ML20236J551
| ML20236J551 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/13/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3702K, NUDOCS 8711060168 | |
| Download: ML20236J551 (4) | |
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f^ x 'Comm::nwealth Edison
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/ On First Mt.tional Plaza, Chicago, Illinois K-j Address Reply to: Post Office Box 767
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(,/ Chicago, Illinois 60690 0767 October 13, 1987 Mr. A. Bert Davis Regional Administrator l
U.S. Nuclear Regulatory Commission l
Region III 799 Roosevelt Road Glen Ellyn, IL 60137 l
Subject:
Byron Station Units 1 and 2 f
NRC Inspection Report Nos.
50-454/87-031 and 50-455/87-029 NRC Docket Nos. 50-454/455 and 50-456/457 Reference (a): August 27, 1987.etter for W.D. Shafer to Cordell Reed (b): October 7, 1987 letter from W.D. Shafer to Cordell Reed
Dear Mr. Davis:
Reference (a) provided the results of an inspection by Mr. Peterson and others of your office on July 27-31, 1987 at Byron Station. Reference (b) provided additional information regarding the inspection findings.
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). Attachment B contains the response to an open item regarding the frequency of training for personnel involved with the emergency plan.
Please direct any questions regarding this matter to this office.
Very truly yours,
/C a or L. D. Butterfield Nuclear Licensing Manager l
CS Attachments cc: Byron Resident Inspector
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i Braidwood Resident Inspector y
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8711060168 871013 PDR ADOCK 05000454 993 15N O
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l ATTACHMENT A l
VIOLATION
~10 CPR 50.54(q) requires that a licensee authorized to possess and/or operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in j
Appendix E.
l Contrary to the above, on October 20, 1986 and March 21, 1987, the licensee failed to, timely and adequately, classify and declare an emergency I
condition per the EALs. This is a failure to adequately follow and implement the Generating Station Emergency plan.
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RESPONSE
l This violation involves classification of two events: one event regarding reactor coolant system (RCS) leakrate and the other event I
concerning a problem with the control rod drive system.
Each event is i
addressed below.
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RCS Leakrate Event This event involved a situation when the unidentified RCS leakrate I
was greater than lgpm. _ Emergency action level (EAL) 16 " Loss of primary l
Coolant" is related to this condition, i
The " Loss of primary Coolant" EAL 16 states than an Unusual Event i
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is required to be classified when " Exceeding Reactor Coolant System leak r ate.as specified in Technical Specifications". Byron Station interprets this to mean that the Limiting Condition for Operation and the Action Requirement time limits must both be exceeded before classification of the l
Unusual Event is required. Technical Specification 3.0.2 states, l
"Non-compliance with a specification shall exist when the requirements of the LCO and associated Action Requirements are not met within the specified
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time intervals".
In this particular event, the LCo limit was exceeded but the Action Requirement time limit was met.
Therefore, Specification 3.4.6.2 was not exceeded and the classification of an Unusual Event was not made.
1 EAL 14 " Conditions or Systems required by Technical Specifications" i
states that an Unusual Event is required to be classified when " Equipment l
described in the Technical Specification is degraded such that a Limitina l
Condition for Operation requires a shutdown". Byron Station interprets this I
to mean the Unusual Event is required to be classified when the Unit operator starts to decrease power as a result of a Technical Specification requirement. The distinction between the two EALs is:
- An Unusual Event per EAL 16 is classified at the time the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> action statement is exceeded (for the RCS leakage specification).
- An Unusual Event per EAL 14 is classified at the time the Unit l
Operator starts to decrease the Unit power level due to a l
Technical Specification required shutdown.
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- The interpretation presented above has been used in past situations when RCS leakrate was greater than 1 gpm. NRC review of these events found i
Byror 's classification acceptable. Refer to Licensee Event Reports 50-454/85-47 and 86-20; NRC Inspection Reports 50-454/85-34 and 50-454/86-25.
CORRECTIVE ACTION TO AVOID'FURTHER VIOLATION Byron EAL 16 " Loss of primary Coolant" has been changed to specifically state that the Limiting Condition for Operation and the Action Requirement time limit must be exceeded t.efore classification of an Unusual
. Event is required. Braidwood EAL 16 has also been changed in the same manner. These changes became effective October 13, 1987.
In accordance with 10 CFR 50.54(q), we have determined these changes to the emergency plan do not decrease the effectiveness of the plan and the plan, as changed, continues to meet the standards of 10 CPR 50.47(b) and 10 CFR 50, Appendix E.
j commonwealth Edison's Corporate Emergency Planning Staff will review the corresponding " Loss of Primary Coolant" EALs for the other four commonwealth Edison nuclear stations to determine if any similar clarifications are warranted.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of the corresponding EAL's, and any necessary clarifications, will be completed by December 15, 1987.
Control Rod Drive System Event This event involved a problem with the Unit I control rod drive system. A Technical Specification Action Requirement was entered that required a reactor shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. During troubleshooting activities while in the shutdown clock, four control rods dropped into the core. The reactor was manually tripped immediately following this. Since the Technical Specification LCO was exceeded, and the Action Statement required the plant to be shutdown within six hours, an Unusual Event per EAL 14 should have been declared. The classification should have been made when reactor power was decreased, or in this specific case, when the reactor was manually tripped.
COkRECTIVE ACTION TO AVOID FURTHER VIOLATION i
The operating supervisor involved with this event will be retrained in the correct usage of the EAL's.
In addition, all licensed operators will L
f be informed of this event through the Required Reading Program.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The operating supervisor will be retrain *d and the required reading will be completed by December 14, 1987.
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!g"rACHMENT B -
i OPEN ITEM l
j Clarification of the term annual as it applies to emergency response drills, exercise, tests and training should ire considered. NRC has determined that'the interpretation of " annual" pertaining to training and.
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other facets with the exception of exercisec is to mean once every 12 months.
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RESPONSE
Commonwealth Edison uses the calendar time periods to define its emergency response program, including training. We acknowledge the term is
-j not defined in the current Generating Station Emergency plan, except for the j
frequency of exercises.
The various definitions of " time" will be included i
in the next revision of the GSEP.
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