ML20213A409

Notice of Violation from Insp on 870217-0313.Violations Noted:Failure to Adhere to Tech Spec Time Requirements When Two Trains of Nonaccessible Area Exhaust Filter Plenum Inoperable & When Both UHS Cooling Towers Inoperable

ML20213A409
Person / Time
Site:	Byron
Issue date:	04/20/1987
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213A405	List: IR 05000454/1987011 ML20213A409
References
50-454-87-11, 50-455-87-10, NUDOCS 8704270544
Download: ML20213A409 (2)

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, NOTICE OF VIOLATION Comonwealth Edison Company Docket Nos. 50-454; 50-455 i

i As a result of the inspection conducted on February 19 - March 13, 1987, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the following violations were identified:

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1. Technical Specification 3.0.3 requires that when a Limiting Condition for Operation (LCO) is not met, except as provided in the associated action requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a mode in which the s)ecification does not apply by placing

the unit in at least Hot Standby Mode 3] within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; in at least Hot Shutdown [ Mode 4] within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; and in at

. least Cold Shutdown [ Mode 5] within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l Technical Specification 3.7.7 requires that three independent

. Non-Accessible Area Exhaust Filter Plenums be operable while in Modes 1, i 2, 3, and 4. The action requirement for this specification allows only one non-accessible area exhaust filter plenum to be inoperable at a time.

Contrary to the above, from 1635 on February 17, 1987 to 1800 on February 18, 1987, with Unit 2 in Mode 1 dampers OVA 026YA, OVA 026YB, OVA 026YC, 0VA030YA, OVA 030YB, 0VA030YC, OVA 034YA, OVA 034YB, OVA 034YC i OVA 038YA, OVA 038YB, 0VA038YC, OVA 042YA, OVA 042YB, OVA 042YC, OVA 046YA, OVA 046YB, and OVA 046YC were shut, rendering the A and B non-accessible area exhaust filter plenums inoperable.

With two trains of non-accessible area exhaust filter plenum inoperable, j in excess of the action requirements of Technical Specification 3.7.7, action was not initiated within one hour to place Unit 2 in Mode 3 within the next six hours. The unit was not placed in Mode 3 within the next six hours and was not placed in Mode 4 within the following six hours.

I This is a Severity Level IV violation (Supplement I). (455/87010-01(DP.P))

2. Technical Specification 3.0.3 requires that when a Limiting Condition for l Operation (LCO) is not met, except as provided in the associated action i' requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a mode in which the s)ecification does not apply by placing the unit i in at least Hot Standby [ Mode 3] within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

i Technical Specification 3.7.5 requires, in part, that two ultimate heat sink (UHS) cooling towers be operable, each with one operable essential service water makeup pump per train while in Modes 1, 2, 3, and 4. The action requirement for this specification allows only one essential service water makeup pump to be inoperable at a time.

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8704270544 870420

! PDR ADOCK 05000454

O PDR

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- Notice of Violation 2 i

l Byron Administrative Procedure, BAP 300-1, " Conduct of Operations," l Paragraph C.3.cc, requires that a component whose control switch is in the " pull-to-lock" position be considered inoperable. l 1

Contrary to the above, from 2210 on February 18,1987 to 0015 on February 19, 1987, with Unit 2 in Mode 1, the local control switch for essential service water makeup pump OSX02PB was in the off position and the remote control switch for essential service water makeup pump OSX02PA was in the

, pull-to-lock position, rendering both of the essential service water makeup pumps inoperable; and consequently, rendering both UHS cooling towers inoperable.

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With both of the UHS cooling towers inoperable in excess of the action requirements of Technical Specification 3.7.5, action was not initiated within one hour to place Unit 2 in Mode 3 within the next six hours.

j This is a Severity Level IV violation (Supplement I) (455/87010-02(DRP))

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Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action

-! taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

APR 2 01981 i

Dated Charles E. Nore11us, Director i

Division of Reactor Projects 1

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