ML20195H750

Responds to NRC Re Violations Noted in Insp Repts 50-454/87-41 & 50-455/87-38.Corrective Actions:Procedure Bap 1600-T11 Checklist Revised.Senior Reactor Operator Must Sign Checklist to Ensure List Properly Completed

ML20195H750
Person / Time
Site:	Byron
Issue date:	01/08/1988
From:	Butterfield COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
4073K, NUDOCS 8801200339
Download: ML20195H750 (4)

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[^'N Commonwealth Edison

.) - Orc First National Plaza. Chicago, IBinois 0

\ C hidross Reply to: Post Omco Box 767

( Chicago,lucas 60690 0767 i

January 8, 1988 i

Mr. A. Bert Davis Regional _ Administrator U.S. Nuclear Regulatory Commission Region III 799 Roc?,velt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 NRC Inspection Report Nos. 50-454/87-041 and 50-455/87-038 NRC DocPet Nos. 50-454 and 50-455 Reference (a): December 10, 1987 letter fz at i W.L. Porney to Cordell Read l

Dear Mr. Davis:

Reference (a) provided the results of an inspection by Messrs.

Brochman and Olshan and Ms. Gilles at Byron Station from October 31 through Nerember 30, 1967. During this inspeci. ion, certain activities were found in violation of NRC requirements. Attachment A of this letter contains Connonwealth Edison's response tc. tie Notice of Violation enclosed with -

reference (a).

Please direct any questions regarding this matter to this office.

Very truly yours,

[r L. D. Butterfield Nuclear Licensing Manager ,

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ATTACHMENT A VIOLATION 1 Technical Specification 4.6.3.1 requires that main steam isolation valve bypass valve 2MS101C shall be demonstrated operable, prior to its return to service after maintenance, by the performance of a cycling test and by verification of its isoletion time.

Contrary to the above, on September 3, 1987, valve 2MS101C was returned to service following maintenance wi!.hout the performance of an isolation thme test.

CORRWCTIVE ACTION TAKEN AND RESULTS ACHIEVED The isolation time test of valve 2MS101c was suc:essfully completed approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> af ter the valve was returned to service on Septeraber 3, 1987.

CORRECTIVE ACTION TO AVOID FURTHER VIOLATION Byron Administrative Procedure BAP 1600 requires a post-maintenance checklist to accompany all work requests, whether the work request is for troubleshooting or repair. This checklist is used to help identify any special post-maintenance testing requirements, such as ASME Section XI valve tests. After the actual work is completed on a piece of equipment, the work request is reviewed and the checklist is completed. This misred surveillance occurred because the BAP 1600-T11 checklist was not properly completed.

The BkP 1600-T11 checklist has been revised. A senior reactor operator must now sign the checklist to ensure it has been properly completed. In addition, the format of the checklist has been changed to help assure it is completed properly. Appropriate personnel iri the operating department received additional training on the proper use ol' the checklist.

DATE VE:N FULL COMPLIANCE WAS ACHIEVED The isolation time test of valve 2MS101C was successfully completed on September 3, 1987. Tne BAp 1600-T11 checklist was revised September 23, 1987. Training of operating department personnel was completed on November 30, 1987.

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4 VIOLATION 2 10 CPR 50, Appendix B, Criterion II, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement (QR) 2.0, requires that the licensee's quality assurance program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Quality Reqcirement 2.0, Section 2.3, requires that personnel engaged in testing activities will be assigned according to their formal education and <

on-the-job training. Additionally, training programs will be developed to indoctrinate and qualify personnel in specific testing activities in which they will be engaged.

P Quality Procedure (QP) 2-52 implements the requirements of QR 2.0 and states that it applies to the administration of training programs for operations, maintanance, technical, management, and quality assurance functicas in the production area so that personnel achieve and maintain suitable proficiency in the performance of their assigned tasks and responsibilities. QP 2-52 requires that the production :rdining manager prepare training standards for applicable production area personnel. A training standard is a document which identifies the training requirements for a given position.

Figure 5. of the Byron Station Addenda to the Commonwealth Edison Company's Quality Assurance Manual indicates that technical staff engineers are part of the station production department, i

The performance of Technical Specification testing on emergency coro cooling system pumps, which is required by the American Society of Mechanical Engineers (ASME) Boiler and fressure Vessel Code,Section XI, is an activity affecting quality. The discharge flowrate of each pump is one ot several parameters which are measured to verify that the pump's performance has not degraded.

Contrary to the above:

a. On November 19, 1987, a technical staff engineer performed an ASME surveillance test on the 2A centrifugal charging pump, without having received any training on the use of the ultrasonic flowmeter which he used to determine the discharge ficwrate of the pump.

b. By November 19, 1987, training standards had not been developed for ,

technical activities (operation of the ultrasonic flowmeters) that are performed by the Byron technical staff engineers.

CORRECTIVE ACTION TAKEN AND MESULTS ACHIEVED The test results of the pump surveillance performed by the untrained '

individual were reviewed. The results were found to be consistent with data 1

from previous surveillances. Therefore, it was concluded pump operability was j net affected.

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on November 25, 1987, a training class war conducted on the use of an ultrasonic flowmeter. This class included a written exam to verify proficiency.

The class was attended 'cy all applicable and available technical staff personnel including the individual wha pertormed the surveillance on the 2A centrifugal charging pump. All personnel passed the written exam. In addition, technical staff personnel have been directed not to allow anyone to perform a surveillance requiring the use of an ultrasonic flowmeter unless thet person has passed the training course.

A testing manual has been diveloped to take the place of the startup manual. Effective January 4, 1988, technical staff personnel who sign off steps in technical specification surveillances or tests must be qualified under the startup manual or testing manual. These personnel are required to have passed an exam on either manual in 1987. Those who passed the startup manual exam in 1987 will remain qualified until July 1, 1988. By that time, those personnel mast pass the testing manual exam. New personnel who join the technical staff will have to pass the testing manual exam prior to performing surveillance or testing activities.

CORRECTIVE ACTION TO AVOID FURTHER VIO!ATION A matrix is maintained in the Byron Training Department which c oss references technical staff personnel with the training those personnel have r ec' .1ved . This matrix will be revised to include an entry for training f

received on the use of test equipment and training received for specializations, A new training standard matrix will be developed which cross referencea technical staff surveillance procedures with the test equipment training required to perform these surveillances.

General training standards for technical staff personnel are outlined in Byron Administrative Procedure BAP 500-4 "Technical personnel Qualifications". This procedure will be revised to include the new matrix which cross references surveillances with required test equipment training.

DATE ICIEN FULL COMPLIANCE WILL BE ACHIEVED The technical staff ene,ineer wh? performed the surveillance test on the ?A centrifugal chary:ng pump was trained o:: the use of an ultrasenic flowmeter on November 2s, 1987. The requi:ement for technical staff perso.'nel to be qualified under the startup manual or testing manual became effective January 4, 1988.

The training department matrix which cross references technical staff personnel with the training they have receive] dill be revised by Apri' 1, 1988. The new training matrix which croso n : Orences technical :taff ,

surveillances with required testing equi: mint training will be develocad by April 1, 1988. The revision to Byron Administrative Procedure BAP 500-4 will be completed by Aoril 1, 1988.

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