ML20235V488
| ML20235V488 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/07/1987 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8710150188 | |
| Download: ML20235V488 (3) | |
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OCT 0 719871 Docket N'o. 50-454, Docket No; 50-455
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. Commonwealth Edison Company
. ATTN:- : Mr. Cordell Reed Serdor Vice President
. Post Office 1 Box 767 Chicago 1 ILL 60690.'
Gentlemen:-
l This letter provides additional. information in regard to a Notice of Violation
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- issued August 27, D37 as a' result' of an inspect 1on-conducted on July '27-31, 1987, at.the Byron Nuclear Plant.
Due to several telephone conversations between' your staff and mine, enclosed is information' that may clarify our.
position-.on the matter, plus a response.to a question.that your staff raised.
regarding the frequency of emergency preparedness training and drills. [As some of the enclosed.information may impact your response to the Notice of Violation, we. feel that October 13,-1987 is now the. appropriate due date for your response' to the Notice,'of' Violation.
l We' will _ gladly discuss any questions you have concerning' this inspection.
' Sincerely, l
}//jYtvcM/5,k W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch
Enclosure:
As stated l
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See Attached Distribution j
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L i i kojo1 98 871007 G
O'N 05000454 PDR e
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. Commonwealth Edison Company 2
OCT 071987 Distribution cc w/ enclosure:
T. J. Maiman,'Vice President, PWR Operations
- 0. Butterfield, Nuclear Licensing Manager R. E. Querto, Plant Manager
.DCD/DCB (RIDS)
Licensing Fee Management Branch Res'ident Inspector, RIII Byron Resident Inspector, RIII Braidwood D. W. Cassel, Jr., Esq.
Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Diane Chavez, DAARE/ SAFE L, 01shan, NRR LPM H. S. Taylor, Quality Assurance Division D. Matthews, EPB, NRR.
W, Weaver, FEMA, RV i
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ENCLOSURE j
Based on the wording of Byron's Emergency Action Level (EAL) No. 16(B), an Unusual Event should have been declared at about 0300 on March 21, 1987, when on-shift personnel were satisfied that an unidentified leak rate exceeded one gallon per minute.
Relevant Technical Specifications (Tech Specs) were 3.0.2 and 3.4.6.2 (Action Statement "b"),
Unusual Event EAL No.14 was not applicable to the situation until about 0529 when operators began reducing reactor power to better determine the source of the leakage. Thus, the eventual declaration of the Unusual Event shortly after the source of the leak was identified at about 0840 was untimely.
In fact, assuming that the identified leakage was less than the newly applicable ten gallon per minute Tech Spec limit, an 1
Unusual Event could have been terminated shortly after 0840 when the source j
of the leak was determined.
As indicated in the August 1987 Inspection Report, an Unusual Event should have been declared per EAL No. 14 on October 2, 1986.
The relevant Tech Spec was 3/4.1.3.1 (Action Statement "b").
In accordance with previous Regional guidance, the event declaration time should have been about 1150 when operators q
reduced reactor power.
In this particular case, " initiating a reduction of reactor power" equated to a manual reactor trip from about three percent power.
However, this operator action also satisfied unusual Event EAL No. 14 and the relevant Technical Specification Action Statement.
Since the reactor was manually tripped at about 1150, an Unusual Event declaration at that time would have been what has commonly been called (by this and other licensees) a " pass through" emergency declaration.
That is, the licensee informs NRC and State officials of plant conditions which had briefly (but no longer) existed, but which had also briefly satisfied an EAL.
A question was also raised regarding the applicability of the calendar versus the Tech Spec definitions of annual and lessor time periods for conducting emergency preparedness exercises and drills, and other annual training on specific emergency organization positions.
NUREG-0654, Revision 1, refers to Tech-Spec frequency requirements for only fire drills. Therefore, unless otherwise stated in a plant's Tech Specs, calendar definitions of time periods are appropriate for other emergency preparedness drills.
Regarding the frequency of other training for emergency organization positions, Region III licensees generally have formally or informally adopted a 12-month cycle plus or minus 25 percent. While this is the preferred frequency, a calendar year interpretation is also acceptable unless a given licensee's emergency plan already includes a commitment to conduct such training on a 12-month cycle plus or minus 25 percent. Therefore, it is recommended that the next Generating Stations Emergency Plan (GSEP) revision include a definition of the word " annual" with respect to the frequency of other than drill-related training for members of the onsite and offsite emergency organizations.
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