The pre-job briefing given to the Mechanical Maintenance (MM) Crew by the system ehgineer and maintenance supervisor on 02/09/98, did not match the scope or direction provided in WR 97003*868-01.
The expectations for pre-job briefings were not met.
The pre-job briefing was inadequate in that contingencies were not discussed and may have created confusion as to the intended scope of the job, because the work request direction did not match scope of work discussed.
On 02/12/98, the as left status of the Seal Table Room drain was not clearly stated on Problem Identification Form (pIF) B1998-00723 and misled the Shift Manager (SM).
The SM concluded that the Seal Table Room drain was open based on the wording in the PIF.
The PIF indicated that the floor drain "was" plugged and immediate action "was" to hydro-laze the floor drain per WR 970107702-01.
The PIF did not state that the floor drain was still plugged.
The event screening committee misinterpreted the PIF and status of the Seal Table Room drain, on 02/13/E9, and issued the PIF closed to WR 970107702-01, due to the unclear documentation in the PIF.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Due to a recent heightened level of awareness on the containment floor drain system's importance in providing RCS leakac e communication with the Unidentified Leak Detection System, the following immediate corrective actions were taken:
1.
The System Engineer wrote Action Request 980014475 to investigate and clear the blockage in the Seal Table Room drain.
2.
A collegial assessment of the event was held with station management. The assessment was convened to determine the significance of the event and actions necessary to recover from the event. During the collegial assessment, management solidly re-emphasized individual accountabilities towards ensuring j
identified problems are properly communicated and rescived in a timely manner.
3.
Operability Assessment 98-019 was performed and determined the RF system was not capable of detecting a small leak (i.e.,
an increase of 1 gpm within a one hour time period) in the Seal Table Room.
Therefore, Site Engineering recommended that the SM enter j
the appropriate LCOAR (Technical Specification 3.4.6.1, Action j
Statement b.) for the RF system in-operability, and pursue corrective action to unplug the drain line in the Seal Table Room.
4.
Sased on the operability Assessment, the SM entered the action statement (LCOAR 1BOS 4.6.1-1A) at 2015, on 02/28/98.
5.
Temporary Alteration 98-1-017 was installed on 03/01/98, to provide an alternate RF drain flow path for RCS leakage in the Seal Table Room.
The temporary alteration provides a flow path th*ough a floor drain clean out in the Seal Table Room through the nor'al RF system drain line to the Unidentified Leak Detection System.
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l 6.
The MM Superintendent conducted meetings with the maintenance l
departments. The MM Superintendent stressed individual l
accountability towards the expectations for clearly documenting work activities, as-left and as-found equipment conditions.
Emphasis was placed on writing PIFs when identified equipment conditions do not meet required plant conditions.
Emphaeis was placed on providing clear, concise and understandable documentation and communication.
7.
The Site Engineering Manager conducted a meeting with the System Engineering department. The Site Engineering Manager stressed individual accountabilities towards ensuring identified problems are properly communicated.
8.
System Engineering provided MM with a list of Unit-1 and Unit-2 containment floor drains to be cleaned or hydro-lazed during refueling outages, for the creation of predefine Model Work Requests. The list contains the locations for each of the drains along with associated plumbing drawings.
9.
MM developed Model Work Requests for cleaning the Unit-1 and Unit-j 2 Containment Floor Drain System. The Model Work Requests include the list of floor drains provided by System Engineering.
Provisions are provided for the workers L; initial and date after the successful cleaning of each drain. The Model Work Requests include compensatory actions if a drain is plugged and can not be satisfactorily cleaned out.
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The MM Senior Work Analyst ensured the model work requests for cleaning the Unit 1 and Unit-2 Containment Floor Drain Syetem are attached to the preventive maintenance predefine program entries in the Electronic Work Control System. The RF System Engineer i
verified the Model Work Requests have an adequate scope of the work. The review also ensured that provisions exist to adequately document the RF system drain cleaning and inspection activities.
11.
The Maintenance Manager re-emphasized to the Maintenance Dep rtments, the expectations for providing work requests that contain accurate scope and direction, performing thororgh work
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package reviews, and performing detailed pre-job briefings that reflect the scope of the work to be perforr.,ed.
12.
System Engineering developed a method, for Unit 2, to verify flow through the cot:tainment floor drains and additional enhancements are being considered.
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l CORRECTIV?! STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOfATION The event was investigated by a resot cause analyst, the root cause and contributing causes of the event were identified. Corrective actions to prevent I
recurrence have been initiated or are in progress as follows:
1.
System Engineering will develop a methed, for Unit 1, to verify flow through the containment floor drains after hydro-lazing activities are performed.
This action will be tracked by NTS# 454-180 SCAQ00004-08, l
2.
Engineering pe* formed an evaluation for the permanent repair of the Unit-1 Seal Table Room Floor Drain. The evaluation determined that to unplug the drain would require special tooling and would be very high dose work.
As a result, the Mod Design Engineer determined that the most cost effective and low dose effort would be to install a permanent drain cover in-place of temporary alteration 98-1-017.
Design change package (DCP) 9800205 is acheduled to remove temporary alteration 98-1-017 and install the permanent drain cover prior to start-up from Refuel Outage BIR09. This c.ction will be tracked by NTS# 454-180-98-SPAQ00004-09.
PATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Ebll compliance was achieved on 3/1/98 when the Seal Table Room floor drain was made operable.
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ATTACHMENT II VIOLATION (454/455-98009-02) 10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings,"
requires, in part, that activitier affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary t,the above, procedures were not appropriate to the circumstances in the following instances:
a.
From January 7 through March 17, 1998, Byron Operating Procedure VC-2, " Shutdown of Control Room HVAC (Heating, Ventilation, and Air Conditioning) System," Revision 2, an activity affecting quality, was noc of a type appropriate to the circumstances, in that, it did not provide direction to secure the main control room I
supply, return, or make-up air filter fans or provide appropriate guidance to verify damper positions when the control room ventilation system described in the Updated Final Safety Analysis J
Report, Section 9.4.1, as a safety-related system, was secured from the main control room.
i b.
Prior to April 6, 1998, Byron Administrative Procedure (BAP) 1600-1,
" Action / Work Request Processing Procedure," Revision 41, was not of a type appropriate to the circumstances, in that, work requests in a " hold" status were not controlled by written i
procedural requirements.
Consequently, work was performed on the I
1B Essential Service Water pump without an authorized work request.
This is a Severity Level IV violation (supplement I).
(50-4 54 /4 55-98009-02 (DRP) )
REASON FOR THE VIOLATION
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Shutdown of Control Room HVAC System I
We agree with the violation.
Per BAP 340-1, "Use of Procedures for Operating Department," procedures shall be followed as written.
If an l
individual believes they cannot perform the activity as written, BAP i
340-1 requires that it be brought to the attention of a supervisor and l
the activity done per procedure or the procedure corrected before any further procedural steps are performed.
j A revision of Byron Operating Procedare (BOP) VC-2, " Shutdown of Control Room HVAC (Heating, Ventilation, and Air Conditioning," in January 1998, mistakenly deleted steps involving the startup and shutdown of VC system fans.
The procedure was used eight times with successful results from the time of issuance, althoegh, as written, the procedure was not executable. The operators had been fil ing in the missing steps of the procedure using " craft capability."
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b.
Action / Work Request Processing Procedure l
We agree with the violation. The procedure lacked sufficient detail for
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placing work requests on hold, with the intention of later re-scheduling the work activities.
No expectations or requirements e::isted to control the signatura page (.uth rization to place a work request on hold and restart the work activity at a later date.
CORRECTIVE STEPS TAKEN AND RESULTS AC]QEVID a.
Shutdown of Control Room HVAC System 1.
. BOP VC-2 was revised replacing the previously omitted steps.
2.
The Shif t Operations Supervisor has conducted tailgate meetings with all operating crews stressing that when a procedure exists it must be used as written or changed before continuing.
Utilizing craft capability for procedure omissions is inappropriate.
3.
The Operations Manager and Shift Operations Supervisor reiterated procedure usage expectations at operations management meeting on 5/20/98.
- b.
Action / Work Request Processing Procedure 1.
BAP 1600-1 " Action / Work Request Processing Procedure" was revised (rev. 42) to include new section D.9 to control work stopped and ren.oved from the schedule prior to completion.
The new section requires the work request to be set back to a " Ready" status, and a now coversheet to be printed out and attached to the hard copy of the work request to be used for documenting shift approval for restart of work. Work requests removed from the schedule after work has started are required to be rescheduled, walked down, and brought back to shift for sign in prior to restarting work.
2.
Maintenance Memo 500-02 "Use of EWCS Hold Codes" was revised (rev.4) to limit work requests that have b d work started from being rolled back to a status 45 " Ready" unless it has been removed from the schedule.
- CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION a.
Shutdown of. Control Room HVAC System 1.
None b.
Action / Work Request Processing Procedure 1.
None l'
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l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED a.
Shutdown of Control Room HhC System Full compliance was achieved on 3/17/98 when a temporary procedure change to BOP VC-2 was approved.
b.
Action / Work Request Processing Procedure Full compliance was achieved on 3/31/98 with the approval of BAP 1600-1.
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.j ATTACHMENT III VIOLATION (454/455-98009-05)
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained for procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Paragraph
' 7.e (4), specifies contamination control as an example of a radiation protection procedure.
-Byron Radiological Protection Procedure 5010-1, " Radiological Posting and Labeling Requirements," Revision 15, Paragraph F.3 states, in part, that any radiologically posted area shall be conspicuously posted so as to warn personnel approaching the area from any direction.
Contrary to the above, on March 9, 1998, the inspectors identified that an established contamination area within the 1A safety injection pump cubicle was not-conspicuously posted so as to warn personnel approaching the area from any direction.
This is a Severity Level IV violation (Supplement I).
( 50- 454 /09009- 05 (DRP) )
REASON FOR THE VIOLATION We agree with the violation. During an inspection there was noted a concern with the radiological boundary in the 1A Safety Injection (SI) pump room, which the inspector discussed with the Shift Manager. A portion of the room next to the pump was roped and posted as a contaminated area.
The concern was that there was an approximately seven feet section in the contamination area boundary not posted (step off pad opening). The two signs that had been posted could not be read from the unposted side, to adequately warn personnel approaching the area.
' Radiation Protection Technicians have had the past practice of allowing the step off pads to be considered adequate "signage" for posting the entrance side of a demarcated contaminated area.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The posting in the 1A SI pump room was immediately corrected.
2.
All Radiation Protection Technicians and foreman were counseled on the I
expectations of roping and posting radiological areas as defined in L
Byron Radiological Procedure 5010-1 during a "Line Management
. Expectations" presentation.
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3.
Radiation Protection policy 0006D, "RPLS Plant Walkdown and Quality i
'Cohtrol. Assessment of the RPA," as provided as an additional check performed by first line supervision to ensure areas are properly roped and posted, had its performance frequency changed from three (3) times per month to one (1) time per week, l
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
None DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 3/9/98 when the posting in the 1A SI pump room was corrected.
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