ML20080M752
| ML20080M752 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/26/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080M744 | List: |
| References | |
| 7336N, NUDOCS 8310040260 | |
| Download: ML20080M752 (3) | |
Text
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s Commonwealth Edison
. One First N1tiontf Plan. Chicago. Ilknois Addr:ss R ply to: Post Offica Box 767 Chica), ll!inois 60690 September 26, 1983 f.
W*W}N Mr. J.
G.
Keppler, Regional Adminstrator g ~ f f ~ ~)
U.S. Nuclear Regulatory Commission b s.
-.G Q v ii E T ~ ~ ;# 3 ' ] t 799 Roosevelt Road Glen Ellyn, IL 60137 gi(~@{
1 Li: 1,
, A-4
Subject:
Byron Generating Station Unit 1 NRC Inspection Report bE_i n it No. 50-454/83-33 NRC Docket No. 50-454 Reference (a):
August 22, 1983, letter from W. S.
Little to Cordell Reed.
Dear Mr. Keppler:
This letter is in response to the inspection conducted at Byron Station by Mr.
H.
L.
Whitener of the Region II office on July 5-8, 1983.
During that inspection certain activities appeared to be in noncompliance with NRC requirements.
Commonwealth Edison's response to the Notice of Violation appended to reference (a) is provided in the attachment to this letter.
We believe the NRC will agree that this deficiency was promptly corrected.
After close review of the circumstances associated with this event, we do not agree that it has been properly classified in accordance with the present enforcement policy.
The NRC's assignment of a Severity Level IV according to Supplement II indicates that this event has more than a minor safety significance.
Our review of the facts indicates that the event was of no safety significance and should therefore not have been identified as a Violation.
It appears that categorization as a Severity Level V would have been more appropriate.
During execution of the thermal expansion test on the primary side, we failed to identify that snubber ISI24008S had been incorrectly listed as rigid support 1SI24008R.
This is certainly an error but it could only have been of a safety significance if there was a physical problem with the snubber and if the problem was not detected prior to operation.
This was not the situation.
Test Procedure 2.028.10 requires seven separate sets of support inspections at various stages in the heatup and cooldown.
The NRC reviewed the results of only the first set of inspections which had been conducted at the initial cold conditions.
During the test this support would have been inspectd at least three more times, including once again t; hen the system returned to the cold condition.
Supports are not usually inspected by the same individual twice in a row and it is highly unlikely that this error would have gone undetected.
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PDR ADOCK 05000454 e~
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-H.
R.-Denton September 26, 1983 Even if it had gone undetected it would not have posed a safety problem.
This snubber is expected to move less than 0.19" during thermal expansion.
Snubber position data are taken only on snubbers expected to.
. move 0.5" or more.
Snubbers such as ISI240085 are only checked to make sure that the snubber is'not at the end of its stroke.
During the initial inspection, this snubber was verified to be in mid-stroke.
There was no safety problem with snubber 1SI24008S.
Actually, because of delays in the heatup caused by a reactor coolant pump bearing failure, this test was revised and completely re-run.
Additional support inspections were performed.
It is requested that the NRC review this matter in light of the information presented here and reclassify this event to Severity Level V.
Please contact this office if additional information is required.
Very truly yours, r-'
L =
v.
D.
L.
Farrar Director of Nuclear Licensing TRT/lm Attachment 7336N
,r r-
--e n,
- 1 f5 ATTACHMENT A RESPONSE TO' NOTICE OF-VIOLATION VIOLATION 10 CFR.50, Appendix B, Criterion V is implemented by FSAR Section 17 which incorporates by reference-the Quality Assurance Topical Report CE-1-A.
'Section 5 of CE-1-A requires, 'in part, that activities affecting quality'shall be prescribed by documented instructions, procedures, or drawings and shall.be accomplished in accordance with these instructions, procedures, or drawings..- The preoperational thermal expansion test procedure TP 2.023.10 Revision 2,JSection 9.1-and data sheet.:11.9, require that during system walkdown inspections to establish. baseline data.for the ambient ~ temperature condition all supports will be observed for. proper-functioning and any support type listed which is.not the same as the-support type installed will be recorded on the data sheet.and a deficiency written.
Contrary to the above, during the walkdown inspection to establish
- baseline data at. ambient temperature for subsystem ISI24 on April 18,
~ 1983, the-licensee failed to observe, record, and write a deficiency on an-installed support listed as a rigid support, 1SI24008R, which was actually a snubber.
Corrective-Actions-Taken and Results Achieved The snubber number was corrected in a later revision of this test procedure.
Corrective Actions Taken to Avoid Further Noncompliance The hanger lists were completely reviewed and revised in preparing Revision 3 of the test procedure.
Additional guidance was also provided to hanger inspectors to help reduce the frequency of such errors.
l i
Date When Full Compliance Will Be Achieved i
[
-September 23, 1983.
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4 7336N R
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