ML20070G373

Responds to NRC Re Violations Noted in Insp Rept 50-454/94-11 & 50-455/94-11.Corrective Actions:Design/ Licensing Basis Lesson Plans Will Be Revised & Expanded

ML20070G373
Person / Time
Site:	Byron
Issue date:	07/14/1994
From:	Graesser K COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9407200089
Download: ML20070G373 (4)

Text

. - . .

O h C:mm::nw cith Edison

/ Byron Nuclear Station

( O ~J e4450 North German Church Road (j Byron, Illinois 61010 July 14,1994 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk

Subject:

Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation inspection Report Nos. 50-454/94011; 50-455/94011 NRC Docket Numbers 50-454,50-455

Reference:

John A. Zwolinski letter to Mr. Wallace, dated June 17,1994, transmitting NRC Inspection Report 50-454/94011; 50-455/94011 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) 50-454/455-94011-01(DRP) which was transmitted with the referenced letter and Inspection Report. The NOV cited a Severity Level IV violation requiring a written response. Comed's response is provided in the attachment.

If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.

S ly j K.

LG raesser Site Vice President Byron Nuclear Power Station Attachment cc: J. B. Martin, NRC Regional Adm;nistrator - Rlli George Dick, Project Manager - NRR H. Peterson, Senior Resident inspector, Byron 94o7200089 940714 4 ADOCK 0500 ,

{DR

i ',

l~ .

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 454/94011:455/94011 Violation (454(455)/94011-01)

During an NRC specialinspection conducted from April 19 through May 31,1994, a violation of NRC requirements was identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1993), the violation is listed below:

l l 10 CFR Part 50.50, " Changes, Tests, and Experiments," provides that the i licensee may not make changes in the facility as described in the Safety Analysis Report, without prior Commission approval, unless a documented safety evaluation has been performed to ensure the change does not constitute an unreviewed safety question.

The Byron Updated Final Safety Analysis Report (UFSAR), sections 3.6, 3.11, and 10.4.5 describes the facility design to include sealed watertight enclosures between the main steam tunnel and the auxiliary feedwater tunnel to ensure that equipment (valves and cabling) in the latter are not exposed to the effects of flooding or of high energy line breaks.

l l Contrary to the above, as of March 29,1994, the auxiliary feedwater tunnel watertight closures were not maintained sealed as designed but were i routinely opened on numerous occasions and for various lengths of time, dating from at least 1990, and no documented safety evaluation was performed to ensure the change did not constitute an unreviewed safety i question.

This is a Severity Level IV violation (Supplement 1).

l

! 1 1

1

o .

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 454/94011:455/94011 REASON FOR THE VIOLATION:

A Problem Identification Form (PlF) was initiated on 3/14/94 which questioned having the Flood Seal Opening (FSO) plates removed for extended periods of time.

During the evaluation of this PIF, it was identified that Byron Station's Safety Evaluation Report (SER) stated that these FSO plates be installed during plant operations.

The original procedure, BAP 399-20 " Control of Water Tight Doors and Flood Seal i Openings", was written and 50.59 evaluation was performed in 1985 to establish administrative control on flood barriers. The proceduralization of the flood seal removal was thought to enhance control of a previously uncontrolled barrier. The ,

removal of the FSO plates was not identified as a change to the facility or a  !

departure from licensing basis. Additionally, subsequent administrative procedure changes (BAP 399-20, BAP 380-3, and BAP 1100-3) and 50.59 evaluations did not identify the overall procedure as a change to the facility.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

Immediate corrective actions included verifying that the Auxiliary Feedwater (AF) tunnel FSO plates were in place on both units and requiring these FSO plates to remain in place until this issue has been evaluated and acceptable resolution achieved.

Byron Station Support Engineering has performed a review of the equipment located within the AF tunnel. The safety related electrical cables (not associated with the AF013 valves) located in the AF tunnel have no terminations in the AF tunnel. The electrical boxes located in the AF tunnel for these safety related cables are only " pull boxes" with no terminations. It can be concluded that since the cables are qualified for use in the MS tunnel, they will not be affected by the removal of the AF flood seals since the worst case environment in the AF tunnel is no different than that experienced by the same cable in the MS tunnel for which the cable is already qualified. Therefore, there is no safety significance in regards to the electrical cables located within the AF tunnel when exposed to the MS tunnel environment.

i l .

The AF013 valves located in the AF tunnel are considered containment isolation vaives. Therefore, a 4 hr LCOAR will be entered whenever access is required to the tunnel. These actions will remain in effect until a full review can be completed j on a longer term option.

l l

l CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:

l Byron has conducted a review of the design basis training currently taught to engineering personnel, as a result of a commitment to a previous violation. From this review weaknesses have been identified. Changes have been made in the 50.59 program that could prevent this from occurring. These changes have been in place since 1991. The training on this issue with regards to design / licensing basis will be completed in 1994. NTS# 454-100-94 31101-01 will track l completion of this training. The design / licensing basis lesson plans will be revised and expanded into the engineering (Site and System) continuing training program for 1995. NTS# 454-100-94-01101-02 will track completion of this training.

The Station Managers of the six Comed nuclear stations have previously committed to review enhancements to the common process of how operability assessments are performed by Commonwealth Edison. In order to improve the process, the following has been reviewed: identifying issues on Problem Identification Forms (PIFs) for review; relationships between departments at the i

station and between stations in determining operability; documenting the review process; clarifying criteria for when the issue or concern threshold is reached; better defining operability relative to the license basis; and re-evaluation of the requirements identified in Generic Letter 91-18. This review is complete.

l Procedure changes and training on the enhanced operability assessment procedure will be completed by 9/30/94. NTS# 454-100-94-01101-03 will track completion of procedure changes and training.

! Byron Station will revise BAP 1100-3 which currently controls flood seal openings l to ensure appropriate actions are taken when flood seals are removed.

j NTS# 454-100-94-01101-04 will track completion of this procedure revision.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

4 Full compliance was achieved on 3/29/94 when all FSO plates were verified installed.