ML20085A279
| ML20085A279 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/29/1983 |
| From: | Whicher J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8307050227 | |
| Download: ML20085A279 (39) | |
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. Ja o UNITED STATES OF AMERICA D~
NUCLEAR REGULATORY COMMISSION P cue,3
,h u.tu 9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'(
(L JUL O 11983 > ~70 In the Matter of ) 05 I.
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g" d "*aserh'. ff COMMONWEALTH EDISON COMPANY ) Docket No. 50-454 4 4 g3
) 50-455 -
(Byron Station, Units 1 and 2) )
INTERVENORS' MOTION TO SUPPLEMENT QA/QC RECORD REGARDING PREOPERATIONAL TESTING Intervenors the Rockford League of Women Voters and DAARE/ SAFE, by their undersigned attorney, hereby move the Board to allow supplementation of the record on Intervenors' Quality Assurance / Quality Control contention. As support for this Mo-tion, Intervenors attach Exhibits A, B and C hereto, all of which are recent issuances from Region III pertaining to pre- ,
operational testing at Byron.
While the record on QA/QC has been formally closed, the evidence contained in the attached exhibits meets the require-ments for opening a closed record. Those requirements are set forth in Kansas City Gas and Electric Company (Wolf Creek Unit No.1), ALAB-462, 7 NRC 320, 338 (1978) and other cases.*/
The motion must be:
(1) timely; (2) raise a significant safety issue, and
- / See June 21 Memorardum and Order Ruling on Intervenors' Motion to Admit Testimony of John Hughes at p.2 n.'. j i
8307050227 830629 PDR ADOCK 05000454 1 i
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(3) hevo potentici for effccting the result.
The process of reopening a closed record using " admissions and statements from applicant and NRC staff and official NRC documents or other documentary evidence" was expressly approved by the Commission in Pacific Gas and Electric Company, (Diablo Canyon, Units 1 and 2), CLI-85-5,13 NRC 361, 363 (1981).
Intervenors submit that each of the three requirements for reopining the record is satisfied, and the record must be re-opened for supplementation.
- 1. Timeliness Exhibit A hereto is a two-page letter from R. L. Spessard, Director Division of Engineering for Region III, and an "En-forcement Conference Summary" of four pages. The letter is dated June 10,1983 and was received by the undersigned within the last week. Exhibit B (Inspection Report 454/83-18) is dated May 26, 1983 and Exhibit C (Inspection Report 454/83-17) is dated May'24, 1983 It is Exhibit A, however, which contains staff statements and admissions as to the safety significance of the results of the a change in Region III inspections which are reported in Exhibits B and C. Thus, because the evidence establishing both the significance and the Region III position has only recently become available, Intervenors' motion is timely.
- 2. Safety significance The issue involved in each of the three exhibits is the adequacy of the preoperational testing program at Byron. This program was the subject of testimony before the Board by the staff during the March and April litigation of the QA/QC Conten-tion. (See Testimony of !!RC Region III on League Contention 1A 2
Transcript of April 7, 1983, p.3569). The clear import of the exhibits, as summarized in the Enforcement Conference Summary, is that Region III inspections have uncovered severe deficiencies in the preoperational testing program "primarily associated with personnel attitude and preparation." (Exhibit A at p.4 of Summary)
The enforcement conference involved, inter alia, the Region III concern with violations noted in the two inspection reports, i 454/83-18 (Exhibit B) and 454/83-17 (Exhibit C).
"Mr. Spessard stated that the purpose of the enforcement conference was to emphasize the seriousness with
,hich w the NRC views problems observed at the Byron Nuclear Station, Unit 1, in the following areas:
Inadequate conduct of preoperational testing. l Inadequate preparation of preoperational test l procedures. l Mr. Spessard stated that problems like those observed are not indicative of a quality te[t program and cannot .
continue." (emphasis supplied)
The Region III letter specifically notes the Severity Level IV violation found in 454/83-18 (Exhibit B), and lists thirteen examples of prior, similar violations by the applicant (Exhibit A at pp. 2-3 of Summary).
Region III letter also specifically notes the violations found in Inspection P3 port 454/83-17 (Exhibit C), listing nine examples of a Severity Level IV violation in Integrated Hot Functionals testing, with two examples of prior, similar viola-tions.
The NRC Region III position on significance of Edison's problems in preoperational testing is clearly stated.
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, "Tha NRC cautioned again0t cn ov0raaphnois on schedulo and production which may have contributed to inadequate procedures and an operations staff which was ill-prepared for the increased involvement of IHF. ...The NRC stressed that, although the licensee corrective actions appear to be reacting to specific NRC observations, a more sggressive attitude is needed to discern potential problems and prevent their occurrence." (Exhibit A at p.4 of Summary).
The NRC staff has thus admitted that Edison is conducting a substandard preoperational testing program at Byron, one emphasi-zing production and schedule with resulting inadequate procedures and an ill-prepared staff. The safety significance of such a program cannot seriously be denied by either Edison or the staff, for it is that program which should demonstrate both the ability of Edison's employees to operate the plant according to NRC standards, and the capacity of the plant to function as intended and as presented by Edison.
3 Potential to affect the result The Board has interpreted this standard to be as "whether the...information reasonably might affect the outcome of the proceeding" (emphasis in original) (Memorandum and Order Setting Special Deposition Session dated May 12, 1983).
Region III has, in effect, admitted through the attached Exhibits that Edison is unable or unwilling to comply with 10 CFR Part 50, Appendix B (as Intervenors' Contention 1A states), with respect to preoperational testing. In addition, the staff has
'taken the position in Exhibit A that Edison's actions may well have been caused by emphasizing production over quality, thus raising serious questions of the independence of quality as-surance functions from other func-tions within Edison.
While Intervenors do not know whether the staff intends to m
u formally change its position previously presented to the Board, or whether the staff or Edison had planned to notify the Board of these developments e
/, this evidence represents both (1) a change of staff position with respect to preoperational testing and (2) evidence through staff documents of serious deficiencies in that program.
Therefore, the record should be reopened in order to supple-ment it with the attached Exhibits.
Respectfully submitted, a
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A)hqP'"
Jane M. Whicher Attorney for the
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Rockford League of Women Voters, and DAARE/ SAFE on issues and matters relating to quality assurance / quality control .
June 29, 1983 Jane M. Whicher 109 N. Dearborn Suite 1300 Chicago, Illinois 60602 (312) 641-5570
)
~*/ Duke Power Company (William B. McGuire Nuclear Station, Units 1 and 2), ALAB-143 6 AEC 623, 625 (1973).
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EXHIBIT A j
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UNITE)3TATES NUCLEAR REGULATORY COMMISSION l
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OLEN ELLYN. ILLINots 00137 l May 26, 1983 l' Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. W. Forney and K. Connaughton of this office on March 1 through April 30, 1983, of activities at Byron Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-130 and No. CPPR-131, and to the discussion of our findings with Mr. V. I. Schlosser and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required.
We are particularly concerned about the repetitive nature of the examples of noncompliance identified during this inspection. Similar items of noncompli-ance were identified in Inspection Reports No. 454/82-07, No. 454/82-10 and No. 454/82-22. In responding to these examples of noncompliance please specify what measures, in addition to those described in your responses to previously identified items of this nature, will be established to provide the necessary additional assurances that preoperational tests will be conducted in accordance with test procedures and applicable test program requirements.
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Commonwealth Edison Company Based on our review of the nonconformance of liner seam welds, your tentative disposition of that nonconformance and interviews with Commonwealth Edison personnel, we are concerned that identified nonconformances with FSAR commit-ments which are dispositioned "use as is" may not be identified in the FSAR as exceptions to those commitments. Please include in your response to this letter, a description of actions taken, or planned to be taken, to assure that nonconformances so dispositioned are identified in the FSAR as exceptions to applicable commitments.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such in-f o rma tion. If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be established. Consistent with Section 2.790(b)(1),
any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the con-siderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.
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Commonwealth Edison Company May 26, 1983 We vill gladly discuss any questions you have concerning this inspection.
Sincerely, h,Y.
C. E. Norelius, Director Division of Project and Resident Programs
Enclosures:
- 1. Appendix, Notice of Violation
- 2. Inspection Reports No. 50-454/83-18(DPRP)
No. 50-455/83-15(DPRP) cc w/encls:
D. L. Farrar. Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent ,
R. E. Querio, Station Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Philip L. Willman, Esq.
Assistant Attorney General Environmental Control Division Reed Neuman, Esq., Assistant Attorney General Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE A
Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 Docket No. 50-455 As a result of the inspection conducted on March I through April 30, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violation was identified:
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 satis-factorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents."
i The Byron FSAR, Chapter 17.0, Quality Assurance, states in part: "Therefore the CE Topical Report CE-1-A, Revision 7 and all subsequent rcvisions unless otherwise 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, Section 11, states in part: Preoperational tests which are performed on critical safety Category 1 equipment are controlled by approved written procedures....."
The Byrcn 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:
2.1.3 Review the pertinent special precautions.
2.1.4 Inform each person what he will be expected to do during the test."
Contrary to the above, (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 loose part j on the loose parts monitoring system was not observed in that all channels of the loose parts monitoring system were in a high alarm state.
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Appendix 2 (c) Reactor Coolant System pressure and temperature were not maintained within their expected ranges and testing continued after the out-of-tolerance values were read from the prescribed instrumentation and recorded.
(d) Pre-test briefing of operators prior to performance of Section 9.5 and 9.6 did not include a review of precaution 8.19 or the Reactor Coolant System temperature and pressure control bands as evidenced by interviews with test support personnel and examples (b) and (c) above.
This is a Severity Level IV violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this effice within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
Dated May 26, 1983 YY. Od %
C. E. Norelius, Director Division of Project and Resident Programs l
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l U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-454/83-18(DPRP); 50-455/83-15(DPRP)
Docket Nos. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Station, Byron, IL Inspection Conducted: March 1 through April 30, 1983 Inspectorb-(' ' jj_ + ' -W'.
. Forney
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. Connau. ton w S-25-83 Date Approved By: D . ye ief Reactor Projects Section IB [J /3 Dste '
Inspection Sumary Inspection _on March 1 through April 30, 1983 (Reports No. 50-454/83-18(DPRP);
50-455/83-15(DPRP))
Areas Inspected:
Routine safety inspection to review preoperational test procedures, witness the conduct of preoperational tests, review allegations and review disposition of Nonconformance Report F-770 on fuel pool liner welds.
The inspection involved a total of 250 inspector-hours onsite by two NRC inspectors Results: including 34 inspector-hours onsite during off-shifts.
Of the four areas inspected one item of noncompliance with four examples was identified in one area.
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DETAILS i
- 1. Persons Contacted Commonwealth Edison Company V. Schlosser, Byron Project Manager G. Sorensen, Project Construction Superintendent R. Querio, Byron Station Superintendent i
R. Tuetken, Project Construction Assistant Superintendent
- C Tomashek, Startup Coordinator
- M. Stanish, Site Quality Assurance Superintendent
- R. Klinger, Project Construction Quality Control Supervisor
- R. Ward, Assistant Superintendent Administrative and Technical Support
- R. Pleniewicz, Assistant Superintendent, Operating
- D. St. Clair, Technical Staff Supervisor F. Hornbeak, Assistant Technical Staff Supervisor for Preoperational Testing T. Schuster, Licensing Staff
- R. Glazier, Licensing Staff
- C. Lenth, Licensing Staff
- G. Klopp, CECO Project Engineering
- N. Westburg, Quality Assurance Engineer L. Wehner, Technical Staff J. Stanton, Technical Staff B. Milner, Technical Staff G. Grabens, Preoperational Test Coordinator ,
W. Smith, Technical Staff M. Robinson, Technical Staff
- Denotes persons attending exit interview on May 2', 1983.
- 2. Preoperational Test Witnessing
- a. General The inspectors witnessed portions of preoperat'ional tests 2.63.10,
" Integrated Hot Functionals", 2.69.10, " Reactor Coolant Pressurizer",
2.52.10, " Neutron Monitoring - Excores", 2.133.10, " Reactor Loose Parts Monitor" and, 2.51.11, " Main Steam (Safety Related - PORV's)",
to determine whether or not operating and maintenance personnel were briefed on the scope and objectives of testing to be performed; prerequisites and initial conditions, as applicable, were met; precautions were observed; test procedures were adhered to; test procedures were current and in use at each test station; communica-tion between test stations were adequate and; deficiencies were documented, evaluated and corrected in accordance with appl'icable program requirements. Observations and findings pertaining to the conduct of individual tests are discussed in Paragraphs 2b through 2f.
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- b. Preoperational Test 2.63.10. " Integrated Hot Functionals" The inspectors reviewed Unit 1 operating logs for April 26, 1983 which indicated that two spurious actuations of Power Operated Relief Valve 455A occurred and were related to the troubleshooting of a temperature instrument loop by instrument maintenance person-nel. Reactor Coolant System pressure dropped from 300 psig to 200 psig within seconds. Details of the cause(s) and corrective action were not clear from a review of the operating log. On April 27, 1983, the System Test Engineer on duty and the Unit 1 operator gave instrument maintenance personnel permission to, again, troubleshoot certain temperature instrument loops. Shortly thereafter reactor coolant pressure was observed to drop rapidly from 300 psig. to 200 psig. Based on the inspectors' observations, the operator appeared not to have recognized that Power Operated Relief Valve actuation had occurred and was the cause of the rapid reduction in pressure.
The operator and Shift Foreman tried to account for the observed pressure transient by evaluation of charging and letdown flow control. The inspectors observed the relief valve actuation and informed operating personnel. The inspectors' expressed concern to the licensee that the operators and technical staff directing the test were apparently not aware of the previous similar occurrence described in the logs as evidenced by.their failure to quickly recognize that a Power Operated Relief Valve actuation had occurred.
Discussions with the Unit 1 operater revealed that he had not been on shif t for some time and was generally not well aware of plant condi-tion requirements and previous occurrences during the test. On April 27,1983, the inspector observed that during the performance of Section 9.5 of the test that reactor coolant system pressure was outside of the expected values provided in the test. The inspector informed the System Test Engineer and inquired as to what values had been observed and recorded to satisfy the earlier step which provided the expected range. A review of the data indicated that both temperature and pressure were outside of their expected ranges and that the deficient condition went unrecognized and several subsequent steps were performed. This is an example of noncompliance identified in the Appendix (50-454/83-18-01c; 50-455/83-15-01c).
Interviews with operating personnel revealed that they were unaware of the ranges of pressure and temperature they were to control to.
The inspector noted that reactor coolant system pressure indicator 1 PI-403, which was to be used to verify that reactor coolant system pressure was being maintained within the expected value range of 375 psig. to 400 psig., was a 0-3000 psig. guage with 50 psig. in-crements. The inspector informed test personnel that the indicator did not have the adequate readability for that application.
Subsequently, test personnel employed a chart recorder, scaled for improved readability, as indication of reactor coolant system pressure. On the same day, the inspectors' observed that all channels of the Loose Parts Monitoring system were in an alarm state.
Upon quizzing the operators, it was determined that they did take data for the Loose Parts Monitor on their round sheets, however, 3
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' the only thing that wbs recorded was the switch position for the -
audible alarm. This switch had been faithfully recorded as "off" for the lar three shifts, while all alarm indicating lights were illuminated.' + This check was the only periodic check of the Loose Parts Monitor that the inspectors could verify as having been per, formed. Based on interviews with the operators, they were unaware of precaution 8.19 in the test procedure which states: "Upon any indication of a loose part on the Loose Parts Mob.itoring System, proceed to exiting Procedure 9.37". Failure on the part of per-sonnel directing the test to brief operating personnel on the control bands for reactor coolant system pressure and tempeisture, and the precaution concerning indicatiens of loose parts on the Loose Parta Monitoring System is an example of noncompliance identified in the Appendix (50-454/E3-18-01d; 50-455/83-15-01d).
Failure on the part of personnel directing the test to' observe the precaution concerning indication of loose parts on the. Loose. Parts Monitoring System is an example of noncompliance identified in the ,
Appe' dix (50-454/83-18-01b; 50-455/S3-15-01b). In reviewing the
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off .;ial test copy of the test procedure the inspectbr noted that initial condition 7.22.2, which required verification of calibration status and identification of vibration measuring equipiscut had not
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been signed off as being established, though the equipmeut had already been used for reactor coolant ptmp vibration measurement in ,
Secticas'9.4, 9.5, and 9.6.e Furthermore, the vibration data avail- ,
able in the centrol room did not contain the information required '
by initial condition 7.22.2. Failure to establish this initial
' condition prior to perfor:sance of ipplicable test sections is a violation of procedure and is an example of noncompliance identified
, i~n the Appendix (50-454/83-18-01a; 50-455/83-18-01a). '
As a result of the foregoing examples of noncompliance, the inspectors held discussions with Byron Station management personnel responsible for execution of the test program and bace again emphasized 'the need ~for thorough review.of initialxconditions and prerequisites, thorough pre-test briefings of test suppo'rt personnel,
- including a review of precautions and other limitations that must be
~ .6brervedt. The inspectors also stated that;for integrated hot
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functional ter, ting, orderly and thorsingh shif t turnovers need to be
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held between all"oncomin'g and ofigoing per'sonnel to review plant
' ' conditions, test (tatus, previously encountered problems with th
- tiest, andsany test changes'that will impact on testing to be f.
performed by oncoming shift pers'onnel. -The Licensee' acknowledged !
these corments and indicated that the necessary emphasin would b- "
provided lirior to resumptio~n of testing which~was expected t6 cccur
' on or about May 14, 1983. {
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g c Preoperational Test 2.69.10, " Reactor Coolant Pressurizer" '
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- s Na items of'none'orepliance were identified. '
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- d. Preoperational Test 2.133.10. " Reactor Loose Parts Monitor" No items of noncompliance were identitied.
- c. Preoperational Test _2.51.11 " Main Steam (Safety Related - PORV)"
The inspector noted during test instrument setup for Section 9.4, that the pressure guage being installed to measure Power Operated Relief Valve actuation setpoints did not have the accuracy required to establish that actuation occurred within the setpoint tolerances specified by procedure. The inspector informed the System Test Engineer of this discrepancy. The System Test Engineer subsequently reviewed the setpoint tolerances specified in the procedure and determined that they had been improperly specified (too narrow a range-by a factor of ten). The test procedure was subsequently changed to indicate the appropriate setpoint tolerances. While the inspector recognized that, in this instance, the " misapplication" of test instrumentation occurred, in part, because a test procedure i
error resulted in overly restrictive setpoint tolerances, the inspector was concerned that test personnel had not recognized the discrepancy up to the point in time when the inspector had pointed it out.
For many applications, test instrument error is negligable when compared to the allowable instrument error associated with the process instrument or control loop being tested and can be neglected without compromising the validity of the verification test data,.
Test procedure Initial Conditions specify the test equipment to be used and, presumably, take into consideration the accuracy and precision required for the test.
The inspector's observations during this test and the Integrated llot Functional Test indicated a need to review additional tests to determine whether or not similar discrepancies have gone unnoticed during test procedure review and/or test performance. This is an unresolved item pending further review by the inspector (50-454/83-18-02; 50-455/83-15-02).
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Preoperational Test 2.52.10. " Neutron Monitorina - Excores" No items of noncompliance were identified.
- 3. Review of Reactor Cavity, Refueling Canal, Decontamination Pit and Spent Fuel Pool Liner Seam Weld Reinspections While attending the Byron Operating License Hearings, the inspectors were liner. informed of " welding problems" associated with the spent fuel pool The inspectors subsequently interviewed licensee personnel and determined that portions of the fuel pool liner welds had been re-inspected (dye penetrant tested) and found to be rejectable. Rework was f initiated for rejected welds. The identified nonconformance was docu-mented and, at the time of the review by the inspectors, considered 5
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I resolved pending rework of the rejected welds. The resolution was based on a determination by Commonwealth Edison Company, Sargent and Lundy, and Consultant personnel that the welds were acceptable. "Overinspec-tion", and " unnecessary" surface preparation were cited as reasons the
" acceptable" welds were found rejectable upon reinspection. The Resident Inspectors felt that the resolution, as documented, was of questionable technical merit. This matter was referred to the NRC Region III Office, Division of Engineering Programs for followup. A special inspection was conducted by K. Ward of the Region III Office. The results of this inspection are documented in NRC inspection report 50-454/83-15 50-455/83-13. Based upon discussions with the Licensee and the results of dye-penetrant testing performed during the special inspection, the Licensee acknowledged that conformance with the Safety-Category I design requirements was not established and that the most attractive alternative to resolve the issue was to amend the FSAR to recategorize the liner as Safety-Category II and include the required analysis to justify the re-categorization. The inspectors learned that an FSAR amendment had not been contemplated prior to the inspectors' review of the matter. The basis for not amending the FSAR was that the individuals who dispositioned the nonconformance repart ascerted that FSAR commitments had been met, despite evidence to the contrary. In any event, a FSAR emendment is currently being sought by the Licensee. Unresolved item (50-454/83-15-01; 50-455/83-13-01) was written as a result of the special inspection and will remain pending NEC approval of the FSAR amendment. The inspectors learned, in the course of discussions with Licensee personnel regarding the liner welds, that identified nonconformances with FSAR commitments which we determined to be genlune but are dispositioned "use as is" may not have resulted in amendments to the FSAR. This is an open item psnding further revicw (50-454/83-18-03; 50-455/83-15-03).
- 4. Investigation of Allegations The alleger stated that a Discrepancy Report was issued by Hatfield Electric Company Quality Control which identified a loose concrete expansion anchor (hilti bolt). The corrective action taken by production personnel was to relax the expansion anchor, tapped the bolt in deeper and reexpand the anchor. The corrective action indicated on the Discrepancy Report merely stated that the anchor bolt installation was acceptable. The alleger was disturbed that the corrective action as documented by production personnel, made Quality Control personnel "look bad". The concrete expansion anchor was inspected by quality control personnel following corrective action and found acceptable.
Subsequent interviews with the alleger revealed that he had not attached any safety significance to this allegation. The inspectors have emphasized to the Licensee, the need to adequately document cor-rective action taken to resolve discrepancies and nonconformances.
Also, a review of a sample of Hatfield Electric Company discrepancy reports and nonconformance reports was performed by the inspector.
Corrective action descriptions were generally sufficient and none of the reports reviewed had corrective action descriptions similar to the one referenced in the allegation.
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- 5. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph 2e.
- 6. Exit Interview The inspector met with Licensee representatives denoted in Paragraph 1 !
on tiay 2, 1983 to discuss the scope and findings of this inspection. '
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UNITE 3 STATES l n NUCLEAR REGULATORY COMMISSION
$ e REGION lli o,
'g /[ 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 80137 l'."l L'1 R D Docket No. 50-454 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Centlemen:
This refers to the enforcement conference conducted by me and members of my staff on May 23, 1983, with Messrs. Stiede, Farrar and Shewski and others of your staff relative to deficiencies identified in the preoperational test proEram for Byron Station, Unit 1, authorized by NRC Construction Permit No. CPPR-130.
The enclosed copy of our report of this enforcement conference identifies those matters discussed during the conference.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) vill be pinced in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed report of the enforcement conference will be placed in the Public Document Room, l
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y Commonwealth Edison Company 2 JU,710 1983 We will gladly discuss any questions you have concerning this enforcement conference.
Sincerely.
R. L. Spessard, Director Division of Engineering
Enclosure:
Enforcement Conference Report No. 50-454/83-23(DE) cc w/ encl:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen Site Project Superintendent R. E. Querio. Station Superintendent -
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Philip L. Willman, Esq.
Assistant Attorney General Environmental Control Division j
Reed Neuman, Esq., Assistant Attorney Generni Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE D
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l U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-454/83-23(DE)
Docket No. 50-454 License No. CPPR-130 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 1 Enforcement Conference: Commonwealth Edison Company Corporate Offices First National Building One First National Plaza Chicago, IL 60690 Enforcement Conference Conducted: May 23, 1983 Conference Attendees:
Div'sion of ngineering r _g[f[f3 L. A. Reye Chief # # F3 -
Test Prog a S etion rn Senior Resident Inspector, Byron Station d!N D8M M. A. Rifig, Inspector O Test Program Section Approved By: R. L. Spessard, Director f[E3 Division of Engineering
! Enforcement Conference Summary i
Enforcement Conference on May 23, 1983 (Report No. 50-454/82-23(DE))
l Subjects Discussed: Deficiencies identified in the Preoperational Test i
Program for Byron Station, Unit 1.
.A._._
DETAILS
- 1. Attendees Commonwealth Edison Cecqny T. Tramm, Nuclear Licensing V. Schlosser, Project Manager, Byron C. Tomashek, Startup and Planning Engineer R. Querio, Station Superintendent R. Pleniewicz, Assistant Superintendent, Operations D. Farrar, Director of Nuclear Licensing W. Stiede, Assistant Vice President L. DelCeorge, Staff Assistant to Assistant Vice President R. Jortberg, Director of Nuclear Safety W. Shewski, Manager of QA J. Bitel Assistant to Manager of QA U.S. Nuclear Regulatory Commission R. Spessard, Director, Division of Engineering L. Reyes, Chief, Test Programs Section W. Forney, Senior Resident Inspector, Byron H. Ring, Inspector, Ter.t Programs Section
- 2. Areas Discussed Mr. Spessard stated that the purpose of the enforcement conference was to emphasize the seriousness with which the NRC views problems observed at the Byron Nuclear Station, Unit 1, in the following areas:
Inadequate conduct of preoperational testing.
Inadequate preparation of preoperational test procedures.
Mr. Spessard stated that problems like those observed are not indicative of a quality test program and cannot continue. The Region III Staff presented a synopsis of the observed problems as follows:
- a. Conduct of Preoperational Testing (1) Inspection Report 454/83-18 fdentified a Severity Level IV violation in the following areas:
(i) Reactor coolant pressure maintained outside of band allowed by test.
(ii) Reactor coolant temperature maintained outside of band allowed by test.
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(iii) Initial condition on vibration equipment not signed. 1 (iv) Precaution on Loose Parts Monitoring not observed.
(v) Inadequate briefings on precautions and pressure / tem-perature bar.ds.
(2) Additional Concerns:
(1) Operators unaware of logs and/or poor turnover and briefings because they did not recognize PORV opening in spite of previous o'?urrences.
(ii) Use of inadequate instrumentation.
(a) 0-3000# gage to maintain 25# band in IHF test.
(b) Pressure gage for Main Steam-PORV test did not meet procedure acceptance criteria of t2# for 1100# plus test.
(iii) Test observers (Ceco) noted unit operators leaving panels for washroom breaks with plant in cold, solid, pressurized condition.
(3) Sinilar examples in following reports:
(1) Inspection Report 454/82-22 (Severity Level V) - Failure to document deficient condition (Containment Spray Test).
(ii) Inspection Report 454/82-10 (Severity Level IV) - Nine examples of poor test conduct (Diesel Generator Test).
(iii) Inspection Report 454/82-07 (Severity Level IV) - Three examples of poor test conduct (Diesel Generator Test).
- b. Preparation of Preoperational Test Procedures (1) Inspection Report 454/83-17 identified a Severity Level IV violation with nine examples in the following areas of IHF Test:
! (1) Failure to confirm FSAR testing commitments (Essential l Service Water, Component Cooling, Radioactive Waste Gas, etc.).
(ii) Failure to follow Startup Manual (Designation of
, Acceptance Criteria).
l l (iii) Misleading typographical errors such that test could not l
be performed correctly.
(2) Concern is the number of problems in a significant test.
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m (3) Similar examples in the following report:
(1) Inspection Report 454/82-21 Control room chilled water test had similar problems.
j (ii) Inspection Report 454/83-12 (Severity Level V) - Failure to demonstrate system capability as described by FSAR Containment Floor Drain Test.
The licensee representatives detailed licensee actions which had been taken over the past 16 months to improve the quality of the test program.
These actions included periodic housekeeping inspections, addition of expected values and tolerances for data recorded in tests; modification of tech staff group leader responsibilities to provide greater control and oversight of test performance; use of Startup Manual qualification exams; stressing the content and importance of briefings; development of the shakedown program; and development of the observer program and expansion of formal briefings to include all personnel associated with the test. For the specific Integrated Hot Functional (IHF) testing problems, the Station Superintendent stated that the duties of the Assistant Superintendent of Operations have been modified to provide oversight of testing, access to Unit I side of the control room is being restricted to minimize operator distractions and interference, and that additional emphasis has been placed on better briefings and shift turnovers.
The NRC cautioned against an overemphasis on schedule and production ,
which may have contributed to inadequate procedures and an operations staff which was ill-prepared for the increased involvement of IHF.
The licensee acknowledged the difficulties encountered in the IHF, but took exception to the opinion that overemphasis on a schedule may have influenced the events. The NRC pointed out that the problems noted were primarily associated with personnel attitude and prepara-tion as opposed to equipment. The NRC stressed that, although the licenseo corrective actions appear to be reacting to specific NRC observations, a more aggressive attitude is needed to discern potential problems and prevent their occurrence. The licensee responded by stating that potential problens are pursued in this way with many successful results but that these successful efforts go unnoticed by the NRC.
The enforcement conference concluded with the NRC stressing the import-ance of quality test program performance and the ifconsee stating the intent to correct the problems and perform a complete and quality test program.
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4 EXIIIBIT C f
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J 7ee noosavati noAo GLEN ELtVN,ILLINotS 60137 MAY 2 4 1983 Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 l Gentlemen:
1 This refers to the routine safety inspection conducted by Mr. M. A. Ring of this of fice on March 30, 31, April 1, 5-8,18-22, 26-29, and May 4, 1983, of l
activities at Byron Nuclear Power Station authorized by NRC Construction i Per. nits No. CPPR-130 and No. CPPR-131 and to the discussion of our findings with Mr. V. Schlosser, Mr. R. Querio and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required. Your respon.=e should reflect your consideration of all of the specific examples documented in Paragraphs 2 and 3 of the enclosed inspection report.
We are concerned about the numerous examples of your failure to follow your own administrative procedures during the development of the important hot functional test procedure. Additionally, we are concerned about the apparent inadequacies of your administrative procedures which allowed the hot functional test procedure to be approved with numerous examples of the {
test procedure not adequately addressing FSAR testing commitments. Please give particular attention to these matters in your response to this letter.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s)'
will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within theyo::
and specified s periods noted above, a copy of this letter, the enclosure (s),
response to this letter will be placed in the Public Document Room.
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Commonwealth Edison Company The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, c,
D D J. F. Streeter, Chief Engineering Branch 1
Enclosures:
- 1. Appendix, Notice of Violation
- 2. Inspection Reports No. 50-454/83-17(DE)
No. 50-455/83-14 (DE) cc w/encls:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station Superintendent DMB/ Document Control Desk (R'DS)
Resident Inspector, RII! E.r,t Resident Inspector, RIII Braidwood Philip L. Willman, Esq. .
Assistant Attorney General Environmental Control Division Reed Neuman, Esq., Assistant '
Attorney Cencral i Ms. Jane M. M.icher Diane Chavez, DAARE/ SAFE l
Commonwealth Edison Company l
l The responses directed by this Ictter (and the accompanying Notice) are I not subject to the cicarance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, 6
J. F. Streeter, Chief Engineering Branch 1
Enclosures:
- 1. Appendix, Notice of Violation
- 2. Inspection Reports No. 50-454/83-17(DE)
No. 50-455/83-14(DE) cc w/encls:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RITI Byron Resident Inspector, RIII Braidwood Philip L. Willman, Esq. .
Assistant Attorney General Environmental Control Division Reed Neuman, Esq., Assistant Attorney General Ms. Jane it. Whicher Diane Chavez, DAARE/ SAFE I
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_ Appendix NOTICE OF VIOLATION Commonwearth Edison Company Docket No. 50-454 Docket No. 50-455 As a result of the inspection conducted on March 30, 31, April 1, 5-8, 18-22, 26-29 and May 4, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:
- 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. Instruc-tions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Criterion XI, 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..."
Section 2.4.3 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 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, mis-leading typographical errors, incomplete testing provisions, and incomplete objectives.
This is a Severity Level IV violation (Supplement II).
- 2. 10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, r. hipping, cleaning and preservation of material and equipment...to prevent damage or deterioration".
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- sq i Appendix 2 The 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 endoraes the requirements of ANSI W45.2.3-1973. Section 3.2.1 of ANSI 45.2.3 states "The work areas shall be kept sufficiently clean and orderly that construction activity can proceed in an efficient manner that will produce and maintain quality in conformance with specified requirements. Where large accumulations of materials 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 col-lected, 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 conditiens that will adversely affect quality."
Contrary to the above, the applicant's program for maintaining clean 11-ness and housekeeping was not being adequately implemented as evidenced by the following examples:
- a. Da April 6 and 7, 1983 the inspector noted many loose pieces of lagging and considerable garbage end 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 that instrument valves could not be operated and loose boards were leaning against valve handwheels and generally strewn about.
- b. On April 20 and 28, 1983 the inspector noted considerable food stuffs (soda cans, banana peels, orange peels, candy bar wrappers and small food tins), loose boards, and cigarette packs in the area of the Unit 2 Diesel and Motor Driven Auxiliary Feed Pumpa.
- c. On April 28, 1983 the inspector noted that the SG "C" cubicle walkway had numerous pieces of rags, pop cans, cigarette butts, flexitallic gasket and gengtal construction material.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
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MM 24 tesa- g g-i Dated J. F. Streeter, Chief Engineering Branch 1
s U.S. Sl' CLEAR REGULATORY COMMISSION REGION III Reports No. 50-454/83-17(DE); 50-455/83-14(DE)
Docket Nos.30-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, linits 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: March 30, 31, April 1, 5-8, 18-22, 26-29 and May 4, 1983 Inspector: MTfk }
!!. A. Ridg
[2.f/63 Date '
Approved By- . A. Reyes ief f/bV93
, Test Progra Section Inspection Summary _
inspection on March 30, 31, April 1, 5-8, 18-22, 26-29 and May 4, 1983 (Reports No. 50-454/83-17(DE); 50-455/83-14(DE)) l l
Areas Inspected: Routine unannounced inspection to review pre-operational test procedures and witness the performance of pre-operational testing. The inspection involved 131 inspector-hours onsite by one NRC inspector including 18 inspector-hours onsite during off-shifts.
Results: Of the two areas inspected, two items of noncompliance were iden-tified; one in each area (failure to pet - rm an adequate test procedure review and approval - Paragraph 3 and failure to adequately implement a ;
j program for naintaining cleanliness and housekeeping - Paragraph 2).
DETAILS
- 1. Persons Contacted
- +V. Schlosser, Project Manager
- B. Stephenson, Operations Manager
- C. Tomashek, Startup Coordinator
- +R. Pleniewicz, Assistant Superintendent, Operating
- R. Tuctkin, Assistant Superintendent, Project Construction
- H. Westberg, QA Engineer
- D. St. Clair, Technical Staff Supervisor
- R. Querio, Station Superintendent h+R. Ward, Assistant Superintendent, Administration and Support Services
- W. Dijstelbergen, Project Engineering, On-Site
- T. Schuster, Technical Staff-Licensing k+W. Eurkamper, QA Supervisor, Operations AM. Stanish, QA Superintendent AG. Klopp, Project Engineering
- G. Abrell, Quality Assurance
- Denotes those attending the exit interview. Mr. Klopp attended per teleconference.
+ Der.otes those attending the Management Meeting on May 4, 1983, with Messrs. L. Reyes, K. Connaughton, J. Ilinds, and M. Ring of the NRC.
- Denotes those attending the management meeting only.
- 2. Pre-Operational Test Performance The inspector witnessed the performance of portions of test Procedures 2.3.10 Auxiliary Feedwater, 2.52.10-Neutron Monitoring-Excotes, 2.69.10-Reactor Coolant-Pressurizer, and 133.10-Reactor Loose Parts Monitor.
The inspector verified the following attributes for these tests:
- a. Test conducted in accordance with an approved procedure
- b. Test equipment properly installed
- c. Test data collected and recorded properly
- d. Adequate ability of personnel conducting the test
- e. Deficiencies and test problems documented
- f. Test changes processed in approved manner No problems were noted rep rding the conduct of the tests. Ilowever, while observing these tests and preparations for others, the following housekeeping prob 1 cms were noted:
- a. While observing Auxiliary Feed Testing on Spril 6, 1983, the inspector noted several housekeeping problems in the MSIV rooms.
Many loose pieces of lagging and considerable garbage and trash 2
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were strewn about, 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 that instrument valves could not be operated and loose boards were leaning against valve hand wheels and generally strewn about. The inspector returned to the same areas on April 7, 1983 and noted the same problems. There was no evidence
- that personnel in the area were attempting to clean up. The inspector reviewed the plant tour sheets through March 21, 1983 with the llousekeeping and Equipment Protection Coordinator and found no evidence that the program was noting this problem.
- b. On a plant tour on April 20, 1983, the inspector noted poor housekeeping in the area of the Unit 2 Diesel and Motor Driven Auxiliary Feed Pumps. Considerable food stuffs (soda cans, banana peels, orange peels, candy bar wrappers and small food tins), loose boards, and cigarette packs littered the area. On April 28, 1983 the inspector returned to the area and noted many of the same items still evident as well as soda cans, cigarette packs and loose rags and paper on the Diesel. In addition, the amount of work in the area had increased since a pipe cutting and welding station had been set up between the pumps.
- c. During an inspection of SG "C" Hydraulic Snubbers on April 28, 1983, it was noted that the SG "C" cubicle walkway had numerous pieces of rags, pop cans, cigarette butts, flexitallic gasket and general construction material.
The above items are considered to be examples of an item of noncompliance (454/83-17-01 and 455/83-14-01).
The inspector also observed the performance of portions of test Procedure 2.63.10, Integrated Hot Functional. The Byron Resident Inspector's Office also observed portions of the 2.63.10 test. During the performance of the test, the inspectors observed actions which were censidered to be items of noncompliance. The details of these items of ncncompliance are recorded in the Resident Inspector's Report Nos.
50-454/83-18 and 50-455/83,-15 These items were discussed in the management meeting held on May 4, 1983.
No other items of noncompliance or deviations were identified.
- 3. Preoperat ional Test Procedure Review The inspector reviewed test Procedure 2.63.10, Integrated llot Functional, and commenced a review of test Procedure 2.51.10, Main Steam (Safety Related). The review of 2.51.10 is not complete and will be doccmented in a later report.
The Integrated Hot Functional test (IllF) was reviewed against the FSAR, SER, Regulatory Guides- 1.68, 1.79 and 1.20, the Westing; house Startup Manual and PLS, the proposed Technical Specifications, and the Byron Startup Manual and the following problem areas were noted:
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- a. Although the IllF test took some data on the performance of the component cooling system during operatiens at temperature and during cooldown, none of the data taken was designated as acceptance criteria per the Byron Startup Manual. The IIIF acceptance criteria section contained no acceptance criteria on component cooling system performance even though FSAR Table 14.2-16 stated data would be taken
.during liiF to verify adequate cooling and as, acceptance criteria, that the system .ould be verified to supply cooling in accordance with the description section of the FSAR, Subsection 9.2.2.3.
b.
The IlfF test contained no acceptance criteria for the performance of the steam dump and residual heat removal system during cooldown event though the FSAR Table 14.2-60 on Integrated Hot Functional Cooldown under the acceptance criteria section stated " Steam Dump and residual heat removal systems cool the plant from hot no-load temperature to cold shutdown conditions in accordance with subsection 5.4.7.1." Additionally, none of the data taken during cooldown was designated as acceptance criteria data.
c.
In four sections of the IHF procedure dealing with loop stop valve timing, reactor coolant pump starting and relief line flew verifica-tion for each of the four loops, there were so many typographical errors (>25) that it was difficult to follow the test and, if performed as written, incorrect data would have been recorded.
d.
The IliF test did not contain any acceptance criteria for the performance of the essential service water system, none of the data taken on the essential service water system was designated as acceptance criteria data and data was not taken on 11 of the 12, components which essential service water may cool. These observa-tions were not consistent with the FSAR Table 14.2-15 which describes verification of ability to maintain adequate component temperatures during IHF and, as acceptance criteria, system ability to supply water under all modes of operation in accordance with the FSAR, Subsection 9.2.1.2.
e.
The IllF test did riot trans,fer control af either the auxiliary feedwater regulating valves or pumps from the main control panel to tions the Remote Shutdown Panel (RSP) and did not perform any evolu-from the RSP with these components to demonstrate their ability to control f rom the RSP, even though the IIIF test listed this operation as one of its objectiver..
f.
The Il!F test contained no acceptance criteria regarding operation of the purification function of the Chemical and Volume Control System (CVCS) even though the FSAR Table 14.2-49 describes demonstration the hot functional of the operation of the purification system during procedure.
g.
The IllF test did not contain any acceptance criteria for the lift checking of the steam generator safety valves or power operated relief valves (PORVs), did not record the safety valves lift set-points in the test procedure, did not provide expected values for 4
a
}J l the safety valve lift setpoints, did not list the pressure assist device in the special equipment section, and did not designate any of the safety valve or PORV data as acceptance criteria data. These observations were inconsistent with test objective 3.8, FSAR Table 14.2-51, the Byron Startup Manual (for designating acceptance criteria) and a Technical Staff Supervisor Memo (for expected values).
- h. The IHF test contained no testing or acceptance critoria regarding the radioactive waste gas system even though the FSAR Table 14.2-24 indicates degassing capability will be checked during hot functional testing and, as acceptance criteria, that the system will perform in accordance with the FSAR descriptive chapter (11.3).
- i. The IHF test did not designate as acceptance criteria data that data which was taken to satisfy acceptance criteria for steam generator B, C, and D Icvel, pressurizer level, pressurizer pressure hi pressure deviation and centrifugal charging pump driven seal injection flow.
This observation is not consistent with the Byron Startup Manual.
The above items are considered to be exampics of an inadequate review of the Integrated Hot Functional Test and are considered to be an item of noncompliance (454/83-17-02).
In addition to the above items, the review of 2.63.10, Integrated Hot Functional Test, produced the following areas where additional information or discussion with the applicant is necessary:
- a. Table 14.2-50 of the FSAR describes an in plant setpoint and seat leakage verification test of the pressurizer safety valves which was not incorporated into the. Integrated Hot Functional Test. The applicant explained that Amendment No. 42 is being submitted to change the lift check to a bench test,
- b. The IHF test did not verify the process parameter values at which various alarms and actuations reset but did verify the action of resetting. The applicant believes the reset values to be adequately verified in the system static checks.
c.
It was uncicar from the 2.63.10 test where each of the attributes of Regulatory Guide 1.68, Appendix A, Paragraph Ib(2) and FSAR Table 14.2-48 regarding proper operation of the CVCS and boration systems is being verified.
- d. The applicant appears to be using plant operating procedures, which are not normally reviewed by all the same groups that review test procedures, in order to perform testing which satisfies commitments made in the FSAR Chapter 14 Tables for CVCS and boration, steam generator safety valve lif t checks, and cooldown.
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- e. Byron proposed Technical Specification 3.7.2.1 requires the temperature of the reactor coolant systen and the main feed to be -
greater than 70*r when the pressure of either of these fluids in the steam generator is greater than 200 psig. The inspector questioned if similar precautions should not be included in the IHF test.
- f. FSAR Tabic 14.2-38 ESF Switchgear HVAC describes testing of the ventilation system to be done during hot functional testing which was not included in the IHF test. The applicant stated that an amendment to the FSAR was also being proposed for this testing.
The above items are grouped together as an open item (454/83-17-03) pending additional information and discussions with the applicant.
No other items of noncompliance or deviations were identified.
- 4. Exit Interview The inspector met with applicant representatives denoted in Paragraph 1 at the conclusion of the inspection on April 29, 1983. The inspector summarized the scope of the inspection and the findings. The applicant acknowledged the statements made by the inspector with respect to the items of noncompliance in Paragraphs 2 and 3.
On May 4. 1983, the inspector, representatives of the Resident Inspector's Office and Region III management met with applicant repre-sentatives denoted in Paragraph 1 in order to convey to the applicant the seriousness with which Region III views the items cited in this report and in Inspection Report Nos. 50-454/83-18 and 50-455/83-15. The applicant acknowledged the statements made by Region III management and described the applicant's view of the items and some steps already taken to minimize similar future problems.
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, ps y N pu CERTIFICATE OF SERVICE
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I hereby certify that I have served copies of Interve'rtors '
Motion to Supplement QA/QC Record Regarding Preoperational Testing on each of the persons listed 'on the attached Service List by causing them to be deposited in the United States mail, first class postage prepaid, except that Messrs. Smith, Cole, Callahan and Goldberg were served via Federal Express, and Mr. Bielawski was served in person, this 29th day of June, 1983.
June 29, 1983 Jane M. Whicher by: LW - -
4 Jane M. Whicher i One of the attorneys for DAARE/ SAFE and the Rockford League of Women Voters on issues and matters relating to quality assurance / quality control Jane M. Whicher 109 North
Dearborn,
- 1300 Chicago, IL 60602 (312) 641-5570 i
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SERVICE LIST Ivan W. Smith. Chairman Steven C. Goldberg, Esq.
Adminiatrative Judge Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission
- Washington, D.C. 20555 Washington, D.C. 20555 Dr. A. Dixon Callahan Office of the Secretary of Administrative Judge the Commission Union Carbide Corporation ATTN: Docketing & Service P.O. Box Y Section Oak Ridge, Tennessee 38730 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Administrative Judge David Thomas, Esq.
Atomic Safety and Licensing Board 77 South Wacker Drive U.S. Nuclear Regulatory Commission Chicago, IL 60621 Washington, D.C. 20555 Alan P. Bielawski, Esq. Joseph Callo, Esq.
Isham Lincoln & Beale Isham Lincoln & Beale Three First National Plaza 1120 Connecticut Avenue, N.W.
Chicago, IL 60603 Room 325 Washington, D.C. 20036 Ms. Betty Johnson 1907 St rat ford Lane Ro ck fo rd, IL 61107 i
n