ML20031A947
| ML20031A947 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/04/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031A941 | List: |
| References | |
| NUDOCS 8109280419 | |
| Download: ML20031A947 (3) | |
Text
"
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(7
) One First futional Plaz9, Chicago. Illinois
' 7 Address Reply to: Post Office Box 767
(,/ Chicago. Illinois 60690 September 4, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 Response to Notice of Violation I.E.
Inspection Report Nos.
50-454/81-08 and 50-455/81-07 Reference (a):
August 7, 1981, letter from C. E. Norelius to Cordell Reed.
Dear Mr. Keppler:
Reference (a) contained the report of an inspection conducted by Messrs. R.
N.
Gardner, R. S. Love, R. B. Landsman and J. F.
Norton of your of fice on July 7-10, 1981, at Byron.
During that inspection, it was determined that certain activities were in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation which was appended to reference (a).
To the best of my knowledge and belief the statements contained in Attachment A are true and correct.
In some respects, these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees and contractors.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address any further questions regarding this matter to this office.
Very truly yours, L. O. De1 George Director of Nuclear Licensing SUBSCRIBED AND SWORJ4 to befope me thJs 8 %
day of duMela.u _
1981 hutb - f).
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Notary Public
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION Violation:
10 CFR 50, Appendix B, Criterion XII, states, " Measures shall be established to assure that..... instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within necessary limits."
Commonwealth Edison Company Topical Report CE-1-A, Revision 15, Section 12, states, in part, " Measuring and test equipment which is used.....to perform the pre-operation testing.....will be periodically calibrated or adjusted to assure that accuracy is maintained within necessary limits...."
Contrary to the above, on July 9, 1981, the inspectors identified that the approved calibration data, dated May 15, 1980, for the voltmeter (located on battery charger 1DC03E) which was used in obtaining data during pre-operational test No. 2.21.10 was out of tolerance at one of the six recorded data points.
Furthermore, there was no calibration period specified for the subject meter.
Corrective Action Taken and Results Achieved The subject voltmeter located on battery charger 1DC03E was:
adjusted and recalibrated on July 31, 1981, and is now within tolerance over its entire range.
The calibration point in question was the 60 Volt point, which is the second calibration point above the zero indication point on the meter scale.
It should be pointed out that this is well below the normal operating range of the battery charger.'
The meter was well within tolerance over the normal range within which it was required to operate as is evidenced by the data taken during pre-operational test No. 2.21.10.
The data obtained from this voltmeter and recorded in pre-operational test No. 2.21.10 was taken for information only, merely to ascertain if this meter was indicating the-approximate battery charger voltage, as was being measured with a certified portable test instrument.
In all cases where data is recorded in pre-operational test No. 2.21.10 and used to verify the acceptance criteria, these readings;are obtained with only certified portable test-instruments.
The voltmeter is not a measuring and testing device used in activities af fecting quality "af ter plant startup."
Battery surveillance is. accomplished using certified portable test Instruments.
a
' Attachment A 2-1 Corrective Action Taken to Avoid Further Non-Com;'iance To prevent a reoccurrence of the noncompliance, a new sign-off item entitled " Instrument (s) Within Tolerance" will-be added'to the Data Form #22 of the System Operation Analysis Department's Electrical Construction Test Procedures.
This will require the i
person calibrating the instruments to review his data to assure that all data points are within tolerance before signing off.
The revised data form has been submitted for approval and the
" Instrument (s) Within Tolerance" sign-off has already been added under "special tests" on the data forms at this site pending approval of the revised form, ate When Full Compliance Will Be Achieved Since this voltmeter is used only to give a relative indication of the battery charge voltage and is not used to verify 1
acceptance criteria, there is no specified calibration period for this instrument.
Data used to verify acceptance criterial for pre-operational test No. 2.21.10 and/or to evaluste the integrity of the battery charger on a periodic basis will De obtained using certified 4
portable test instruments.
We are effective this date in full compliance with regard to this item.
In addition, Form No. 22 of the System Operational Analysis Department's Electrical Construction Test Procedures will be modified by October 1, 1981.
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