Text

Responds to 860506 Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $50,000 Based on Insp on 850812-1031.ECCS Inoperability Denied.Penalty Mitigation Requested.Payment Encl
	ML20199K282
Person / Time
Site:	Byron
Issue date:	07/03/1986
From:	Bernard Thomas; COMMONWEALTH EDISON CO.
To:	Taylor J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
	1816K, EA-86-048, EA-86-48, NUDOCS 8607090111
	Download: ML20199K282 (19)
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y} g g JO Cd Commonwealth Edison

}'q3 Z- 72 West Adams Street, Chic 5go, Illinois v() '#

Address Reply to: Post Office Box 767 If)

Chicago, Illinois 60690-0767 July 3, 1986 Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Byron Station Unit 1 j

Proposed Civil Penalties EA 86-48

. NRC Docket No. 50-454 References (a): November 14, 1985 letter from C. E. Norelius to Cordell Reed (b): November 22, 1985 letter from C. E. Norelius to Cordell Reed i (c): May 6, 1986 letter from J. G. Keppler to

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J. J. O'Connor i

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Dear Mr. Taylor:

References (a) and (b) provided the results of inspections at Byron Station between August 12 and October 31, 1985. As a result of these inspections and further discussions during an Enforcement Conference on November 27, 1985, certain activities were found to be in violation of NRC requirements. Reference (c) transmitted a Notice of Violation and Proposed Imposition of Civil Penalties related to the violations identified in references (a) and (b). Attachments A and C of this letter contain Commonwealth Edison's response to the Notice of Violation enclosed with reference (c). On May 15, 1986, commonwealth Edison was granted a 30-day j extension on the due date for the response to the Notice of Violation and

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Proposed Imposition of Civil Penalties.

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With respect to Item 1 in the Notice of Violation, Commonwealth j Edison believes that the circumstances surrounding these events neither constitute a, Severity Level III violation nor warrant a $50,000 civil penalty. The only examples in Supplement 1 of the NRC Enforcement Policy which could apply to these events are examples C.1 and C.2. However, for reasons discussed below, neither example is applicable here. The events

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- Mr. J. M. Taylor July 3, 1986 neither resulted in "a system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions" nor "a significant violation of a Technical Specification Limiting condition for Operation where the appropriate Action Statement was not satisfied within the time allotted by the Action Statement". Moreover, these events did not involve circumstances rising to the level of seriousness appropriate to Severity Level III events.

Item 1 is responded to in Attachment A. It explains that the intended function of the two emergency core cooling system (ECCS) subsystems is to limit peak clad temperature to within specified Itmits following a loss of coolant accident (LOCA). The analysis in Attachment A shows that during this event an BCCS subsystem was capable of performing its intended temperature control function while a portion of the RHR injection flow path was isolated. Consequently, these events did not involve a situation in which a system designed to prevent or mitigate a serious safety event was not able to perform its intended function under certain conditions.

1 These events also did not constitute a significant violation of a

. Technical Specification Limiting Condition for Operation. The RHR system j valve alignment during these events did not result in two inoperable l subsystems of the ECCS requiring action in accordance with Technical Specification 3.0.3. An operable subsystem must be capable of performing its specified function. As discussed above, an ECCS subsystem could still perform its intended, i.e. specified, function. Therefore, no violation of a Technical Specification Limiting Condition for Operation Action Statement existed during these events.

Notwithstanding our belief that Item 1 was wrongfully classified as a Severity Level III violation, even if it is properly classified we believe that there is an adequate basis for mitigating the proposed civil penalty.

The five factors contained in Section V.B of 10 CFR Part 2, Appendix C are addressed in Attachment B.

With respect to violations IIA through F, Commonwealth Edison has taken corrective actions to enhance the programs and controls for assuring compliance with Technical Specifications. However, Commonwealth Edison does not share the NRC's conclusion that these events collectively demonstrate inadequate management. Our investigation of the events shows that they were mainly isolated errors which resulted from disparate root causes.

Nevertheless, the Enforcement policy provides the NRC Staff considerable discretion to accumulate violations for evaluation in the aggregate. Because such exercises of staff discretion have traditionally been sustained by the commission, we have determined that the probability of successfully challenging l

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Mr. J. M. Taylor July 3, 1986 the staff's determination to evaluate these deficiencies collectively is too low to warrant appealing this decision. Accordingly, Commonwealth Edison has enclosed a check in the amount of $50,000 for payment of this proposed civil penalty.

Please direct any questions regarding these matters to the Director of Nuclear Licensing.

Very truly yours,

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Bide Thomas Executive Vice President Im Enclosure Attachments j cc: J. G. Keppler - Region III M. C. parker - IDNS SUBSC BED AND SWORN to befok mg this W day of ( n (4- , , 1986

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ATTACHIENT A ITEM 1 Technical Specification (TS) 3.5.2 requires that two independent emergency core cooling system (ECCS) subsystems shall be operable with each subsystem comprised in part of one residual heat removal (RHR) pump and an operable flowpath when in Modes 1, 2, or 3.

Technical Specification 3.0.3, which applies when TS 3.5.2 is not met and if two RHR pumps are inoperable, requires that within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the licensee shall initiate action to place the unit in a mode in which the specification does not apply by placing it, as applicable, in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , at least hot shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and at least cold shutdown within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The definition of operability for the injection path for the ECCS is discussed in the Byron Unit 1 PSAR, Section 6.3 where it states that each RHR subsystem injects into all four cold legs of the reactor coolant system.

Contrary to the above, on March 6, 1985 for approximately 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , March 7, 1985 for approximately 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , April 20, 1985 for approximataly 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months , April 23, 1985 for approximately 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , May 30, 1985 for approximately 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , May 31, 1985 for approximately 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and on July 24, 1985 for 3 separate periods of approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , while in Mode 1, both RHR subsystems of the ECCS were rendered inoperable during surveillance testing in that neither RHR pump was capable of injecting, as stated in the PSAR, into all four reactor coolant system cold legs due to the fact that valves 1RH8716A and ISI8809A for RHR pump A and valves 1RH8716B and ISI8809B for RHR Pump B were closed while system performance was being measured.

DENIAL OF THE ALLEGED VIOLATION Commonwealth Edison denies that both subsystems of the emergency core cooling system were inoperable during surveillance testing on the various occasions listed in the alleged violation. This is in part because Commonwealth Edison disagrees with the NRC's statement of the definition of operability for the injection flow path for the emergency core cooling system (ECCS). Consequently, Commonwealth Edison denies that Technical Specificatioris 3.5.2 and 3.0.3 were violated.

Operability of an ECCS Subsystem Technical Specification 3.5.2 defines an operable ECCS subsystem to be comprised of: (a) one operable centrifugal charging punp, (b) one operable safety injection pump, (c) one operable RHR heat exchanger, (d) one operable RHR pump, and (e) an operable flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatic opening of the containment sump suction valves.

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! The Technical Specifications also define a subsystem to be operable if it is " capable of performing its specified function". The issue here was l

whether a subsystem of the ECCS was operable with the RHR flowpath limited

to injection into two of the four RCS cold legs. For the following reasons, l we believe that an ECCS subsystem was operable under those conditions.

The specified function of an ECCS subsystem is stated in Chapter l 6.3 of the Byron /Braidwood FSAR. "

The primary function of the ECCS is to ,

i remove the stored and fission product decay heat from the reactor core

! during accident conditions" (FSAR page 6.3-1). The PSAR further states "The

design bases for selecting the functional requirements of the ECCS are

! derived from Appendix K limits for Fuel Cladding Temperature... The I subsystem. functional parameters are selected to integrate so that the Appendix K requirements are met..." (FSAR page 6.3-1). "The Emergency Core Cooling System (ECCS) components are designed in order that a minimum of three accumulators, one charging pump, one safety injection pump, and one a residual heat removal pump together with their associated valves and piping

! will ensure adequate core cooling in the event of a design-basis LOCA".

(FSAR page 6.3-2; Section 6.3.2)

These PSAR statements regarding the specified function of the BCCS show that an ECCS subsystem is operable if it is capable of limiting peak

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clad temperature to within specified limits following a LOCA.

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The FSAR LOCA analysis considers both large and small break l'

events. Since the small break LOCA analysis is not dependent upon RHR flow, the small break LOCA results are not dependent upon RHR system valve alignment. However, because the large break LOCA event relies on RHR flow

delivery, its analysis was reviewed to determine the impact of having one

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SI8809 valve and one RH8716 valve closed concurrently. With.this RHR system

! valve alignment, only one RRR pump would be available to inject into two of the RCS cold legs. For the large break LOCA analysis with minimum safeguards actuation (one ECCS subsystem actuation), Westinghouse conservatively assumed that the broken RCS cold leg is one of the two aligned to receive RRR injection flow. With this configuration, the RHR pump can deliver 190

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! lbs/sec. during the core reflood phase rather than the 390 lbs/sec flow l

currently modeled. Early in the large break LOCA scenario, the accumulators inject to fill the downcomer of the reactor completely. Then the ECCS pumps I must supply sufficient flow to maintain the downcomer level during core i reflood. The centrifugal charging and safety injection pumps together can l supply 110 lbs/sec. and this flow combined with the RHR pump flow of 190 lbs/sec. results in flow to the RCS of 300 lbs/sec. Westinghouse's review I of the analysis indicates that 300 lbs/sec. is adequate flow to maintain the

downconer water level. This flow was available here. Therefore, very

! little or no penalty in calculated peak clad temperature can occur in the i Byron minimum safeguards large break LOCA FSAR analysis due to one SI8809

and one RH8716 valve being closed concurrently. The increase in peak clad temperature is estimated to be less than 10*F and therefore the predicted peak clad temperature remains well below the limit established in 10 CPR 50.46.

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3-For these reasons, an ECCS subsystem was capable of performing its specified functio' nduring the surveillance testing periods and was therefore

, operable.

However, recognizing that closure of an SI8809 valve and RH8716 valve concurrently isolates the automatic injection path of one RHR pump, l the Station entered the Technical Specification 3.5.2 Action Statement during the surveillance testing periods. This Action Statement allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for restoration of an ECCS subsystem. At no time was this 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months clock exceeded during the surveillance testing periods. Consequently, Technical Specifications 3.5.2 and 3.0.3 were not violated.

Definition of Operability of the ECCS Iniection Flow Path Item 1 in the Notice of Violation implied that both RHR pumps were inoperable because the injection, i.e., discharge, segments of their i flowpaths were not operable. This was based on the belief that the

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definition of operability for the injection path for the ECCS, discussed in the Byron Unit 1 FSAR, Section 6.3, requires that each RHR subsystem inject into ali four cold legs of the reactor coolant system.

Contrary to Item 1, Section 6.3 of the FSAR does not state that each RHR subsystem injects into "all four" cold legs of the reactor coolant system (RCS). Rather, the FSAR speaks only of injection "into" the RCS or delivering flow "to" the cold legs. Moreover, FSAR Figure 6.3-2 (referenced in inspection report 50-454/85-042) only depicts the maximum safeguards flow path available. It does not indicate the minimum flow path necessary for operability.

For the preceding reasons, we disagree with the NRC's interpretation that each RHR subsystem must inject into all four RCS cold legs for the ECCS injection path to be considered operable. Therefore, we disagree with the conclusion that there was no operable flow path for the

, ECCS subsystems. Rather, for the reasons discussed above, the ECCS injection flow path was operable during the surveillance testing periods.

i l Operability of a RHR Subsystem t

Technical Specification 3.5.2 does not refer to operability of a RHR subsystem, but rather to the operability of an ECCS subsystem. The i operability of an ECCS subsystem has been addressed earlier in this response. Although it is not clear from the Notice of violation, it appears that the terms RHR subsystem and ECCS subsystem have been used interchange-ably. Accordingly, we believe the operability or inoperability of a RHR subsystem presents no new issue regarding compliance with Technical 4

Specification 3.5.2.

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4 CORRECTIVE ACTIONS i

Although Commonwealth Edison disagrees that Technical Specifications 3.5.2 and 3.0.3 were violated by concurrently closing valves SI8809 and RH8716 during surveillance testing, actions have been taken to avoid this situation again.

1 Byron Operating Procedures (BOP's), Operating Surveillance (BOS's),

General Procedures (BGP's), and Technical Staff Surveillances (BVS's) for i

the RH, SI, CV, RC, and CS systems were reviewed.

1 Operating procedures which specifically addressed closing the 4

SI8809 and RH8716 valves were BOP's RH-3, 4, 5, 6 and 7. Temporary changes j were n'ede prior to the next execution of these procedures and permanent changes were made to these procedures on May 5, 1986 as part of the Byron /Braidwood procedure standardization process. Statements were added in the Limitations and Action section of these procedures which also address when these valves are allowed to be closed and the operating modes that apply.

> The Technical Staff Surveillances that were revised to prevent closing a SI8809 and RH8716 valve are IBVS 5.2.f.3-1, IBVS 5.2.f.3-2, 1BVS 5.2.f.2-1 and IBVS 4.6.2.2-1. The other procedures which were reviewed were found acceptable.

In addition, the main control board switches for the SI8809 and RH8716 valves were tagged to advise reactor operators to maintain the valves in the open position during Modes 1, 2, 3 and 4.

i An operating Clarification was issued to operating personnel

! indicating the Modes in which these valves are required to be open.

i Subsequently, a Technical Specification Interpretation was issued replacing l the Operating Clarification. The Technical Specification Interpretation serves as a reminder to operating personnel on the required position of these valves during the applicable modes.

Independent of the Station review, a separate review of RCS and ECCS Technical Specification surveillances was conducted by the Westinghouse Site Engineering Team. The review was directed at identifying other similar situations where procedural steps may be inconsistent with assumptions in the accident analyses. No similar situations were identified. This review was completed February 26, 1986.

The majority of the actions discussed above were completed by the end of August, 1985. Since July 31, 1985, there have been no incidents of l SI8809 and RH8716 valves being closed concurrently in Modes where operability l

of ECCS subsystems is required.

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i ATTAQWENT B Commonwealth Edison believes an adequate basis exists for full mitigation of the proposed $50,000 civil penalty related to Item I in the Notice of Violation. The five factors in Section V.B of 10 CFR Part 2, Appendix C are addressed below.

i 1 Prompt Identification and Reportinq l

The base penalty may be reduced by 50% if the licensee promptly

, identifies and reports a violation to the NRC. That was the case here. The i Station, through its active program of keeping abreast of developments in the nuclear industry, monitors the INPO Network Exchange for events which may be applicable to the Station. That monitoring led the Station to identify a potential concern through review of information concerning an incident at callaway Station. The onsite Nuclear Safety Group formally notified the Station of a potential concern on July 17, 1985. On July 25,

1985, the Station's compliance Group received a copy of Callaway's LER abstract and issued a concern sheet to the Primary Group requesting it to 1 investigate the incident. By July 31, 1985, the results of that investiga-tion had already led to the Station's issuance of an LER. This demonstrates i

prompt identification and reporting by the Station. This is acknowledged in reference (c). Since Byron Station personnel identified the event at the 3

l first available opportunity for discovery, the Station should be given full credit for promptly identifying and reporting the events.

Corrective Actions i Unusually prompt and extensive corrective actions including actions to prevent recurrence support the reduction of a civil penalty by as much as

! 50%. Our corrective actions were comprehensive. They were initiated and

! pursued to conclusion under our own initiative and went far beyond the narrow I confines of the violation. The corrective actions for these events were l taken as promptly as possible consistent with the nature of these actions and full credit should be given for this timeliness, once the situation was l identified, temporary changes to permanent procedures were instituted to prevent closing a SI8809 valve concurrently with a RH8716 valve. Incidents

of closing these valves did not recur after July 31, 1985. Extensive

! procedure reviews were performed to address this concern. For all these

! reasons, the penalty should be reduced by the full 50%.

i Past Performance i A civil penalty may be reduced by up to 100% of the base amount for good prior performance in the general area of concern. However, the base l

civil penalty may be increased for prior poor performance in the general

area of concern. In the Station's view, its prior performance in this area j has been good. In this regard, the Station does not agree that the events j leading to the June 5, 1985 Severity Level IV Notice of Violation were e

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relevant. That event involved the isolation of two safety injection pumps

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while the plant was in Mode 3. The Station's corrective actions, as stated in the July 10, 1985 letter, included reviewing and revising all operating procedures involving ECCS systems that could affect Technical Specification LCO's. These corrective actions were taken to ensure that operators would follow procedures. Here, procedures were followed. Therefore, those corrective actions were not relevant to this event for which following instructions led to an improper valve alignment.

The SI pump event was considered a violation because 10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings and shall be accomplished in accordance with these instructions, procedures or drawings." Byron Operating Procedure (BOP) SI-9, provides for isolating a charging flowpath to the SI accumulators. Contrary to this, the operator performed steps not contained in BOP SI-9 thereby isolating both SI pumps from the RCS cold leg injection header. The operator did not accomplish a procedure in accordance with the documented instructions. As part of the corrective actions, we performed a review of all operating procedures involving ECCS systems to determine those procedures that could impact Technical Specification LOO's. Any affected operating procedures were revised.

Thus, this event is dissimilar to that SI pump event because the RHR pump surveillances here were performed in full accordance with procedures reviewed and approved by the Station. No actions were taken contrary to established procedures.

Moreover, review of the ECCS operating procedures'for the SI pump event also would not have been expected to identify the concern with the RHR system valve alignment because the Station understood the particular RHR system valve alignment to be acceptable. This understanding was consistent with that of other utilities. The Westinghouse Standard System Description included closing those valves as a recommended method for performing some RH system surveillances.

i I' Also contributing to our belief that the surveillance was acceptable was a satisfactory NRC review of the surveillance procedure to ensure it was consistent with the FSAR and proposed Technical Specification. This was documented in Inspection Report No. 50-454/84-42. In addition, our Resident Inspectors witnessed the execution of the surveillance and verified that the l

LCO was being met. This was documented in Inspection Report 50-454/85-21.

i From all indications, this was an acceptable valve configuration for performing the RHR pump surveillance and therefore would not be identified in the original procedure review performed in response to the SI

! pump event. For these reasons, the SI pump event does not indicate past poor performance for the purposes of evaluating the RHR pump event. Byron I Unit I has been operating for over one and one half years with no similar event documented.

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Prior Notice }

Byron Station first learned that the RHR system valve alignment may be of concern when it learned of the callaway event through review of information provided via the INPO Network Exchange. The Station was not formally notified of this concern as a result of a licensee audit, or specific NRC or industry notification. Effective preventive steps were i taken Lamediately by the Station. Moreover, as the discussion above shows, j until the Callaway event there were several good reasons to believe that the valve alignment was acceptable. Accordingly, there could be no finding of a failure to act upon a prior notice.

Multiple occurrences

- The base civil penalty may be increased as much as 50% where

! multiple examples of a particular violation are identified during the inspection period. The detailed analysis of the times for each surveillance showed that the duration of occurrences is less than stated in the Notice of violation.

The Notice of Violation indicates that both RHR subsystems were inoperable for certain time periods on certain days. In fact, these times were demonstrated not to be accurate and were revised per reference (b).

One SI8809 valve was closed concurrently with one RH8716 valve on March 6,

, 1985 for separate periods of approximately 1.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 0.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , March 7, 1985 for approximately 1.'4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , April 19, 1985 for approximately 1.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ,

! April 20, 1985 for approximately 3.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , April 23, 1985 for approximately j 1.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , May 30, 1985 for approximately 13.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , May 31, 1985 for approximately 8.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , July 23, 1985 for approximately 6.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , July 24, 1985 for separate periods of 5.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 2.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , and July 25, 1985 for approximately 0.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months . The time periods when this valve alignment existed were significantly less than those indicated in the Notice of Violation.

For the reasons discussed earlier, we had no reason to be aware i that a violation was occurring. Once we became aware of the situation, corrective action was taken. Therefore, the separate incidents were classified properly as one violation and should not be considered multiple occurrences for penalty determination.

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4 ATTACISEbfT C

t ITEM II.A Procedura 19063.1.1-21, " Train B SSPS Bimonthly Surveillance,"

requires that whenever an operability surveillance test is performed on the subject system, certain functions including main steam isolation and auxiliary feedwater must be successfully tested before the train can be declared operable.

Contrary to the above, after performing surveillance testing on July 15, 1985, the licensee improperly declared Train B of the solid state l protection system operable even though the main steam isolation and auxiliary feedwater functions had not been verified during the surveillance as being operable.

! Admission of the Alleoed Violation

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We have reviewed the inspector's account of the event and find it to be accurate. We admit that on July 15, 1985, only that the main steam isolation and auxiliary feedwater functional units of the solid state protection system (SSPS) Train B were improperly declared operable from a voided surveillance. However, all functional units of SSPS Train B were

! properly declared operable on July 16, 1985.

Reason for the Violation This violation was caused by an improper administrative disposition of a surveillance.

I Corrective Action Taken and Results Achieved On July 16, 1985, surveillance procedure 1BOS 3.1.1-21 was performed successfully and all functional units of SSPS Train B were properly declared

operable.

Corrective Action to Avoid Further Violation

! A memo was issued to Ghift Engineers informing them that voiding a surveillance is not an acceptable means of dispositioning a surveillance.

Date When Full ConDliance Was Achieved On July 16, 1985, surveillance procedure 1Bos 3.1.1-21 was performed successfully and all functional units of SSPS Train B were properly declared operable.

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ITEM II.B Technical Specification 3.3.2 requires that for Modes 1, 2, and 3, the engineered safety features actuation system (ESPAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be operable. It also states that with an ESFAS instrument channel inoperable, apply the applicable action statement requirements of Table 3.3-3 until the channel is restored to operable status.

Table 3.3-3 requires, in part, that Functional Units 4.b, " Steam Line Isolation, Automatic Actuation Logic and Actuation Relays" and 6.b,

" Auxiliary Feedwater, Isolation Automatic Logic and Actuation Relays," have a minimum of 2 operable channels when the plant is in Mode 1, 2, or 3. If the minimum channel requirement is not satisfied, then Action Statement 21 shall be followed.

Table 3.3-3, Action Statement 21 requires for Functional Units 4.b and 6.b that with less than 2 operable channels be in at least hot standby (Mode 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least hot shutdown (Mode 4) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . However, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1 provided the other channel is operable.

Contrary to the above, on July 14-15, 1985, while in Mode 3, Train B of the ESFAS was declared inoperable, which rendered both required Train B channels for Functional Units 4.b and 6.b inoperable and the plant was not placed in hot shutdown (Mode 4) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The plant was not put in Mode 4 until approximately 19 hours2.199074e-4 days 0.00528 hours 3.141534e-5 weeks 7.2295e-6 months after the ESPAS train was declared inoperable. In addition, Train B of the ESFAS was placed in the bypass

' condition for 10.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , which exceeded the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time limit allowed by technical specifications.

Admission of the Alleged Violation l

f We have reviewed the inspector's account of the event and find it l to be accurate. We admit that Action Statement 21 of Technical Specification 3.3.2 was not properly entered on July 14, 1985.

Reason for the Violation l

Operating shift management incorrectly chose the wrong Action l

Statement due to the complexity and confusion of the Technical Specification l

Limiting conditions for operation.

Corrective Action Taken and Results Achieved Upon discovery of entering the wrong Action Statement, the correct Action Statement (21) was entered.

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Corrective Action to Avoid Further Violation A list of the functional unit tested by each switch position of the SSPS self tester has been made for shift personnel to help clarify the proper Action Requirements of Technical Specification 3.3.2. In addition, clarifications have been made to operating procedures to distinguish between

" train" and " channel" and a provision has been added to check all items affected to assure the most restrictive applicable Action Requirement is followed.

Date When Full Compliance was Achieved Action Statement 21 was entered on July 15, 1985. The clarifications for operating shift personnel discussed above were implemented by November 27, 1985.

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ITEM II.C ,

Technical Epecification 3.11.2.5, " Radioactive Effluents Explosive Gas Mixture,". requires that the concentration of oxygen in the waste gas holdup system shall at all times be limited to less than or equal to 2% by j

I volume whenever the hydrogen concentration exceeds 4% by volume.

Technical Specification 3.11.2.5, Action Statement a., requires that with the concentration of oxygen in the waste gas holdup system greater than 2% by volume, but less than or equal to 4% by volume, the licensee shall reduce the oxygen concentration to the above limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

4 Contrary to the above, even though Special Chemistry Data Sheet, j BCP-400-T.60, Revision 0, which was completed at 11:40a.m. on July 6, 1985

. stated that the waste gas holdup system had a hydrogen concentration of 5.5%

3 by volume and an oxygen concentration of 3.9% by volume, the licensee failed

! to reduce the oxygen concentration to less than or equal to 2% by volume within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This condition existed for approximately 130 hours0.0015 days 0.0361 hours 2.149471e-4 weeks 4.9465e-5 months .

! Ad=ission of the Alleged Violation 1

We have reviewed the inspector's account of this event and find it to be accurate. We admit that Action Statement (a.) of Technical Specification 3.11.2.5 was not properly entered on July 6, 1985.

Reason for the Violation Ineffective communications took place between the Radiation Chemistry Technicians (RCT's) and their supervisory personnel.

i Corrective Action Taken and Results Achieved l

Upon recognition of the out-of-spec condition in the waste gas holdup system, Action Statement (a.) of Technical Specification 3.11.2.5 was l

entered.

I corrective Action to Avoid Further Violation A data sheet has been implemented that is only for gas decay tank data. This new form requires the tank being sampled to be identified on the form and the Technical Specification limits on concentrations have been added to the form to aid the RCT in recognizing an out-of-spec condition.

Other chemistry data sheets were reviewed and revised, as necessary, to aid l

RCT's in recognizing out-of-spec conditions. Discussions were held with RCT's to emphasize the importance of bringing out-of-spec conditions to the immediate attention of their supervisors. The necessity for completeness and legibility on all data sheets was also addressed with the RCT's.

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L Data When Full Compliance was Achieved Technical Specification 3.11.2.5 Action Statement (a.) was entered on July 11, 1985. However, the time allowed in this Action Statement was exceeded by five hours (see item II.D).

The actions discussed above to avoid further violation were completed by September 27, 1985.

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ITEM II.D Technical Specification 3.11.2.5, " Radioactive Effluents Explosive Gas Mixture," requires that the concentration of oxygen in the waste gas holdup system shall at all times be limited to less that or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume.

Technical Specification 3.11.2.5 Action Statement b., requires that with the concentration of oxygen in the waste gas holdup system greater than 4% by volume, and the hydrogen concentration greater than 4% by volume, the l

licensee shall immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or equal to 4% by volume; then take Action a. above.

Contrary to the above, even though Special Chemistry Data Sheet, BCP-400-T.60, Revision 0, which was completed at 9:20p.m. on July 11, 1985, stated that the hydrogen concentration was 4.1% by volume and the oxygen concentration 10.8% by volume and the licensee did not benediately take action to reduce the concentration of oxygen to less than or equal to 4% by j volume. This condition existed for approximately 53 hours6.134259e-4 days 0.0147 hours 8.763227e-5 weeks 2.01665e-5 months .

i Admission of the Alleged Violation

! We have reviewed the inspector's account of the event and find it

to be accurate. We admit that Action Statement (b.) of Technical Specification 3.11.2.5 was not properly followed on July 11, 1985.

I Reasons for the Violation i

Actions taken to reduce the out-of-spec concentrations in the waste l

i gas holdup system did not allow for delays caused by equipment failure. A i

restrictive procedure which only allowed one waste gas decay tank to be i

released at a time also contributed to this event.

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) Corrective Action Taken and Results Achieved i

Approximately five hours after the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months clock of Technical l Specification 3.11.2.5 Action Statement (a.) had expired, the gas

' concentrations in the waste gas holdup system were brought into specification.

Corrective Action to Avoid Further violation i

Technical Specification Action Requirements which have been entered j

and are in progress are now discussed in the Station's plan of the Day meeting. A red stamp, "LCOAR", is now used on all nuclear work requests l that are written and involve a critical Technical Specification LCOAR condition. This stamp is used by all departments handling the nuclear work request form to further emphasize the importance of the timeliness of the j

work.

Date When Full Compliance was Achieved I The gas concentrations in the waste gas holdup system were within j specifications on July 14, 1985. The administrative actions discussed above i were implemented by August 30, 1985.

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Item II.E Technical Specification 3.3.3.10 requires that the radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-13 shall be operable as stated in the table.

Technical Specification 3.3.3.10, Action Statement b. requires that with less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels operable, the licensee shall take the action shown in Table 3.3-13.

Table 3.3-13, Instrument 3.a, Hydrogen Analyzer OAT-GW8000, requires a minimum of one channel to be operable during waste gas holdup system. operation or Action Statement 38 shall be applied.

Table 3.3-13, Instrument 3.b, Oxygen Analyzers OAT-GW8003 and OAT-GW8004, requires a minimum of 2 channels to be operable during waste gas holdup system operation or Action Statement 38 shall be applied.

Table 3.3-13, Action Statement 38 requires that with the number of channels operable one less than required, operation of the waste gas holdup system may continue provided grab samples are taken from the system and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Contrary to the above, from July 28 to August 4, 1985, with the waste gas holdup system operating and with all Hydrogen Analyzer OAT-GW8000 and Oxygen Analyzer OAT-GW8003 channels inoperable, grab samples were not taken and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Admission of the Alleged Violation We have reviewed the inspector's account of the event and find it to be accurate. We admit that Action Statement (b.) of Technical Specification 3.3.3.10 was not followed from July 28 to August 4, 1985.

Reason for the Violation The daily grab sample requirement of the Action Statement was improperly terminated. The means of tracking the sample requirement was inadvertently erased from the status board in the Radiation Chemistry Department office.

Corrective Action Taken and Results Achieved Upon discovery of the error on August 5, 1985, the daily grab sampling was resumed.

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Corrective Action to Avoid Further Violation A Limiting Condition for Operation Action Requirement (LCOAR) tracking program has been implemented which provides a documented means of tracking LCOAR's involving a grab sample surveillance. This program also involves direct interfacing of supervisory personnel in the Radiation Chemistry and Operating Departments to review the status and results of the surveillances.

Termination of a surveillance is now authorized by a SRO.

This program was discussed individually with each Radiation Chemistry Foreman and Shift Foreman by the Lead Health physics Foreman. This program should help eliminate missed grab sample surveillances.

Date When Full Compliance was Achieved On August 5, 1985, the daily grab sampling required by Technical Specification 3.3.3.10 Action Statement (b.) was resumed.

The LCOAR tracking program was initiated and discussions with Radiation Chemistry and Shift Foremen were completed by September 10, 1985.

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ITEM II.P -

10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished Instructions, in accordance with these instructions, procedures or drawings. -

procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

permanent Facility Modification (pFM) #M6-0-84-242 was used by the licensee to install a blank-off plate in the control room ventilation Train OA makeup ductwork.

Technical Specification (TS) 3.7.6 requires two independent control room ventilation systems to be operable for Modes 1, 2, 3 and 4. With one of two independent control room ventilation systems inoperable, the system must be restored in 7 days or the plant must be in hot standby within the next six hours and in cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If two control room ventilation systems are inoperable, TS 3.0.3 applies, which requires that actions be initiated within one hour to place the unit in a mode in which the specification does not apply by placing it as applicable in at least hot standby within the nex" six hours and at least hot shutdown within the following six hours.

Contrary to the above, on September 5, 1985, pFM #M6-0-84-242 did not contain appropriate quantitative or qualitative acceptance criteria for determining that the installation of the blank-off plate was satisfactorily accomplished. As a result, the blank-off plate was installed in the wrong location. Plant personnel did not discover the error until September 13, 1985 when Train OA was used and it could not maintain the required differen-tial pressure. Since one train had been inoperable from September 5-13, 1985, without the plant being put in the required mode, this was a violation of TS 3.7.6. Train OB was also rendered inoperable by theAslicensee on a result, both September 12, 1985, at 6:20 p.m. to perform maintenance.

control room ventilation trains were simultaneously inoperable, in13,violation 1985.

of TS 3.0.3 until Train OA was restored at 1:20 p.m. on September Admission of the Alleged Violation We have reviewed the inspector's account of the event and find it to be accurate. We admit that modification M6-0-84-242 did not contain drawings appropriate to the circumstances and that Technical Specifications 3.7.6 and 3.0.3 were violated on September 12, 1985.

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4 Reasons for the Violation The drawings associated with modification M6-0-84-242 were confusing and not accurate and construction personnel did not notify the Operating Department of work involving a temporary alteration or modification. In addition, a single electrical feed was taken out-of-service which affected multiple unidentified loads.

Corrective Action Taken and Results Achieved Upon discovery of the inoperable control room ventilation system, Technical Specification Action Statement 3.0.3 was entered. Electrical power was restored to the OB train of control room ventilation and it was declared operable. The blank-off plate was removed from its wrong location in the HVAC ductwork and a new plate was installed in the correct position.

The OA train of control room ventilation was declared operable.

Corrective Action To Avoid Further Violation The power distribution book used by the Operating Department was revised to include identification of all electrical feeds with multiple loads on January 21, 1986.

The Project Construction Department (PCD) was directed to review HVAC drawing conventions with personnel responsible for interpreting them, including the personnel involved with improperly installing the blank-off plate. PCD personnel have been counseled on the requirements of the Temporary Alteration Program (i.e., the Shift Engineer's approval must be obtained before any Temporary Alteration is removed). These actions were completed by November 25, 1985.

Date When Full Compliance was Achieved Both trains of the control ventilation system were restored to operable status on September 13, 1985.

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ML20199K282

Text

Subject:

Dear Mr. Taylor:

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