ML20079H074
| ML20079H074 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/06/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20079H044 | List: |
| References | |
| 7909N, NUDOCS 8401230310 | |
| Download: ML20079H074 (3) | |
Text
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['N Commonwealth Edison
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Ons First Nationit Pina Checrgo, Illinois
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Z 7 Adoress Reply to. Post Office Box 767
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/ Chicago. lilinois 60690 January 6, 1984 Mr. James C. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station Unit 1 IE Inspection Report No. 50-454/83-53 Reference (a):
December 5, 1983 letter from J. F.
Streeter to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided the results of an inspection of activities at Byron Generating Station by Messrs. M. Ring and D.
Williams on November 8-10 and 15-23, 1983.
During that inspection it was determined that certain activities were not in compliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation which was appended to reference (a).
Please direct any questions regarding this matter to this office.
Very truly yours, p4~
D. L. Farrar Director of Nuclear Licensing 1m-Attachment 7909N g
'8401230310 840117 PDR ACDCK 05000454 e
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ATTACHMENT A P
Response to Notice of Violation
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i Violation Y
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10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, f
m; procedures, or drawings, of a type appropriate to the circumstances and j
shall be accomplished in accordance with these instructions, procedures, mr u
or drawings."
The Byron Startup Manual paragraph 4.1.2.2 states, "Under 1
re-entry control, systems cannot be taken out of service without the concurrence of the System Test Engineer or Preop-coordinator as to the out t
of service boundaries."
Hunter Corporation Site Implementation Procedure 7
g (SIP) No. 4.000, " Control of Construction Processes," Paragraph 12.8 4
regarding disassembly of previously completed work states, "When the i
F hardware is under the Owner's Re-entry Control Program...their T
t authorization shall be obtained before performing additional work..."
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Contrary to the above, on May 12, 1983, the System Test Engineer, I
while attempting to conduct Pre-operational Test FC31.10, discovered that T
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Hunter Corporation personnel were conducting work activities on Spent Fuel p
Pool Pump 1FC0lP without concurrence or authorization from the System Test x-
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Engineer as required.under re-entry and construction control procedures.
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Corrective Action Taken And Results Achieved L-g
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Hunter personnel initially went to the Spent Fuel Pool Cooling Pump, E
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1FC0lP, to verify the torque on the anchor bolts as part of the con-t tractor QC Inspector Qualification Reinspection Program (454/82-05-19).
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The verification of torque is considered an inspection activity that did not require an out-of-service (00S) or violate re-entry control.
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During this verification it was noted that torque could not be achieved on one bolt because of inadequate engagement in the embedded 4
L nut.
A hardware removal form, as required by established procedures, c
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was generated but an 00S number was not obtained from Project 2
g Construction Personnel.
The bolt was removed and the threads i
cleaned.
At this point the System Test Engineer (STE) found the 7
ga Hunter Personnel replacing the bolt and generated Deficiency Y which g
identified that work was being performed.
The bolt was reinstalled g
and an acceptable torque achieved.
Since this incident occurred over 6 mcnths ago, the installation is h
currently acceptable, and the STE is aware of the work performed.
No y
further action is required to correct this noncompliance.
Ek
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,j. Corrective Action Taken To Avoid Further Noncompliance Appropriate Hunter QC and Craft Personnel will be retrained in the requirements of SIP 4.000 in regard to hardware removal forms and owner approval prior to performing work on systems under re-entry control.
Date When Full Compliance Will Be Achieved January 20, 1984.
7909N
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