ML20198B042
| ML20198B042 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/01/1985 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0430K, 430K, NUDOCS 8511060280 | |
| Download: ML20198B042 (8) | |
Text
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N Commonwealth Edison
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) On3 First Nition11 Plaza, Chicago, Ithnois I O Address Reply to: Post Othce Box 767 Chicago, Illinois 60690 I
August 1, 1985 L
Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 i
Subject:
Byron Station Unit 1 I.E. Inspection Report No. 50-454/85-008 L
References (a): May 3, 1985 letter from R. L.
Spessard to Cordell Reed (b): June 10, 1985 letter from D. L.
Farrar to J. G. Keppler
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(c): July 12, 1985 letter from R. L.
l Spessard to Cordell Reed l
Dear Mr. Keppler:
In reference (a), you informed us of certain activities related to our review of test results from the startup test program that appeared to be in violation of NRC requirements. Reference (b) provided our initial response to the Notice of Violation for these issues ~and requested thet you reconsider whether the items were correctly categorized as noncompliance with
'NRC regulations. Upon further review, you have concluded in reference (c) that these items concerning the adequacy of our test results review were.
properly categorized as examples of violation. You requested that we provide an additional response to the Notice of Violation and also address an Unresolved Item related to these issues from another inspection repor't. On July 18, 1985, Commonwealth Edison was granted a ten day extension on the due date for the additional response.
We continue to believe that these documentation deficiencies described in reference (a) should be considered at most Level V items of noncompliance. Nevertheless, we do not wish to continue to pursue this dispute. We-feel the enclosed corrective actions are responsive to your concerns and should prevent recurrence of the deficiencies.
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J. G. Keppler August 1, 1985 You have raised an additional important issue in reference (a) about satisfying or modifying FSAR commitments related to our Initial Test Program.
.We understand the distinction between modifying a Chapter 14 FSAR commitment and our ability to deviate from test acceptance criteria when appropriately justified with supporting documentation. We believe the change to the Byron Startup Manual described in reference (b) addresses the latter of the two issues. It is our understanding that Operating License NPF-37 Condition 2.C.(3) addresses the former.
This license condition allows us to modify our test program commit-ments without prior NRC approval. During the performance of testing or evaluation of test results, we may discover changes that need to be made to our Initial Test Program described in Chapter 14 of the FSAR. If these changes are made in accordance with 10 CFR 50.59, we believe it is acceptable to' proceed with the testing program and inform you of these changes within one month of the change. We understand that if upon notification to the NRC, these changes are not found acceptable, further testing or evaluation may be required.
If you have any concerns or questions regarding our additional response to the Notice of Violation or our understanding of License Condition 2.C.(3), we think it would be beneficial to meet with you at your convenience to discuss these matters further.
Very truly yours, L
a L. O. DelGeorge Assistant Vice Presiden im Attachment cc: Byron Resident Inspector 0430K
ATTACHMENT A VIOLATION la 10 CFR 50, Appendix B, criterion XI as implemented by the Commonwealth Edison Quality Assurance Manual, Quality Requirement 11.0 and the Byron Startup Manual requires that a test program be established. This
- program is required to demonstrate that systems will perform satisfactorily in service and is required to be performed in accordance with test procedures which incorporate the acceptance limits of the design documents. Furthermore, the test results are required to be documented and evaluated in order to verify that the test requirements have been satisfied.
1 Contrary to the above, the following example of inadequate evaluation
- and documentation of test results was identified:
The licensee approved the results of startup test NR 32.33 which obtained values for the reactivity worth of Rod Control Cluster Assembly F-10 and Shutdown Bank A in excess of its acceptance criteria and in a test method the licensee determined to be inaccurate. Therefore, the licensee did not verify the control rod reactivity worths as specified in the PSAR.
Furthermore, the licensee proceeded to a higher power level plateau without obtaining, evaluating and approving the results of all testing required to be performed in the low power test sequence as required by the PSAR.
SUPPLEMENTAL RESPONSE Our FSAR commitment to verify that control rod worths were in accordance with the Westinghouse Nuclear Design Report was fulfilled to the
. extent intended and possible. The test objective in FSAR Table 14.2-78 states that selected differential individual and bank integral rod worths would be determined and that rod worths would be verified for shutdown capability. This implies that not'all the control rod reactivity worths would be determinea and, as we have explained in reference (b), it was not feasible to accomplish this for rod control cluster assembly (RCCA) F-10 and Shutdown Bank A.
Additionally, since Westinghouse wrote the Nuclear Design Report, PED believed that Westinghouse was the appropriate source to assist in determining whether the test results were in accordance with their Design Report. Westinghouse accepted the test results and this supported PED's reasoning that the PSAR commitment was satisfied.
' COFRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
The results of startup test 2.32.33 concerning the rod worths of RCCA F-10 and Shutdown Bank A were re-evaluated by PED and it was verified that their original assessment of the data with respect to shutdown capability was valid.
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4 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE In accordance with our startup test procedure review practice for the remaining three units, the acceptance criteria in test 2.32.33 will be clarified to account for the limitations in verifying the values of rod worth for RCCA F-10 and Shutdown Bank A as predicted in the Westinghouse Nuclear Design Report.
In addition, the FSAR commitment in Table 14.2-78 will be revised to more clearly indicate the testing limitations associated with validating the rod worths in the Westinghouse Nuclear Design Report.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The clarification to the acceptance criteria of startup test 2.32.33 will be made at least 30 days prior to execution of this test on the next unit. The revision to FSAR Table 14.2-78 will be made by August 30, 1985.
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VIOLATION lb L
10 CFR 50, Appendix B, Criterion XI.as implemented by the Common-wealth Edison Quality Assurance Manual, Quality Requirement 11.0 and the
, Byron Startup Manual requires that a test program be establishedf This test program is required to demonstrate that systems will perform satisfactorily in service and is required to be performed in accordance with test procedures.
which incorporate the acceptance limits of the design documents.
Furthermore, the test results are required to be documented and evaluated in order to verify that the test requirements have been satisfied.
Contrary to the above, the following example of inadequate evaluation and documentation of test results was identified.
The licensee approved the results ofIstartup test RD 64.33 with a value
,for the reactivity worth of Control Bank D in excess of its acceptance criteria without completing an adequate evaluation.
SUPPLEMENTAL RESPONSE The detailed Westinghouse analysis mentioned in reference (c) was not required to demonstrate that the results of startup test 2.64.33 were acceptable..This additional Westinghouse analysis was performed only to
. improve their prediction of the boron worth of control Bank D (CBD). The PED and-Westinghouse acceptance of the results of test 2.64.33 was based on the
.results deviating in the conservative direction and, additionally, because of-
' ttue corresponding results of test 2.64.30A regarding CBD.
Startup test
'2.64.30A, which measured the integral worth of CBD and did not depend on L
boron concentration, was in excellent agreement ~with the predicted value of the bank. This test supported the results of test 2.64.33 and fulfilled the FSAR commitment to verify that control rod reactivity worths are within their respective design predictions.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The.results of startup test 2.64.33 concerning the boron worth of CBD were re-evaluated by PED and it was verified that their original conclusions regarding available shutdown margin and acceptability of the results were valid.
Additionally, the detailed Westinghouse analysis has recently been completed and the predicted boron worth of CBD has been revised. The revised value has been compared to the originally measured value from test 2.64.33' and the originally measured boron worth of CBD fell well within i 10% of the revised predicted value.
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CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE As discussed above, the recently completed Westinghouse analysis revised the predicted boron worth for CBD.
This revised information will be appropriately incorporated into the tests for Byron 2 and Braidwood 1 and 2.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The detailed Westinghouse analysis that revised the predicted boron worth of CBD was completed on May 30, 1985.
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.. VIOLATION Id 10 CFR 50, Appendix B, Criterion XI as baplemented by the Comunonwealth Edison Quality Assurance Manual, Quality Requirement 11.0 and the Byron Startup Manual requires that a test prograra be established. This test program is required to demonstrate that systems will perform satisfactorily in service and is required to be performed in accordance with test procedures which incorporate the acceptance limits of the design documents. Furthermore, the test results are required to be documented and evaluated in order to verify that the test requirements have been satisfied.
Contrary to the above, the following example of inadequate evaluation and documentation of test results was identified:
The licensee approved the results of startup test NR 52.35D with an incorrect data calculation and test evaluation.
SUPPLEMENTAL RESPONSE We agree that an independent review cannot conclude whether the PED evaluation did or did not endorse the results evaluation in the test package. PED did not provide any amplifying comments concerning the extrapolated data because they did not believe the evaluation of it by station test personnel was technically incorrect.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The measured data of startup test 2.52.35D related to the overlap of source and intermediate' range nuclear instrumentation channels was re-evaluated by PED and it was verified that their original conclusion regarding acceptability of the results was valid.
CORRECTIVE ACTION TO AVOID FURTHER NONCOMPLIANCE Since some tests. involve the use of data that is not observed and recorded to determine if acceptance criteria are satisfied, instructions are provided in the test procedure specifying how additional data should be interpolated or extrapolated from measured data, and then evaluated. We believe this practice, when specified in a test procedure, is consistent with-conventional data reduction techniques and therefore is acceptable.
A Technical Staff memo will be issued to system test. engineers that will require deviations from example calculations or data reduction
. techniques in test-procedures to be noted in the test results evaluation.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Technical Staff memo described above will be issued by August 15, 1985.
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.. UNRESOLVED ITEM 454/85-017-01 With respect to the results evaluation of startup test RY 69.30, the inspector noted that a deficiency was not generated as required by the Byron Startup Manual for pressurizer heater phase currents and powers in Data Table 11.3.8 which were outside their expected ranges. Pressurizer heater phase currents and powers directly effect the pressurizer heater effectiveness as expressed in Acceptance Criteria 4.3.
This acceptance criteria was initially not satisfied and was subsequently resolved by a Project Engineering Department (PED) evaluation of the test data on January 31, 1985. The licensee's staff have indicated that the data in question was specifically considered as part of the PED evaluation of the startup test. However, the licensee's staff confirmed that the deficient condition identified in Table 11.3.8 was not specifically addressed in the test summary, Test Review Board evaluation or Project Engineering approval of the test results.
RESPONSE
Although the Byron Startup Manual does not contain a specific requirement to write a deficiency for test data which does not meet expected values, we agree that a deficiency should have been written to ensure the data in question was appropriately resolved. Even though a deficiency was not written, the pressurizer heater data which did not fall within the expected values was specifically reviewed and resolved during PED's evaluation of the test. This is evident from PED's comment noted on their review copy of the executed test. The test data which deviated from the expected values did not affect the ability to demonstrate that acceptance criterion 4.3 was satisfied. Consequently, it was not specifically addressed in the PED review letter of January 31, 1985.
Annual retraining of te:st personnel on implementation of the Byron Startup Manual includes instruction on guidelines for writing test deficiencies. This will help to ensure test deficiencies are written when deficient conditions are observed during testing.
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