Similar Documents at Byron |
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P6171999-10-21021 October 1999 Forwards non-proprietary & Proprietary Versions of HI-982083, Licensing Rept for Byron & Braidwood Nuclear Stations. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20217M2871999-10-21021 October 1999 Refers to Rev 5 Submitted in May 1999 for Portions of Byron Nuclear Power Station Generating Stations Emergency Plan Site Annex.Informs That NRC Approval Not Required Based on Determination That Plan Effectiveness Not Decreased ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217F7891999-10-0808 October 1999 Forwards Insp Repts 50-454/99-12 & 50-455/99-12 on 990803- 0916.One Violation Occurred Being Treated as NCV ML20217B6351999-10-0505 October 1999 Forwards for Info,Final Accident Sequence Precursor Analysis of Operational Event at Byron Station,Unit 1,reported in LER 454/98-018 & NRC Responses to Util Specific Comments Provided in ML20212L1791999-10-0505 October 1999 Informs That as Result of Staff Review of Util Responses to GL 92-01,rev 1,suppl 1 & Suppl 1 Rai,Staff Revised Info in Rvid & Is Releasing Rvid Version 2 ML20217B2991999-10-0101 October 1999 Forwards Insp Repts 50-454/99-16 & 50-455/99-16 on 990907-10.No Violations Noted.Water Chemisty Program Was Well Implemented,Resulted in Effective Control of Plant Water Chemistry ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20212J6751999-09-30030 September 1999 Forwards Replacement Pages Eight Through Eleven of Insp Repts 50-454/99-15 & 50-455/99-15.Several Inaccuracies with Docket Numbers & Tracking Numbers Occurred in Repts ML20217A5821999-09-29029 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20216F8051999-09-17017 September 1999 Forwards Insp Rept 50-454/99-14 & 50-455/99-14 on 990823-27. Security Program Was Effectively Implemented in Areas Inspected.No Violations Were Identified ML20211P1841999-09-0808 September 1999 Forwards Insp Repts 50-454/99-15 & 50-455/99-15 on 990824- 26.No Violations Noted.Objective of Insp to Determine Whether Byron Nuclear Generating Station Emergency Plan Adequate & If Emergency Plan Properly Implemented ML20211Q6821999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Byron Operator Licesne Applicants During Wks of 000619 & 26.Validation of Exam Will Occur at Station During Wk of 000529 ML20211N5151999-09-0303 September 1999 Ack Receipt of Re Safety Culture & Overtime Practices at Byron Nuclear Power Station.Copy of Recent Ltr from NRC to Commonwealth Edison Re Overtime Practices & Safety Culture Being Provided ML20211K1081999-09-0202 September 1999 Responds to Request for Addl Info to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity, for Braidwood,Units 1 & 2 & Byron,Unit 2 ML20211M1371999-09-0202 September 1999 Discusses 990527 Meeting with Ceco & Byron Station Mgt Re Overtime Practices & Conduciveness of Work Environ to Raising Safety Concerns at Byron Station.Insp Rept Assigned for NRC Tracking Purposes.No Insp Rept Encl ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211G4021999-08-25025 August 1999 Forwards Insp Repts 50-454/99-10 & 50-455/99-10 on 990622-0802.No Violations Noted ML20211B8691999-08-20020 August 1999 Forwards Insp Repts 50-254/99-10,50-265/99-10,50-454/99-09, 50-455/99-09,50-456/99-10 & 50-457/99-10 on 990628-0721. Action Plans Developed to Address Configuration Control Weaknesses Not Totally Effective as Listed 05000454/LER-1998-008, Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER1999-08-12012 August 1999 Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210K0771999-07-30030 July 1999 Submits 30-day Rept Re Discovery of ECCS Evaluation Model Error for Byron & Braidwood Stations,As Required by 10CFR50.46 ML20210J8951999-07-29029 July 1999 Submits Other Actions,As Described,To Be Taken for Valves to Resolve Potential Pressure Locking Concerns,In Light of Extended Period for Valve Bonnet Natural Depressurization,In Response to GL 95-07, Pressure Locking & Thermal.. ML20210E2151999-07-23023 July 1999 Forwards Byron Unit 1 B1R09 ISI Summary Rept Spring 1999 Outage,980309-990424, in Compliance with Requirements of Article IWA-6000, Records & Repts of Section XI of ASME & P&PV,1989 Edition ML20209H2991999-07-16016 July 1999 Withdraws 980529 LAR to Credit Automatic PORV Operation for Mitigation of Inadvertent Safety Injection at Power Accident.Response to NRC 990513 RAI Re LAR Encl ML20210A3151999-07-16016 July 1999 Forwards Insp Repts 50-454/99-08 & 50-455/99-08 on 990511-0621.Three Violations Being Treated as Noncited Violations ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20207H7501999-07-12012 July 1999 Forwards Revised Pressure Temp Limits Rept, for Byron Station,Units 1 & 2.Revised Pressurized Thermal Shock Evaluations,Surveillance Capsule Rept & Credibility Repts, Also Encl ML20209G1391999-07-0909 July 1999 Forwards Results of SG Tube Insps Performed During Byron Station,Unit 1,Cycle 9 Refueling Outage within 12 Months Following Completion of Insps ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20196K0161999-06-30030 June 1999 Discusses 990622 Meeting at Byron Nuclear Power Station in Byron,Il.Purpose of Visit Was to Meet with PRA Staff to Discuss Ceco Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA Staff ML20196G2161999-06-25025 June 1999 Forwards for NRC Region III Emergency Preparedness Inspector,Two Copies of Comed Emergency Preparedness Exercise Manual for 1999 Byron Station Annual Exercise. Exercise Is Scheduled for 990825.Without Encls ML20212H8241999-06-24024 June 1999 Informs That Effective 990531 NRC Project Mgt Responsibility for Byron & Braidwood Stations Was Transferred to Gf Dick ML20209D4861999-06-17017 June 1999 Informs That R Heinen,License OP-30953-1 & a Snow,License SOP-30212-3,no Longer Require License at Byron Station 05000454/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed1999-06-0808 June 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed ML20207G0601999-06-0707 June 1999 Provides Updated Info Re Number of Failures Associated with Initial Operator License Exam Administered from 980914-0918. NRC Will Review Progress Wrt Corrective Actions During Future Insps ML20207G0421999-06-0404 June 1999 Forwards Insp Repts 50-454/99-04 & 50-455/99-04 on 990330-0510.Violations Identified & Being Treated as non-cited Violations ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20207E5451999-05-28028 May 1999 Forwards Insp Repts 50-454/99-07 & 50-455/99-07 on 990517-20.No Violations Noted.Fire Protection Program Was Effective ML20211M1611999-05-28028 May 1999 Discusses 990527 Meeting with Comed Re Safety Culture & Overtime Control at Byron Nuclear Plant from Videoconference Location at NRC Headquarters.Requests That Aggressive Actions Be Taken to Ensure That Comed Meets Expectations ML20207D5261999-05-26026 May 1999 Forwards Response to NRC 990318 RAI Concerning Alleged Chilling Effect at Byron Station.Attachment Contains Responses to NRC 12 Questions ML20207B6361999-05-25025 May 1999 Forwards SE Accepting Revised SG Tube Rupture (SGTR) Analysis for Bryon & Braidwood Stations.Revised Analysis Was Submitted to Support SG Replacement at Unit 1 of Each Station ML20211M1781999-05-25025 May 1999 Summarizes Concerns with Chilling Effect & Overtime Abuses at Commonwealth Edison,Byron Station.Request That Ltr Be Made Part of Permanent Record of 990527 Meeting ML20195C7911999-05-25025 May 1999 Forwards Revised COLR for Byron Unit 2,IAW 10CFR50.59.Rev Accounts for Planned Increase of Reactor Coolant Full Power Average Operating Temp from 581 F to 583 F 05000454/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed1999-05-21021 May 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed ML20206U3471999-05-20020 May 1999 Forwards Insp Rept 50-454/99-05 on 990401-22.No Violations Noted.Insp Reviewed Activities Associated with ISI Efforts Including Selective Exam of SG Maint & Exam Records, Calculations,Observation of Exam Performance & Interviews ML20207A2151999-05-19019 May 1999 Forwards Insp Repts 50-454/99-06 & 50-455/99-06 on 990419-23.No Violations Noted.Insp Consisted of Review of Liquid & Gaseous Effluent Program,Radiological Environmental Monitoring Program,Auditing Program & Outage Activities 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217P6171999-10-21021 October 1999 Forwards non-proprietary & Proprietary Versions of HI-982083, Licensing Rept for Byron & Braidwood Nuclear Stations. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) 05000454/LER-1998-008, Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER1999-08-12012 August 1999 Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210K0771999-07-30030 July 1999 Submits 30-day Rept Re Discovery of ECCS Evaluation Model Error for Byron & Braidwood Stations,As Required by 10CFR50.46 ML20210J8951999-07-29029 July 1999 Submits Other Actions,As Described,To Be Taken for Valves to Resolve Potential Pressure Locking Concerns,In Light of Extended Period for Valve Bonnet Natural Depressurization,In Response to GL 95-07, Pressure Locking & Thermal.. ML20210E2151999-07-23023 July 1999 Forwards Byron Unit 1 B1R09 ISI Summary Rept Spring 1999 Outage,980309-990424, in Compliance with Requirements of Article IWA-6000, Records & Repts of Section XI of ASME & P&PV,1989 Edition ML20209H2991999-07-16016 July 1999 Withdraws 980529 LAR to Credit Automatic PORV Operation for Mitigation of Inadvertent Safety Injection at Power Accident.Response to NRC 990513 RAI Re LAR Encl ML20207H7501999-07-12012 July 1999 Forwards Revised Pressure Temp Limits Rept, for Byron Station,Units 1 & 2.Revised Pressurized Thermal Shock Evaluations,Surveillance Capsule Rept & Credibility Repts, Also Encl ML20209G1391999-07-0909 July 1999 Forwards Results of SG Tube Insps Performed During Byron Station,Unit 1,Cycle 9 Refueling Outage within 12 Months Following Completion of Insps ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20196G2161999-06-25025 June 1999 Forwards for NRC Region III Emergency Preparedness Inspector,Two Copies of Comed Emergency Preparedness Exercise Manual for 1999 Byron Station Annual Exercise. Exercise Is Scheduled for 990825.Without Encls ML20209D4861999-06-17017 June 1999 Informs That R Heinen,License OP-30953-1 & a Snow,License SOP-30212-3,no Longer Require License at Byron Station 05000454/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed1999-06-0808 June 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20211M1611999-05-28028 May 1999 Discusses 990527 Meeting with Comed Re Safety Culture & Overtime Control at Byron Nuclear Plant from Videoconference Location at NRC Headquarters.Requests That Aggressive Actions Be Taken to Ensure That Comed Meets Expectations ML20207D5261999-05-26026 May 1999 Forwards Response to NRC 990318 RAI Concerning Alleged Chilling Effect at Byron Station.Attachment Contains Responses to NRC 12 Questions ML20211M1781999-05-25025 May 1999 Summarizes Concerns with Chilling Effect & Overtime Abuses at Commonwealth Edison,Byron Station.Request That Ltr Be Made Part of Permanent Record of 990527 Meeting ML20195C7911999-05-25025 May 1999 Forwards Revised COLR for Byron Unit 2,IAW 10CFR50.59.Rev Accounts for Planned Increase of Reactor Coolant Full Power Average Operating Temp from 581 F to 583 F 05000454/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed1999-05-21021 May 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB ML20207E9831999-05-18018 May 1999 Forwards Copy of Commonwealth Edison Co EP Exercise Evaluation Objectives for 1999 Byron Station Annual EP Exercise,Which Will Be Conducted on 990825.Without Encl ML20206N8551999-05-11011 May 1999 Forwards 1998 Annual Radioactive Environ Operating Rept for Byron Station. Rept Includes Summary of Radiological Liquid & Gaseous Effluents & Solid Waste Released from Site ML20206U3351999-04-30030 April 1999 Forwards Evaluation of Matter Described in Re Byron Station.Concludes That Use of Overtime at Byron Station Was Controlled IAW Administrative Requirements & Mgt Expectations Established to Meet Overtime Requirement of TS ML20206F5381999-04-30030 April 1999 Forwards Magnetic Tape Containing Annual Dose Repts for 1998 for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR20.2206(c).Without Magnetic Tape ML20206C7901999-04-23023 April 1999 Provides Suppl Info Re Use of W Dynamic Rod Worth Measurement Technique,As Requested During 990413 Telcon.Rev Bars in right-hand Margin Identify Changes from Info Submitted by ML20206E7521999-04-22022 April 1999 Submits Rept on Number of Tubes Plugged or Repaired During Inservice Insp Activities Conducted at Plant During Cycle 9 Refueling Outage,Per TS 5.6.9 ML20206A7431999-04-22022 April 1999 Forwards Comments Generated Based on Review of NRC Ltr Re Preliminary Accident Sequence Precursor Analysis for Byron Station,Unit 1 ML20206B3941999-04-21021 April 1999 Forwards Annual & 30-Day Rept of ECCS Evaluation Model Changes & Errors, for Byron & Braidwood Stations.Updated Info Re PCT for Limiting Small Break & Large Break LOCA Analysis Evaluations & Detailed Description of Errors ML20206B2471999-04-20020 April 1999 Informs That SE Kuczynski Has Been Transferred to Position No Longer Requiring SRO License.Cancel License SOP-31030-1, Effective 990412 ML20205S9621999-04-20020 April 1999 Responds to 981203 RAI Telcon Re SG Tube Rupture Analysis for Byron Station,Unit 2 & Braidwood Station,Unit 2.Addl Info & Subsequent Resolution of Issues Discussed During 990211 Telcon Are Documented in Encl ML20206A8141999-04-20020 April 1999 Advises NRC of Review of Cycle 10 Reload Under Provisions of 10CFR50.59 & to Transmit COLR for Upcoming Cycle ML20205T3901999-04-13013 April 1999 Forwards Byron Station 1998 Occupational Radiation Exposure Rept, Which Is Tabulation of Station,Utility & Other Personnel Receiving Annual Deep Dose Equivalent of Less than 100 Mrem ML20196K6661999-03-31031 March 1999 Forwards Byron Nuclear Power Station 10CFR50.59 Summary Rept, Consisting of Descriptions & SE Summaries of Changes, Tests & Experiments.Rept Includes Changes Made to Features Fire Protection Program,Not Previously Presented to NRC ML20205K5841999-03-31031 March 1999 Submits Rept on Status of Decommissioning Funding for Reactors Owned by Comm Ed.Attachment 1 Contains Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) ML20205B4241999-03-23023 March 1999 Provides Results of drive-in Drill Conducted on 990208,as Well as Augmentation Phone Drills Conducted Since 981015,as Committed to in Util ML20207K0351999-03-0404 March 1999 Forwards Util Which Transmitted Corrected Pages to SG Replacement Outage Startup Rept.Subject Ltr Was Inadvertently Not Sent to NRC Dcd,As Required by 10CFR50.4 ML20205C6861999-03-0404 March 1999 Provides Notification That Byron Station Implemented ITS on 990205 & Braidwood Station Implemented ITS on 990219 ML20207D6831999-03-0101 March 1999 Forwards fitness-for-duty Program Performance Data for Each Comed Nuclear Power Station & Corporate Support Employees for Six Month Period Ending 981231,per 10CFR26.71(d) ML20207D4301999-02-26026 February 1999 Informs NRC That Supplemental Info for Byron & Braidwood Stations Will Be Delayed.All Mod Work Described in Ltr Is on Schedule,Per GL 96-06 ML20207B8971999-02-25025 February 1999 Expresses Concern That Low Staffing Levels & Excessive Staff Overtime May Present Serious Safety Hazard at Some Commercial Nuclear Plants in Us ML20203C7001999-02-0202 February 1999 Informs That Mhb Technical Associates No Longer Wishes to Receive Us Region III Docket Info Re Comed Nuclear Facilities.Please Remove Following Listing from Service List ML20202F5911999-01-29029 January 1999 Forwards Byron Unit 1 Cycle 9 COLR in ITS Format & W(Z) Function & Byron Unit 2 Cycle 8 COLR in ITS Format & W(Z) Function. New COLR Format Has Addl Info Requirements ML20199E1611999-01-15015 January 1999 Forwards Response to 980902 RAI Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations. CE Endorses Industry Response to RAI as Submitted by NEI ML20199B7511999-01-0808 January 1999 Forwards Proprietary Versions of Epips,Including Rev 52 to Bzp 600-A1 & Rev 48 to Bzp 600-A4 & non-proprietary Version of Rev 52 to Bzp 600-A1 & Index.Proprietary Info Withheld 1999-09-30
[Table view] |
Text
Onnme mn rahh 14hv m Company
- llynm Generating Mathm e' 1 n%4 North (,rtinAn Clittf(h Ro.kl It) ton,1141010 979 4 Tel Hl$ 254 5411 November 19, 1997 LTR: BYRON 97-0274 FILE: 1.10.0101 i
U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Efron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97015; 50-455/97015 NRC Docket Numbers 50-454. 50-455
REFERENCE:
Geoffrey E. Grant letter to Mr. Graesser dated October 20, 1997, transmitting NRC Inspection Report 50-454/97015; 50-455/97015 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited three (3) Soterity Level IV violations requiring a written response. Comed's respo'.se is provided in the attachment.
This letter contains the following commitments:
- 1) Maintenance groups will brief all maintenance staff personnel on the subject of the inadvertent OB SX Make-up pump / inadvertent PORV lift events, and to challenge work package quality and demonstrate the proper channels to communicate work package weaknesses.
- 2) Instrument Maintenance personnel will be instructed to expect precautions to be addressed in work packages that were previously left to calibration procedures to accomplish.
/[g 9711290127 971119 PDM G ADOCK 05000454 pg kl.EI.El.H.i.lE.IM.i.l (p r \9 ?bylt rs\ 970274.wpf \1)
A Unkunt Comp.tns
- l Byron Ltr. 97-0274 n November 19, 1997 Page 2
- 3) Revise NSWP-A-03 to istruct workers to follow BFP FH-31 when working in fuel handling cleanliness zones.
- 4) Submit a Technical Specification Amendment to revise the minimum allowable CST level and update TS Table 3.3-4 with the appropriate value.
- 5) Revise Byron Procedure 1 BIS 3.2.1-021 and 2 BIS 3.2.1-021 with the appropriate Technical Specification values.
If . tour staff has any questions or comments concerning this letter, please refer tb*m to Don Brindle, Regulatory Assurance Supervisor, at (815)234 ~441 ext.2280.
Respectfully, l
- %~'
K. L. Grae se Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc: A. B. Beach, NRC Regional Administrator - RIII G. F. Dick Jr., Byron Project Manager - NRR Senior Fvsident Inspector, Byron M. J. Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS (pt\97byltts\970274.wpf\2)
ATTACHMENT, I VIOLATION (4 54 /4 55- 97015-021 Appendix B, Criterion XVI, " Corrective Action," of 10 CFR Part 50, *ce quire s , in part, that in the case of significant conditions adverse to qua'.ity, measures shall be established to assure that corrective action be t r. ken to preclude repetition.
Contrary to the above, the inspectors identified that the corrective actions resulting f rom the inadvertent lif t of a Unit 2 pressurizer power operated rehef valve on March 5, 1997, were inadequate to prevent the inadvertent start of the OB essential service water make-up pump on September 2, 1997. Specifically, precautions were not identified in the work request describing potential system response (50-4 54 ; 4 5 5/97015-02 (DRP) ) .
This is a Severity Level IV Violation (Supplement I) .
BEASON FOR THE VIOLATION The Instrument Maintenance Department concurs with the violation in that:
The inadvertent lif t of the Unit 2 pressurizer relief valve (PORV) may have been prevented with additional work package instructions, and the corrective action taken as a result of the relief lif ting was too narraw in focus to prevent other similar activities from causing inadvertent actuations.
Work packages for complex, inf requently performed activities require additional precautions to aid in the prevention of unplanned equipment responses. In the case of the auto-start of the OB Essential Service Water Make-up Pump, the work instructions were unclear and poor communication was exhibited at the job briefing and job sign-in.
CORRECTIVE _STEPR TAKEN AND RESULTS ACHIEVED
- 1. The work was immediately stopped and the event was reviewed with the Shift Manager and personnel involvcd in the event.
- 2. The work package for the opposite train was revised to include putting the pump into " Pull-to-Lock" with appropriate sign-offs prior to determinating the switch.
- 3. Work package preparers were directed to include in the work packages actions required by other departments (i.e., ooS's, precautions and expectations).
l 1
l 1
(pi\97byltrs\970274.wpf\4)
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIQt{
- 1. Maintenance groups will brief all maintenance staff personnel on the subject of these events, and to challenge work package quality and demonstrate the proper channels to communicate work package weaknesses.
This action will be tracked by NTS item # 454-100-97-01502-01.
- 2. Instrument Maintenance personnel will be instructed to expect precautions to be addressed in work packages that were previously left to calibration procedures to accomplish. This action will be tracked by NTS item # 454-100-97-01502-02.
DATE WHEN TULL COMPLIA_N_QE WILL BE ACHIEVED Full compliance was achieved on 09/05/97 when LCOAR OBOS 7.5-1A was exited.
l l
l l (pa\97byltrs\970274.wpf\5) l l
l
m ATTACHMKIT II VIOLATION (454/455-97015-03a/b)
Technical Specification 6.8.1 requires that procedures be established, implemented, and maintained for activities covered in Appendix A of Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Section e, covers the use of general procedures for control of maintenance and modification work.
Byron Fuel Handling Procedure (BFP) FH-31, " Fuel Handling Cleanliness Zones and Requirements," Revision 4, is a general pr]cedure used in the control of maintenance and modification work. Paragraph F.5.e of BFP FH-31 requires tools to be tethered and logged.
BFP FH-31, " Fuel Handlir.g Cleanliness Zones and Requirements," Revision 4, is a general procedure used in the control of maintenance and modification work.
Paragraph F.5.f of BFP FH-31 requires personnel accountability to be accomplished by logging in and out each individual at the control point of a cleanliness area.
Contrary to the above,
- a. On July 28, 1997, the inspectors identified untethered tools, including needlenose pliers, a hammer, and several other hand tools, in the cleanliness area established for spent fuel pool fuel transfer canal modification work.
( 50 -4 54 / 97015 - 03 a (DRP) ; 50 - 4 5 5 / 97015 - 03 a (DKP) )
- b. On Guly 28, 1997, the inspectors identified that a person had logged 4.ato the cleanliness area established for spent fuel pool transfer canal modification work on June 23, 1997, but had not logged out (50-4 54 /97015-03b (DRP) ; 50-4 55/97015-03b (DRP) ) .
This is a Severity Level IV Violation (Supplement I).
BEASON FOR THE VIOLATION The work packages prepared and being used by the contractors perf orming t...e work, on the spent fuel pool fuel transfer canal modification, contained directions to follow NSWP-A-03, " Foreign Material Exclusion," for Foreign Material Exclusion (FME) controls and not BFP FH-31, " Fuel Handling Cleanliness Zones and Requirements." The contract workers had not been trained on the proper use of BFP FH-31, which contains additional requirements, and this procedure was not included as a part of the work packages.
(pi\97byltrs\970274.wpf\6)
. _- . _ _ - _y. __ _ _ _ _ _ . _ .- _ _ ~ . . _ . . _ _._ . _ . _ _ _ _ _ . _
CORRECTIVE STEPS TAKEN AND REJ_ULTS ACHIEVED
'1. Assigned Fuel) Handling Department ; personnel - to be in attendance. . and monitor the work activities.for the remainder of the project.
- 2. Performed a complete audit andLinventory of all: logs, and corrected the logs.
- 3. Removed equipment not required to be in the FME area.
t
- 4. : Briefed contractor personnel on the use of BFP FH-Si
)
- 5. . Revised BFP FH-31 to allow work and storage of materials within cleanliness zones-provided appropriate barriers are' erected.
CORRECTIVE STEPS THAT WILL LE TAKEN TO AVOID FURTHER VIOLATION
-1. Revise NSWP-A-03 to instruct workers to follow BFP FH-31 when working in fuel handling cleanliness zones. This action will be tracked by NTS item #
454-201-97-CAQS02198-02.
DATE WHEN FULL.CONPLIANCE WILL BE_ ACHIEVED Full. compliance- was achieved on 8/12/97 when the work area and logs were -
corrected, and work proceeded in accordance with BFP FH-31.
?
(pi\97bStts\970274 wpf \7) l 1 l
_ _, , - __. ._ _ _. _ . .s, - _ .__ _
ATTACHMENT III ylpJ4 TION (454/455-97015-04a/b)
Appendix B, Criterion XVI, " Corrective Action," of 10 CFR Part 50, requires, in part, that measures be established to asaure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above:
- a. The inspectors identified that since December 1994, the licensee failed to implement timely corrective action for a condition adverse to quality, in that Techncal Specification Table 3.3-4, Functional Unit 6.g, had not been revise to accurately reflect a change in the auxiliary feedwater pump low suction pressure transf er to essential service water (50-454/97015-04a (DRP);
50-4 55/ 97015-04a (DRP) ) .
- b. The inspectors identified that since Dccember 1994, the licensee failed to implement timely corrective action for a condition adverse to quality, in that procedure 1 BIS 3.2.1-021," Functional Test of Auxiliary Feedwater Pump Suction Pressure," Revision 8, had not been revised to accurately reflect a change in the allowable value trip setpoint for the auxiliary feedwater pump low suction pressure transfer to essential service water (50-4 54 / 97015-04b (DRP) ; 50-4 55/97015-04b(DRP) ) .
This is a Severity Level IV Violation (Supplement I).
BRAJON FOR THE VIOLATION
- a. Failure to update AF TS setpoint In 1994, Byron Station identified a conce rn during a review of the Auxiliary Feedwater (AF) system. The concern centered around a scenario where a seismic event could degrade the automatic AF pump suction switchover f rom the Condensate Storage Tank (CST) to the Essential Service Water (SX) system. The seismic event was postulated to cause a break in the safety class II condensate piping on the auction side of the AF pumps.
The effect of the break would be to drain the piping header and its associated loop seals, thereby exposing the AF pump suction to atmospheric pressure. At the time this issue was discovered, the SX switchover setpoint was subatmospheric at 14.1 psia. With the header drained and the loop seal ineffective, it was postulated that the pump suction piping would empty before the SX switchover setpoint was reached. In this circumstance, the suction pressure instrumentation would sense only
! atmospheric pressure and the automatic SX switchover would not occur. In l
response to the identified issue, Byron Station performed an operability assessment (94-011) and implemented a corrective action to increase the setpoints on the suction pressure switches for the four (4) AF pumps on l both Byron units. In addition, a coicpensatory action to administratively maintain a higher volume of water in the CST was implemented to prevent an
! inadvertent switchover f rom the CST to SX water supply and to maintain the
! licensing basis requirements for available CST inventory. The AF suction (pi\97byltrs\970n4.wpf\81 i l
g alarm setpoints were raised from 16.1 to 20.1 psia, the SX switchover setpoints - were raised from 14.1 to 18.1 psia, and the AF : pump trip setpoints were raised _from 22.5 to 16.5 psia. These new setpoints were chosen so that if the pump suction pressure dropped to atmospheric due to a lossLof the suction header and loop seal, all three (3) actuations would still occur. The setpoint changes were implemented in Byrdn setpoint change requests (SSCRs)94-073, 94-074, 94 075, and 94-076. A 50.59 safety evaluation (T1-94-0146) was performed to support the setpoint-changes. The safety evaluation appropriately identified TS Table 3.3-4, Functional Unit 6.g. as being potentially impacted by the setpoint change, llowever, the changes .were identified as being _in the conservative ;
direction with respect to the TS limits defined in Table 3.3-4, Functional Urait 6.g. and therefore, it was concluded that the margin of safety was not reduced. Furth.irmore , since the existing condition was considered to be temporary until a longer term corrective action could be implemented, the change to 'IS Table 3,3-4 was not considered appropriate or necessary.
In summary, the reason for the violation was the failure to recognire the urgency to make an administrative change to the TS values contained in Table 3.3-4, Functional' Unit 6.g. since the revised setpoint value was determined to be conservative with respect to the TS.
- b. Failure to revise procedure 3 BIS 3.2.1-021 As discussed in the previous section above, Byron Station completed Operability Assessment 94-011 which implemented corrective and compensatory actions in response to the identified operability issue for AF pump suction switchover, one of the corrective actions was to revise the AF suction setpoints. The AF suction alarm setpoints were raised f rom 16.1 to 20.1 pala, the SX switchover setpoints were raised from 14.1 to 10.1 psia, and the AF pump trip setpoints were raised from 12.5 to 16.5 psia. These new setpoints were chosen so that if the pump suction pressure dropped tu atmospheric due to a loss of the auction header and loop seal, all three (3) actuations would still occur. The setpoint changes were implemented in Byron setpoint change requests (SSCRs)94-073, 94-074,94-075, and 94-076. As part of the SSCRs, procedures 1 BIS 3.2.1-021 and 2 BIS 3.2.1-021, " Surveillance Fun:tional Test of Auxiliary Feedwater Pump Suction Pressure Loop," were revised to incorporate the new setpoints. Revision 8 of each procedure was issued on December 27, 1994 which correctly incorporated the revised AF suction setpoints identified in the 'bove SSCRs. The specific changes in the BIS procedures
, was the document , Out of Tolerance range, llowever, as discussed in section a. above, no change to TS Table 3.3-4, Functional Unit 6.g. was ,
identified as being required in the supporting 50.59 safety evaluation.
Therefore, even though the out of Tolerance ranges were revised in the two
-(2) BIS procedures, the corresponding minimum allowable TS value was not revised. In summary, the reason for this violation is the failure to recognize the need to make an administrative change to the Byron values contained in TS Table 3.3-4, Functional Unit 6.g. In addition, since the TS values were not revised, the corrasponding minimum allowable TS values contained in 1 BIS 3.2.1-021 and 2 BIS 3.2.1-021 were not revised either.
i i
i i
, (p \97byltrs\970274.wpf\9) l l
l
- .l
.. i e
1 qQSffCTIVE STEPS TAKEN AND RESULTS ACHIEVELD
- a. Failure to update AF TS setpoint Dyron Station, in conjunction with Braidwood Station, is in process of generating a TS amendment to revise the minimum allowable CST level and to update Table 3.3-4 with the appropriate value. This TS amendment is being developed in conjunction with the replacement steam generator project for Byron Unit 1 and Braidwood Unit 1. The TS change request will be issued by December 31, 1997. In the interim, Byron Station has previously implemented appropriate setpoint changes to reflect the current design basis of the AF system to ensure that switchover from the CST to SX will occur, if needed.
The setpoint changes were correctly evaluated per the requirements of 10CFR50.59. In addition, a compensatory action remains in place to maintain minimum CST level of >75% to 'nsure that an inadvertent switchover f rom the CST to SX does not occur and to ensure that the licensing basis requirements for minimum available CST inventory are maintained. The administrative control on CST level will remain in effect pending NRC approval cf the TS amendment request discussed above.
- b. Failure to revise procedure 1 BIS 3.2.1-021 Byron Procedure 1 BIS 3.2.1-021 and 2 BIS 3.2.1-021 will be revised with the appropriate TS value once NRC approval of the proposed TS amendment discussed in section a. above is received. This revision will incorporate the appropriate TS allowable value for the SX switchover setpoint. In the interim, the current allowable setpoint out of Tolerance range documented in the procedures reflects the current design basis for the AF system. If any "as found" setpoint is identified as being Out of Tolerance, the proc _ es require immediate notification of the operating Shif t Manager for appropria s LCOAR entry. Therefore, based on the current guidance provided in the procedure, there is no possibility that operation outside of the design basis for the AF system will occur, p_0_RJECTIVE STEPS THAT WItL BE TAKEN TO AVOID FURTHER VIOLATION Recent training and communication has been provided to Byron Station personnel on design and licensing basis issues. One particular area of focus was related to literal compliance with plant technical specifications and the 14 ancing basis as described in the Updated Final Safety Analysis Report (UF % This focused training is expected to reinforce the management expe,:tatica for literal compliance and the prompt identification of TS and UFSAW issues that require prompt disposition.
Submit a Technical Specification Amendment to revise the minimum allowable CST level and update TS Table 3.3-4 with the appropriate value. This action will be tracked by NTS item # 454-100-97-01504a-01.
Revision of Byron Procedure 1 BIS 3.2.1-021 and 2 BIS 3.2.1-021 with the appropriate TS value, once NRC approval of the proposed TS amendment discussed in section a above is received, will be performed. This action will be tracked by NTS item # 454-100-97-01504b-01.
(pi\97byltrs\970274.wpf\10)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVID Full compliance will be achieved within 30 days of the NRC approval of the proposed TS Amendment to revise the minimum allowable CST level and update TS Table 3.3-4, and the appropriate procedure revisions to IBIS 3.2.1-021 and 2 BIS 3.2.1-021 are made in response to the TS Amendment. The TS Amendment request will be submitted by December 31, 1997 as an ordinary administrative change for NRC review.
1 I
tp:\97byltrs\970274.wpf\11)
!