ML20137L631
| ML20137L631 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/17/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0379K, 379K, NUDOCS 8601280041 | |
| Download: ML20137L631 (3) | |
Text
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Commonwealth Edison Address Reply to: Post Office Box 767 Chicago, lilinois 60690 July 17, 1985 Mr. James G. Keppler Regional Administrator' U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Unit 1 IE Inspection Report No. 50-454/85-021 NRC Docket No. 50-454 Reference (a): June 17, 1985 letter from R. F.
Warnick to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of inspections by Messrs. Hinds and Brochman at Byron Station from May 2 through June 3, 1985. During these inspections, certain activities were found to be in violation of NRC require-ments. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a).
Please direct any questions regarding this matter to this office.
Very truly yours, h
D. L. Farrar Director of Nuclear Licensing 1m Attachment cc: Byron Resident Inspector 8601280041 850717 0379K PDR ADOCK 05000454 M 18 $g3 PM 3g,/\\\\
e ATTACHMENT A VIOLATION la Technical Specification 3.0.2 states:
" Noncompliance.with a specification shall exist when the requirements of the limiting conditions for operation and associated ACTION requirements are not met within the specified interval."
Byron Administrative Procedure, BAP 300-22, " Conduct of Operation" implements the requirements of Technical Specification 3.0.2 and states:
"If any... condition indicates that a system is not operable as required by Technical Specifications, the Shift Engineer is to immediately begin the action required by the Technical Specifications as stated in the applicable LOCAR procedure."
Technical Specification 4.6.3.1 states: "The isolation valves specified in Table 3.6-1 shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isolation time."
Contrary to the above, on April 1, 1985, while in Mode 1, the isolation time surveillance was not performed on. containment isolation valve 1PR066.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery of the missed ' surveillance on April 3,1985, the Limiting Condition for Operation fnr containment isolation valve 1PR066 was entered and the isolation time surveillance was performed. The valve isolation time was acceptable.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOW LIANCE An Operating ' Clarification (a method of documenting interpretations of Technical Specifications) was written to inform operating personnel of
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conditions which require declaring a valve inoperable and the testing required after maintenance in order to declare a valve operable. The Operating Clarification was issued on May 6,1985 and licensed operators read this document by June 17,'1985.
DATE MEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on April 3, 1985 when the isolation time surveillance was performed on valve 1PR066.
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r 2-VIOLATION lb Technical Specification 3.0.2 states:
Noncompliance with a specification shall. exist when the requirements of the limiting conditior.s for operation and associated ACTION requirements are not met within the
.specified time interval."
Byron Administrative' Procedure, BAP 300-22, " Conduct of Operation" implements the requirements of Technical Specification 3.0.2 and states:
"If any... condition indicates that a system is not operable as required by Technical Specifications, the Shift Engineer is to immediately begin the action required by the Technical Specifications as stated in the applicable LOCAR procedure."
Technical Specification 4.4.8 states:
The specific activity of the reactor coolant shall be determined to be-within the limits by l
performance of the sampling and analysis program of Table 4.4-4.
Contrary to the above, on April 10, 1985, while in Mode 3, the required reactor coolant sample was not collected until 7.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> after a j-thermal change of 28% in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery of the missed surveillance, a reactor coolant sample j
was collected and analyzed. The sample analysis yielded acceptable results.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE A file organizer has been placed in the Station counting room for initiated surveillance procedures. Technicians are periodically instructed by the responsible foreman to review the file for initiated surveillances.
Initiated surveillar;as are also tracked on the counting room shift turnover sheet. In addition, a sheet has been placed on the duty foreman's desk outlining the sampling requirements for reactor startups, shutdowns and thermal power changes of greater. than'15% in one hour. These actions were implemented by April 15, 1985.
DATE WiEN FULL COWLIANCE HAS BEEN ACHIEVED Full compliance was achieved on April 10, 1985 when the missed reactor coolant sample was' collected and analyzed.
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