ML050680255

G20050160 - Barry Quigley Ltr Re 2.206 - Byron Station/1C RCS Cold Leg Loop Stop Isolation Valve

ML050680255
Person / Time
Site:	Byron
Issue date:	03/02/2005
From:	Quigley B Exelon Corp
To:	Reyes L NRC/EDO
References
2.206, G20050160
Download: ML050680255 (3)

Text

EDO Principal Correspondence Control FROM: DUE: 04/06/05 EDO CONTROL: G20050160 DOC DT: 03/02/05 FINAL REPLY:

Barry Quigley Rockford, Illinois TO:

Reyes, EDO FOR SIGNATURE OF - ** GRN ** CRC NO:

Dyer, NRR DESC: ROUTING:

2.206 - Byron Station/IC RCS Cold Leg Loop Stop Reyes Isolation Valve Virgilio Kane Merschoff Silber Dean DATE: 03/07/05 Burns Congel, OE ASSIGNED TO: CONTACT: Caputo, OI Caldwell, RIII NRR Dyer Cyr, OGC Skay, NRR SPECIAL INSTRUCTIONS OR REMARKS: Goldberg, OGC lzqLIoQ £ QboLooQ1 -- etl~s: a0-1

March 2, 2005

Dear Mr. Reyes,

This is a request for enforcement action (under 10CFR2.206) against Exelon Nuclear's Byron Station for failure to comply with 10CFR50 Appendix B, Criterion XVI.

Specifically, the 1C RCS Cold Leg Loop Stop Isolation valve (lRC8002C) has been broken for at least 6 years and has not been repaired.

The Byron Reactor Coolant System is equipped with Motor Operated Loop Stop Isolation Valves. These are sometimes difficult to close to the point of protective features of the motor actuating. Our current practice is to reopen the valve and keep attempting to close it until it goes all the way closed. The failure mechanism is metal-to-metal contact between the valve disc and a misaligned valve guide. A repair is available.

We are currently in refueling outage BIR13. Plans had been made for the last year to implement the repair; a high cost, high dose job. Two days before the outage, our senior management got together and started "sharpshooting" the schedule in an attempt to reduce dose. It was decided that if the valve closed without too much trouble, the repair would be pulled from the outage. This morning, the first closing attempt resulted in the protective feature actuating. However on the second attempt the valve closed completely and the repair for this outage cancelled.

I have several concerns:

1. The cultural aspect of accepting actuation of a protective function,

2. Failure to correct a longstanding equipment issue,

3. The excessive emphasis on dose reduction is compromising plant safety. To the uninitiated dose reduction sounds noble, in our case it is allowing the valve to continue to grind metal to metal, leaving debris in the RCS.

4. I would like to point out that a significant portion of the site executives' (and my) bonus is tied to meeting aggressive dose goals. This is similar to Davis-Besse where dose prevented adequate head inspections and focus on monetary bonuses by executives caused other major issues. Note that the Institute of Nuclear Power Operations sets these dose goals, so this may be an industry concern.

Due to the small time window available to repair this valve, I am requesting immediate NRC action.

Respectfully, Barry Quigley 3512 Louisiana Rockford, IL 61108 815-397-3392 815-222-4745 EDO -- G20050160

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Subject:

Exelon 2.206 Petition Creation Date: 3/2/05 4:59PM From: <barry.quigleygexeloncorp.qom>

Created By: barry.quigley(exeloncorp.com Recipients nrc.gov owf4 o.OWFNDO SDW2 (Sandra Walker)

Post Office Route owf4po.OWFNDO nrc.gov Files Size Date & Time MESSAGE 1184 03/02/05 04:59PM Exelon 2.206 Petition.doc 23040 Mime.822 34671 Options Expiration Date: None-Priority: Standard Reply Requested: No Return Notification: None Concealed

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