ML20092N404
| ML20092N404 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/18/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20092N394 | List: |
| References | |
| 8647N, NUDOCS 8407030098 | |
| Download: ML20092N404 (5) | |
Text
"
_P
(
/
s Commonwealth Edison
[
j on a First National Plazt. Chicigo, !!!inois -
\\ G } Addrrss R; ply to: Post Office Box 767 (f. Chicago. lilinois 60690 May 18, 1984 Mr. James'G..Keppler
-Regional Administrator U.S.. Nuclear Regulatory Commission 1799 Roosevelt-Road
- Glen Ellyn, IL 60137
^
Subject:
Byron Generating Station Unit 1 I&E Inspection. Report No. 50-454/84-16 Reference (a):
April 17, 1984 letter from R. D. Walker to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided.the report of an inspection at Byron
~ Station in February, March, and April.
During this inspection certain activities were found to be not in compliance with NRC requirements. ~ Attachment A to this letter contains Commonwealth Edison's response-to the' Notice of Violation appended to reference
'(a).
-Please direct further questions regarding this matter to this office.
Very-truly yours, N.
N 4e D. L. Farrar Director of Nuclear Licensing
.lm Attachments 8407030098 840620 gDRADOCK 05000454 PDR 8647N gg 22 M
L.
(..
- P
}
?
A ATTACHMENT A AN RESPONSE,TO NOTICE OF VIOLATION
[ VIOLATION 110 CFR:50,-Appendix B, Criterion XI, Test-Control, as. implemented by the
" Commonwealth. Edison Quality Assurance Manual, Quality Requirement 11.0 sand the:ByronLStartup Manual' requires:that. test.results be evaluated to LassunLconformance.with design-and performance requirements; that the data
-display-thefadequacy of the equipment to meet specified requirements; and ethat: appropriate and calibrated! test equipment be used.
~
- Contrary:toTthe above, the following examples of inadequate' implementation of theitest: program were identified:
7 l1.
The Byron TestiReview Board analyzed the-incorrect. curves for the two containment spray pumps in the evaluation-of the results of preopera-tional1 test procedure-CS--17.10, " Containment Spray."
Commonwealth
-Edison's Project;En
-Review' Board error.gineering Department failed to correct the Test 2._
_The Byron, Test' Review Board: analyzed the. incorrect-curves for the two
? residual heat ~ removal-pumps in the'. evaluation ~of the:results of
- preoperational test. procedure RH 67.10, " Residual Heat Removal."
. Commonwealth Edison's Project Engineering Department failed to correct the Test Review Board error.
~
~
3.-
The-Byron Station. failed te provide all of the strip chart' recordings S-from-preoperationalitest procedure EF 26.ll,."ECCS Full Flow," to the
_ Project Engineering Department so that a complete evaluation of~the
-results-.could be.made.
14.-
'The calibrated signal generator' chosen by the Byron-Technical Staff
- to Jserve as a calibration. check of -the strip chart recorders used in ipreoperational test. procedure EF 26.11, "ECCS Full Flow " was not appropriate.in._that:its: setting was changed:and its calibration r
rendered meaningless.
.5.
Bothisaferv injection-pumps were operated at less than 45.gpm in cviolation of precaution 8.5.1:of preoperational test procedure SI c
-73.12,~" Safety Injection-Flow Balance."
C 15. (Both' residual heat. removal pumps were operated at~less than 500 gpm
'in_ violation of' precaution'8.6.1 of preoperational test procedure SI M
J73.12, " Safety. Injection-Flow Balance."'
u
- 8647N
'E.;
4 p
(,
w
^;
l
- .i _
,;v
'a,
'"5 fl,
>\\ '
~
, m
~
a LEXA'MPLIS =l and 2 :.
i
~ - [ CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
~
~ iProject1. Engineering'sfreview of CS-17.10 and RH-67.'10 determined the performance of1the1 containment spray-and residual heat. removal pumps sto;be! acceptable;through.the~use of.the' correct curves.
Project (Engineeringcdiscovered1the-incorrect.use of the pump. curves.by the
'StationJTRB but: neglected to disclose this finding to the Station TRB kinitheir ? comments.. - The. performance -test data for all four pumps was w
? reviewed subsequent to'thisJinspection.
The performance of the residualTheat: removal: pumps.is acceptable'.
Closer examination of the containment spray pump performance data indicates that the pump ilmpellers.may not have been installed' properly.
This matter was
- reported 1to: Region.'III on May 4,;1984 pursuant-to the requirements of 410=CFR.50.55(e).
ACTION TAKEN TO AVOID FURTHER' NONCOMPLIANCE:
'ProjectiEngineering has reviewed ~the-following thirteen "a
preoperational tests to1see if there are any similar differences betweent the-TRB and. PED: evaluations of matters-affecting test acceptance:
03.10
>18.11-CVCS
'31.10-Fuel Pool-Cooling 46/10 I & C~ Power
-~51.10-Main Steam
.51.11 Main Steam - PORV's 52.10!
Excore1 Detectors J63.ll RC MOV 63.12 RC I & C n
l69.10~
, Pressurizer 273.12' Safety Injection 86.10 Diesel Generator Ventilation it" 99.10 Switchgear Ventilation
- 0f these' thirteen. tests, only one (86.10) required supplemental 1 documentation to bring
- station files up to current standards.
The 1 PED-review and~ approval of that test was-not completed until May 11, L1984.. An earlier initial review letter was not intended to close out
-the PED review of test 86.10.
Project _ Engineering-Personnel have been instructed to clearly list
-any: future corrections or differences with regard to the Station TRB analysis of results:in-the PED review letter to the Station TRB.
The LStation's Post TRB~ Checklist (TSM #10) has been modified to include
.an: item to1 remind the TRB to specifically call out any items Trequiring; PED response.
r:
DATE:WHEN' FULL COMPLIANCE WILL BE ACHIEVED:
The PED review of other preoperational tests was completed on May 11, 1984.
Changes to test. review practices were implemented as of May 15, 1984.
-EXAMPLE 3 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
The Byron Station TRB initially failed to provide PED with all of the strip charts for the EF 26.11 preoperational test.
Upon PED request some strip charts were subsequently provided.
These charts, when provided, were sufficient for PED to complete the test evaluation.
No additional' actions are necessary.
ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
The Post Test Review Checklist, which is contained in a Tech Staff Supervisor Memo-(TSM #10) has been modified to require a determination of what data (rough or final) should be included in the review package to PED.
A checklist is.also being used to ensure all necessary information is sent to and received by PED.
DATE-WHEN FULL COMPLIANCE WILL BE ACHIEVED:
May 15, 1984 EXAMPLE 4:
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
'Each strip chart recorder used to collect data was subsequently checked to verify its accuracy.
For a chart speed of 10mm/sec, each recorder was accurate to 0.5%.
Project Engineering independently evaluated the test results and determined that the chart speed was accurate.
Based on the analyses, the test data for pre-operational test EF26.ll was found to be acceptable without use of the questionable signal generator time reference.
JACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
Byron Station is reviewing previous uses of strip chart recordings for data collection in order to ensure the adequacy of test results.
Also, Tech Staff Supervisor Memo #35, " Guidelines for Strip Chart Recorders" will be revised to incorporato necessary controls and precautions.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
June 1, 1984 L
7 s
t.
'e.
A_
EXAMPLES 5 and15:
1,
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
Within the execution of. 51-73.12, both the SI and RHR pumps were
-operated below the minimum flow levels.
In both cases the STE was aware of the test precautions and had determined no damage would o ' occur atithe lower flow rates However, no deficiency or test change request was written.
Operation.of the RHR and SI' pumps below the flowrate listed in the test " Precautions" was also reviewed by PED and found to be acceptable.
ACTION TAKEN TO A' VOID FURTHER NONCOMPLIANCE:
The Technical Staff Supervisor's Memo (TSM #07), " Documenting of Improper / Incorrect Actions During Testing" has been expanded to
~ specifically include precautions and required corrective actions.
DATE WHEN FULL. COMPLIANCE WILL BE ACHIEVED:
May 15, 1984
/
i 5
8647N A
S
..t