ML20217C376
| ML20217C376 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/17/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-98-08, 50-454-98-8, 50-455-98-08, 50-455-98-8, BYRON-98-0130, BYRON-98-130, NUDOCS 9804230288 | |
| Download: ML20217C376 (4) | |
Text
Commonwealth 141ison G>mpany 11)ron Generating Station 4 WI North German Churt h Ito.id H) ron,11. 61010 9791 Tcl H15 2M5 H1 April 17, 1998 LTR:
BYRON 98-0130 FILE:
1.10.0101 l
U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/98008; 50-455/98008 NRC Docket Numbers 50-454, 50-455 i
Reference:
John A. Grobe letter to Mr. Kingsley dated March 20, 1998, transmitting NRC Inspection Report 50-454/98008; 50-455/98008 Enclosed is Commonwealth Edison Company's response to the Notice of violation (NOV) which was transmitted with the referenced letter and Inspection Report.
The NOV cited one (1) Severity Level IV violation requiring a written response.
Comed's response is provided in the attachment.
l This letter contains the following commitments:
/
1)
Review BCP 300-77 to determine whether enhancements can be l
made to eliminate the repetition needed to strip gas from a g
reactor coolant sample, y
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9804230288 900417 PDR ADOCK 05000454 G
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Byron Ltr. 98-0130
' April' 17, 1998 Page 2 If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully, d
L.
a ser Site Vice President Byron Nuclear Power Station l
KLG/DB/rp Attachment (s) cc:
A.
B.
Beach, NRC Regional Administrator - RIII J.
B.
Hickman, Byron Project Manager - NRR E.
W.
Cobey, Senior Resident Inspector, Byron M.
J.
Jordan, Reactor Projects Chief - RIII F.
Niziolek, Division of Engineering - IDNS l
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9 ATTACHMENT I VIOLATION (454/455-98008-01)
Technical Specification 6.8.1 requires, in part, that written procedures be j
established, implemented, and maintained covering the applicable procedures i
recommended in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978.
l Regulatory Guide 1.33, Appendix A recommends that procedures be implemented which specify chemistry instructions and the calibration of laboratory instruments.
Step F.9.h of procedure BCP 300-77 (Revision 9), " Preparing a Pressurized Liquid Sample for Analysis Using the Degassing Panel," dated February 13,.
1998, requires that valve V8 (degassing panel buret isolation) be closed prior to withdrawing gas samples from the panel for hydrogen and isotopic analysis.
Contrary to the above, on March 6, 1998, a chemistry technician failed to close valve V8 before withdrawing 2 gas samples from the panel for hydrogen and isotopic analysis.
This is a Severity Level IV Violation (supplement I).
(50-454/455-98008-01(DRP))
REASON FOR THE VIOLATION we agree with the violation. The Chemistry Technician failed to follow Byron Chemistry Procedure (BCP) 300-77, as written, due to inattention to detail.
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A contributing cause is the repetitive nature of section F.9 of BCP 300-77, covering the stripping of gas from the reactor coolant sample.
Steps F.9.f through F 9.h requires the technician to start a sample pump and cycle valve V8 to remove gas from the sample. These steps are required to be repeated a minimum of five (5) times.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
Upon identification that the valve had been left open, the sample and analysis were considered invalid. Additional sampics were obtained, and the analysis was properly performed.
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2.
The Chemistry Technician was counseled as to the importance of verbatim procedural adherence and the effects procedure adherence has on providing accurate sample results.
1 3.
The violation and importance of verbatim procedural adherence was
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discussed with all Chemistry Technicians during a weekly departmental safety meeting.
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l l-CORRBCTIVE* STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION l
1.
Review BCP 300-77 to determine whether enhancements can be made to eliminate the repetition needed to strip gas from a reactor coolant sample.
This action will be tracked by NTS item #454-100-98-00801-01.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on March 6, 1998, when the sample and analysis were performed in accordance with the existing procedure.
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