ML20215A894
| ML20215A894 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/15/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2110K, NUDOCS 8610060279 | |
| Download: ML20215A894 (4) | |
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Address Reply tz Post Omco Box 767 Chicago, llhnois 60690 - 0767 Septembar 15, 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. 50-454/86025 NRC Docket No. 50-454 Reference (a): August 15, 1986 letter from R. F. Warnick to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of an inspection at Byron 4
Station on July 1 through July 31, 1986. During this inspection, certain activities were found in violation of NRC requirements. Attachment A of this letter contains commonwealth Edison's response to Item 2 of the Notice of Violation appended to reference (a).
Please direct any questions concerning this matter to this office.
Very truly yours, lor D. L. Farrar Director of Nuclear Licensing Im Attachment cc: Byron Resident Inspector 8610060279 860915 2110K PDR ADOCK 0500045A PDf4 G
%o I SEP 16198F
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ATTACHMENT A VIOLATION 2a Technical Specification 3.3.1, Table 3.3-1, Action Statement No. 2 requires that with a Power Range (PR) Nuclear Instrument (NI) channel inoperable that the respective bistables be placed in the tripped condition within six hours, while in Modes 1 and 2.
Contrary to the above, on June 30, 1986, while in Mode 1, from 1049 to 2245 with PR channel N41 inoperable, the high and low Neutron Flux protective trips and positive and negative Neutron Flux Rate High protective trips were not placed in the tripped condition for 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />; thereby l
exceeding the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> limit by 5.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The channel calibration of power range channel N41 was satisfactorily completed and the channel was declared operable at 2245 on June 30, 1986.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION-On July 1, 1986, a Daily Order was issued to shift personnel to j
clarify the action requirements for an inoperable power range channel and what are acceptable means of implementing them when performing surveillance BIS 3.1.1-214, " Surveillance Calibration for the Nuclear Instrumentation System Power Range N41-N44".
A short version of surveillance BIS 3.1.1-214 will be developed, which will be used on a quarterly basis to meet the Technical Specification 93-day surveillance requirements. The procedure will have a step to pull j
the control power fuses within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of declaring the channel inoperable, to document the time and to notify the Shift Engineer of this action. This shortened procedure will be numbered BIS 3.1.1-226, "92 Day NIS Power Range N41-N44".
BIS 3.1.1-214 will be revised to meet the Technical Specification 18 month surveillance requiremer.tu. A requirement will be included in the procedure revision to pull control power fuses within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of declaring the channel inoperable, document the time and notify the Shift Engineer.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The channel calibration of power range channel N41 was satisfactorily completed and the channel was declared operable at 2245 on June 30, 1986.
Procedure BIS 3.1.1-214 will be revised and procedure BIS 3.1.1-226 will be developed by September 30, 1986.
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., VIOLATION 2b Technical Specification 3.4.6.1, Action Statement c.3 requires that with the containment Atmosphere Particulate Radioactivity Monitor and the Containment Gaseous Radioactivity Monitor inoperable that a Reactor Coolant System (RCS) water inventory balance be performed once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while in Modes 1, 2, 3 and 4.
Contrary to the above, on June 14, 1986, while in Mode 1, with the Containment Atmosphere Particulate Radioactive Monitor and the Containment Gaseous Radioactive Monitor inoperable, the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit for performing the RCS water inventory balance was exceeded by 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED During a shift review, it was discovered that the time interval for performing a RCS water inventory balance was er.ceeded. All subsequent surveillances were performed within the required eight hours.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION A memorandum was issued to shift personnel which clarifies how technical specification action requirements with a periodicity are to be properly satisfied. LER 454/86-21, which discusses this missed surveillance, was placed in the required reading program for all licensed personnel.
DATE WHEN PULL COMPLIANCE WILL BE ACHIEVED The subsequent surveillances for a RCS water inventory balance were performed within the reuqired eight hours beginning June 14, 1986.
The memorandum to shift personnel was issued on July 8, 1986. The required reading of LER 454/86-21 by licensed personnel was completed September 3, 1986.
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.,. VIOLATION 2c and d Technical Specification 3.3.1, Table 3.3-1, Functional Unit No. 6.b requires that two Source Range (SR) Nuclear Instrumentation channels be operable in Modes 3, 4 and 5 or else follow Action Statement No. 5.
Table 3.3-1, Action Statement No. 5 requires with both SR channels inoperable, within one hour, open the reactor trip breakers, verify valves ICVillB, ICV 8428, ICV 8439, ICV 8435, and ICV 8441 are secured in the closed position, and suspend all operations involving positive reactivity changes.
Contrary to the above, on July 3, 1986, while in Mode 3, from 0140 to 1142 with both SR channels inoperable, valves ICVlllB, ICV 8428, ICV 8439, ICV 8435, and icv 8441 were not verified to be secured 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 />; thereby exceeding the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit by 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.
On July 3, 1986, while in Mode 3, from 0910 to 1057 with-both SR channels inoperable, positive reactivity was added to the core by cooling down the Reactor Coolant System from 557 to 535'F; thereby exceeding the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit by 0.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery of the source range channels inoperability, valves
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ICVlllB, ICV 8428, ICV 8439, ICV 8435 and ICV 8441 were secured 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 />. In addition, the cooldown to cold shutdown (Mode 5) was halted and the RCS was stabilized at 535'F and 2000 psig.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION The Technical Staff engineer involved with the deficiency discussed in LER 454/86-015 was personally counseled about the importance of effective implementation of corrective action. The matter was discussed at Technical Staff Group Leader meetings and at the August Technical Staff department meeting. Emphasis was made concerning written communications, i.e., placing instructions in operating standing' orders or in daily orders.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Instruction on the importance of effective implementation of corrective action was given to all Technical Staff personnel by August 13,
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