ML20076L322
| ML20076L322 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/13/1983 |
| From: | Mark Miller COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8307190122 | |
| Download: ML20076L322 (27) | |
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UNITED STATES OF AMERICA
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- 0 ON NUCLEAR REGULATORY COMMISSION C -
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M cnea 12 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD oggrg d,9
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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Station, Units 1 )
and 2) )
MEMORANDUM OF COMMONWEALTH EDISON COMPANY IN OPPOSITION TO INTERVENORS' MOTION TO SUPPLEMENT QA/QC RECORD REGARDING PREOPERATIONAL TESTING This is the second in what promises to be a series of motions by the Rockford League of Women Voters and DAARE/
SAFE ("Intervenors") to reopen the record in this proceeding.
The first motion concerned the testimony of John Hughes.
Another is promised when Intervenors' counsel receives an in-spection report regarding the Quad Cities Station (Letter, Jane M. Whicher to the Licensing Board, June 29, 1983). While Applicant recognizes that each motion must be evaluated on its merits, it is clear that the potential exists for diversion of the resources of the Board and the parties in responding to such motions. This is particularly true given Applicant's extensive nuclear power plant commitments, comprising four operating nuclear power plants and two under construction.. The issuance 8307190122 830713 PDR ADOCK 05000454 G ppg, Dbhj
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- f . of inspection reports and other documents by the NRC's Division of Inspection and Enforcement can be expected on a routine basis for the foreseeable future.
Applicant respectfully requests the Board to deny this motion. In addition, we believe the Board should also provide some further guidance to the parties so that the filing of motions such as this one, dealing with matters that are tangential and immaterial to the Quality Assurance issues actually liti-gated before this Board may be inhibited. As set out below, the issue of preoperational testing was referred to in passing only by the Staff and a full-fledged evidentiary presentation on that issue is equivalent to introducing an entire new subject into the proceeding. Moreover, the specific items referred to in the inspection reports do not constitute items of safety significance within the meaning of this Board's May 12, 1983 order nor does consideration of these inspection reports by the Board have the potential to affect the result.1/
1/ Applicant does not concede that the motion is timely. The underlying inspection reports regarding preoperational testing were apparently received by Intervenors about 4 month prior to the filing of the Motion. These reports contain language com-parable to that found in the June 10 memorandum of the Enforce-ment Conference on this subject. Given the advanced stage of this' proceeding, it would seem that a more prompt filing is required under the Vermont Yankee case (Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station) 6 AEC 520, 523, n.12 (1973).
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A. The conduct of preoperational testing is not fairly comprised within the scope of Intervenors' Contention lA which deals with quality assurance.
In order to place Intervenors' present motion in context, it should be noted that the inspection reports and memorandum of an enforcement conference attached to the motion do not deal with any deficiencies in Applicant's Quality As-surance' Program, but rather with apparent deficiencies in the implementation of the preoperational testing program. While the items of noncompliance discussed in the inspection reports reference one of the criteria found in 10 CFR 50, App. B, the details of implementation of preoperational testing were not litigated by the parties in any meaningful sense during the course of the evidentiary hearings.
A review of the history of Contention lA reveals that Intervenors made only a passing reference to preoperational testing in their answers to interrogatories. The Rockford League of Women Voters' answer to Applicant's first set of written interrogatories identified two NRC inspection reports which refer to preoperational test procedures. (Rockford League of Women Voters Answer to Applicant's Interrogatory 1(a) on Contention lA dated July 6, 1982.) One of.tdu3 Inspection Reports, 50-454/82-06 merely referred to certain preoperaticpal testing
, ' procedures as an open item. The other Inspection Report
( 50-454/81-11 identified two procedural problems with the con-duct of' specific preoperational tests,Jas well as a proofreading
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error in the Startup Manual. A Severity Level V and VI item of non-compliance was assessed.
Given the insignificance of these items, Applicant did not submit any direct testimony addressing the subject of preoperational testing. The Staff did so in its prepared direct testimony (Forney, NRC Staff Prepared Testimony at pp.
10-11, (Tr. 3586)). Moreover, contrary to the citation to the Transcript found at page 3 of Intervenors' Motion, there is no discussion of preoperational testing at p. 3569. Indeed, the only reference to preoperational testing is found at Transcript pp. 3808-12. At those pages, Staff witness Forney referred to preoperational testing as the reason for increased NRC inspection activities at Byron and a consequent greater number of items of noncompliance. There is simply no discussion of the substance of the preoperational testing program in the evidentiary record to date.
Intervenors apparently wish to supplement the record with the attachments to the Motion. Yet, such a procedure would be the basis for further evidentiary submittals by the parties.
At a bare minimum, Applicant's responses to the inspection reports must also be received. The result will be an untoward expansion of the extensive Quality Assurance record, which so far has focused on matters far removed from the subject of preoperational testing. Intervenors' motion is tantamount to
. introducing a new contention long after the contentions were L
t, _, _
l 3 filed and the substantial matters in controversy identified and litigated.
B. The preoperational testing items referred to in Intervenors' motions are not of safety significance and will not change the outcome of this proceeding.
- 1. Contrary to Intervenors' characterization of the inspection reports attached to the Motion as disclosing " severe deficiencies in the preoperational testing program" (Motion p. 3) ,
each inspection report identifies one item of noncompliance with a Severity Level IV designation. Applicant, of course, takes these items of noncompliance Feriously. But they hardly rise to the level of safety significance, particularly when Inspection Report 50-454/83-18 identifies the conduct of only 1 of 5 preoperational tests as leading to an item of noncompliance.
Inspection Report 50-454/83-17 covers the same time period and identifies another item of noncompliance with respect to the same preoperational test asserted to be deficient in Inspection Report 50-454/83-18. Inspection Report 50-454/83-17 identifies no discrepancies with respect to 4 other preoperational tests.
Unlike Mr. Hughes' assertions of fraudulent quality assurance inspection practices (See Memorandum and Order Setting Special Deposition Session, p. 4 dated May 12, 1983), the intensified review of preoperational testing and a concomitant increase in identified items of noncompliance is an expected consequence as a nuclear power plant progresses from construction towards fuel load. _The NRC Staff'has so testified specifically with
- f. ' respect to the Byron Station. (See e.g. Tr. pp. 3808-3810).
- 2. It is also apparent that any consideration of this issue by the Licensing Board is extremely unlikely to change the result. As noted above, preoperational testing is but one insignificant portion of the present Quality Assurance con-tention and the evidentiary record developed to date. In 4
deciding whether App'11 cant has met'its burden of proof on Con-tention lA, the Board,will be considering evidence on such matters as construction quality assurance practices for Hatfield Electric Company, batch plant operations by Blount Brothers Construction Co., an evaluation of an extensive inspection performed in the Spring of 1982 by the NRC Staff and the manner in which QC inspectors have been trained and certified.
(See Memorandum and Order dated June 21, 1983). To suggest that the details surrounding two inspection reports which resulted j in two Severity Level IV items of noncompliance is going to alter the outcome of the proceeding is unreasonable. In.
view of the extent of the evidence adduced on Contention lA so far, it is extremely unlikely that these preoperational testing matters will themselves add to the existing evidence so as to persuade the Licensing Board'to-find in Intervenors' i Moreover, in view of the attention favor on Contention lA. -j to this matter by the NRC Staff, as evidenced by the enforcement conference, imposition of license conditions by the Board
- would be an untimely and relatively. ineffective technique
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for rectifying any problems with preoperational testing.
More importantly,.as demonstrated by the attachments to the affidavit of Tom Tramm which is appended to this Memorandum as Exhibit A, the Applicant has implemented extensive corrective action in a timely manner.
Conclusion For all the foregoing reasons, Intervenors' Motion should be denied.
fld Michael I. Mi~ller
/A t_
One of the Attorneys for
[ Commonwealth Edison Company l
Isham, Lincoln & Beale 3 First National Plaza Chicago, Illinois 60602 (312) 558 7500 Dated: July 13, 1983 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Station, Units 1 )
and 2) )
CERTIFICATE OF SERVICE I, Michael I. Miller, one of the attorneys for Commonwealth Edison Company, hereby certify that a copy of " Memorandum of Commonwealth Edison Company In Opposition to Intervenors' Motion to Supplement QA/QC Record Regarding Preoperational Testing" was served upon c.ll persons shown in the attached service list by deposit in the United States mail, first class, this 13th day of July,1983.
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Michael I. Miller SUBSCRIBED AND SWORN before me this 13th day of July, 1983.
AMl A Notary Public My Commission Expites knuary E 1982
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r SERVICE LIST l i
Ivan W. Smith, Chairman Atomic Safety and Licensing Administrative Judge Board Panel Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commissior l U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licensing Dr. A. Dixon Callihan Appeal Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Union Carbide Corporation Washington, D. C. 20555 P. O. Box Y Oak Ridge, Tennessee 37830 Docketing & Service Section Office of the Secretary Dr. Richard F. Cole U.S. Nuclear Regulatory Commission Administrative Judge Washington, D. C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission David C. Thomas, Esq.
Washington, D. C. 20555 77 S. Wacker Drive Chicago, Illinois 60601 Joseph Gallo, Esq.
Isham, Lincoln & Beale Suite 840 1120 Connecticut Avenue, NW Washington, D. C. 20036 Region III U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Ms. Diane Chavez 326 N. Avon Street Rockford, Illinois 61103 Dr. Bruce von Zellen c/o DAARE P. O. Box 261 DeKalb, Illinois 60015 Doug Cassel, Esq.
Jane Whicher, Esq.
109 N. Dearborn Street Chicago, Illinois 60602 Ms. Pat Morrison 5568 Thunderidge Drive Rockford, Illinois 61107
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN TliE ~ MATTER OF )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454
) 50-455 (Byron Station, Units 1 )
and 2) )
AFFIDAVIT Tom R. Tramm deposes and states that:
- 1. He is the Nuclear Licensing' Administrator j at Commonwealth Edison Company, and in that capacity he is responsible for the filing of Commonwealth Edison's responses to Nuclear Regulatory Commission Staff Inspection Reports.
- 2. -The documents attached as Exhibits 1 and 2 to this Affidavit are the responses filed by Commonwealth Edison Company to N.R.C. In'spection Reports 50-454/83-17 455/83-15 and 50-454/83-18-455-83/15. ,
k, fd W Tom R. Tramm Subscribed and Sworn to before me.this f3* day iof^ July,-1983.
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/ Notary Pbblic My Commission Expires Juna 9,1984 EXHIBIT A m
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Commonwealth Edison one First Nationet Plan Chicago. Ittencis Address Reply to: Post OtSce Box 767
'* Chicago. !!!inois 60690 June 21, 1983 1
9 Mr. James G. Keppler, Regional Administrator
_ Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 Response to IE Inspection Report Nos. 50-454/83-17 and 50-455/83-14 NRC Docket Nos. 50-454 and 50-455 Reference (a): J. F. Streeter letter to Cordell Reed dated May 24, 1983.
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by Mr. M. A. Ring of your office during the periods of March 30, 31, April 1, 5-8, 18-22, 26-29, er.d May 4, 1983, of retivities at our Byron Station.
During that inspectio1, certain activities appeared to be in noncompli-ance with MRC requirements. The Attachment to this letter provides the Commonwealth Edison Company response to the Notice of Violation as appended to Reference (a), and reflects our consideration of the specific examples documented in paragraphs 2 and 3 of the inspection report as requested.
Additionally, Reference (a) indicated Region III's concerns regarding the numerous examples of our failure to follow our admini-strative procedures during the development of the hot functional test procedure, and the apparent inadequacies of our edministrative procedures l
i which allowed the hot functional test procedure to be approved with numerous examples of the test procedure not adequately addressing FSAR f testing commitments. These matters were considered in the development of l
our response as requested, and we believe that the corrective actions stated should prevent such recurrence. 1 I
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' To the best of my knowledge and belief, the statements contained in:.the Attachment are true and correct. In some respect _s these statements are'not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees. Such information h;as been reviewed in accordance with Company practice and I believe it to be reliable. -
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EXHIBIT 1
s J. G. Keppler June 21, 1983 l
'-i Please address any questions that you or your staff may have concerning this matter to this office. 4
-- Very ruly yo
_ $_ g v_N nnis L. Farrar Director of Nucle'ar Licensing EDS/im Attachment cc: Region III Inspector - Byron 6797N
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ATTACHMENT Response to Notice of Violation 4
VIOLATION 1 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualita-tive acceptance criteria for determining that important activities have been satisfactorily accomplished."
Criterion XI, states, ln part, "A test program shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents..."
SectionH2.4.3 of the Byron Startup Manual assigns Project Engineering the responsibility to review and approve all pre-operational and startup tests, provide test acceptance criteria, and ensure test objectives are 2 properly-stated and met by acceptance criteria.
Contrary to the above, the applicant approved and issued for performance Test Procedure 2.63.10, " Integrated Hot Functional," without performing an adequate review of the procedure as evidenced by incomplete or missing acceptance criteria, data not designated as acceptance criteria, misleading typographical errors, incomplete testing provisions, and incomplete objectives.
RESPONSE TO ITEM 1 l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED: l An extensive review was conducted of Revision 2 to the Integrated Hot Functional (IHF) Test procedure and the applicable FSAR commitments.
.As a result, the IHF Test procedure was revised and Revision 3 was
.+1ssued. Corrective actions taken to~ address and resolve each specific QexampleidentifiedinReference(a)areasfollows: .
3a. A Test Change Request (TCR) was written to Reviilon 2 of the IHF ,
Test and this change was subsequently incorporaled into Revision I 3 to include the Component Cooling data taken as acceptance criteria. See Step 4.12 of Revision 3.
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3b. A TCR was written to Revision 2 of the IHF Test ind subsequently
_ incorporated into Revision 3. Included as acceptance criteria (Step 4.10 & 4.11) was the capability of the Stttm Dumps and Residual Heat Removal System to cool down the plant in accordance with Section 5.4.7.1 of the FSAR. Procedural steps have been reviewed and approved by the Project Engineering Department.
i 3c. A TCR was written to Rev'ision 2 of the IHF Test and subsequently incorporated into Revision 3 to correct typographical errors. In addition, Revision 3 was reviewed to eliminate typographical errors.
3d. A TCR was written to Revision 2 of the IHF Test and subsequently incorporated into Revision 3 to include Essential Service Water data taken as acceptance criteria. See Revision 3 of the IHF Test, Step 4.13. Additional components serviced by Essential '
Service Water were added to Revision 3 of the IHF Test.
3e A TCR was written to Revision 2 of the IHF Test and subsequently included into Revision 3 of the IHF Test to include the Auxiliary Feedwater Pumps and regulating valves as part of the Remote Shutdown Panel test section and acceptance criteria, thus meeting ,
the test objective as stated.
3f. A TCR was written to Revision 2 of the IHF Test and subsequently included into Revision 3 of the IHF Test, to include acceptance criteria for the Chemical and Volume Control Purification System (Step 4.14.)
3g. A TCR was written to Revision 2 of the IHF Test and subsequently incorporated into Revision 3 to include acceptance criteria (Steps 4.16 and 4.17) for the Steam Generator Safety Valves and the Steam Generator Pressure Operated Relief Valves lift setpoints. . The pressure gauges used to take data are listed in Section 7 of the IHF Test, Revision 3 s:)ecial equipment. Other equipmsnt used will be listed in the sequence of events, if necessary.
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3h. Table 14.2-24 of the Byron FSAR was amended (Amendment No. 42,
. May 1983) to verify the degassing capability of the radioactive c' waste gas system during startup testing.
I 3 A TCR was written to Revision 2 of the IHF testband subsequently l 1 31.
incorporated into Revision 3, Steps 4.7 and 4.18 to add Steam Generator B, C and 0 level, Pressurizer level,] Pressurizer pressure high deviation and centrifugal pump driven seal injection flow as. acceptance criteria.
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4 CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE:
- a. A matrix will be developed tracking particular preoperational and
_. startup test program requirements against specific test program commitments. The matrix will be compiled through a re-review of the Byron FSAR, SER, Regulatory Guides, NRC Technical Bulletins and Notices and Industry Standards. The commitments will be referenced to the appropriate systems and preoperational test number. This matrix will be used by the Test Review Board (TRB) during initial and pre-test reviews to ensure that all require-ments are established, and during post test review to verify that all acceptance criteria were met.
- b. In addition to the procedure review and approval by the Test Review Board members, an individual other than the cognizant System Test Engineer will check for and correct misleading typographical errors after the tests are typed.
- c. Test deficiencies will be written as necessary to document 1) testing commitments identified in the FSAR which are not included in a specific preoperational or startup test and 2) changes necessary to a reference document such as the FSAR to accurately reflect the test program.
- d. A test checklist will be prepared to provide a detailed listing of areas to be covered during review of initial, pre and post preoperational test reviews.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
August 15, 1983
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i VIOLATION 2 i
- 10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, skipping, cleaning
' and preservation of material and equipment...to prevent damage or
, deterioration."
l lThe Commonwealth Edison Company Quality Assurance Program contains in Quality Requirement QR 2.0 a commitment to the regulatory position of Regulatory Guide 1.39, Revision 2 which endorses the requirements of ANSI
- j. N45.2.3-1973. . Section 3.2.1 of ANSI N45.2.3 states, "The work areas j
shall be kept sufficiently clean and orderly that construction activity can proceed in an efficient manner that will produce and maintain quality j in conformance with specified requirements. Where large accuiaulations of l raterials occur on a nonroutine basis, such as the stripping of concrete forms, the material shall be promptly removed or stored neatly. Garbage, trash, scrap, litter, and other excess materials shall be collected,
- removed from the job site, or disposed of in accordance with specified
- requirements or planned practices. Such excess material shall not be allowed to accumulate and create conditions that will adversely affect
- quality."
}
- Contrary to the above, the applicant's program for maintaining
! cleanliness and housekeeping was not being adequately implemented as evidenced by the following examples:
! e. On April 6 and 7, 1983, the inspector noted many loose pieces of lagging and considerable garbage and trash strewn about the MSIV rooms, and a coating of lagging dust covered almost everything in the .
- B and C MSIV rooms. The A and D MSIV rooms had staging built such i that instrument valves could not be operated and loose boards were l
leaning against valve handwheels and generally strewn about.
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- b. On April 20 and 28, 1983, the inspector noted considerable food ;
stuffs (soda cans, banana peels, orange peels, candy bar wrappers and l i small food tins), loose boards, and cigarette packs in the area of the Unit 2 Diesel and Motor Driven Auxiliary Feed Pumps.
r c. On April 28, 1983, the inspector noted that the SG "C" cubicle l walkway had numerous pieces of rags, pop cans, cigarette butts, L flexitallic gasket and general construction material.
RESPONSE TO ITEM 2 e -
-CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i Byron Site Instruction #23, Rev. 3 dated June 3, 198 details the i Housekeeping Plan to be implemented by the Project Construction Department. This instruction identifies specific areas of the building, their appropriate cleanliness zone as defined in ANSI N45.2.3-1973, and. acceptance criteria for surveillances of the' Housekeeping Plan. Form SQP 18-2.27 is used to document a monthly
' surveillance of housekeeping activities performed per Byron Site
-Instruction #23.
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3 a.
s The following details the action taken with respect $c the specific examples identified in Reference (a):
4 Example 2A: MAIN STEAM ISOLATION VALVE ROOMS The attached form SQP 18.2-27 (Attachment 1) documents that a surveil-lance of the MSIV Rooms was performed on April 4, 1983 identifying that the area needed cleaning. The same form indicates that the area was cleaned to appropriate acceptance criteria on April 8, 1983.
The operability of valves is part of the Pre-Preop Test walkdown performed by the System Test Engineer. Items identified on this walkdown are resolved on a case by case basis.
Example 28: UNIT 2 DIESEL AND MOTOR DRIVEN AUXILIARY FEED PUMPS Attachment 2 contains the April and May Form SQP 18-2.27 surveil-lances. The April surveillances indicate that the Auxiliary Building, Elevation 383' and the Auxiliary Feed P' imp Diesel Day '
Tank Room were clean.
Example 2C: STEAM GENERATOR "C" CUBICLE Steam Generator "C" Cubicle is part of the normal Reactor Building housekeeping surveillance. The April and May surveillances indicate that the Reactor Building housekeeping was acceptable. A special cleanup was made of Steam Generator "C" Cubicle on May 10,1983 as part of the preparations for Hot Functional Testing.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE:
t As stated in our response to the above specific examples, the
-established Housekeeping Plan defined in the Byron Site Instruction ;
- 23 has identified tress deficient in housekteping and documented the '
correction of these Ceficiencies. .In our jurgment, the implementa-tion of this Housekeeping Plan is adequate to keep site work areas sufficiently clean anc orderly as required by ANSI N45.2.3-1973.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Complete
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/D 4Commonwealth Edison
) : One First National Pteri. Chca00, menoss
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C- Addrtss Ripty to: Pos* CAc2 Box 767 CNcago, Illmois 60690 June 24, 1983 4
Mr. James G. Keppler, Regional Administrator
- Region III U.S. Nuclear Regulat:ry Commission ~
799 Roosevelt Road Glen Ellyn,.IL 60137
Subject:
' Byron-Station Units 1 and 2 Response to IE Inspection Report Nos. 50-454/83-18 and 50-455/83-15 NRC Docket Mos. 50-454 and 50-455 Reference (a):- C.E.NorelkuslettertoCordell Reed dated May 26, 1983. -
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by Messrs. W. Forney and K. Connaughton of your office during the period of March 1 through April 30, 1983, of activities at our Byrao Station.
During that inspection, certain activities appeared to be in noncompli-ance with NRC requirements. .The Attachment to this letter provides the Commonwealth Edison Compan appended to Reference (a).y response to the Notice of Violation as
! Reference-(a) indicated Region III's particular concern regarding the repetitive nature of the examples of noncompliance identified during this inspection, and requested that Commonwealth Edison specify what measures will be established beyond previous commitments to provide the necessary. additional assurances that preoperational tests will be l
conducted in accordance with test procedures and applicable test program requirements. These matters were considered in t ie development of our i
response to the Notice of Violation, and we bellete that our corrective
, -actions as outlined herein should prevent such recurrence.
Additionally, Reference (a) indicated Region III's concern that identified nonconformances with FSAR commitments which are dispositioned "use as is" may not be identified in the FSAR as exceptions to those.
commitments, and requested that we provide a. description of actions taken, or planned to be taken, to assure that nonconformances so'dispositioned are}identifiedintheFSARasexceptionstoapplicablecommitments. r In ' response to this area of concern, our basic approach for establishing the need for FSAR amendments resulting from honcomformance dispcsition revolves around the process of achieving the Wisposition. As l
p EXHIBIT 2 4l , m.
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l J. G. Keppler 'eund'24, 1983 thenonconformanceandproposedresolution(s)areevaluafh5,.thhcognI-zant Project Engineer Department (PED) engineer evaluates'the status of the-nonconformance and proposed resolution (s), if any, relativt to FSAR commitments. If the resolution constitutes an exception to exitti,ng FSAR commitments, the PED engineer initiates, or causes the initiatio,n of, an FSAR amendment. In our judgment, this process which is requirkd by existing design control procedures is adequate-to jnsure that th6 ,
requisite changes to the FSAR are made. ~
To the best of my knowledge and belief, the statements.'06htained herein and in the Attachment are true and correct. In some respects these statements are not based on my personal knowledge but upon inform'- a tion 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 any questions that you or your staff may have concerning this matter to this office.
Very ly yours, r -
-m f%
Dennis L. Farrar Director of Nuclear Licensing EDS/lm Attachment cc: Region III Inspector - Byron 1
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ATTACHMENT Response to Notice of Violation r
z VIOLATION t 10 CFR 50, Appendix B, Criterion XI, " Test Control" states, in part, "A test program shall be' established to assure that all testing required to demonstrate that structures, systems, and components will perform
. satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents."
The Byron FSAR, Chapter 17.0, Quality Assurance, states in part:
"Therefore the CE Topical Report CE-1-A, Revision 7 and all subsequent revisions unless othernise noted in this chapter, is the basis for the QA Program at Byron /Braidwood Station."
Commonwealth Edison Company Topical Report CE-1-A, Quality Assurance Program for Nuclear Generating Stations, Revision 20 dated February 17, 1982,iSection 11, states in part: Preoperational tests which are per-formed on critical safety Category 1 equipment are controlled by approved written procedures....."
i The Byron Startup Manual, Revision 13, dated February 3, 1983, Section 4.7.2, " Pre-Test Briefing" states'in part: " Prior to starting the test the System Test Engineer will brief participants to:
2.1.) Review the pertinent special precautions.
2.1.4 Inform each person what he will be expected to do during the test."
i
- Contrary to the above, i
(a) Initial Condition 7.22.2, " Vibration Equipment for Sections 9.4, 9.5,'9.6, 9.7, 9.17, 9.22, 9.25, 9.26 and 9.27" had not been satisfied prior to performance of Sections 9.~4, 9.5 and 9.6.
(b) During the performance of Sections 9.4 and 9.5 of Preoperational Test 2.63.10 " Integrated Hot Functional Test", precaution 8.19 which required that the test be exited upon any indication of a
, l
, loose part on the loose parts monitoring system was not observed !
4' in that all channels of the loose parts monitorihg system were in a high alarm state. ;.
-(c) ~ Reactor Coolant System pressure and-temperature were not l maintained within their expected ranges and testing continued after the out-of-tolerance values were read.from the prescribed
. instrumentation and recorded.
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(d) Pre-test briefing of operators prior to performaYce of Section 9.5 and 9.6 did not include a review of precaution 8.19 or the Reactor Coolant System temperature and pressure tontrol bands as evidenced by interviews with test support personnel and examples (b) and (c) above.
ITEM (a) RESPONSE CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED':
The Identification number and calibration date for the vibration equipment used for Sections 9.4, 9.5 and 9.6 was entered in step 7.22.2 of the Integrated Hot Functionals (IHF) procedure and signed off on April 28, 1983..
CORRECTIVE ACTION TAKEN TO PREVENT FURTHER NON-COMPLIANCE:
The Integrated Hot Functionals (IHF) System Test Engineers have been designated the responsible individuals for verifying and signing all prerequisites, initial conditions and procedure steps.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 20, 1983.
ITEM (b) RESPONSE CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
Fuels Group members were called to the U1 Auxiliary Electric Room by
. Operating on April 27, 1983 to evaluate the Loose Parts Monitoring System (LPMS) status.- All the Loose Parts Ce:ectors (LPDs) were found in the " LOW ALARM" state which indicate s a lack of background noise. At least some of the LPDs were in the "HIGH ALARM" state.
The audio alarm switch was in the "off" position to silence an otherwise continuous alarm due to the LPD " LOW ALARM" states in the Auxiliary Electric Room. The LPMS System Test Engineer (STE), was able to clear all the HIGH ALARM lights by using the reset switch for pach LPD. This indicated'that the HIGH ALARM lights were due to
. Reactor Coolant Pump-(RCP) cycling required by the IHF procedure.
- Because the RCPs were no longer running, the HIGH ALARMS could reset and the LOW ALARMS would stay on. This agreed with plant conditions and no further action was necessary relative to Precaution 8.19.
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o-CORRECTIVE ACTION TAKEN TO PREVENT FURTHER NON-COMPLTANCE:
- Several actions were taken to prevent recurrence: 4 2
_- 1. Byron Annunciator Response (BAR) 1-13-E9 has been written to j assist the operators in determining what actions to take in response to a.LPMS alarm.
- 2. The LPMS alarm modules now initiate an alarm in the Main Control Room when an alarm condition is reached.
- 3. The Integrated Hot Functionals Coordinators and selected personnel in Operating including some Shift Engineers have been instructed on how to perform an initial diagnosis of LPMS prob-lems. They have also been instructed in the basic' understanding of the LPMS.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 20, 1983.
ITEMS (c) and (d) RESPONSE CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED: .
i Test Deficiency AG for the Integrated Hot Functionals (IHF) preoperational test was written to document that recorded values for temperature and pressure were outside the bands specified in the test procedure. The Test Deficiency will be' reviewed by the Post Test I Review Board and is the record of improper actions taken by the STE.
Test Change Request #56 changed the allowable temperature range from i the span of 140*F to 160*F, to greater than 'O'F which is still consistent with NSSS vendor recommendations. The STE and the Unit One operator both began using the 403 Pressure Loop for maintenance of Reactor Coolant System Pressure within the specified limits. The STE then reperformed the steps of sections 9.5 & 11.5 in which pressure and temperature were initially outside the specified bands.
-CORRECTIVE ACTION TAMEN TO PREVENT FURTHER NON-COMFLIANCE:
2' '
-QSeveral actions were taken to prevent recurrence of test briefing problems as identified in Reference (a) anc in previous Inspection Reports as follows.
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- 1. A letter from the Assistaat Superintendent of Ophrating to the Nuclear Station Operators (NS0s) was issued on May 19, 1983.
The purpose of the letter was to delineate the risponsibilities of the NS0s with regards to shift turnovers and test briefings received.from STEs. Some of the minimum requirements the NS0s are to expect and demand of test briefings include reviewing all pertinent precautions and operational bands specified by the IHF test procedure.
- 2. Per a letter from the Assistant Superintendent of Opera, ting, approved by the Station Superintendent, to the Department Heads
, and Shift Engineers dated April 27, 1983, the Assistant 3 Superintendent has delegated his normal daily activities to the Operating Engineer. The Assistant Superintendent of Operating has devoted himself to full time coordination of the Integrated Hot Functional activities to provide the highest level of responsibility and authority as well as Technical and Management expertise. Three experienced individuals have been designated as IHF Coordinators and report directly to the Assistant Superintendent of Operations. Their main responsibility is to coordinate interdepartmental actions relating to Hot Functionals.
- 3. An Onsite Review was held to review recent problems encountered in the test program. The three main topics discussed were system control, test conduct, and design changes to the plant.
Some of the conclusions of this review were to:
- a. ~ Re-emphasize that the STE should be aware of all changes or maintenance to his system for proper. system control. An
- example of the increased attention paid to systemicontrol is
! the fact that the Tech Staf f Representative at the Plan of
! the Day Meeting reviews all Nuclear ' fork Requests and notes j on the Work Request any special co.nd.tions or precautions to be observed.
- b. Reduce the number of non-IHF activities during the Hot L Functionals test which might detract from its performance.
- c. Re-emphasize that the NS0s are responsible,for conservative
, operation of the plant.
f' S, d. -Improve the quality of shif t turnovers. For example, Shift l Supervisors coming off shift now periodicall;y observe shift
- turnovers by Operating personnel. They prot {de verbal feedback to the operstors on their turnover and record the
- .results on Station observer forms for. review by station I l- management.
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- e. Use Status boards in the Main Control Room to enhance '
awareness of plant status by all station departme'nts.
- 4. The Station Superintendent has met with various work groups in the station to discuss the test program and each group's responsibilities relating to a high quality program. l I
DATE WHEN' FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 20, 1983.
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