ML20138D560

Notice of Violation from Insp on 970201-0313.Violation Noted:On 970217,inspectors Identified That Radwaste Operator Did Not Monitor Release Tank & Regen Waste Drain Tank Level Recorders During Transfer of Liquid Radwaste

ML20138D560
Person / Time
Site:	Byron
Issue date:	04/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138D524	List: ML20138D520 ML20138D560 ML20138D565
References
50-454-97-02, 50-454-97-2, 50-455-97-02, 50-455-97-2, NUDOCS 9705010163
Download: ML20138D560 (3)

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NOTICE OF VIOLATION l

Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2  !

License Nos. NPF-37: NPF-66 l q

During an NRC inspection conducted from February 1 through March 13,1997, four t violations of NRC requirements were identified. In accordance with the NUREG-1600,

" General Statement of Policy and Procedure for NRC Enforcement Actions," the violations l are listed below )

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1. Technical Specification 6.8.1.a requires that procedures be established, i

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implemented, and maintained for activities covered in Appendix A of Regulatory l

Guide 1.33. Regulatory Guide 1.33, Appendix A, Section 7.a.(1) recommends the I use of procedures for water collection in liquid radioactive waste systems.

Procedure BOP WX-121, " Release Tank Transfer to 22,000 Gallon Regen Waste Drain Tank," Revision 3, step 15, required that the radwaste operator monitor the releass tank level recorder and the re..oq waste drain tank level recorder during the liquid radioactive waste transfers.

Contrary to the above, on February 17,1997, the inspectors identified that the radwaste operator did not monitor the release tank and the regen waste drain tank level recorders during the transfer of liquid radioactive waste from the release tank to the regen waste drain tank. (50-454/455-97002-01(DRP)).

This is a Severity Level IV violation (Supplement 1).

2. Technical Specification 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems shall be operable, with each subsystem including one operable residual heat removal pump, in Modes 1,2, and 3.

Technical Specification 3.5.2, Action statement a. requires that with one ECCS subsystem inoperable, the licensee must restore the inoperable spray system to operable within 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, the licensee identified that since December,1985, with Unit 1 in Modes 1, 2, and 3, the 1 A residual heat removal pump was inoperable and action was not taken to restore the inoperable subsystem to operable within 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. (50-454/97002-04(DRP))

l This is a Severity Level IV violation (Supplement I).

3. Technical Specification 3.6.2.1 requires that two independent containment spray i systems shall be operable in Modes 1, 2, 3, and 4 l \

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9705010163 970423 PDR ADOCK 05000454 G

PDR l

i Notice of Violation l l

l Technical. Specification 3.6.2.1, Action statement requires that with one l

containment spray system inoperable, the licensee must restore the inoperable l- spray system to operable within 7 days or be in at least hot standby within the next l 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l Contrary to the above, the licensee identified that since 1986, with Unit 1 in Modes 1,2,3, and 4, the IB containment spray pump was inoperable and action was not taken to restore theinoperable subsystem to operable within 7 days or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. (50-454/97002/05(DRP))

This is a Severity Level IV violation (Supplement 1).

4. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. ~

a. Contrary to the above, two events identified that procedure SMP-M-4, " Foreign Material Control," Revision 0, was not of a type appropriate to the circumstances in that implementation of the procedure did not prevent foreign material from entering the containment spray system. Specifically, on February 28,1997, foreign material was identified between the thrust bearing seating surfaces of the thrust bearing housing of the 1B containment spray pump. Additionally, on March 2,1997, foreign material was identified between the mechanical seal seating surfaces of the 1 A containment spray pump (50-454/455-97002-06a(DRP)).

b. Contrary to the above, on March 5,1997, due to an event, the inspector identified that the troubleshooting procedure for Unit 2 pressurizer spray valves, 2RY4558 and C, was not of a type appropriate to the circumstances.

Specifically, Work Request 970025538, " Pressurizer Pressure Control Appears to be Drifting," Revision 1, failed to identify that circuit troubleshooting the spray valves could affect and resulted in an inadvertent opening of 2RY455A, pressurizer power operated relief valve (50-454/455-97002-06b(DRP)).

This is a Severity Level IV violation (Supplement 1).

5. 10 CFR Part 50, Appendix B, Criterion lil, " Design Control," requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and l instructions. Design changes, including field changes, shall be subject to design j- control measures commensurate with those applied to the original design.

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! Notice of Violation l l

a. Contrary to the above, on February 28,1997, the inspectors identified that -

since initial fuelloading, a field change made to the Unit 1 service air system downstream of valve 1SA038A, was not subject to a seismic evaluation, which is a design control measure commensurate with those applied to the original design (50-454/455-97002-07a(DRP)).

b. Contrary to the above, the inspectors identified that as of December 1, 1996, the requirements of the safety evaluation to enter a limiting condition for operation action requirement for modification M6-1-88-060 '

were not translated into Byron Operating Surveillance SX-M1 "1 A AF Pump SX Suction Line Monthly Flushing Surveillance," Revision 1 which is a design control measure commensurate with those applied to the original design (50-454;455-97002-07b(DRP)).

This is a Severity Lavel IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR Part 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting the Notice of Violation (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an '

adequate reply is not received within the time specified in the Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without reduction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated a Lisle, Illinois this.1 day of April 1997 l

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