IR 05000454/1985056

Safety Insp Rept 50-454/85-56 on 851202-13.Violation Noted: Failure to Write Adequate Surveillance/Calibr Procedure. Violation Noted in Insp Rept 50-454/85-42 Re Exceeding Reactor Core Licensed Thermal Power Rating Retracted

ML20197J591
Person / Time
Site:	Byron
Issue date:	12/30/1985
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197J553	List: IR 05000454/1985042 IR 05000454/1985056 ML20197J575
References
50-454-85-56, NUDOCS 8605200083
Download: ML20197J591 (3)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 5'0-454/85056(DRP)

Docket No. 50-454 License No. NPF-37 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 1

. Inspection At: Byron Station, Byron, IL Inspection Conducted: December 2-13, 1985 Inspectors: J. M. Hinds , J P. G. Brochman RFu)vwlek frr 4/yo/rr Approved By: W. L. Forney, Chief Reactor Projects Section IA Date '

Inspection Sumary

? Inspection on December 2-13, 1985 (Report No. 50-454/85056(DRP))

Areas Inspected: Special unannounced safety inspection by the resident inspectors to review supplemental information presented at the Enforcement Conference for Inspection Report 454/85042(DRP) . The inspection consisted of 14 inspector-hours onsite by two NRC inspectors including five inspector-hours during off-shift Results: This report identified one violation of NRC requirements: (failure to write an adequate surveillance / calibration procedure - Paragraph 3). This violation is considered to be of more than minor safety significance which had the potential to affect the public's health and safety. As a result of the supplemental infomation provided by the licensee, the apparent violation (454/85042-07(DRP)) identified in Inspection Report 454/85042(DRP) is no longer considered to be a violation and it is hereby retracte g60520oos3e60506 R

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DETAILS Persons Contacted Commonwealth Edison Company (Ceco)

• R. Querio, Station Manager

• Pleniewicz, Production Superintendent

• R. Ward, Services Superintendent T. Joyce, Assistant Superintendent, Technical Services Burkamper, Chernick,

• Quality Assurance Compliance Supervisor Supervisor,

• W.Operating C. Kilbride, Technical Staff P. Reister, Technical Staff M. Snow, Technical Staff

• J. Langan, Compliance Staff

• Britton, Quality Assurance Staff The inspectors also contacted and interviewed other licensee and contractor personnel during the course of this inspectio * Denotes those present during the exit interview on December , 198 . General by the licensee at an Enforcement Conference discuss items identified in Inspection Report N , 1985, to held on Nove 9 454/85042(DRP) This supplementary information related to exceeding the Reactor Core Thermal

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Power limit and (ECCS) Subsystems operating the unit with both Emergency Core Cooling System inoperabl .

Exceeding the Reactor Core Thermal Power Limit (Closed) Apparent Violation (454/85042-07(DRP)):

Subsequent to the issuance of Inspection Reportexceeding the Reac 454/85042 the licensee's Nuclear Instruments (NI) were set conservatively This conserva-by 0.8%. staff r tive error was established by the review of a Operational Demonstration 2.80.49, period "NSSS as this event.Acceptance Test" which was performed during the same time accurate, instrumentation and when the results of the test were co to the Byron Technical Specification Surveillance 1805 3.1.1-2 higher than the Test 2.80.49." Calorimetric Calculation Surveillances" the BOS c .

the use ofof the performance the80 less accurate, normally installed instrumentation in theThis and verified that reactor core power was maintained less than 100.0%T cveraged over an eight hour shift during this time perio Consequently, cnd it is hereby retracted. Region III no longer considers this to be a violation (4

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However, Technical Specification 6.8.1.a states, in part: " Written procedures shall be established. . . covering the activities referenced. . .

for. . .the applicable procedures as recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978." Regulatory Guide 1.33, Revision 2, Appendix A, Section 8.b(1)(w) requires that specific procedures for Heat Balance - Flux Monitor Calibrations should be writte .1.1-2 implements this requiremen Appendix B to 10 CFR 50 requires activities affecting quality to be prescribed by procedures appropriate to the circumstance The omission of the Feedwater Tempering Line Flowrate from the heat balance equation resulted in the NI being adjusted to read less than the actual reactor core thermal power. This nonconservative error had the potential to cause serious consequences. This inadequate procedure was used from February 2 through August 6,1985, while the unit was in Modes 1 or The failure to write an adequate surveillance procedure by not including feedwater tempering line flowrate in IBOS 3.1.1-2 is a violation of Technical Specification 6.8.1.a (454/85056-01(DRP)). Fortuitously, this failure did not result in exceeding Facility Operating License limit on Reactor Core Thermal Powe . Operating the Unit With Both ECCS Subsystems Inoperable (0 pen) Appaia Violation (454/85042-01(DRP)): Operating the unit with both ECCS subsystems inoperable and the failure to follow Technical Specifications with both subsystems inoperable. The licensee presented supplemental information at the Enforcement Conference regarding the length of time the valves ISI8809A, 1518809B, 1RH8716A, or 1RH8716B were shut during the performance of the RHR pump surveillance and both subsystems were inoperable. The inspector reviewed those records provided by the licensee and verified that the length of time the valves were shut was less than the information originally provided to the inspector indicated. The dates and the old and revised times are listed below:

Date Time Shut Revised Time Shut i

l March 6, 1985 13.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 1.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> l March 6, 1985 (1) 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> March 7, 1985 13.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> l 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

, April 19, 1985 30.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> i

April 20, 1985 (1) 3.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> April 23, 1985 6.3. hours 1.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> May 30, 1985 30.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 13.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> May 31, 1985 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 9.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

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, July 24, 1985 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 5.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> l July 24, 1985 1.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> (2)

i July 24, 1985 6.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 2.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />

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July 25, 1985 (1) 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> July 23,1985 (3) 6.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

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Notes:

(1) The surveillance was stopped and the valves were opened. The surveillance was then re-entered and the valves were close The

" revised time shut" valves reflects the credit for opening the valves while the surveillance was stoppe (2) The valves remained closed even though the surveillance was stoppe (3) During a review of the records the inspector identified an additional 6.4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period where the valves were shut. However, on this occasion the valves were shut in an attempt to identify excess Reactor Coolant System leakage; rather than in the performance of a surveillance procedur With both ECCS subsystems inoperable, Technical Specification 3. required that within one hour action should have been initiated to place the unit in Hot Standby (Mode 3) within the next six hours and the unit should have been placed in Hot Shutdown (Mode 4) within the following six hours. Based on this new information licensee personnel failed: (1) to initiate action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on the following dates:

March 6, 7; April 19, 20, 23; May 30, 31; and July 23, 24 (twice);

(2) to place the unit in Mode 3 within the next six hours on the following dates: May 30, 31; and (3) to place the unit in Mode 4 within the following six hours on the following date: May 3 This information will be used to assist in the determination of the Enforcement Actions for the apparent violations described in Inspection Report (454/85042(DRP)). Exit Interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on December 13,1985. The inspectors summarized the purpose and scope of the inspection and the findings. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar .

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