Similar Documents at Byron |
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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] Category:UTILITY TO NRC
MONTHYEARML20059K6741990-09-17017 September 1990 Suppls Responses to Violations Noted in Insp Repts 50-454/89-11,50-455/89-13,50-456/89-11 & 50-457/89-11. Corrective Actions:Procedures Changed & Valve Tagging Status Provided ML20059L6611990-09-10010 September 1990 Forwards Byron Station Units 1 & 2 Inservice Insp Program ML20064A3681990-08-24024 August 1990 Forwards Response to 900517 Request for Addl Info Re Design of Containment Hydrogen Monitoring Sys.Util Proposes Alternative Design That Ensures Both Containment Isolation & Hydrogen Monitoring Sys Operability in Event of LOCA ML20064A0181990-08-16016 August 1990 Submits Supplemental Response to NRC Bulletin 88-008,Suppls 1 & 2.Surveillance Testing Revealed No Leakage,Therefore Charging Pump to Cold Leg Outage Injection Lines Would Not Be Subjected to Excessive Thermal Stresses ML20063Q1051990-08-10010 August 1990 Forwards Monthly Operating Repts for Jul 1990 for Byron Units 1 & 2 & Corrected Monthly Operating Rept for June 1990 for Unit 2 ML20055J1221990-07-25025 July 1990 Notifies That Plants Current Outage Plannings Will Not Include Removal of Snubbers.Removal of Snubbers Scheduled for Future Outages.Completion of Review by NRC by 900801 No Longer Necessary ML20055H7631990-07-25025 July 1990 Forwards Financial Info Re Decommissioning of Plants ML20055J1261990-07-25025 July 1990 Notifies That Replacement of 13 Snubbers w/8 Seismic Stops on Reactor Coolant Bypass Line Being Deferred Until Later Outage,Per Rl Cloud Assoc Nonlinear Piping Analyses ML20055G3251990-07-16016 July 1990 Responds to SALP Board Repts 50-454/90-01 & 50-455/90-01 for Reporting Period Nov 1988 - Mar 1990.Effort Will Be Made to Continue High Level of Performance in Areas of Radiological Controls,Plant Operations,Emergency Preparedness & Security ML20044A9621990-07-13013 July 1990 Forwards Rev 0 to Topical Rept NFSR-0081, Comm Ed Topical Rept on Benchmark of PWR Nuclear Design Methods Using PHOENIX-P & Advanced Nodal Code (Anc) Computer Codes, in Support of Implementation of PHOENIX-P & Anc ML20044B1411990-07-12012 July 1990 Forwards Addl B&W Rept 77-1159832-00 to Facilitate Completion of Reviews & Closeout of Pressurized Thermal Shock Issue,Per NRC Request ML20044B2081990-07-11011 July 1990 Responds to Generic Ltr 90-04 Re Status of GSI Resolved W/ Imposition of Requirements or Corrective Actions.Status of GSI Implementation Encl ML20044B2141990-07-11011 July 1990 Withdraws 891003 Amend Request to Allow Sufficient Time to Reevaluate Technical Position & Develop Addl Technical Justification ML20044A9521990-07-10010 July 1990 Provides Supplemental Response to NRC Bulletin 88-001. Remaining 48 Breakers Inspected During Facility Spring Refueling Outage ML20044A7991990-06-29029 June 1990 Forwards Description of Change Re Design of Containment Hydrogen Monitoring Sys,Per 900517 Request.Util Proposing Alternative Design Ensuring Containment & Hydrogen Monitoring Sys Operability in Event of Power Loss ML20055D4811990-06-29029 June 1990 Discusses Revised Schedule for Implementation of Generic Ltr 89-04 Re Frequently Identified Weaknesses of Inservice Testing Programs.All Procedure Revs Have Either Been Approved or Drafted & in Onsite Review & Approval Process ML20055D2951990-06-22022 June 1990 Discusses Results of 900529-0607 Requalification Exam.Based on Results of Exam,Station Removed/Prohibited Both Shift & Staff Teams & JPM Failure from License Duties.Shift Team Placed in Remediation Program from 900611-14 ML20058K3521990-06-22022 June 1990 Requests Withdrawal of 900315 Application for Amends to Licenses NPF-37,NPF-66,NPF-72 & NPF-77,changing Tech Specs 3.8.1.1 & 4.8.1.1.2 to Clarify How Gradual Loading of Diesel Generator Applied to Minimize Mechanical Stress on Diesel ML20043D3151990-06-0101 June 1990 Forwards Rev 30 to Security Plan.Rev Withheld (Ref 10CFR73.21) ML20043E3141990-05-31031 May 1990 Withdraws 880302 Application for Amend to Licenses NPF-37, NPF-66,NPF-72 & NPF-77,changing Tech Spec 4.6.1.6.1.d to Reduce Containment Tendon Design Stresses to Incorporate Addl Design Margin,Due to Insufficient Available Data ML20043F4731990-05-30030 May 1990 Forwards Suppl to 881130 Application for Amends to Licenses NPF-37,NPF-66,NPF-72 & NPF-77.Changes Requested Per Generic Ltr 87-09,to Remove Unnecessary Restrictions on Operational Mode Changes & Prevent Plant Shutdowns ML20043C8641990-05-29029 May 1990 Forwards Rept of Local Leakage Rate Test Results for Third Refueling Outage.Leakage Rates of Six Valves Identified as Contributing to Failure of Max Pathway Limit ML20043B7691990-05-23023 May 1990 Forwards Endorsement 11 to Nelia & Maelu Certificates N-93 & M-93 & Endorsement 9 to Nelia & Maelu Certificates N-101 & M-101 ML20043A9161990-05-16016 May 1990 Provides Advanced Notification of Change That Will Be Made to Fire Protection Rept Pages 2.2-18 & 2.3-14 ML20043A6391990-05-11011 May 1990 Submits Revised Schedule for Implementation of Generic Ltr 89-04 Guidance.Rev to Procedures for Check Valve & Stroke Time Testing of power-operated Valves Will Be Completed by 900629 ML20043A2891990-05-10010 May 1990 Forwards Monthly Operating Rept for Apr 1990 & Corrected Rept for Mar 1990 for Byron Nuclear Power Station ML20042G7111990-05-0707 May 1990 Responds to NRC Questions Re leak-before-break Licensing Submittal for Stainless Steel Piping.Kerotest Valves in Rh Sys Will Be Replaced in Byron Unit 2 During Next Refueling Outage Scheduled to Begin on 900901 ML20042F6851990-05-0404 May 1990 Requests Resolution of Util 870429,880202 & 0921 & 890130 Submittals Re Containment Integrated Leak Rate Testing in Response to Insp Repts 50-454/86-35 & 50-455/86-22 by 900608 ML20042G3591990-04-30030 April 1990 Forwards Errata to Radioactive Effluent Rept for Jul-Dec 1989,including Info Re Sr-89,Sr-90 & Fe-55 Analysis for Liquid & Gaseous Effluents Completed by Offsite Vendor ML20055C5761990-04-30030 April 1990 Forwards Results of Investigation in Response to Allegation RIII-90-A-0011 Re Fitness for Duty.W/O Encl ML20042E9601990-04-30030 April 1990 Forwards Response to NRC 900327 Ltr Re Violations Noted in Insp Repts 50-454/90-09 & 50-455/90-08.Response Withheld (Ref 10CFR73.21) ML20042E9111990-04-25025 April 1990 Forwards Rev 1 to Nonproprietary & Proprietary, Steam Generator Tube Rupture Analysis for Byron & Braidwood Plants. ML20012E1081990-03-21021 March 1990 Forwards Calculations Verifying Operability of Facility Dc Battery 111 W/Only 57 of 58 Cells Functional & Onsite Review Notes,Per Request ML20012D8671990-03-21021 March 1990 Reissued 900216 Ltr,Re Changes to 891214 Rev 1 to Updated Fsar,Correcting Ltr Date ML20012C5471990-03-12012 March 1990 Provides Results of Completed Util Reviews & Addresses Addl Info Requested by NRC Re 890317 Application for Amends to Licenses NPF-37,NPF-66,NPF-72 & NPF-77 to Change Tech Spec 4.5.2,supplemented on 890825 & 890925-27 Meetings ML20006E1441990-02-16016 February 1990 Forwards Suppl to Rev 1 to Updated FSAR for Braidwood Station,Units 1 & 2 & Byron Station,Units 1 & 2,per 881214 & 891214 Submittals ML20012A4491990-02-16016 February 1990 Advises That 16 Tubes in All Four Steam Generators Removed from Svc as Result of Eddy Current Insp During Cycle 3 Refueling Outage.Tube Plugging Distribution Between Steam Generators Listed ML20006E4201990-02-14014 February 1990 Requests NRC Approval for Use of Alloy 690 Steam Generator Tube Plugs for Facility,Prior to 900301,pending Final ASME Approval of Code Case for Alloy 690 ML20006E2611990-02-0909 February 1990 Responds to NRC Bulletin 88-009 Re Thimble Tube Thinning. Thimble Tube Insps Performed Using Eddy Current Testing Methodology & Performed at Every Refueling Outage Until Sufficient Data Accumulated to Generate Correlation ML20011F3661990-02-0707 February 1990 Forwards Errata to Radioactive Effluent Rept for Jan-June 1989 & Advises That Sr-89,Sr-90 & Fe-55 Analysis for Liquid & Gaseous Effluents Completed by Offsite Vendor ML20006D6911990-02-0202 February 1990 Provides Alternative Design Solution to Dcrdr Implementation at Facilities.Simpler Design Devised,Using Eyelet Screw Inserted in Switch Nameplate Which Is Identical to Providing Caution Cards in Close Proximity to Switch Handle ML20006E1521990-01-31031 January 1990 Discusses Applicability of Safety Evaluations Prior to Manipulation of ECCS Valves,In Response to Violations Noted in Insp Repts 50-454/89-16 & 50-455/89-18.Nuclear Operations Directive Re ECCS Valve Positions Will Be Sent by 900415 ML19354E4451990-01-22022 January 1990 Submits Update on Status of RHR Sys Iconic Display at Facilities,Per Generic Ltr 88-17 Re Loss of Dhr.Computer Graphics Display Data in Real Time & Reflect Status of Refueling Water Level & RHR Pump Parameters ML20005G7161990-01-20020 January 1990 Forwards Rev 1 to Updated FSAR for Braidwood & Byron Units 1 & 2.Changes in Rev 1 Include Facility & Procedures Which Were in Effect as of 890610.W/o Encl ML20005G3831990-01-10010 January 1990 Suppls 891117 Application for Amends to Licenses NPF-37 & NPF-66,incorporating Further Clarification of Curve Applicability in Tech Spec Figure 3.4-2a,per 891229 Telcon W/Nrc ML20005G6431990-01-10010 January 1990 Responds to Generic Ltr 89-21 Re Implementation of USI Requirements,Consisting of Revised Page to 891128 Response, Moving SER Ref from USI A-10 to A-12 for Braidwood ML20006B8821990-01-10010 January 1990 Reissued Ltr Correcting Date of Util Ltr to NRC Which Forwarded Updated FSAR for Byron/Braidwood Plants from 881214 to 891214.W/o Updated FSARs ML20005E1911989-12-26026 December 1989 Forwards Revised Page 2 Correcting Plant Implementation Date for USI A-24 Requirements in Response to Generic Ltr 89-21 ML20005E1751989-12-22022 December 1989 Forwards Rev 29 to Security Plan.Rev Withheld (Ref 10CFR73.21) ML19332F6621989-12-14014 December 1989 Forwards Amend 12 to, Byron/Braidwood Stations Fire Protection Rept. Amend Reflects Changes to Facility & Procedures Effective 890630 1990-09-17
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' CoRMnonwealth h
'H-- Q One Fast Nabonel Plaza, Cruce0o. lilinois
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( / Address Reply to: Post Omco Box 767 V/ Ctucago,lunois 60000 0767 Y[ December 30, 1986
Mr.~ James M. Taylor,; Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission
' Washington, DC. 20555
Subject:
-Byron Station Unit 1 Proposed Civil Penalty EA 86-163
'NRC Docket No. 50-454 References (a): August 18, 1986 letter from
" ~
C.E.'.Norelius to Cordell Reed (b): November 18, 1986 letter from J.G. Keppler to J.J. O'Connor
Dear Mr. Taylor:
Reference (a) provided the results of an inspection at Byron Station between' July 21 and August 8, 1986. As a result of this inspection and further discussions durjng an enforcement conference on August 25, 1986, certain activities were found to be in violation of NRC requirements.
Reference (b) transmitted a. Notice of Violation and Proposed Imposition of Civil Penalty related to the violations identified in reference (a). a Attachment A of this letter contains Commonwealth Edison's response to tile Notice of Violation enclosed with roference (b). On December 17, 1986, Conunonwealth Edison was granted a 14-day extension on the due date for the response to the Notice of Violation and Proposed Imposition of Civil Penalty.
Commonwealth Edison believes the proposed civil penalty should have been mitigated completely. This is based not only on the discussion in Attachment B of this letter regarding the five factors in Section V.B of 10 CFR Part 2, Appendix C, but also on the following discussion of the NRC's enforcement discretion as it should be applied to this situation.
M_inimal Safety Sinnificance Commonwealth Edison believes the installation of the inoperable pressurizer safety valve presented minimal safety significance This should allow the NRC to exercise its enforcement discretion to completely mitigate the proposed civil penalty.
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The aggregated violations (A through C) involve the installation of
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one inoperable l pressurizer safety valve. There are three pressurizer safety 1 valves installed:in the plant. Their function is to prevent reactor coolant system pressure from exceeding.110% of system design pressure. . The design j
. pressure of the reactorLeoolant system is 2485 pois. Additionally, there are
.two: pressurizer. power operated relief valves installed.in the plant. Their functions.are to prevent' actuation of the reactor high-pressure trip during
-design transients and to limit undesirable openings of the pressurizer safety
, o valves. <
Under the. actual conditions that' existed during this event, it is
-clear that the possibility of overpressurizing the reactor coolant system was not present. Reactor coolant pressure could not be increased above 1750 psig because of,the lowered setpoint of the inoperable pressurizer safety valve.
Even if it was fortuitous that the inoperable pressurizer safety l valve'11fted at a-lower setpoint of 1750 psis, assuming the valve would rot actuato at any pressure and assuming a transient occurred which caused reactor coolant pressure to increase above normal operating pressure, the reactor
. coolant system was still adequately protected from overpressurization. This is bec6use the two pressurizer. power operated relief valves were operable during this event. :A review of FSAR table 5.4-16 indicates the pressurizer power operated relief valves together have the relief capacity of a
- pressurizer safety valve.
The reactor coolant system was protected from overpressurization While the inoperable pressurizer safety valve was installed. Therefore, Commonwealth Edison believes this event was of minimal safety significance and warrants WRC enforcement discretion to completely mitigate the proposed penalty.
Separate Violations Aanreasted f
l Violations A and C, the installation of an inoperable valve which was j.
!also not tested before installation, were the unavoidable consequences of
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. violation B, failure to properly control nonconforming equipment to prevent its inadvertent installation, since these two consequences (violations A and
(' C) were not separate, additional errors, the NRC did not have to consider these consequences as separate violations. The installation of an untested.
l linoperable valve did not result from a separate failure to follow procedures
- l. .for' testing the valve or determining its operability. Those tests and determinations had been performed for the valve which the Byron personnel believed they were installing. Thus, the NRC should exercise its discretion to recognize that the events underlying violations A and C were simply unavoidable consequences of violation B which does not warrant their treatment as independent violations.
With respect to violation D, its aggregation with the others is not appropriate. The specification of an incorrect tolerance was unrelated to the repair-related events in violations A through C. Violation D is related to the other violations only in the broadest sense that it was maintenance
.related. Such a generalized relationship between events does not justify its l
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aggregation.with~the other violations into one collective Severity Level III ,
problem.
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.The foregoing discussion provides another basis for the NRC to Lexercise'its_ enforcement dis:retion and completely mitigate the proposed penalty..
. Punitive Aspects of Proposed Enforcement Action
- ' Commonwealth Edison believes that its broad ranging response, both
~for the short and long term. warrant the NRC's exercise of discretion to minimize rather than maximize the violations associated with these events.
The prompt and extensive short term corrective actions did result in a partial mitigation of the penalty and, thus, will not be relied on further. The long
~ term corrective' actions, the broad look at all maintenance activities by the Institute for Nuclear Power Operations (INPO) and the establishment of a task .
~ force.to review the maintenance situation and develop a conduct of maintenance program all clearly demonstrate Cosmonwealth Edison's recognition of the need for disciplined control of maintenance activities and a commitment to such
. control. . In view of Conunonwealth Edison's commitments, the. NRC's imposition
.;.of a civil penalty would. add nothing to Commonwealth Edison's appreciation of the problem or determination to achieve its solution. Rather, the civil
, penalty would be simply a punitive fine which is inconsistent with Commonwealth Edison's response.
For all the reasons presented above and in Attachment B, Commonwealth Edison believes the proposed civil penalty for this event should be completely mitigated.
Please direct any questions regarding this matter to the Director of Nuclear Licensing.
Very truly yours,
/ A2r -
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L.
Bide L. Thomas Executive Vice President Attachments cc: oJ.C." Keppler-Region III J
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SUBSCRIBRD'and SWORN to before me'thisifo % ay l of X]O r :m /vn, 1986 d Y ko +M)
Nota Public I
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ATTACHMENT A
- Violations A. B a'nd C JA2 ? Technical Specification 3.4.2.2 requires that all' Pressurizer Code Safety
- Valves.be operable in Modes, 1, 2, and 3 with a lift setting of 2485 psig t'l percent, and that with.one Pressurizer Code' Safety Valve inoperable, either. restore-the inoperable valve to Operable status within 15 minutes or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least Hot Shutdown
-within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Technical l Specification 3.0.4 requires that entry into an Operational Mode shall not be made unless the conditions for the Limiting condition for Operation'are met without reliance on the provisions contained in the Action requirements.
- Contrary to the above, on July 17, 1986, Unit 1 entered Mode 3 with Pressurizer Code Safety Valve, Serial No. N56964-00-0031 inoperable in
.that the valve dise was not installed and the lift setting was not 2485 psig 1 1 percent. In addition, on July 17-18, 1986 while in Mode 3, actions were not taken to restore valve No. N56964-00-0031 to an operable status within 15 minutes or be in at least hot shutdown within the l; following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
B. 10'CFR Part 50, Appendix B, Celtet*lon IV, Nonconforming Materials, Parts, or Components, as implemented by ihe Commonwealth Edison Quality Assurance Manual, Quality Requirement 15.0, requires that measures shall be established to control materials, parts, or components, which do not conform to requirements in order to prevent their inadvertent use or installation.- These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations.
Contrary to the above, in October 1985, the licensee's program did not assure the . control of nonconfoaming materials in that af ter partial g
maintenance on Pressurizer Code, Safety Valve, Serial No. N56964-00-0031, was performed, the valve was not properly identified, documented, or segregated and on July 6, 1986 the valve was inadvertently installed.
C. . Technical. Specification 4.0.5.a requires that inservice inspection of ASME Code Class 1, 2, and 3 components and ASME Code Class 1, 2 and 3 pumps and valves shall be performed in'accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code and applicable Addenda as required by 10 CFR 50.55a(g), 'except where specific written relief has been granted by the Commission.
The applicable ASME B&PV Code is the 1980 Edition, Winter 1981 Addenda, Which in Section II, Subsection IWV-3200 requires that when a valve or its control system has been replaced or repaired or has undergone maintenance that could affect its performance, and prior to the time it is returned to
- - service, it shall be tested to demonstrate that the performance parameters which could be affected by the replacement, repair or maintenance are
' within acceptable limits.
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Contrary to the above, on July 6, 1986 Pressurizer Code Safety Valve
~ Serial No. W56964-00-0031, an ASME B&PV Code Class 1 valve, was installed
~ and placed into; service after'it had undergone maintenance that could affect its performance without any testing being performed to demonstrate that-it would perform acceptably.
4dmission of Alleaed Violations We have reviewed the inspector's. account of the events and find it to
-be' accurate. We admit that our measures to control a nonconforming
<pressuriser safety valve (serial no. N56964-00-0031) did not prevent the
- inadvertent installation:of the valve.' As a result of this, we admit: a
' pressurizer safety valve (serial no. N56964-00-0031) was returned to service without being tested to demonstrate its performance parameters were within Lacceptable' limits; Technical Specification 3.0.4. was not met because Unit 1 entered Mode'3 without the limiting condition for operation of Technical ^
Specification 3.4.2.2 being satisfied and; the action statement of Technical Specification 3.4.2.2 for an inoperable pressurizer safety valve was not met.
Reason for Violations The violations are attributed to documentation for a pressurizer safety valve (serial no. N56964-00-0031) reflecting the test information for another pressurizer safety valve.
- Corrective Action Taken and Results Achieved Upon discovery of.the inoperable pressurizer safety valve, Unit I was placed in cold shutdown and the inoperable valve was replaced.
Corrective Action to Avoid Further Violation The following actions have been taken:
- Meetings were held with appropriate departments stressing that documentation must match the equipment being tested or worked on.
The meetings were completed August 6, 1986.
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- The safety valve bench test procedure was revised to more clearly
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indicate equipment identifications. The procedure revision was approved for use on August 22, 1986.
- Segregation cages have been constructed for storage of contaminated equipment. This was completed November 18, 1986.
- The Conduct of Maintenance Task Force implemented a program to review the control of other 'like' components being repaired. A work practice was established in the maintenance department that only allows one component to be worked on at a time in each segregated
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area. Additionally..the stores department has been-directed to accept into their control system reworked spare parts that are not to be inunediately installed in the plant. These programs were
-implemented in September, 1986 and will be evaluated regarding their effectiveness during the first' refueling outage for Unit 1.
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- _A segregated storage area for contaminated spare parts was established in the auxiliary building. This was completed October 1, 1986.
-- An INPO assessment of maintenance activities was requested. The assessment was completed August 15, 1986 and the recommendations are being reviewed and acted upon appropriately.
- Date ilhen Full Compliance was Achieved Unit .1 was plued in cold shutdown on July 18, 1986. The inoperable
- pressurizar safety valve was removed and replaced on July 19, 1986. The replacement valve was tested prior to its installation. The majority of the enhanced measures to control maintenance activities and nonconforming parts were implemented by November 18, 1986. Some of the INPO reconnendations are still being considered.
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Violation D v
10fCFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.-as implemented by the Cownonwealth Edison Quality Assurance Manual, Quality Requirement 5.0, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a
. type' appropriate'to the circumstances and shall be accomplished in accordance
.with these instructions, procedures, or drawings. Instructions, procedures,
'or drawings'shsil include appropriate quantitative or qualitative acceptance criteria.for determining that important activities have been satisfactorily accomplished.
Contrary to the above, the licensee's program failed to assure that
' appropriate' quantitative acceptance criteria were specified in instructions or procedures. Nuclear Werk Request B31703, used on July 19, 1986 to test the lift setting of Pressurizer. Code Safety Valves 1RY8310A and 1RY8010C, t
. referenced Maintenance Procedure BNP 3100-9, R3 vision 1, which specified a tolerance of i 3 perce It instead of i i percent as required by technical specifications. As a result Pressurizer Code Safety Valve 1RY8010C was set with a tolerance greater than i i percent.
Admission of the Allemed Violation We have reviewed the inspector's account of the event and find it to be. accurate. We admit that Maintenance Procedure BNP 3100-9, Revision 1 did not contain appropriate quantitative acceptunce criteria for the tolerance on the lift setting for pressurizar safety valves.
Reason for Violation since the maintenance procedure did not contain a pre-determined tolerance for the lift setting of the pressurizer safety valves, the tolerrnce specified in the vendor manual for.the valves was used. The vendor manual specified a tolerance of i 3 percent.
Corrective Action Taken and Results Achieved Upon discovery of the wrong tolerance being used in the maintenance procedure, a review of the valve lift setting test results was performed. The lift setting for valve IRY8010A was found to be within the i 1 percent tolerence specified in the Technical specifications. This was determined from a review of the pre-calibration and post-calibration data on the test gauge ,
which showed the instrument was reading high. Valve IRY8010C was removed from '
the reactor coolant system and ratested to meet the i i percent technical j specification tolerance.
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' Corrective Action to Avoid Purther Violation The following maintenance procedures were developed which contain specific setpoints and tolerances for safety and relief valves which are listed in the Technical specifications:
BMP 3120-1 pressurizer safety valves BMP 3119-2 RHR relief valves BMP 3114-12 main steam safety valves
.Date When Full Compliance was Achieved BMP 3120-1 was approved for use on August 22, 1986. BMP 3119-2 and BMP 3114-12 were approved for use on December 11, 1986.
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y ATTACHMENT B
'Section V(B) of 10 CFR Part 2, Appendix C authorizes the Commission
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e .to mitigate civil penalties and enumerates the mitigation factors which will
.be considered. These factors are addressed below and are shown to warrant
. full. mitigation of the proposed penalty.
prompt Identification and Reporting
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" Reduction of up to :50% of the base civil penalty may be given when a
' licensee identifies the violation and promptly reports the violation to the
- NBC . . ...No consideration will be given to this factor if the licensee does
~not take immediate action to correct the problem upon discovery". (10 CFR Part 2, Appendix C Note V.B.1). Commonwealth Edison took immediate corrective action upon discovering that'an. inoperable valve had been installed inadvertently. Therefore, mitigation is available here for prompt Lidentification~and reporting of the violation. Commonwealth Edison believes
.that it promptly identified and reported the violation. The NRC staff disagrees because Commonwealth Edison became aware of the problem only after the valve actuated, as opposed to when it was installed. While this is clearly correct, it does not preclude mitigation when all the factors identified by the Commission are considered.
"In weighing [ prompt identification and reporting), consideration
.will be given to, among other things, the length of time the violation existed prior to discovery, the opportunity avellable to discover the violation, the ease of discoveey and the promptness and completeness of any required report" (10 CFR part 2, Appendix C Note, V.B.1). Commonwealth Edison believes the NRC t
staff considered only the first factor -- the length of time the violation existed prior to discovery.
The gravamen of Violation A was that the valve was not operable when Mode 3 was entered. Thus, Violation A actually occurred when Mode 3 was entered with an inoperable valve, and not when the valve was actually installed. Accordingly, Violation A was discovered almost immediately after it occurred. Similarly, the record shows that Violation D was discovered one day after-it occurred. This leaves only Violatiors B and C (failure to adequately control nonconforming materials and failure to test a repaired valve prior to its installation) as the only violations which went undiscovered for any length of time. However, these two violations should not be considered as separate, cumulative events because Violation C was an unavoidable consequence of Violation B. The valve which Commonwealth Edison believed it had installed had been tested. Under these circumstances, the length of time for which the violatiets went undiscovered does not weigh heavily against mitigation.
Violations A through C all resulted from a mixup of two valves, one ;
of which was internally incomplete. Once the two valves were interchenged, there was no opportunity to discover that fact until the incomplete valve actuated. It was essentially impossible to discover the mixup until Mode 3 was entered and reactor coolant pressure increased. Therefore, Violations B and C went undiscovered for the minimum time possible under the circumstances.
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n Finally, Commonwealth Edison provided the URC with complete reports of the violations. ,
For all these reasona, commonwealth Edison believes that consideration of all the timeliness factors in the Commission's Enforcement policy. supports the full 50% mitigation for prompt identification and reporting.
Corrective Actions Because the NRC Staff has recognized this factor to the fullest extent possible, no further discussion is warranted.
past performance Prior good performance in the general area of concern permits the reduction of a civil penalty by up to 100% of the base value. Byron Station has had a good record in this general area of concern since operation began approximately one and one-half years prior to this event. Although a
.long-term record of performance has yet to be created, the record established thus far in the maintenance area warrants an additional degree of mitigation for this factor.
Prior Notice Byron has not received any earlier notices in this general area.
Multiple Occurrences There have not been any multiple occurrences in this general area at Byron.
Conclusion The foregoing discussion of the mitigation factors in Section V(B) of 10 CFR Part 2 Appendix C shows that full mitigation of the proposed civil penalty is warranted.
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