ML20137W195
| ML20137W195 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/14/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0264K, 264K, NUDOCS 8510040246 | |
| Download: ML20137W195 (11) | |
Text
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Commonwealth Edison R
)
one First National Plazr. Chicago, Ilknois i
Addrew rieply to: Post Office Box 767 Chicago, Illinois 60690 v
June 14, 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.
50-454/85-016 References (a):
May 16, 1985 letter from R. F. Warnick to Cordell Reed.
(b): June 3, 1985 letter from R. E. Querio to J. M. Hinds.
Dear Mr. Keppler:
Reference (a) provided the results of inspections by Messrs.
Hinds, Brochman, Connaughton, and Butler at Byron Station from April 2 through May 1, 1985. During these inspections, certain activities were found to be not in compliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a).
In addition to the actions discussed in Attachment A to prevent 1
recurrence of the specific examples of violation, Byron Station has initi-ated a " Conduct of Operations Improvement Program" to prevent recurrence of the types of noncompliance that are the subject of Violations 1 and 2.
This program is described in reference (b).
Please direct any questions regarding this matter to this office.
Very truly yours,
((
G D. L. Farrar irector of Nuclear Licensing lm i
Attachment JU"181985 cc: Byron Resident Inspector
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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 time interval."
f Byron Administrative Procedure, BAP 300-22, " Conduct o Operation" implements the requirements of Technical Specificatit 13.0.2 and states: "If any... condition indicates that a system is not coerable as required by Technical Specifications, the Shift Engineer is tc immediately begin the action required by the Technical Specifications as stated in the applicable LOCAR procedure."
Technical Specification 3.2.2.3 states, in part:
"One charging pump...shall be OPERABLE and capable of being powered from an OPERABLE emergency power source...With no charging pump OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving... positive reactivity changes."
Contrary to the above, on December 26, 1984, while in mode 5, with the emergency power source for the 1B Centrifugal Charging Pump inoperable, the applicable LCOAR procedure was not imple?.ented.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED The lA Centrifugal. Charging Pump was restored to operable status in compliance with Technical Specification 3.1.2.3 on December 26, 1984.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE The Shift Engineer and Shift Control Room Engineer have been instructed concerning the importance of maintaining proper plant status-according to the Technical Specifications.
In addition, a Technical Staff
. Memo has been written to stress the importance of maintaining an operable plant status during the performance of technical staff surveillances, operating surveillances, tests, and maintenance activities.
DATE WHEN FULL f'0 WLIANCE WILL BE ACHIEVED The 1A Centrifugal Charging Pump was restored to operable status on December 26, 1984.
f
, VIOLATION lb Technical Specification 3.0.2 states: " Noncompliance with a specification shall exist when the requirements of the limiting conditions for operations 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 3.4.4 states, in part:
"With both PORVs inoperable due to causes other than excessive seat leakage, within 1 hout...close their associated block valves and remove power from the block valves..."
Contrary to the above, on January 19, 1985, while in mode 3, with t
both Pressurizer PORVs inoperable for reasons other than excessive seat leakage, the applicable LOCAR procedure was not implemented and the Pressurizer PORV block valves were not de-energized in the closed position within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
CORRECTIki ACTION TAKEN AND THE RESULTS ACHIEVED The reactor coolant system was depressurized to normal operating pressure and.the power operated relief valves and their block valves were returned to operable status.
s CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIAtCE The operating personnel involved in this event were rebriefed on the intent of the Technical Specification Limiting Condition for Operation.
DATE WFEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on January 19, 1985 when the reactor coolant system was depressurized to normal operating pressure and the power operated relief valves and their block valves were returned to operable status.
, VIOLATION Ic Technical Specification 3.0.2 states:
" Noncompliance with a specification shall exist when the requirements of the limiting conditions t
for operetton 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 4
Technical Specification, the shift engineer is to immediately begin the 4
action required by the technical specifications as stated in the applicable LOCAR procedures."
Technical Specification 3.3.3.1 requires that with Radiation Monitoring Instrumentation Channel ORE-PR0328 inoperable Train "A" of the' Main Control Room Ventilation System be placed in the make-up mode within JL hour.
Contrary to the above, on March 19, 1985, while in mode 5. with
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Radiation Monitoring Instrumentation Channel ORE-PR032B inoperable, the applicable LOCAR procedure was not implemented and Train "A" of the Main Control Room Ventilation System was not placed-in the make-up mode within 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 TFE RESULTS ACHIEVED The Train "A" Main Control Room Ventilation System was immediately placed in:the make-up mode.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE The Shift Control Room Engineer involved in the event was cautioned regarding the importance of checking Technical Specifications applicability when switching trains of safeguards equipment.
DATE WHEN FULL CO WLIANCE.WILL BE ACHIEVED Full compliance was achieved on March 19, 1985, when the Train "A" Main Control Room Ventilation System was placed in the make-up mode.
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, VIOLATION 2a Technical Specification 4.0.3 states: " Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation."
Technical Specification 4.0.4 states, in part:
" Entry into an OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval..."
Technical Specification 4.3.3.7.1 required that fire detection instruments shall be demonstrated OPERABLE at least once per 6 months by performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST.
Contrary to the above, on October 31, 1984, mode 6 was entered' without completing a-TRIP ACTUATION DEVICE OPERATIONAL TEST for an ultraviolet fire detector.
4 CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED The Technical Specification surveillance that was missed on October 31, 1984 was discovered on February 13, 1985. An hourly fire watch should have been established in the affected fire zone when the surveillance was missed. Although this was not accomplished on October 31, 1984, an hourly fire watch was established on December 21, 1984 for other reasons.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIAtCE The Electrical Maintenance Department has been instructed by the station's surveillance coordinator to initiate an independent review of future work packages prior to considering a surveillance complete and successful.
DATE WHEN FULL COWLIANCE WILL BE ACHIEVED.
Full compliance was achieved on December 21, 1984, when an hourly fire watch was established in the affected fire zone.
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4 VIOLATION 2b Technical Specification 4.0.3 states:
" Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the 03ERABILITY requirements for a Limiting Condition for Operation."
Technical Specification'4.0.4 states, in part:
" Entry intu an OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been. performed within the stated surveillance interval..."
Technical Specification 4.0.5.a requires inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code
" Class 1, 2 and 3 pumps and valves to be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Codes and applicable Addenda as required by 10 CFR 50.55a(g).
ASME Boiler nod Pressure Vessel Code Section XI, Article IS-400 requires reinspectior af components following repair or replacement, prior to resumption of operation.
Contrary to the above, on October 31, 1984 through March 18, 1985, 4
the following components were returned to service following mainte,ance without having performed an ASME visual inspection: Valves ICV 0668, 1CV067A,1BR003A,1SI89488,1FWOl7D,1RH030A and Pump OABOlPA.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED On March 18, 1985, when it was discovered that valves 1CV0668 and 1CV067A were returned to service without having performed the required Technical Specification surveillance, an ASME visual inspection was subsequently completed with satisfactory results.
In addition to valves 1CV066B and 1CV067A, on March 18, 19d5, it was also discovered that valves 1BR003A, 1SI89488, 1FWOl7D, 1RH030A, and pump OAB0lPA were returned to service without having performed the required inservice inspection. An ASME visual inspection of valves 1BR003A and 1RH030A was performed on March 28, 1985 with acceptable results. An acceptable visual inspection of valve 1SI8948B was completed on January 15, 1985. On April 1, 1985, the inservice inspection surveillance for pump OAB0lPA was performed with satisfactory results.
Valve 1FWOl7A has been isolated from service and will be inspected when the proper plant conditions exist.
, CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE Work requests, when receiveo by the Operating Department following "QC Release" for testing, are now required to remain in the control room until testing requirements are complete.
In addition, copies of work requests with pending testing requirements are being forwarded to the appropriate departments to assure completion in a timely manner.
A memo has been issued to Shift Personnel to clarify the procedural intent of processing work requests and removing and returning equipment out-of-service. Another. memo has also been issued to clarify the method of expediting inservice inspection testing requirments and who can perform those requirements.
The Quality Control Department has attended a documented training session on verifying that the ISI group has specified testing requirements on safety-related work requests.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when the required surveillance was performed for the respective components as described above.
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_ VIOLATION 2c Technical Specification 4.0.3 states: " Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERASILITY requirements for a Limiting Condition for Operation."
Technical Specification-4.0.4 states, in part:
" Entry into an OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval..."
The licensee's Preservice/ Inservice Inspection Program Plan for valves requires that a Position Indication Test be performed every 3 years for valve 1S18809A.
Contrary to the above, on March 10, 1985, Mode 3 was entered without performing a Position Indication Test on valve 1SI8809A.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED On January 10,1985, mode 3 was entered without performing a Position Indication Test on valve 1SI8809A. This was discovered on January 24, 1985 and a Position Indication Test was successfully performed on valve ISI8809A that same day.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE The surveillance procedure which specifies valves that require a Position Indication Test is being revised to include the 1SI8809 valves.
A revision to the station administrative procedure has been implemented to assure all revised ISI surveillances require a review by the ISI Coordinator prior to their implementation.
DATE WFEN FULL COMPLIANCE WILL BE ACHIEVED The Position Indication Test for valve ISI8809A was performed on January ~24, 1985. The surveillance procedure for valves requiring a Position Indication Test will be revised to include the 1SI8809 valves by July 12, 1985.
, VIOLATION'2d Technical Specification 4.0.3 states: " Failure to perform a Surveillance Requirement within the specified time interval shall.
constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation."
Technical Specification 4.0.4 states, in part:
" Entry into an OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed wit; in the stated surveillance interval..."
Technical Specification 3.8.1.1.a specifies that with a required offsite electrical circuit inoperable, demonstrate the OPERABILITY of the remaining circuit by performing Technical Specification 4.8.1.1.la within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Contr?.ry to'the above, on January 11-12, 1985, while in mode 3, Surveillance 4.8.1.1.la was not performeo within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and wit
.1 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, to demonstrate OPERABLE the remaining offsite elect _ical circuit.
CORRECTIVE ACTION TAKEN AND TE RESULTS ACHIEVED
-On-January ll, 1985, the required surveillance was performed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the offsite electrical circuit was-taken out of service. The surveillance was performed late again,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the first surveillance. The offsite electrical circuit was restored to operable status 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after performance of the second surveillance.
CORRECTIVE ACTION TO AVOID FURTHER NONCO WLIANCE All licensed operators will read this violation and response by August 9, 1985.
DATE WHEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on January 12, 1985 when the offsite electrical circuit was restored to operable status.
i VIOLATION 2e Technical Specification 4.0.3 states:
" Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the 03ERABILITY requirements for a Limiting Condition for Operation."
Technical Specification 4.0.4 states, in part:
" Entry into an i
OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval...."
4 Technical Specification 4.8.1.3.a requires that the 2A Diesel Generator be demonstrated OPERABLE once per day.
I Contrary to the above, on J&nuary ll, 1985, while-in Mode 3, Surveillance 4.8.1.3.a was not performed to demonstrate the 2A Diesel Generator capable of providing power to Bus 141.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED When the missed surveillance was discovered on January 12, 1985, the 2A Diesel Generator surveillance was immediately performed with satisfactory results.
CORRECTIVE ACTION TAKEN TO AVOID FURTW R NONCOW LIANCE
'A revision has been made to the shiftly and daily operating
- surveillance data package cover sheet. This revision lists the 2A Diesel Generator daily surveillance as a document to be attached to the package.
DATE WW N FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on January 12, 1985 when the 2A Diesel Generator daily surveillance was successfully performed.
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1 VIOLATION 2f Technical Specification 4.0.3 states:
" Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation."
Technical Specification 4.0.4 states, in part:
" Entry into an OPERATIONAL MODE....shall not be made unless the Surveillance Requirement (s) associated with the Limiting _ Condition for Operation have been perforned within the stated surveillance interval...."
Technical Specification 4.6.3.3 requires that containment isolation valves shall be stroke timed every quarter.
Contrary to the above, on January 16, 1985, while in Mode 3, the quarterly surveillance interval for Containment Isolation valve ISD005C was exceeded.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED The surveillance on valve ISD005C was performed on January 17, 1985. The valve initially failed its acceptance criteria. After mainten-ance was performed on the valve, the surveillance was repeated with satisfactory'results.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCO WLIANCE The surveillance program has been modified to identify components requiring an increased testing frequency and to notify supervisory personnel of surveillances which are nearing their due date.
DATE WFEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on January 17, 1985 when the valve surveillance was performed with satisfactory results.
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.,. 4 VIOLATION 20 Technical Specification 4.0.3 states: _" Failure to perform a Surveillance Requirement within the specified time interval shall constitute a ' failure to meet the OPERABILITY requirements for a Limiting Condition for-Operation."
Technical Specification 4.0.4 states, in part:
" Entry into an OPERATIONAL MODE...shall not be made unless the Surveillance
' Requirement (s) associated with the Limiting Condition for Operation have
-been performed within the stated surveillance interval..."
Technical Specification 4.7.10.3.1 requires that the Lower Cable System be demonstrated OPERABLE at least once per 31 Spreading Room CO2 days.
Contrary to the above,' the Lower Cable Spreading Room CO2 System was not demonstrated OPERABLE-in the months of January and February, 1985.
CORRECTIVE ACTION TAKEN AND TW RESULTS ACHIEVED The Lower Cable Spreading Room CO2 System was not operable in the ~ months of January and February,1985. However, it was not required to be demonstrated operable since a continuous fire watch was posted in the-Lower Cable Spreading Room during the months of January and February, 1985.
This was in accordance with the applicable LCO action requirement of the Technical Specification.
The monthly CO2 System valve position surveillance was not perforned for the remainder of the CO2 System separate from the Lower Cable Spreading Room during the months of January and February. When this was discovered on March 13, 1985, the entire surveillance was performed.
The Lower Cable Spreading Room failed again' and the continuous fi watch remained in place.
4 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE
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The Station Surveillance Coordinator has been instructed to check i-failed surveillances against actions taken by the Shift Engineer to meet F
Technical Specification action statements in order to determine which portion of the surveillance must continue to be performed.
DATE W{N FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on March 13, 1985 when the entire CO. System valve position surveillance was performed.
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,.. VIOLATION 2H Technical Specification 4.0.3. states: " Failure to perform a Surveillance Requirement within _the specified time interval shall constitute a failure to meet the 03ERABILITY requirenents for a Limiting Condition for Operation."
. Technical Specification 4.0.4 states, in part:
" Entry into an OPERATIONAL MODE...shall not be made unless the Surveillance Requirement (s) associated with-the Limiting Condition for Operation have been performed within the stated surveillance interval...."
. Technical. Specification 4.3.1.1 requires that the Turbine Emergency Trip Header Low Pressure Reactor Trip Surveillance be performed prior to a reactor startup.
Contrary to the above, on March 1, 1985, Mode 2 was entered without performing a Turbine Emergency Trip Header Low Pressure Reactor
-Trip Surveillance.
CORRECTIVE ACTION TAKEN Ato THE RESULTS ACHIEVED
~The missed surveillance was discovered on March 2, 1985 and was immediately perforned with satisfactory results.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE The surveillance computer program has been changed to include this surveillance'in the non-routine list for entering Mode 2.
DATE WHEN FULL COWLIANCE WILL BE ACHIEVED Full compliance was achieved on March 2, 1985 when the surveillance was satisfactorily performed.
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