IR 05000454/1985008
| ML20129H591 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/12/1985 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20129H595 | List: |
| References | |
| NUDOCS 8507190258 | |
| Download: ML20129H591 (3) | |
Text
.
g* *I UN11ED ST ATES
,.
- f,' -
r-(
!
REGION lli i
NUCLEAR nEGULATORY COMMtsslOfs O
E f7.
799 ROOSE.VE LT RO AD c., S ffj cur ~ utvs. itu~Ois soin
.y
,-
.....
JUL 121985 Docket Nc. 50-454 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690
.
Gentlemer. :
This is ir. response to your letter dated June 10, 1985, informing us of the steps you have taker. to correct the violations which we brought to your attenticr, in Inspection Report Nc. 50-454/85008, forwarded by our letter dated May 3, 198E.
Ir. your response you requested that we reconsider the categorizatier. and the basis for items 1 and 2 in the Notice of Violatier..
Furthermore, yot, requested that particular attention be given to the issue of whether it is appropriate to proceed in the testing program without repeating c test when the results deviate fron the acceptance criteria.
We have reviewed the severity level of the first violation and have concluded that our original conclusion was correct.
It should be noted that this violatior. contains four separate examples of inadequate documentation of results evaluatior..
These examples were used to cemonstrate what we considered to be more than an isolated case of inadequate results evaluation.
We consider that a review process which does not adequately document the depth of the resiew and the specific technical justification for the deviation from the acceptance criteria to have more than minor safety significance. A severity level 4 was assigned to reflect our concern on this issue.
We have reviewed the basis for the first violation and have concluded that our original conclusions were correct. The first two examples in the violation concern test results which do not meet the acceptance criteria as stated in the Final Safety Analysis Report (FSAR).
You have acknowledged that the Byron Startup Manual precludes approving tests whose results do not meet acceptance criteria and that based on the difficulties meeting the stated requirements of the FSAR, the FSAR test abstract is required to be revised. We do not question your responsibility to review and accept, if appropriate, test data which falls outside expected values and acceptance criteria. However, it is incumbant upon you to identify and obtain prior approval of modifications te commitments which have been made to the NRC. Concerning the first twc examples, you comitted to verify that rod worths were in accordance with the Westinghouse Design Report. This was not or could not be performed. We believe that this testing comitment should have been satisfied or modifiec prior to proceeding to the next higher power level test sequence.
8507190258 850712 i
PDR ADOCK 05000454
I\\
G PDR IEbj
..
JUL 121985 Comonwealth Edison Company
and Low Power Test Sequence)ge for startup test 2.32.33 (Initial Criticality Specifically, the test packa does not clearly demonstrate that the test method used for obtaining the rod worth of rod control cluster assembly (RCCA) F-10 was accurate.
This is in light of deficiency AD which indicated that Westinghouse believed that the procedure employed to measure the worth of RCCA F-10 is not accurate.
You have inferred in your response that it is not feasable to verify this value by direct measurement.
If so then a modification to your testing comitments is apparently required.
Furthermore, the test package for startup test 2.64.33 (Boron Endpoint Determination)
documents a reactivity worth in excess of the value assumed by the Design Report. Westinghouse letters provided as justification for the PED acceptance of these results indicated that a detailed analysis of the exceeded acceptance criteria would be provided at a later time. Again, we agree that it is permissible within the requirements of 10 CFR 50 Appendix B to accept deviations from acceptance criteria with appropriate technical justification and approval. However, in light of the absence of the detailed analysis to be provided to Westinghouse and your commitment tc verify that control rod reactivity worths are within their respective design predictions, it is not clear that your testing comitments have been satisfied.
Concerning the third example of the first violation, we have reviewed your corrective actions and have no further concerns for this specific example.
The fourth example is considered to be significant in that the review of the test results were not accurately documented to demonstrate the depth and adequacy of the review.
You have stated that the PED evaluation did not rely on extrapolated data as the basis for their conclusions. However, in the absence of amplifying coments, an independent review cannot conclude that the PED evaluation did not endorse the incorrect results evaluation provided in the test package. Although there is not a question as to the adequacy of the specific test results, this example supports our conclusion that the depth and adequacy of your results evaluation is not supported by the documentation of the same.
Concerning the second violation, in which startup test 2.05.30 (Loss of Offsite Power) was modified to use a different source of offsite power during the test. We have reconsidered the basis for this violation and although we do not agree with the portion of your response which indicates that normal breaker position and a potential review by an offsite non-licensed operator is considered to be positive control of breaker ACB 3-7's position, based upon the new infonnation provided in your response concerning the status of the Unit 2 ring bus and the position of circuit breaker ACB 6-7 whose position was specified by the test procedure, we have concluded that the violation should be withdrawn.
Ir summary, we have reviewed the basis and severity levels of the violations and have concluded that our original determination in regard to the first violation is correct for the reasons stated above.
In addition, we believe the question of accepting data outside acceptance criteria to be adequately addressed. The second violation is withdrawn based upon the new information provided for review, and our records are being revisec accordingl
..
Commonwealth Edison Company
JUL 121985 In light of the significance you place on the first violation in regards to its likely recurrence as you complete your test program, and in the absence of corrective and preventative actions concerning this item, you are requested to respond to the Notice of Violation, dated May 3, 1985, within 10 days of the date of this letter.
In addition, you are requested to include in your response your actions concerning another example of this violation which was brought to your attention in a subsequent inspection (Report No. 50-454/85017). In this report, Unresolved Item 454/85017-10 documented the inadequate documentation of the evaluation of the pressurizer heater phase currents and their effect on pressurizer heater effectiveness as expressed in Acceptante Criteria 4.3.
This item was identified as an unresolved item because it occurred in the same time period as the previous examples and because the corrective actions and action to prevent recurrence for the violation could reasonably be expected to encompass this additional example.
In accordance with 10CFR2.790 of the Conmission's regulations, a copy of this letter will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
" Original signed by R.L. Spessard'
R. L. Spessard, Director Division of Reactor Safety cc:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager G. Sorensen, Site Project Superintendent R. E. Querio, Plant Manager cc w/ltr dtd 06/10/85:
DMB/ Document Control Desk (RIDS)
D. W. Cassel, Jr. Esq.
Resident Inspector, RIII, Byron Diane Chavez, DAARE/ SAFE Resident Inspector, RIII, Braidwood H. S. Taylor, Quality Assurance Phyllis Dunton, Attorney General's Division Office, Environmental W. Paton, ELD Control Division E. Chan, ELD L. Olshan, NRP J. St vens, N
RIII RIII RI I R I,I R II RII (
<@VanDenburgh/jk RingQ?iCYgr h
iC/m o e H rrison Str.ter 5. ssard 07/12/85 g/m f c-g/