IR 05000454/1988019

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000 for Violations Noted in Insp Rept 50-454/88-19 Re Loss of One Train of RHR Sys While Water Level in RCS Being Lowered on 880919

ML20247K838
Person / Time
Site:	Byron
Issue date:	05/24/1989
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
Shared Package
ML20247K842	List: IR 05000454/1988019 ML20247K847
References
EA-88-266, NUDOCS 8906020037
Download: ML20247K838 (4)

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h May 24, 1989 Docket No. 50-454 License No. NPF-37 '

EA 88-266 Commonwealth Edison Company ATTN: Mr. J. J. O'Connor Chief Executive Officer Post Office Box 767 Chicago, Illinois 60690

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Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-454/88019(DRP))

This refers to our letter dated October 12, 1988, which forwarded the results of a special safety inspection conducted on September 19 through 28,1988, to review the circumstances surrounding the loss of one train of the residual heat removal system (RHR) while the water level in the reactor coolant system was being. lowered on September 19, 198 On October 21, 1988, we held an enforcement conference with members of your staff during which the apparent violations, the root causes and your corrective actions were discusse The inspection 'results show that when the event discussed above occurred the unit was operated contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 5.0, which requires that activities affecting quality be prescribed by' documented procedures of a type appropriate to the circumstance Byron Operating Procedure B0P RH-9, Revision 51A, " Pump Down of the Reactor Cavity to the RWST," was inauequate in that it did not specifically require the use of any means of Reactor Coolant System (RCS) level indication during draining of the reactor cavity below the reactor vessel flang In addition, Byron Operating Procedure 80P RC-4a, Revision 51, " Reactor Coolant System Drain," which contains instructions for installation of the tygon hose level indication system, was inadequate because it failed to ensure that the tygon level hose was an accurate indication of RCS leve In a letter to you dated October 4, 1988, we described our concern that you were apparently failing to factor previous industry lessons learned, transmitted by NRC generic correspondence, into plant procedures and practice In reply, you advised us that both your corporate and individual plant staffs routinely review generic correspondence to ensure that lessons learned from events are evaluated for applicability and that a determination is made of whether actions to preclude such occurrences are warranted at your facilities. However, Information Notices 86-01, 87-23, 87-46, and 88-36 as well as Generic l

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Commonwealth Edison. Compan May 24, 1989

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I Letter 87-12 address issues applicable to this event. Had you taken adequate action in response to those issuances, the loss of decay heat removal capability during low. reactor . coolant level operations may have been prevente Further, it is evident that the plant operators were relying upon a makeshift procedure-that had not been properlyL developed and reviewed. This event, therefore, represents a serious concern regarding your staff's ability to ensure the operability of safety-related system l The NRC has considered your argument that the operators reasonably should not have been expected to recognize the phenomenon that caused the loss of RCS level. The NRC has concluded that how the loss of level occurred is not a primary concern in this case. Rather, there are two issues of immediate concern to the NRC based on the September 19, 1988 even First, an .

undetected loss of level occurred and no matter what the reason for it, that  !

is unacceptable. Further, the reliance on only direct visual indication to monitor RCS level did not provide for an accurate method of level indication had the RCS level decreased below the vessel flange for reasons as. simple as the operator failing to or improperly securing the draindown. The need to  !

consider and anticipate all possible scenarios as well as the need to maintain 4 the availability of redundant. indicators are concepts that are basic to safe  !

plant operations. Moreover, it is of concern that your procedures required the  !

availability of the tygon level hose as a prerequisite but then did not provide for its us I To emphasize the importance of ensuring that critical plant parameters and systems are controlled in accordance with appropriate station procedures and I that necessary corrective actions are taken in response to generic communica-tions, I have been authorized,' after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violation described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13,1988) (Enforcement  ;

Policy), the violation described in the enclosed Notice has been categorized at '

Severity Level III. The base value of a civil penalty for a Severity Level III violation is $50,000. The escalation and mitigation factors in the Enforcement Policy were considered and although escalation for prior notice could have been applied,'it was not, given that none of the previously cited generic issuances specifically address the type of problem under consideration here. Nevertheless ,

when those documents are considered in total, it is clear that the NRC expects careful RCS level control and monitoring in all situations. Additionally, as discussed above, had your staff taken adequate action in response to those issuances, this problem may have been prevente You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional I

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Commonwealth Edison Company 3 May 24, 1989 1 l

i actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is 4 necessary to ensure compliance with NRC regulatory requirement l 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 in the NRC Public Document Roo l 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 required by the Paperwork Reduction Act of 1980, PL 96-51 I

Sincerely Driginsi cigned by jl. Bert Davia l

A. Bert Davis Regional Administrator i

Enclosures Notice of Violation and Proposed Imposition  ;

of Civil Penalty Inspection Report No. 50-454/88019(DRP)

cc w/ enclosures:

T. J. Maiman, Vice President, PWR Operations H. Bliss, Nuclear Licensing Manager i R. Pleniewicz, Station Manager ~

DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Byron Residtnt Inspector, RIII Braidwood D. W. Cassel, Jr., Es Richard Hubbard J. W. McCaffrey, Chief, Public *

Utilities Division Diane Chavez, DAARE/ SAFE (

L. Olshan, NRR LPM l H. S. Taylor, Quality Assurance i Division 1 OE D:0E DEDS RIli RIII RIII RIII RIII M FA7 JLuehman/ jaw by JLieberman W Wb Schultz

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