ML20212A751
| ML20212A751 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/30/1987 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2652K, NUDOCS 8703030408 | |
| Download: ML20212A751 (4) | |
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Commonwealth Edison M* : Ons First NTional Plaza, Chicago, Illinois Address Rep! to: Post Omc3 Box 767 f
Chica00, Illinois 60690 - 0767 January 30, 1987 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Unit 2 I&E Inspection Report No. 50-455/86034 NRC Docket No. 50-455
Reference:
December 31, 1986 letter from C. J. Paperiello to Cordell Reed
Dear Mr. Keppler:
This letter concerns the routine safety inspection conducted by M. L.
McCormick-Barger, along with other members of your office and their consultants, on September 29 through November 14, 1986, of activities at Byron Station. The referenced letter indicated that certain of our activities appeared to be in violation of NRC requirements. Commonwealth Edison Company's (CECO) rGronse to this violation is contained in the Attachment to this letter.
The referenced letter also requested that Ceco review the adequacy of corrective actions taken regarding Inspection Report Items 454/84007-06; 454/85008-04; and 454/85017-01, and specifically address actions taken or planned to ensure that the lessons learned regarding deficiency documentation for the preoperational testing program are applied to the startup testing program. This review has concluded that the long term corrective action taken in response to the present violation also adequately addresses this concern.
If there are any questions concerning this matter, please contact this office.
very truly yours, e
f
/*4 D. L. Farrar Director of Nuclear Licensing
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- F ATTACHMENT BYRON STATION UNIT 2 RESPONSE TO NOTICE OF VIOLATION VIOLATION 10 CFR 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 11.0, requires that results be documented and evaluated to assure that requirements have been met.
Commonwealth Edison Company's Quality Assurance, Quality Procedure No. 11-2, requires that the documentation of pre-operational tests include a list of any apparent deficiencies.
Byron Startup Manual, Paragraph 4.7.3.7, requires that deficient conditions discovered during testing be recorded as deficiency drafts.
Technical Staff Memorandum (TSM) T03.03A implements these requirements and requires that when a System Test Engineer (STE) identifies a problem with a system during the performance of a test (i.e., data outside expected range, incorrect indications, etc.) the STE will document the problem in a deficiency draft.
Byron Startup Manual, Paragraph 4.1.4 requires that deficient conditions be documented on deficiency record forms.
Contrary to the above:
a.
Byron Preoperational Test CV 18.61, " Chemical and Volume Control, Charging, Letdown and Reactor Coolant Pump Seal Injection Logic Test,"
Step 9.0.3 requires that Local and Main Control Board timed valve responses be within 20% of each other.
On November 11, 20 and 21, 1985, the STE failed to initiate deficiency drafts when Step 9.0.3 determined that the difference between remote versus local timing values exceeded 20% for valves 2CV8160, 2CV0459 and 2CV8149C, respectively.
.. b.
Byron Preoperational Test RY 69.67, " Pressurizer (Integrated Hot Punctional)," Step 9.5.18, requires the power operated relief valve discharge line surface temperatures be measured and recorded at 30 minute intervals until the temperatures stabilize.
On May 30, 1986, the STE failed to initiate a deficiency draft for a Power Operated Relief Valve (PORV) discharge line temperature spike and to draft a deficiency noting the PORV discharge line temperatures had not been measured and recorded until the temperature had stabilized for PORV 2RY455A.
c.
Byron Preoperational Test RH 67.60, " Residual Heat Removal System,"
Section 13, Appendix C, requires verification of four plant operating procedures pertaining to the residual heat removal system.
Prior to February 19, 1986, when the test package was closed, the STE failed to initiate a deficiency draft for plant operating procedures which were not verified during the performance of RH 67.60.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The CV 18.61 test step 9.0.3 requirement for agreement of local vs.
remote valve stroke tin.a within 20% was obscure in section 9 of the test, as opposed to being indicated next to the test step or on the data sheet as an expected range, This situation contributed to the problem that the valve stroke times outside of the 20% tolerance were not documented on deficiency forms.
As identified in the inspection report, Valve 2CV0459 had previously been retested as a result of another deficiency. The results of this retest (R-2019) demonstrated that the difference between remote and local readings for both the opening and closing times was less than 20%. A supplemental letter to the evaluation file was initiated to address this fact.
Additionally, the supplemental evaluation letter addressed the closing time deviations in excess of 20% for valves 2CV8160 and 2Cv8149C and found the results to be acceptable. The evaluation letter was reviewed and concurred to by the TRB and Project Engineering on October 22, 1986.
As identified in the inspection report, appropriate annotation was added to the test documentation package to acknowledge the lack of deficiencies for the anomalies recorded for Valve 2RY455A. This was completed prior to the end of the inspection period. Therefore no additional actions for this item associated with RY 69.67 are necessary.
.. As identified in the inspection report, the subject plant operating procedures were performed on November 4 and 5, 1986, and documented in the operating logs.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Inspection Report Items 454/84007-06, 454/85008-04 and 454/85017-01 were reviewed and evaluated with the preceeding examples of violation. This evaluation resulted in a determination that although no programmatic problems existed, an improvement in the implementation of the requirements for deficiency identification was required. As a result, a department meeting on October 23, 1986 addressed the importance of the need to initiate deficiencies.
The parameters of this discussion were then disseminated by Tech Staff Memo RST03.07 dated October 31, 1986. The meeting and memo specifically highlighted the need to scrutinize the test body and implement a conservative threshold for deficiency initiation. These actions have been structured to reinforce to the working group the importance of the requirement for deficiency indentifica-tion.
In addition, Tech Staff Memo #ST04.01, Rev. A. " UNIT 2 S/U TEST-POST REVIEW" dated January 15, 1987 incorporated additional check list parameters to provide additional emphasis to scrutinize the executed test for conditions which require initiation of a deficiency during the post test review process.
As a result of reviews conducted to date on completed Unit 2 startup tests, we believe that deficiency identification is being adequately applied to the startup test program.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Byron Station is in compliance at this time.
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