ML20205Q127

Responds to NRC Re Violations Noted in Insp Rept 50-454/86-12.Corrective Actions:Voltage Measurements Which Exceeded Acceptance Criteria Reevaluated & Instrument Procedure 2000-004 Revised

ML20205Q127
Person / Time
Site:	Byron
Issue date:	05/21/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1705K, NUDOCS 8605280169
Download: ML20205Q127 (3)

Text

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. N Commonwealth Edison

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, ) One First Niten:1 Plazs. Chictgo. Ilhnois i O 'l Addr:ss R ply to Post Office Box 767

,-- ( / Chicago, litinois 60690 May 21, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Unit 1 I&E Inspection Report No. 50-454/86-012 NRC Docket No. 50-454 Reference (a): April 21, 1986 letter from J. J. Harrison to Cordell Reed

Dear Mr. Keppler:

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

Walker and Sutphin at Byron Station on March 16 through April 2, 1986.

During this inspection, certain activities were found in violation of NRC

. requirements. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a).

Please direct any questions regarding this matter to this offico.

Very truly yours, D. L. Farrar Director of Nuclear Licensing Im Attachment cc: Byron Resident Inspector stjf2;g;g gtgahP MAY 2 21986 1705K G i 1 flo f

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'd ATTACIMENT A VIOLATION 1 10 CPR 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Quality Assurance program, requires that test results be documented and evaluated to assure that test requirements have been satisfied.

Contrary to the above, results of surveillance test BOS DC-21, conducted on December 10, 1985, listed two readings that exceeded acceptance criteria as specified in the procedure. Test results were indicated as satisfactory, and there were no indications that the problem was noted on subsequent reviews of the test results.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On May 16, 1986, the Byron Station On-site Review Group reviewed the results of "ESF Station Battery Daily Surveillance" (BOS DC-21) performed on December 10, 1985. The two voltage measurements which exceeded the acceptance criteria were re-evaluated and found acceptable. This on-site review has been documented.

CORRECTIVE ACTION TO AVOID FURTHER VIOLATION A memo was issued to the Shift Supervisors, Operating Engineers, the Technical Staff Supervisor and the operating Surveillance Coordinator emphasizing the following items to be considered during the review of operating surveillance results:

1. Acceptance criteria are met

2. Review for inoperable equipment

3. Review for out-of-tolerance conditions

4. Review for proper execution

5. Failures or out-of-tolerance conditions are marked for easy identification

6. The Data package Cover Sheet properly reflects all failures or out-of-tolerance conditions.

In addition, the memo stated the " comments" section of the Data package Cover Sheet should be used to explain abnormal conditions or corrective actions taken.

Tailgate sessions with shif t personnel will be held by each Shif t Engineer concerning operating surveillance execution, including identifica-tion of out-of-tolerance results.

PATE WHEN FULL COMPLIANCE WILL BE ACHIEVED _

The On-site review of the December 10, 1985 battery surveillance was conducted on May 16, 1986. The memo regarding review of operating surveillance results was issued on May 16, 1986. Tailgate sessions with shift personnel will be completed by June 20, 1986.

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VTOLATION 2 10 CFR 50, Appendix B, Criterion XII, as implemented by Commonwealth Edison Quality Assurance Program, requires that measures be established to assure instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

Contrary to the above, the station " Instrumentation Scheduling File Listing", issued February 28, 1986, contains numerous listings of plant instrumentation r,verdue for calibration. Of these overdue instruments, at least 27 were deeermined to be safety-related.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Byron Instrument Procedure 2000-004, " Frequency of Calibration of Plant Instrumentation", has been revised to include a 25% allowance on instrument calibration intervals. This is consistent with surveillance interval extensions allowed in Technical Specifications. Taking into account this 25% extension, the 27 safety related instruments are within their calibration frequency. These instruments will be recalibrated within the allowed interval.

Non-safety related instruments in the Preventive Maintenance Program which have exceeded their calibration interval have been reviewed by the On-site Review Group. This review has concluded that some of these non-safety related instrumentu have not been available for recalibration due to inaccessibility during plant operations, pending system modifications, and ALARA concerns. Plans have been established to recalibrate overdue 15, 1986.

non-safety related instruments, which are available, by June CORRECTIVE ACTION TO AVOID FURTHER VIOLATION A memorandum is being issued by the Assistant Superintendent for Maintenance to the Instrument Maintenance Department. This memo will emphasize adherence to existing administrative controls established in the Station General Surveillance Program and their applicability to surveillance frequencies for instruments in the Preventive Maintenance Program.

In addition, recalibration schedules for some of the non-safety related instruments in the Preventive Maintenance Program are being adjusted to take into account instrument inaccessibility during plant operations, pending system modifications, and ALARA concerns.

DATE WHEN FULL COMPLIANCE WILL,BE ACHIRVED Byron Instrument Procedure 2000-004 was revised on April 21, 1986.

The memo emphasizing adherence to surveillance frequencies will be issued to the Instrument Maintenance Department by May 22, 1986. Overdue non-safety related instruments, which are available, will be recalibrated by June 15, 1986. Recalibration schedules for overdue non-safety related instruments which are not available will be adjusted by June 15, 1986.

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