ML20031D934
| ML20031D934 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/23/1981 |
| From: | Hind J, Jackiw I, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20031D926 | List: |
| References | |
| 50-454-81-11, NUDOCS 8110140383 | |
| Download: ML20031D934 (5) | |
See also: IR 05000454/1981011
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U.S. NUCLEAR REGUI ATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No.- 50-454/81-11
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Docket No. 50-454
License No. CPPR-130
i.icensee: Commonwealth Edison Company
P. O. Be:- 767
Chicago, 2L 60690
Facility hame: Byron Station, Unit 1
Inspection At: Byron Site, Byron, IL
Inspection Conducted: July 27 and August 26-28, 1981.
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Inspectors:
M. Ring
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J. Hinds (July 27)
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Approved By:
I.N. Jac
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Test Programs Section
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Inspection Summary
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Inspection on July 27 and August 26-28, 1981 (Report No. 50-454/81-11
Areas Inspected:
Routine announced inspection to review preoperational
test procedures and results; previous open items relating to the pre-oper-
stional test program and the cold hydrostatic test procedure for the reactor
coolant system. The inspection involved 31 inspector-hours onsite by two
NRC inspectors including 0 inspector-hours onsite during off shifts.
Results: Of the four areas inspected, no apparent items of noncompliance
or deviations were identified in one area.
Within the three remaining areas
two apparent items of noncompliance were identified, one of which contained
examples in two areas (failure to follow procedures-Paragraphs 4, 5a, and 5b;
failure to perform adequate review of changes - Paragraph 3.
110140383 811001
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DETAILS
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1.
Persons Contacted
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R. Querio, Station Superintendent
- R. Ward, Assistant Superintendent, Administration an/. Support
- R. Pleniewicz, Assistant Superintendent, Operating
- L. Sues, Assistant Superintendent, Maintenance
- M. Stanish, Quality Assurance Superintendent
- R. Tuetkin, Assistant Project Superintendent
- P. Ervin, Tech Staff Supervisor
- J. DeRosia, Field Engineer-Construction
- R. Westberg, Lead Quality Assuranca Engi .eer, Operations
- R.
Grams, Master Instrtment Mechanic
A. Chernick, Preoperational Test Coordinator
P. Johnson, Electrical Group Leader
T. Didier, Quality Control Supervisor
R. Branson, Operating Engineer
S. Swan, Start-up Staff
G. Schwartz, Master Electrician
D. Johnson, Instrument Foreman
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Inspection Findings
a.
(Closed) Open Item (454/80-23-08): The inspector reviewed-
Revision 0 of B0C-HK-1, Station Housekeeping Surveillance,
dated July 1981 and interface agreements between the Opera-
tions and Construction organizations. The inspector dis-
cussed comments with the licensee and determined the above
items to be acceptable.
b.
(C1csed) Open Item (454/80-23-09): The inspector reviewed
Revision 0 of BAP 400-4, Control of Station Measuring and Test
Equipment, dated June 1981 as the licensees procedure which
pr vides overall control and direction to several more detailed
proceJures covering usage of test and measuring equij ent.
The
procedure appears to be adequate.
c.
(Closed) Open Item (454/81-06-01): The inspector reviewed
Revision 1 of BQI 23.2, Monitoring of Pre-Op fests, dated
August 13, 1981. The procedure incorporated pre-operational
test specific audit procedures pertaining to such things as
preparation by audit personnel, extent of audit and surveill-
ance coverage and assignment of responsibility. The procedure
appears to be adequate.
d.
(Closed) Open Item (454/81-06-02): The inspector also review-
ed BQI 23.2, Monitoring of Pre-Op Tests for specific job-related
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activities and training requirements relative to the pre-opera-
tional test phase. The procedure appears to be adequate in ti-is
area.
(Closed) Open Item (454/80-23-05):
This item dealt with comments
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made by the inspector when tte Start-up Guidelines document was
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elimated via Revision 2 to the Startup Manual. Revision 5 to the-
Startup Manual was reviewed by the inspector as centaining the
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resolution to those comments. Revision 4 adequately resolved
the inspector's comments and therefore the item is considered
closed.
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f.
(0 pen) Open Item (454/80-23-07): The inspector discussed _com-
ments with the licensee resulting both from the pre-performance
review and the completed test review of Pre-Operational Test
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2.21.10, 125 V DC Distribution. Since neither the Station nor
the Project Engineering Department have yet accepted this test,
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the item will remain open pending resolution of inspector comments,
completion of licensee review and subsequent review by the in-
spector.
3.
Jtartup Manual Review
During the Startup Manual review, the inspector noted that :n
Section 3.5.2 entitled Major Changes to Pre-Operational Tests or
Startup Tests, sub paragraphs 2.1 and 2.1.1, 2.1.2, and 2.1.3
were contradictory.
Paragraph 2.1 was consistent with the title
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stating that "any change that changes the intent of a procedure is
a major change." However, sub paragraphs 2.1.1, 2.1.1 and 2.1.3
all describe minor change attributes such a in 2.1.2, "The revision
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does not change the intent of the procedure." The Startup Manual
describes the method of making changes to the manual as requiring
proofreading and review by the Startup Group, concurrence by Site
Quality Assurance and authorization by the Project Manager. Failure
to adequately review and proofread the chaage to the Startup Manual
is considered to be a violation of 10 CFR 50, Appendix.B, Criterion
VI and the Startup Manual paragraph 1.4.4 and is an example of an
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item of noncompliance (454/81-11-01).
4.
Preoperational Test Procedure Results Review
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During the revi w of completed test procedure PT 2.21.10, 125V DC
Distribution, the inspector questioned how the test engineer was
able to " Verify all installed instrumentation in the SDP (System
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Documentation Package) is within current calibration intervals" as
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required by paragraph 6.3 of PT 2.21.10.
Since the particular test
engineer had subsequently left the licensee's employ, members of
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the Technical Staff agreed to determine how th.is requirement was
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satisfied. Upon investigation, Tech Staff representatives stated
that "being calibrated" was satisfied by asking OAD (Operational'
Analysis Department) but they did not know-how "within current
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intervals" was satisfied since OAD reported ta the Tech dtsff that
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the calibration intervals for the instruments in question were not
yet established. Failure to perform the test in accordance with
the procedure is considered to be a violation of 10 CFR 50 Appendix
B, Criteria V and XI and is an example of an item of noncompliance
(454/81-01c).
5.
Cold Hydrostatic Test
The inspector reviewed a copy of the completed construction test pro-
cedure 2.63.810, Reactor Coolant Cold Hydrostatic Test and inter-
viewed one of the test conductors, one of the operating engineers,
a member of the Technical Staff and one of the instrument foremen
with respect to the Celd Hydro. The inspector noted the fallowing
problems:
a.
Paragraph 6.2 of the test procedure states, " Verify that all
instrumentation in Appendix A is within current calibration in-
te rvals . " In the completed procedure, Appendix A consisted
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of a computer printout of many instrun,ents and components (many
of which cannot be calibrated) listing the date on which the
instrument was calibrated. Review of the list showed several
components with a calibration date of "1/1/90N." When the in-
spector questioned the meaning of a 1990 date, the instrumenc
foreman indicated this was a fictituous date deliberately
applied to allow the computer to printout and indicating the
component was not a "calibrateable" component. However, the
inspector noted that a pressure switch, IPS/-RC0403, which
the instrument foreman said should be able to be calibrated,
showed a 1/1/90N date.
Since the list contained several 1990
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designations, the inspector questioned how the Hydro test re-
quirement of paragraph 6.2 was actually satisfied. The test
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conductor indicated that if the instrument contained a calibra-
tion date, it was considered satisfactory. The inspector
reviewed the list for calibration dates and noted four instru-
cents, ITS/-RC0433A, IPT-CV0115, ITE-CV0167, and ILT-SIO930
which had no calibration dates at all listed. Additionally,
the " current calibration intervals " described in paragraph 6.2
were reported by the instrenent foreman to be not yet established
for most of the instruments. The above problems constitute fail-
ure to verify the prerequisite paragraph in accordance with the
procedure which is considered to be a violation of 10 CFR 50
Appendix B, Criteria V and XI and is an example of an item of
noncompliance (454/81-11-02a).
b.
Paragraph 9.2.49 of test procedure 2.63.810 says to " increase
system pressure to 3102-0+25 psig" while the following para-
graph 9.2.50 states " Maintain the 3102-0+12.5 psig pressure for
a minimum of ten minutes". Actual p. essure recorded on the
by.irostatic test certificate was 3135 psig. While this actual
pressure meets the minimum pressure for a satisfactory strength
and tightness test and does not exceed the calculated over
p essure point, it does exceed the pressure bands of paragraphs
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9.2.49 and 9.2.50.
Failure to perform the test in accordance
with the procedure is considered to be a violation of 10 CFR 50
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Appendix B, Criteria V and XI and is an example of an item of
noncompliance (454/81-11-02b).
In addition, the inspector observed portions of the test performance
and reviewed the completed test procedure. The inspector observed
the conduct of the test, verification of prerequisites, observation
of precautions, calibration and placement of hydro test gauges,
overpressure protection, documentation of results and deficiencies.
With the exception of the previous items of noncompliance, these
areas were all considered adequate.
6.
Exit Interview
The inspector met with licensee representatives (denoted in paragraph
1) on August 28, 1981. The inspector summarized the scope and findings
of the inspection. The licensee acknowledged the statements by the
inspector with respect to the open items and the items of noncompliance
(Paragraphs 3, 4 and 5).
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