ML20217Q967
| ML20217Q967 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217Q928 | List: |
| References | |
| 50-454-98-09, 50-454-98-9, 50-455-98-09, 50-455-98-9, NUDOCS 9805130048 | |
| Download: ML20217Q967 (3) | |
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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2 License Nos. NPF-37; NPF-66 During an NRC inspection conducted on February 24 through April 6,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
1.
Technical Specification 3.0.4 required that entry into an operational mode shall not be made when the conditions for the Limiting Condition for Operation (LCO) are not met and the associated action required a shutdown if they are not met within a specified time interval.
Technical Specification 3.4.6.1.b requires that the containment floor drain and reactor cavity flow monitoring systems shall be operable in Modes 1,2,3, and 4. With the required leakage detection systems inoperable, restore to operable status within 7 days; otherwise be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on February 27,1998, Unit 1 changed operational mode from Mode 5 to Mode 4 when the conditions for the LCO of TS 3.4.6.1.b were not met and the associated action required a shutdown if they were not met within a specified time interval. Specifically, the floor drain in the Unit 1 seal table room was plugged causing the containment floor drain system to be inoperable.
This is a Severity Level IV violation (Supplement I) (50-454/98009-01(DRP))
2.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, procedures were not appropriate to the circumstances in the following instances:
a.
From January 7 through March 17,1998, Byron Operating Procedure VC-2,
" Shutdown of Control Room HVAC [ Heating, Ventilation, and Air Conditioning]
System," Revision 2, an activity affecting quality, was not of a type appropriate to the circumstances, in that, it did not provide direction to secure the main control room supply, retum, or make-up air filter fans or provide appropriate guidance to verify damper positions when the control room ventilation system described in the Updated Final Safety Analysis Report, Section 9.4.1, as a safety-related system, was secured from the main control room.
b.
Prior to April 6,1998, Byron Administrative Procedure (BAP) 1600-1, " Action / Work Request Processing Procedure," Revision 41, was not of a type appropriate to the circumstances, in that, work requests in a " hold" status were not controlled by written procedural requirements. Consequently, work was performed on the 1B Essential Service Water pump without an authorized work request.
This is a Severity Level IV violation (Supplement I), (50-454/455-98009-02(DRP))
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Technical Specification 6.8.1.a states that written procedures shall be established, implemented and maintained for procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1918.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Paragraph 7.e(4),
specifies contamination control as an example of a radiation protection procedure.
Byron Radiological Protection Procedure 5010-1, " Radiological Posting and Labeling Requirements," Revision 15, Paragraph F.3 states, in part, that any radiologically posted area shall be conspicuously posted so as to wam personnel approaching the area from any direction.
Contrary to the above, on March 9,1998, the inspectors identified that an established contamination area within the 1 A safety injection pump cubicle was not conspicuously posted so as to wam personnel approaching the area from any direction.
This is a Severity Level IV violation (Supplement 1). (50-454/98009-05(DRP))
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region ill, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each I
violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may refe ence or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in the Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mWit specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will f
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Notice of Violation create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2,790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 5th day of May 1998 l
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