ML20137Q346

Responds to NRC Re Violations Noted in Insp Rept 50-454/85-33.Corrective Actions:Program Being Developed for Use on nonsafety-related Equipment Similar to Troubleshooting Practices Re safety-related Equipment

ML20137Q346
Person / Time
Site:	Byron
Issue date:	08/28/1985
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20137Q315	List: ML20137Q311 ML20137Q346
References
0573K, 573K, NUDOCS 8509200129
Download: ML20137Q346 (2)

Text

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• $ Commonwealth Edison Oni First Nationit Ph zt, Chic;go. Illinois

1. [

7 Address Reply to: Post Once Box 767

/ Chicago, Illinois 60690 August 28, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Unit 1 NRC Inspection Report No. 50-454/85-033 deference (a): August 13, 1985 letter from C. J.

Paperiello to Cordell Reed

Dear Mr. Keppler:

Reference (a) provided the results of an inspection by Mr.

VanDenburgh from July 9 through July 26, 1985 at Byron Station. During this inspection, a concern was brought to our attention regarding maintenance and troubleshooting efforts at the station and the level of documentation associated with these actisities. This letter is to inform you of our actions to address the identified concern.

We have reviewed the concern discussed in section 2.d of the Inspection Report attached to reference (a) and agree that some aspects of our maintenance and troubleshooting efforts to address the P-8 control rod problem contributed to delays in achieving a timely resolution of the problem. Since the electrical components of the control rod drive system are classified as non-safety related, the documentation requirements for maintenance and troubleshooting of safety related equipment were not applied. Maintenance and troubleshooting techniques for the investigation of safety related equipment p oblems have provided a timely resolution of problems and a completely documented summary of the maintenance activities.

Additional documentation that provided a written record of the activites associated with the series of P-8 control rod problems would have been useful to promote an expedient root cause determination and to help prevent possible miscommunications regarding the extent of the troubleshooting activities.

In light of this, Byron Station is developing a program for use on non-safety relai.ed equipment which is similar to the troubleshooting practices applied to safety related equipment. This program will be used whenever initial troubleshooting techniques do not reveal the root cause of a problem on non-safety related equipment.

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J. G. Keppler August 28, 1985 If a root cause determination cannot be made from the initial investigation of an equipment problem, the maintenance foreman will be required to obtain a " Maintenance Troubleshooting", checklist form from the work analyst. Implementation of this form will require the maintenance crew i to repeat all their investigations and document on the checklist what troubleshooting actions have been performed. These actions will be performed again in an attempt to establish the root cause. If a root cause determination cannot be made upon completion of the second troubleshooting effort, the results of the investigation will be reviewed by station management to evaluate the adequacy of the troubleshooting. After a thorough review of the troubleshooting actions, management personnel will i determine whether the actions are complete and reasonable prior to giving their approval to return the equipment to service.

If the deficient condition appears again after returning the equipment to service, the same troubleshooting technique will be repeated and the evaluation will be extended. The necessary resources will be provided to continue the investigation and resolve the problem. Offsite personnel will be consulted to help determine whether a Potentially Significant Event report should be generated.

A procedure to implement the program described above will be in place by Septenter 30, 1985.

I We believe the program described above will address the concern identified in the Inspection Report by providing complete documentation and analysis of problems involving non-safety related equipment whose root cause cannot be determined with a high degree of confidence. Additionally, this program should minimize the potential for miscommunication of information related to maintenance and troubleshooting of equipment as well as promoting timely resolution of difficult non-safety related equipment problems.

Very truly yours, L.~0. DelGeorge Assistant Vice President lm cc: Byron Resident Inspector 0573K