ML20101S571

Responds to NRC Re Violation Noted in Insp Rept 50-454/84-73.Corrective Actions:Special Test Procedure SPP-85-1 Used to Test Valves Listed in Tech Spec Table 3.4.1.Review & Approval of Test Complete

ML20101S571
Person / Time
Site:	Byron
Issue date:	01/23/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9661N, NUDOCS 8502050503
Download: ML20101S571 (4)

Text

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'N Commonwe:lth Edison

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.) one First National Plaza. Chicago, Illinois O } Address Reply to: Post Office Box 767 Q,/ Chicago, Illinois 60690 January 23, 1985 Mr.. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Unit 1 I&E Inspection Report No. 50-454/84-73 NRC Docket No. 50-454 Reference (a):

November 23, 1984 letter from R. L. Spessard

^to Cordell Reed

Dear Mr. Keppler:

Reference (a) provided the results of inspections of Byron Station testing activities by Messrs. Ring, Ferrell, VanDenburgh, Butler, Dunlop and Reys and Ms. McCormick-Barger.

During that inspection certain activities were found to be not in compliance with NRC requirements..No response was required for two of the three items of noncompliance.

Commonwealth Edison Company's response to the:other item in the Notice of Violation is provided in

.the' enclosure.-

Very ruly yo

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D nnis L. Farrar-Director of Nuclear Licensing Enclosure cc:

Resident Inspector - Byron 9661N-4.

8502050503 850123

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t ti ATTACHMENT A Response to Notice of Violation (Violation:

1.-210;CFR 50, Appendix XI,' Test Control, as implemented by the

. Commonwealth _ Edison Quality Assurance Manual, Quality

Requirement ll.0 and the Byron Startup Manual requires that test results:be. evaluated to assure conformance with design and

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performance requirements-and that the_ data display the adequacy

.of:the equipment to meet specified requirements.

-Co' ntrary to the above, the following examples of inadequate evaluation of-the results of.preoperational test procedure SI

.73.13,_" Safety Injection-ECCS Check Valve Operability and iLeakage", were identified.

.a. :

The licensee approved the results of retest R-248 with

' acceptance criterion 4.2 which allowed a leakage value in excess of that which would be required by proposed

-Technical Specification 3.4.6.2.f.

' (the Technical Specification has1 subsequently been approved).

b.

The-licenseefapproved the results of leakage tests performed at a pressure'less than the Reactor Coolant System-pressure described in proposed Technical

. Specification 13.4.6.2.f.(or functional pressure). as described.in the specification and-in the ASME Code Section JXI-subsectionLIWV, " Valve Leak Rate Test".

-If the

' adjustment.is applied to the test.results, ISI 8956D,

?lSI~8819A,' 1SI 8819B, 1SI 8819C, 1SI 8819D, 1SI 8900A, and

'1SIL8900B. exceed 1.0 gpm leakage and hence would not-

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-satisfy. Technical Specification 3.4.6.2. f.

' Response ~-to" Item of' Violation

'In~ items of! violation ~:454/84-73-03a and 454/8A-73-03b,the 1.ispector 4

cited two examples of failure to: demonstrate the adequacy of equipment;-

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?to meet: Technical:Specificationfrequirements within preoperational-test;SI-73.13 and retest'R-248. - Although we understand that.the-S purpose' of' preoperational~ testing includes deconstration of the

adequacy 1of equipment design and verification of conformance -to.

l design,Lweido not feel that verbatim-verification'of Technical

' Specification -surveillancei requirements for equipment performance sis

^_ ' required within preoperational tests.. This is underscored by.the' fact

. i athat;the-Technica1' Specifications were not approved.until the Lpreoperational? test program was near.. completion.

Demonstration of 0,<

equipment availability and operability--is demonstrated prior to the j

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Lequipment. being : required for: service' by satisfying _ Technical Specification ' mandated surveillances'.'

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'Th'e71nspectorlstat'ed that_ acceptance criterion 4.2 of Retest R-248,

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(whichLallowed110.0 gpm cumulative leakage for the four pairs of SI8956

'and SI8948 check.. valves, could have allowed individual check valve L

' leek. rates in' excess of the 1.0.gpm maximum leak rate required by

approved Technical Specification 3.4.6.2.f.

The SI8948 and SI8956 valvesLwere-satisfactorily. tested and demonstrated to have a leak rate Jof less;than one gpm at a reduced pressure during retest R-248.

This resulted in meeting ~ acceptance criteria 4.1 and-4.2.

TheJ1eak5 rate;results obtained:for valves SI 8819A, B, C, D, SI 8900A,

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B,Jand.8956D in retest R-248, when adjusted for reduced pressure s

Ttesting,Twould have failed the 1.0 gpm Technical Specification maximum allowable leak rate criterion.

It_was_ intended, however, that the' sfinal? demonstration of equipment operability for the valves listed in 7 Technical Specification Table 3.4-1 would be performed by a Technical

' Specification surveillance prior to being required for service.

[Preopera'eional ' test;results collected in SI-73.13 and R-248 utilized a treduced: pressure. testing technique.

Approved Technical Specification 3.'4J6.2.f requires ' that ' adjustments tur made to correct valve ~1eak

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' rates;obtained_during leak rate tests performed at reduced pressures.

At.the time that testing land results evaluations.were being performed on,preoperational test'SI-73.13 and retest R-248 final Technical Specifications had not been. approved for Byron Station.

" Proof and

-Revieu" draft Technical Specification 3.4.6.2 did not address reduced jpressure: leak rate testing.

f0ui experience.with check valve leak rates had shown that valve leak s

rate ~ testing ~ performed at1 higher ~ pressures normally-produced lower leak? rates because of higher disk: seating forces.

By testing at a

. reduced pressure,41t;was felt 1that.an acceptable. approach was being Jusedaand thatLno correction for testing 1st reduced pressure:was necessaryLfor preoperational test evaluation.

-It should be noted

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.that,1with no correction for reduced pressure testing,.all of the

valves required 7to be tested in preoperational. test

SI-73.13 met;their 11.0 gpm maximum:allowableLTechnical Specification leak rate criterion-

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iin' retest.R-248..

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cAIRT6-85-016..has'been. written.to ensure that-the SI check valve leakagesiobtainediduring Unit.Two preoperational testing.will be 1

ladjustedLas necessary based upon the-Unit Two Technical 4 Specifications, when available.

The Braidwood pre-operational test

' data =will;also be. adjusted as necessary.

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w Corrective < Action-Taken and the Results Achieved 2

.Special-Test' Procedure SPP-85-1 was used to leak test the-valves listed in Technical Specification Table 3.4-1.

Review and approval of the results.of thisLtest are complete.

The reviews indicate that the

1eak rate results obtained when adjusted for reduced pressure testing are. acceptable.

In:the future, leakage through the valves listed in Technical Specification: Table.3.4-1 will be verified to be within Technical

~ Specification limits by Surveillance BVS 4.6.2.2-1.

Corrective Action Taken'to Avoid-Further Noncompliance Periodic-performance of surveillance testing of Reactor Coolant System pressure isolation valves-listed in Technical Specification Table

?3.'4-1 in accordance with the requirements.of Technical Specification 13.4;6.2.will_ ensure that test results obtained using' reduced pressure v'alve. leakages are adjusted as necessary to reflect the functional

-pressure; valve leak rate.

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' DateEof FulI-Compliance:

'urvei11ance testing;results for the SI check valves have been S

reviewed;and were approved prior to entry into mode 2.

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