ML20073H325
| ML20073H325 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/29/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9105070068 | |
| Download: ML20073H325 (4) | |
Text
Ctmm:nwealth Edistn 6
+*
O. - 1400 Opus Place C 7' Downste Grove, Illinois 60515
(]
April 29,1991
- Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Rill Glen Ellyn, ll 60137 P
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-454/91007: 50 455/91007 4
NEKLRocheLNosJi0-45Al910DLaniS0-455!910.07
Dear Mr. Davis:
Enclosed is Commonwealth Edison Company's (CECO) response to the subject Notice of Violation (NOV) which was transmitted with the referenced letter and Ins:>ection Report. The NOV cited one Level IV violation regarding three examples of
- f all ng to follow administrative procedures.
CECO understands the significance of the events, the need for effective
- corrective actions to prevent recurrence and has considered these in developing -
actions in response to the cited violation.
4 If your staff has any questions or comments concerning this letter, please refer them to Perry Barnes, Compliance Supervisor at (708) 515 7278.
Very truly yours,
/
..Kpvach Nuclear Lic6tfsing Manager Enclosure cc:
A.H. Hsia-NRR r){h~-
i W.J. Kropp-Byro'n Document Control Desk NRR l-I 9105070068 91o429 DR ADoCK 0500 4
.Pj.B/scl:lD867:1 APR 3o 39;
- d util 69
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-454/91007 and 50 455/91007 VIOLATION 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison's Quality Requirement 5.0, states that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions and procedures.
BAP 100 7, Revision 4, " Overtime Guidelines for Personnel That Perform Safety Related Functions," paragraph C5.b states that the following overtime guideilnes shall be followed: b. An individual should not be permitted to work...more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period. Paragraph C6 and C8. further state that deviations shall be approved by the Station Manager or his designee in accordance with BAP 100 7T1,
" Overtime Deviation Authorization," and after the fact, approvals should be obtained by the following normal work day or as soon as oractical and insure BAP 100 7T1 is completed through Step 6 (Department Heac Approval),
a.
Contrary to the above, a Fuel Handling Foremar. performing duties as a Senior Reactor Oaerator Limited (SROL) exceeded the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> guidelines by 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> the wee < of September 20-26,1990, without authorization documented on BAP 100 7T1 " Overtime Deviation Authorization."
BAP 330 5, Revision 4, " Lock and Key Control," paragraph C 4 states that a Key Control Log shall be maintained in the Shift Engineer's office. Any entry will be made in the lo g whenever a key from the key control cabinet in the Shift Engineer's office is checkec out. Upon retum of the Key, the date and time returned will be completed, b.
Contrary to the above, on February 6,1991, key #451 for the Unit 2 Train A Safeguards Test Cabinet panel was found in the door without an entry in the key controllog authorizing the key for checkout. Also, key #489/160 was found in the key control cabinet, without an entry in the key control log for the return of the key.
BAP 1100-3, Revision 8," Fire Protection Systems, Fire Rated Assemblies, Radiation, Ventilation and Flood Seal Impairments," Paragraph F.1.c, required that a Fire Protection impairment Permit (FPlP) to be initiated by the Supervisor in charge of the
- work, c.
Contrary to the above, on January 21,1991, a FPlP was not initiated for repairs to the 2B Emergency Diesel Generator door. As a re uit, when the door was removed for the re 3 airs the licensee f ailed to either post a continuous fire watch or veri'y operability of fire detectors on at least one side of the door within one hour.
This is a Severity Level IV violation (Supplement 1). (50-454/1007 01 (DRP));
50-455/91007-01(DRP)).
PLB/scl:lD867:2
ATIACBMENL(continued) y BESEQNSE Commonwealth Edison acknowledges the violation stated above.
General.GortactireActionslaken toAvold.EurttleLWelation Byron Station will conduct a review of relevant performance indicators including Deviation Reports, Licensee Event Reports and Notices of Violation to determine whether a trend in procedural adherence can be identified. The results of this review will be communicated to Station staff and appropriate action taken as necessary. This review and subsequent action is expected to be completed by August 30,1991.
A.
BAP 100 7, Revision 4, " Overtime Guldelines for Personnel That Perform Safety Related Functions:
Corte.ctizeActionslaken_andEesultsAcbleve.d A memo was issued to all personnel on November 21,1990, stating...... In the interim period, all departments are expected to comply with the current BAP 100 7 guidelines regardless whether or not the activities being performed are safety related......
CorrentlyeActionslahurLloAvold_EuttheLVJolation On April 22,1991, the Production Superintendent held a meeting with schedulers / timekeepers from all departments. The requirements of Generic Letter 8212 and BAP 100-7 were reviewed. Adherence to BAP 100-7 was reemphasized.
Additionally, "before the fact" authorization with appropriate signatures is required prior to exceeding Generic Letter 82-12 overtime guidel nes.
The Corporate Directive, NOD OA.13, Overtime Guidelines, is currently in revision. On April 26,1991 a Station Overtime Policy was issued by the Byron Station Manager which clarifies the requirements of Generic Letter 8212. The Station Overtime Policy will be followed until NOD OA.13, Rev. 2, is issued for use. At that time the Station Overtime Policy will be reviewed to ensure compliance.
D;tteEben_EulLGomplianceAch!eved Full compliance has been achieved.
B.
BAP 330 5, Revision 4. " Lock and Key Control":
R.orrectlye_ActionlakeILandEOSullSAchie.Yed l
L lipon notification the Shift Engineer immediately dispatched an operator to correct the loentified deficiencies. The Auxiliary A Safeguards Test Cabinet panel (2PA11J) was inspected and then properly locked. The other cabinets located in the Auxillary Electric room were also verifiec to be properly locked.
PLB/scl:lD867:3
AIIACtlMENL(continued)
Corientitelclionslaken to Avald_EuribeLVJolation Te'iigate Memo #39 was issued to the Shift Engineers instructing them to discuss the rcquirements of 3 roper key control with their shift. These discussionc were completed on April 22,199' In addition to the Weekly Key Audit, OBOS XKK-W1, the Operating Engineers w!H review the key control,ogs monthly for six months, beginning April 29,1991, to heighten awareness of the key log program.
Qate_When.EulLComplianceAchlered Full compilance has been achieved.
C.
BAP 1100-3 Revision 8," Fire Protection Systems, Fire Rated Assemblies, Radiation, Ventilation and Flood Seal impairments":
OstractiteAcilons Taken tolyold_EuribeLY1olation
= The Fire Marshal conducted training sessions from February 4,1991 to March 15,1991 with Fire Watch inspectors, Site Engineering and Construction, Pope supervisors and Maintenance personnel to review the rec ulrements and the use of the fire protection impairment permits as required by BAP 100-3.
Rate When.EulLQompUanceAchieved Full compliance has been achieved o
- PLB/scl:lD867:4
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