ML20212K272
| ML20212K272 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/24/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2550K, NUDOCS 8701290034 | |
| Download: ML20212K272 (5) | |
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I COIRIRORWealth h N
. { ~, s One First Nabonal Plaza, Chca00. lilinois '
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.g Address Reply to: Poet Omco Box 757 Chca00, Illinois 60600 0767 -
December 24, 1986 Mr. James G. Keppler Regional Administrator.
U.S. Nuclear' Regulatory Comunission Region III.
.799 Roosevelt Road Glen Ellyn, IL 60137-1
Subject:
Byron Station Unit 1 IE Inspection Report No. 50-454/86040 NRC Docket No. 50-454 Reference (a): November 25, 1986 letter from C. E. Morelius to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of an inspection on October 1 through October 31, 1986, at Byron Station. During this inspection, certain activities were found in violation of NRC requirements. Attachment A of 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 office.
Very truly yours, D. L. Farrar Director of Nuclear Licensing
-Im Attachment cc: Byron Resident Inspector 2550K DO
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ATTACHMENT A VIOLATION 1 10 CFR 50, Appendix B, Criterion XIII requires that measures shall be established to control the storage of equipment in accordance with work and inspection instructions to prevent damage or deterioration.
ANSI N18.7-1976/ANS-3.2, " Quality Assurance for the Operational Phase of Nuclear Power plants," is endorsed by Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Revision 2, is committed to in Appendix A of the Byron FSAR.
ANSI N18.7-1976/ANS-3.2, Section 5.2.13.4 requires that measures shall be provided to control handling, storage and shipping, including cleaning, packaging and preservation of materials and equipment to prevent damage, deterioration and loss.
Section 5.2.10, requires that housekeeping practices shall be utilized recognizing requirements for the control of work activities, conditions, and environments that can affect the quality of important parts of the nuclear plant. Housekeeping encompasses all activities related to the control of cleanliness of facilities and material. Housekeeping practices shall assure that the quality of items is not degraded as a result of housekeeping practices or techniques. Particular attention should be given to housekeeping in work and storage areas where important items are handled and stored to prevent damage.
The Safety Related Ccmponent List for Byron Station states that replacement battery charger lAFOlEA-1 is a Class 1-E, safety related, electrical component.
Contrary to the above, from September 29 to October 29, 1986, the Class 1-B, safety related, battery charger lAFolEA-1 was not stored in a manner to prevent damage or deterioration, and the housekeeping practices in the area where the battery charger was storta did not assure that its quality would not be degraded in that the charger was found in an employee eating area.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon notification of the inadequate storage location for replacement battery charger lAFOlEA-1 on October 30, 1986, Hatfield Electric Company Quality Assurance personnel initiated discrepancy report 8566. Level B storage was required for the battery charger. Accordingly, discrepancy report 8566 required a material storage surveillance to be performed in accordance with Hatfield Electric Company Procedure #14 to verify that no visible damage had occurred to the battery charger. The surveillance was conducted on October 30, 1986 and it was documented that the equipment was visibly free of damage.
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The battery charger was moved to its designated location and installed on October 30, 1986.
ACTIONS TAKEN TO RESTORE THE QUALITY LEVEL OF THE BATTERY CHARGER AND TESTING TO VERIFY THAT NO DBGRADATION OF ITS PERPORMANCE HAS OCCURRED commonwealth Edison testing personnel have performed a visual inspection of the battery charger and found it to be visibly free of damage. This was completed November 21, 1986.
b The battery charger will undergo performance testing as required
.under modification M6-1-85-0060 prior to the equipment being placed in service.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The responsible Hatfield production supervisors have been trained to return equipment to the proper storage area if similar conditions should occur in the future.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The material storage surveillance was performed October 30, 1986.
The battery charger was moved to its designated location and installed on October 30, 1986. Training for the producrion supervisors regarding proper storage locations was completed by December 10, 1986. Performance testing of the battery charger in accordance with modification M6-1-85-0060 will be completed during the upcoming Unit I refueling outage.
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- i. VIOLATION 2 10 CFR 50, Appendix B, Criterion VI, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 6.0, requires that methods shall be established to control the issuance of documents, such as drawings, including changes thereto, which prescribe activities affecting quality.
Quality Procedure'(QP) 6-52, " Document Control for Operations,"
implements this requirement and Section B.2.b requires that drawings which are utilized by Control Room staff to effectuate their decision making, be updated to reflect the as-built condition of the plant and its equipment.
Byron Administrative Procedure BAP 1340-3 implements these requirements. Paragraph C.l.h, defines Critical Drawings as "A group of drawings identified in BAP 1340-AS which are maintained as-built for Operating Shift decision making."
BAP 1340-A5 lists P&ID M-37 as a Critical Control Room Drawing.
ANSI N18.7-1976/ANS-3.2 " Quality Assurance for the Operational Phase of Nuclear Power Plants," is endorsed by Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Revision 2, is committed to in Appendix A of the Byron FSAR.
ANSI N18.7-1976/ANS-3.2, Section 5.2.7 requires that modifications which may affect the functioning of safety-related structures, systems, or-components shall be performed in a manner to ensure quality at least equivalent to that specified in the original design bases and requirements.
Section 5.2.19.3 requires that tests shall be performed following plant modifications to confirm that the modifications reasonably produce expected results and that the change does not reduce safety of operations.
ll Modification M6-1-84-065 required that a visual examination be performed, as the required post-modification testing, on the new piping and valves.
i Contrary to the above:
a) From March 31 to October 2, 1986, critical control room drawing P&ID M-37 was not updated to reflect the as-built condition of the plant after Modification M6-1-84-065 was installed.
l b) From March 31 to October 2,1986, the required post-modification testing, a visual examination, was not performed after Modification M6-1-84-065 was installed.
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, -. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Piping and instrumentation diagram M-37 has been updated to reflect the as-built condition of the plant after modification M6-1-84-065 was installed. The required post-modification testing has been performed with satisfactory results.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Byron Station administrative procedures dAP 1650-1 and BAP 1650-3 have been revised to require control room critical drawings to be updated prior to conducting the post-modification test.
Meetings were held with technical staff group leaders to emphasize post-modification testing requireme.nts.
A daily order was written to operating shift personnel stating that the modification test cover sheet, modification approval sheet, and the nuclear work request must be all together and properly signed-off indicating acceptance of modification test results before returning the affected equipment to service in accordance with BAP 1650-3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i
Piping and instrumentation drawing M-37 was updated on October 24, 1986. Post-modification testing of modification M6-1-84-065 was completed on October 24, 1986. Procedures BAP 1650-1 and BAP 1650-3 were revised on October 9, 1986. The meetings with the technical staff group leaders were completed on December 16, 1986. The daily order written to operating shift personnel was issued December 18, 1986.
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