IR 05000454/1987011
| ML20213A403 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/20/1987 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20213A405 | List: |
| References | |
| NUDOCS 8704270542 | |
| Download: ML20213A403 (3) | |
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APR 2 01987
Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago,'IL '60690 Gentlemen:
This refers to our letter dated March 24, 1987, which forwarded the results of a special safety inspection conducted to review the circumstances surrounding the inoperability of redundant trains of two safety related systems (NRC Inspection Reports 454/87011(DRP)and 455/87010(DRP)). The letter'also stated that we were evaluating enforcement actions.
The evaluation has been completed and the NRC staff has determined that certain of your activities appear to be in violation of NRC requirements, as specified in the enclosed Notice. The inspection found that the actions required by Technical Specification 3.0.3 had not been met when two of three trains of the Non-Accessible Area Exhaust Filter plenums of the Auxiliary Building Ventilation System were inoperable for approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and both trains of the Essential Service (SX) Makeup pumps were inoperable for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
These two violations could be considered a Severity Level III problem because they both involved operation of Unit 2 in a condition beyond those specified in the Technical Specifications (redundant trains of safety related equipment simultaneously inoperable) and the corrective actions following an apparently similar event in December 1986, [both trains of the Emergency Core Cooling System (ECCS) being simultaneously inoperable], failing to prevent these events.
However, following our review of additional information you provided at an Enforcement Conference held in the Region III office on April-7,1987, between Mr. L. O. DelGeorge and members of your staff and Mr. C. J. Paperiello and members of his staff, we believe that a basis exists to categorize these violations at other than Severity Level III. During the time the A and B non-accessible area filter plenums were inoperable, the C non-accessible area O/04270542 870420
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A?R 201987 filter plenum was operable (50% capacity); additionally, you provided to the staff an analysis which demonstrates that offsite doses and doses to control'
room' personnel can be maintained within the limits of 10 CFR 100 and 10 CFR 50, Appendix A, Criterion 19, with the entire VA system inoperable and ECCS equipment leakage rates of 60 gallons per hour. The actual leakage rate during this event was 2.172 gallons per hour. During the time that both SX pumps were inoperable, separate safety related and non-safety-related water sources were available for makeup to the Ultimate Heat Sink (UHS); additionally, the control room operators would have had 55 minutes,'after receiving a low level alarm for the UHS, to reposition the remote control switch and start the A SX makeup pump before the UHS basin was drained (assuming no makeup following a loss-of-coolantaccident). Based on this infomation, we have concluded that the appropriate enforcement action for these two events is the issuance of two Severity Level IV violations. A written response is required.
The NRC recognizes that while the root causes of these two events and the event in December 1986 were not identical, we are concerned with the increasing number of personnel errors which are resulting in redundant trains of safety related equipment being simultaneously inoperable. The NRC believes that licensee management needs to increase efforts to reduce personnel errors and assure that established policies and programs are effectively implemented, to ensure that a single personnel error will not go undiscovered and conse-quently allow redundant trains of safety related equipment to be simultaneously inoperable.
The NRC is concerned with the failure of the reactor operators assigned to the " center desk" (comon equipment) control room position to take aggressive action in regard to the acknowledgement of, and response to, annunciator.
alarms. Operators need to assure they understand the root cause of an alarm, s
especially remote trouble alarms and alarms that can be initiated by multiple
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pieces of equipment. These problems have been exacerbated by managements lack of success in ensuring the timely resolution of defective alarms. Action should be taken to minimize these and any other such distractions which might contribute to operator errors.
Your reply to this letter and the results of future inspections in this area will be considered in determining whether escalated enforcement actions may be appropriate if'similar violations are identifie.
Comonwealth Edison Company
APR 2 01987 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed i
in the NRC Public Document Room.
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as i
required by the Paperwork Reduction Act of 1980, PL 96-511.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, OMGINAL RONE w c, g. NOREf.nPt Charles E. Norelius, Director -
Division of Reactor Projects Enclosure: Notice of Violation l
cc w/ enclosure:
i D. L. Farrar, Director of Nuclear Licensing
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V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Plant Manager DCS/RSB(RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Byron l
Resident Inspector, RIII Braidwood
D. W. Cassel, Jr., Esq.
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Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Diane Chavez, DAARE/ SAFE Steve Lewis, OGC L. Olshan, NRR LPM H. S. Taylor, Quality Assurance Division Y"
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