ML20234E864
| ML20234E864 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/10/1987 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20234E841 | List: |
| References | |
| 3186K, NUDOCS 8707080021 | |
| Download: ML20234E864 (3) | |
Text
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' Commonwealth Edison
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44 One First National Plaza, Chicago, Illinois -
C Address Reply to: Post Office Box 767.
. Chicago, Illinois 60690 - 0767 June 10, 1987 Mr.'A. Bert Davis Regio".L1 Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road
- Glen Ellyn, IL 60137-e
Subject:
Byron Station Unit 1 I & E Inspection Report No. 50-454/87-016 NRC Docket No. 50-454 Reference (a).: May 11, 1987 letter from C.W. Hehl to Cordell Reed
Dear Mr. Davis:
Reference (a) provided the results of an inspection by Ms.
Rescheske and Ms. Azab at Byron Station on April 1-9, 1987. During this inspection, certain activities were found in violation of NRC requirements.
Attachment A of this' letter contains Commonwealth Edison's response to the Notice of Violation enclosed with reference (a),
our review of the violation presented in reference (a) has not concluded this item is properly classified as Severity Level IV.
This violation involved documentation for a surveillance to verify the water level in the reactor cavity and spent fuel pit is maintained within Technical Specification limits during refueling operations. Since the water level was always maintained within Technical Specification limits, we believe this documentation problem would be more appropriately classified as Severity Level V.
Additionally, the Inspection Summary on page 1 of the inspection report states this violation is of minor safety significance. This is consistent with the description of a severity Level V violation in Supplement 1 of the NRC Enforcement policy (10 CFR 2, App. C).
For these reasons, we request the HRC to consider reclassifying this violation to Severity Level V.
Please direct any questions regarding this matter to this office.
Very t ly yours, B7070B0021B{O
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D D4
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ADOCK O PDR
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PDR D. L. Farrar O
Director of Nuclear Licensing Attachment cc: Byron Resident Inspector JUN 121997 3186K
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ATTACHMENT A VIOLATION Technical Specifications, Section 6.8.1.a. states that written procedures shall be established, implemented, and maintained for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2.
Procedures for surveillance tests listed in the Technical Specifications are required to be written by Part 8.b of Appendix A.
Surveillance Procedure 1BOS 0.1-6,
" Unit One Mode 6 Shiftly and Daily Operating Surveillance," requires that reactor cavity water level be determined in accord 6nce with Temporary change No. 87-1-283.
SFP level is also required to be documented. These surveillances are used to satisfy Sections 4.9.10 and 4.9.11 of the Technical Specifications.
Contrary to the above, the licensee failed to adhere to Procedure IBOS 0.1-6 during the Byron Unit 1 core reload, in that, the cavity and SFP levels were not properly documented.
CORRECTIVE ACTION TAKEN AND RESULTS ACHlFVED Upon discovery that the spent fuel pit and reactor cavity water levels were not being correctly documented, a daily order was issued by the operating department to advise equipment attendants of the difference in the reference water level for the reactor cavity and the spent fuel pit. Since issuance of the daily order, the water levels were properly documented during the surveillances, i
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION Byron operating procedure BOP 199-A70 was revised to indicate unit specific level readings and clarify the reference level difference.
Additionally, a memo was written to all operating department personnel re-emphasizing the requirements of Technical Specification 6.8.1.a.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED The daily order mentioned above was issued April 8, 1987. A temporary change to BOP 199-A70 was issued June 5, 1987 and the permanent procedure change was made June 8, 1987.
The memo to operating department I
personnel was issued June 3, 1987.
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