ML20236W134

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Responds to NRC Re Violations Noted in Insp Rept 50-454/87-26.Corrective Actions:Annunciator Response (BAR) 1-1-C1, Spent Fuel Pit Level High Low, Revised to Reflect Options Available in Event of Low Level Alarm
ML20236W134
Person / Time
Site: Byron Constellation icon.png
Issue date: 08/21/1987
From: Butterfield L
COMMONWEALTH EDISON CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3478K, NUDOCS 8712070295
Download: ML20236W134 (3)


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F Y'  : Commonwealth Edison g

/ 4;' One First Nnional Plaza, Chicago, Illinois

l. k O f Addiess R: ply to: Post Office Box 767

!; V Chicago, Illinois 60690 0767 l

August 21, 1987 l

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Mr. A. Bert Davis Regional. Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Unit 1 NRC Inspection Report No. 50-454/87026 NRC Docket No. 50-454 Reference (a): July 23, 1987 letter from C. W. Hehl to Cordell Reed

Dear Mr. Davis:

Reference (a) provided the results of an inspection by Ms. Azab at Byron Station on June 24 through July 8, 1987. Duripg 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).

Please direct any questions regarding this matter to this office.

Very truly.yours, j- .

h L. D. Butterfield Nuclear Licensing Manager Attachment cc: Byron Resident Inspector 8712070295 870821 S PDR ADOCK 05000454:.

G PDR 3178K AfM 4199 l

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ATTACHMENT A VIOLATION Technical Specifications, Section 6.8.1.a, states that written procedures shall be established, implemented and maintained covering activities referenced in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Procedures for abnormal or alarm conditions are required to be written by part 5 of Appendix A. Abnormal Operating Procedure, IBOA Refuel-3, " Spent Fuel Pool Level Loss - Unit 1," Revision 51, required, among other things, that the licensee stop all movement in response to the spent fuel pit low level alarm.

Contrary to the above, during the entire refueling, the licensee failed to stop all fuel movement while the spent fuel pit level was below the alarm setpoint and the alarm was enunciated.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED During the Unit I refueling, Byron operated for a period of time with the spent fuel pool (SFP) low level alarm activated during fuel movement. The low SFP level was due to a slow leak from the refueling cavity through a nozzle cover. A temporary pump and filter were put in place to reclaim and return the leaking water to the SFP. Makeup from the chemical volume and control system was not possible because of modification work. At no time was the level below the Technical Specification limit of 422'-7.6". Extensive radiation protection activities near the fuel pool during those times indicated no unusual dose rates. Further, the Station has estimated that dose rates at that level would result in .125 mr/hr at the water's surface (FSAR limit 2.5 mr/hr).

The situation was appraised by the Operating Engineer and shift personnel on a daily basis. The fuel handlers were aware of the low level condition and monitored the SFP for any unexpected level loss 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Additionally, the SFP level was logged shiftly by the equipment I attendants. The low level alarm was anticipated and the condition was understood.

Byron annunciator response (BAR) 1-1-Cl, " Spent Fuel Pit Level High Low" has been revised to reflect the options available in the event of a low level alarm. Entry into the abnormal operating procedure, IBOA Refuel-3, is no longer mandatory when it has been determined that uncontrolled or unexpected conditions have not caused the alarm to annunciate. This change is consistent with current operator training.

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CORRECTIVE ACTION TO AVOID FURTHER VIOLATION BAP 340-1, "Use of Procedures for the Operating Department", will be revised to provide guidance for entry into a BOA (Byron Abnormal Operating Procedure). The intent of this procedure revision is to further clarify that off-normal conditions should be evaluated to determine applicability of the BOA. Additionally, BAP 340-1 will provide instructions for the use and applicability of BAR's.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED BAR l-1-Cl was revised and approved for use July 22, 1987. BAP 340-1 will be revised by September 21, 1987.

l 3478K

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