ML20086E281
| ML20086E281 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/21/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111270150 | |
| Download: ML20086E281 (3) | |
Text
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Commonwsalth Edison a
C 1400 Opus Place
~.O Downers Grove, Illinois 60515 November 21,1991 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l
1
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Repod Nos. 50-454/91022; 50 455/91022 NRC Docket Numbers 50-454 and 50-455
Reference:
H. Miller letter to Corde0 Reed dated October 22nd transmitting NRC Inspection Report 50 454/91022;50-455/91022 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report. The NOV cited are Severity LevelIV violation. The violation concerned the failure to collect Type A leakage rate test data within the required timeframe. CECO's response is provided in the following attachment.
In addition, page 15 of the inspecGon report states, in pari, *During the 1991 Unit 1 Type A test, the inner door shaft seal on the emergency airlocks...." should read "During the 1991 Unit 1 Typeion.A test, the inner door seals on the personnel airlocks..." Please note this correct If your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at (708) 515-7285.
Very truly yours,
/
@I'.'. Kovach Nuclegt1 censing Manager l
Attachment cc:
A. Bert Davis, NRC Regional Administrator - Rlli A. Hsia, Project Manager - NRR W, Kropp, Senior Resident inspector 9111270150 911121 pas Acocu 0s0004D4
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RESPONSE TO NOTICE OF VIOLATION 50-454/91022;455/91022 VIOLATION 10 CFR Part 50, Ap)endix J. Section Ill.A.3.a requires, in part, that all Type A tests be conducted in accorc ance with the provisions of the American National Standard N45.41972 " Leakage Rate Testing of Containment Structures for Nuclear Reactors" March 16,1972. Section 7.0 of this standard requires in aart, that pressure, tamperature, and humidity observations be made within ile containment structure and l
recorded during the course of the leakage rate test at hourly or more frequent intervals.
Contrary to the above, on September 14,1991, during the conduct of the Type A leakage rate test, data was not recorded from 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> until 2114 hours0.0245 days <br />0.587 hours <br />0.0035 weeks <br />8.04377e-4 months <br />.
l BEASON. EOR _TBEXIOLAllON During the performance of the Integrated Leak Rate Test (lLRT) there was a loss of electrical power to the Data Acquisition System (DAS) and the Precision Pressure Monitors (PPMs). The mainframe computer obtains data from the DAS and PPMs at ten minute Intervals. This data is used by the ILRT test personnel to calculate the containment leak rate.
Station operating personnel selectively de energized breakers in an effort to support the ILRT and a simultaneous maintenance activity. The ILRT instrumentation was 1
understood to be powered from a local electrical outlet. The operating aersonnel inadvertently opened breakers which supplied power to the DAS and P 3Ms causing an interruption in data acquisition from 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> to 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />.
l ILRT testing personnel are required by procedure to record the obtained data in the test document every hour. The loss and subsequent restoration of power caused the required time to be exceeded by 12 minutes which is contrary to the requirements of Appendix J.
l CORRECTIVE.STERS_THAT_HAVE BEEN TAKEN AND_RESULTS. ACHIEVED l
An immediato investigation resulted in the appropriate breakers being restored and power was returned to the DAS and PPMs.
I ILRT test personnel recognized the required time for data acquisition had been j
exceeded by 12 minutes and called an NRC Region ill representative at 2200, on 9/14/91. A alscussion ensued as to the acceptability of continuing the test or if it was l
l necessary to restart the test. The NRC representative stated that it would be acceptable to continue the test if continuity of all test data parameters could be shown before the loss of power and af ter power restoration.
1 ZNLD/1333/2
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Sets of data taken at ten (10) minute intervals were acquired after power restoration.
All of the thermistors and dowcells were tracking as expected, without signs of the transient. However, the two pressure channels were reading lower than expected.
Both pressure channels recovered to the expected pressure decay curves one hour af ter power restoration.
At 2245 on 9/14/91, a second NRC representative contacted the ILRT test personnel for test status. The ILRT testing personnel provided the current status including the recovery from the loss of power. The second NRC reposentative then concurred that the test could be continued if the pressure channels co tinued to follow the expected arossure decay curve it was recommended that this Update be passed on to the first 1RC contact for concurrence. The ILRT personnel made the contact and received concurrence that the test did not need to be restarted.
The test was completed after successful acquisition of additional data and demonstration by station personnel that loss of power did not adversely affect the test results.
CORRECTIVELSTEPS THAT_WILL BE TAKEN TO AVOID.EU.RIHER_ VIOLATION 1/2 BVS 6.1.2.a 1, Primary Containment Tyao A Integrated Leakage Rate Test (ILRT),
will be revised to contain procedural steps defining the power sources to the instrumentation and safeguards to prevent unintentional mispositioning of breakers.
Additionally, the revision will require that test equipment operability is verified by test personnel at 15 minute intervals to ensure proper instrumentation support during the statisticalleak rate and verification test executions. This revision and training of appropriate o aerating and testing personnel will be completed by 8/30/92, which is prior to the next ILT performance, to the ILRT instrumentation for sho(UPS) will be purchased to ensure power is supplied An Uninterruptable Power Supply rt durations. This UPS will also provide a filtering function to minimize problems to the equipment caused by power spikes. The UPS will-be installed and appropriate training of testing personnel completed by 8/30/92.
DAIE.WB EN.EUL LCOM ELI AN C EMILLB E ACHIEV E D Full compliance was achieved on 9/14/91 following successful completion of the test ZNLD/1333/3
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