ML20153E439

Responds to NRC Re Violations Noted in Insp Rept 50-454/85-56.Corrective Actions:Temporary Change to Calorimetric Calculation Surveillance 1BOS 3.1.1-2 Issued to Include Feedwater Tempering Line Flow in Heat Balance

ML20153E439
Person / Time
Site:	Byron
Issue date:	01/29/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1209K, NUDOCS 8602250034
Download: ML20153E439 (3)

Text

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,' s Commonwealth Edison M one rirst sti onji Plaza Chicano. Ilknois

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\ ') Address Reply to Post Othee Box 767

's / Chicago, Illinois 60690 January 29, 1986 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 I&E Inspection Report No. 50-454/85-056 Reference (a): December 31, 1985 letter from C. E. Norelius to Cordell Reed

Dear Mr. Keppler:

Reference (a) provided the results of an inspection by Messrs.

Hinds, Jr. and Brochman at Byron Station on December 2-13, 1985. During this inspection, certain activities were found to be in violation of NRC requirements. 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 ruly yours,

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D. L. Farrar i Director of Nuclear Licensing im Attachment ec: Byron Resident Inspector 8602250034 PDR ADOCK h54 PDR g, k O

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ATTACHMENT A VIOLATION Technical Specification 6.8.1.a states, in part: " Written proce-dures shall be established. . . covering the activities referenced . . .

for. . .the applicable procedures as recommended in Appendix A, of Regul; story Guide 1.33. Revision 2 February 1978."

Regulatory Guide 1.33, Revision 2, Appendix A. Section 8 b(1)(w) requires that a specific procedure for Heat Balance - Flux Monitor Calibrations should be written.

Byron Operating Surveillance 1BOS 3.1.1-2, " Calorimetric calculation Surveillance," implements this requirement.

Appendix B to 10 CFR 50 requires activities affecting quality to be prescribed by procedures appropriate to the circumstances.

Contrary to the above, on February 2 through August 6,1985, while in Modes 1 or 2, the procedure to calibrate the Nucicar Instrumentation Power Fange Channels was not appropriate to the circumstances in that this procedure did not include the Feedwater Tempering Line Flowrate.

CORpKCTIVE ACTION TAKEN AND RESULTS ACHIEVED A temporary change to the Calorimetric Calculation Surveillance (IBOS 3.1.1-2) was immediately issued to include feedwater tempering line flow in the heat balance. The procedure was subsequently permanently revised. A comprehensive investigation was conducted to determine if the reactor thermal power limits were ever exceeded as a result of the discre-pancy in the calorimetric calculation. The results of this investigation indicated that the reactor thermal power limits were never exceeded.

On December 31, 1985, a calorimetric calculation was programmed into the plant process computer to give control room operators the cption of performing this surveillance with the computer.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Byron Operating Procedures are currently being reviewed in The accordance with the Byron /Braidwood procedure standardization program.

scope of this program includes operatirg surveillances, procedures, emergency procedures, abnormal procedures, annunciator responses, generalIn this procedures, and the 300 series of the administrative procedures.

program, each station performs a thorough review of the other station's

s' procedures. Comments and concerns on each procedure raised in this review are jointly reconciled and one common procedure is generated. This procedure is then processed through the review structure of each station.

Although the primary purpose of this program is procedure standardization.

the end result is that each of the procedures within the serpe of this program receives additional reviews and approvals. This program began in June, 1985 and is currently scheduled to be completed in April, 1986. At the time the feedwater tempering line flow omission was discovered, the Calorimetric Calculation Surveillance had not yet been through the procedure standardization program.

In addition to the procedure standardization program, Byron Unit 1 procedures will, in effect, receive an additional review when these proce-dures are used as the basis for developing ths Byron Unit 2 procedures.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Calorimetric Calculation Surveillance was revised to include feedwater tempering line flow on August 7, 1985.

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