BYRON 2015-0097, Reply to a Notice of Violation; 05000454/2015008-09; 05000455/2015008-09

Reply to a Notice of Violation;05000454/2015008-09; 05000455/2015008-09

ML15232A486
Person / Time
Site:	Byron
Issue date:	08/20/2015
From:	Kearney F Exelon Generation Co
To:	Document Control Desk, NRC/RGN-III
References
1.10.0101 (1D.101), BYRON 2015-0097, IR 2015008
Download: ML15232A486 (4)

Text

Byron Generating Station Exeton Generation 4450 North German Church Rd Byron, IL 61010-9794 www.exeloncorp.com August 20, 2015 LTR: BYRON 2015-0097 File: 1.10.0101 (1D.101)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Reply to a Notice of Violation;05000454/2015008-09; 05000455/2015008-09

Reference:

Letter from Christine A. Lipa (U.S. NRC) to Bryan C. Hanson (Exelon Generation Company, LLC), Byron Station, Units 1 and 2, NRC Component Design Basis Inspection Report 05000454/201 5008; 05000455/2015008 and Notice of Violation, dated July 21, 2015.

In the referenced letter, based on the results of an inspection completed on June 16, 2015, the NRC concluded that Byron Station was in violation of 10 CFR 50, Appendix B, Criterion XVI Corrective Action, which requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

The NRC requested Exelon Generation Company, LLC (EGC) to respond to the Notice of Violation within 30 days of the date of the referenced letter. EGC does not contest the violation. to this letter contains EGCs response to the Notice of Violation. This letter contains a new regulatory commitment which is identified in Attachment 2.

If you have any questions regarding this reply, please contact Mr. Douglas Spitzer, Regulatory Assurance Manager, at (815) 406-2800.

Respectful Site Vice President Byron Generating Station FAK/AC/dd r Attachments 1. Reply to Notice of Violation

2. Summary of Regulatory Commitments cc: Regional Administrator NRC Region Ill NRC Senior Resident Inspector Byron Station

AUACHMENT 1 Reply to Notice of Violation In a letter from Christine A Lipa f U.S. NRC) to Bryan C. Hanson (Exelon Generation Company, LLC), dated July 21, 2015, the NRC issued a Notice of Violation. The violation of NRC requirements was identified during an NRC inspection completed on May 22, 2015. The violation is repeated below:

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, from June 15, 2012, to May 22, 2015, the licensee failed to correct a condition adverse to quality (CAQ). Specifically, on June 15, 2012, the NRC issued NCV 05000454/2012007-05; 05000455/2012007-05 for the failure to provide means to detect and isolate a leak in the ECCS within 30 minutes for Byron Station, Units 1 and 2, as described in UFSAR Section 6.3.2.5, which is a CAQ. As of May 22, 2015, the licensee had not corrected the CAQ in a reasonable period. Instead, the licensee created action tracking items to develop a plan to correct the CAQ, and the associated due date was extended at least eight times.

This violation is associated with a Green Significance Determination Process finding.

Response

1) Reason for the violation Byron Station received a NRC violation in the 2012 CDBI as documented in Issue Report fIR) 1398434. A Corrective Action (CA) was created from IR 1378257 documenting the NRCs initial question. However, the direction of the CA did not resolve the issue and was downgraded to a lower level action tracking item. The action was extended several times with little progress made. In February of 2015, Station Nuclear Oversight (NOS) identified the lack of CA and lack of progress which prompted the creation of a new CA. During the 2015 CDBI, the NRC identified the new CA had the same deficiency as the 2012 CA; i.e., it did not resolve the issue.

The reason for the finding is the Corrective Actions created in 2012 and again in 2015 did not meet the SMARTER criteria (Specific, Measurable, Accountable, Reasonable, Timely, Effective, Reviewed) as documented in Exelon Procedure Pl-AA-125, Corrective Action Program (CAP)

Procedure. The CA created from the 2012 finding stated to develop a plan to address the issue. The CA should have been more specific by stating, revise the UFSAR to match the plants leak detection capabilities or modify the plants leak detection capabilities to match the UFSAR. A contributing reason for the violation was the lack of understanding of the risk significance of the action and the lack of questioning attitude when the actions were created.

2) Corrective steps that have been taken and the results achieved Byron Station Operating Procedures 1/2BEP ES-i .3, Transfer to Cold Leg Recirculation, were revised to add a caution reinforcing the importance of the ESF to non-ESF cross-tie in light of

ATtACHMENT 1 Reply to Notice of Violation the need to identify and isolate ECCS leakage into the Auxiliary Building while in the recirculation mode.

The station has also performed an extent of condition to determine whether any other violations have been tracked inappropriately. No other issues were found.

3) Corrective stejs that will be taken Byron Station has initiated a revision to the UFSAR under CA 02454767-05 to reflect the plants existing leak detection capabilities. Two calculations and the UFSAR change package have been prepared, reviewed and approved. A 50.59 Evaluation and engineering change have been prepared, reviewed and are awaiting approval. One additional calculation is currently being prepared to support this CA.

4) Date when full compliance will be achieved Full compliance will be achieved with implementation of approval of UFSAR change package (DRP)16-018 and supporting documents by November 6, 2015.

ATTACHMENT 2 Summary of Regulatory Commitments The following table identifies those actions committed to by Exelon Generation Company. LLC, (EGC) for the Byron Station in this submittal. Any other actions discussed in the submittal represent intended or planned actions by EGO, are described only for information, and are not regulatory commitments.

Commitment Committed Date or Commitment Type Outage One-Time Action Programmatic (YES/NO) (YES/NO)

Exelon Generation November 6, 2015 Yes No Company, LLC (EGC) will complete the UFSAR change and supporting documents to reflect the plants existing leak detection capabilities and provide to the NRC resident.