ML20038B677
| ML20038B677 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/09/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20038B674 | List: |
| References | |
| NUDOCS 8112090013 | |
| Download: ML20038B677 (5) | |
Text
.
E'N Commonwealth Edison s
[\\(O
) one First National Plata. Chicago, libnois u
Address Reply to: Post Office Box 767 Chicago, Illinois 60690 November 9, 1981 Mr. James G.
+<epple r. Directo r Directorate of Inspection and Enforcement - Region III J.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 I&E Inspection Report No. 50-454/81-11 NRC Docket No. 50-454 Reference (a):
October 1, 1981, letter from C. E. Norelius to Cordell Reed.
Dear Mr. Keppler:
Reference (a) contained the report of an inspection conducted by Messrs.
M.
Ring and J.
Hinds of activities at Byron Station.
During that inspection, certein activities were found to be in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation.
To the best of my knowledge and belief the statements contained in the attachment 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.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address questions regarding this matter to this office.
Very truly yours, u.
O.
De1 George Director of Nuclear Licensing 1m SUBSCRIBED AND SWORN to bef re me this _9 d day of As0 1981.
'Oll -
A.L Notary Public 2824N 8112090013 811201 DRADOCK05000g g } g 1981 L
J ATTACHMENT A Response to Notice of Violation Violation 1:
10 CFR 50, Appendix B, Criterion VI, requires that measures be established to control the issuance of documents wnich prescribe all activites affecting quality.
These measures shall assure that documents, including changes, are leviewed for adequacy.
The Byron Startup Manual, Revision 4, requires in Section 1.4.4 that changes to the Startup Hanual be initiated by the originator, drafted, typed and proofread by the Startup Group, reviewed by the Startup Croup, concurred in by Site Quality Assurance and authorized by the Project Manager.
Contrary to the above:
The licensee did not adec.uately review and proofread all of the changes made by Revision 4 to the Startup Manual for categorizing majcr and minor procedure changes.
Criteria written for making major test procedure changes was the same as that used for making minor test procedures.
Corrective Action Taken and Results Achieved Revision 4 to the Startup Manual required the deletion of three steps in paragraph 3.5 among other changes.
The deletions did not occur.
Revision 5 deletes these three steps.
Corrective Action Taken to Avoid Further Noncompliance The Startup Coordinator has been ine.tructed to ensure that revi-sions are reviewed af ter typing and prior to dissemination of the manual.
Date When Full Compliance Will Be Achieved Full compliance was achieved when Revision 5 to the Startup Manual was distributed on October 29, 1981.
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c.
Attachment Violation 2:
10 CFR 50, Appendix B, Criterion V, states in part that "acti-vities affecting quality shall be prescribed by documented instructions, procedures, or drawings,
. and shall be accomplished in accordance with these instructions procedures or drawings.
10 CFR 50, Appendix B, Criterion XI, requires that all testing renuired to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.
Violation 2a:
The licensee did not adequately " verify that all instrumentation in Appendix A is within current calibration intervals" in accordance with paragraph 6.2 of construction test procedure 2.63.810, Reactor Coolant Cold Hydrostatic Test.
Four of the instruments listed in Appendix A of the completed test did not have any calibration date listed.
One of the instruments which should have been calibrated was listed as calibrated on 1/1/90N (Indicating not able to be calibrated).
Additionally, the
" current calibration intervals" were described as "not yet established" for most of the instruments.
Corrective Action Taken and Results Achieved As indicated in the Inspection Report, Appendix A of the completed test procedure is a computer printout listing the status of many instruments at the time of the cold hydro.
It lists many more instruments than those which were delineated in Appendix A of the approved test procedure.
The computer listing does not, however, indicate which instruments were not on the approved Appendix A and is very hard to audit.
Our comparison of the two lists indicates that one instrument in the approved Appendix A cid not have a calibration date:
ITE-CV0167, Reactor Coolant Pump 1A lower seal temperature.
A defective terminal strip in this circuit had been documented by Instrument Discrepancy Report 1-160-81 on July 11, 1981.
This discrepancy was overlooked in the review of the test but did not af fect the satisfactory completion of the test.
Corrective Action Taken to Avoid Further Noncompliance All Test Conductors and System Test Engineers have been instructed to ensure that all required instruments are calibrated and that all non-necessary instruments aIe specifically identified or deleted by procedure modifications.
Attachment Date When-Full Compliance Will Be Achieved November 9,.1981.
Violation 2b:
The licensee exceeded the pressure. band specified in the Reactor Coolant Cold Hydrostatic Test, 2.63.810.
The minimum. pressure to demonstrate satisfactory strength and tightness was met and the calculated over pressure point.was not exceeded, however, the pressure band of 3102-0+12.5 psig specified in the procedure for the 10 minute hold was exceeded.
f Corrective Action Taken and Results Achieved Construction Test Procedure 2.63.810 (Reactor Coolant Cold Hydrostatic Test), paragraphs 9.2.49 and 9.2.50 have been modified to correctly specify the test pressure range as 3102-0, not to exceed 3287-psig.
.This is consistent with the Westing-house recommended test pressure band contained in letter CAW-3640 dated July 17, 1981, which had been added as an attachment to the Test Procedure without modifying paragraphs 9.2.49 and 9.2.50.
The discrepancy was not identified and corrected by test conductors but had no ef fect upon satisfactory completion of the test.
Corrective Action Taken to Avoid Further Noncompliance Test Conductors.and System Test Engineers who are authorized to modify the test procedures were instructed to ensure that all the necessary test steps involved in a procedures modification are uniformly changed.
Date When Full Compliance Will Be Achieved November 9, 1981.
Violation 2c:
The licensee did not adequately " verify all installed instrumen-tation in the SDP (System Documentation Package) is within current calibration intervals" as required by paragraph 6.3 of Preoperational Test 2.21.10, 125 V DC Distribution.
The Tech Staff representatives stated that OAD does not have calibration intervals available yet for the instruments lisced.
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Attachment.
_4_
Corrective Action-Taken and Results Achieved The subject voltmeter was recalibrated July 31, 1981.
It was found to be in tolerance ~over the range of voltages present during the conduct of Preoperational Test No. 2.21.10.
(This was reported on September 4, 1981, by L. O. DelGeorge letter to J. G. Keppler).
As the data taken with this voltmeter was for inforcation only, no retesting is planned.
Corrective Action Taken To-Avoid Further-Noncompliance The Instrument Maintenance Department has drafted a procedure to define instrument calibration intervals.
The intervals will be used following first field calibration of a given instrument.
To assure that instruments required to obtain acceptance criteria data are calibrated during tests, Test Conductors and System Test Engineers will verify calibration of individual instruments by inspectireg calloration stickers or by checkira the calibration records.
Date When Full Compliance Will Be Achieved t-Calibration intervals will be defined for all instruments by January 1, 1982 Until that work is complete, Calibration intervals will be established for specific instruments when they are required for test.
Test Conductors and System Test Engineers currently involved in preoperational testing were advised of the proper method for verifying calibration as of November 9, 1981.
All others will be informed by December 1, 1
1981.
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