ML20213E181
| ML20213E181 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/03/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2360K, NUDOCS 8611130043 | |
| Download: ML20213E181 (4) | |
Text
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') Commonwealth Edison One First National Plaza, Chicago, Illinois y
\\ ~ _/ Address Reply to: Post Office Box 767
'd Chicago, Illir:ois 60690 - 0767 November 3, 1986 Mr. James G.
Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL. 60137
Subject:
Byron Station Units 1 and 2 IE Inspection Report Nos. 50-4 54 / 8 6--3 5 and 50-455/86-22 NRC Docket No. 50-454/455
Reference:
(a)
October 3,
1986 letter from C.W.
Hehl to C.
Reed
Dear Mr. Keppler:
Reference (a) provided the results of an inspection by Messrs.
F. Maura and R. Mendez on July 11 through September 17, 1986 at Byron Station.
During this inspection, certain activities were found in violation of NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to Item #1 as discussed in the Notice of Violation appended to reference (a).
(As stated in the Inspection Report, action for Item #2 had been taken to correct the identified violation and to prevent its recurrence, and as such no response was deemed necessary).
Please direct any questions you may have regarding this matter to this office.
Very tr y yours, Dennis Farrar Director of Nuclear Licensing k
D j
att.
cc:
Byron Resident Inspector 2360K NOV 71986
<b TEOl
t VIOLATION #1 10CFR 50, Appendix J.
Section III, Leakage Testing Requirements, states in part, "a program consisting of a schedule for conducting Type.
B tests shall be developed for leak testing the primary reactor containment and related systems and components penetrating the primary containment pressure boundary.
Upon completion of construction of the primary containment and prior to any reactor operating period, preoperational and periodic leakage rate tests, as applicable shall be conducted Section II.G. of Appendix J, defines Type B tests and states in part, ' Type B Tests' means tests intended to detect local leaks and to measure leakage across each pressure containing or leakage limiting boundary for Containment penetrations whose design incorporates piping penetrations fitted with expansion bellows."
Contrary to the above:
As of July 16, 1986, the inspectors had determined that:
a.
The fuel transfer tube bellows for the Unit 1 reactor was not Type B tested either during the preoperational testing program prior to any reactor operation, or during the first periodic Type B testing performed in December 1985.
Subsequent to identification of this finding, the licenses tested the fuel transfer tube bellows for both Unit 1 and 2 with satisfactory results.
b.
The licenses had not established a pre-operational test program or developed periodic tests and schedules to test the Units 1 and 2 fuel transfer tube bellows.
CORRECTIVE ACTION AND RESULTS ACHIEVED Item a)
The Fuel Transfer tube bellows had not been pre-operational tested or periodically tested as a Type B test.
The Commonwealth Edison interpretation of the ASME Code was the following as had been stated in FSAR, Amendment 45 in response to NRC Question Q22.7:
"The bellows of the fuel transfer tube sleeve are MC components and do not require testing other than the Type A test."
This had been issued prior to the receipt of the Unit 1 license and based on this statement, the fuel transfer tube bellows penetration was considered an MC component not requiring a Type B test.
It was subsequently tested as part of the Type A test performed in September of 1983, prior to Unit 1 fuel load.
Periodic Type B testing of the fuel transfer tube penetration was, therefore, considered unnecessary.
The exclusion of the fuel transfer tube bellows from Byron's Test Program was not an act of omission but was rationally excluded from consideration and recorded as such as stated in the response to NRC Question Q22.7.
r Port C of Question Q22.7 states " Identify any penotration fitted with expansion bellows that does not have the design capability for Type B testing and provide justification."
Byron Station responded, as previously stated, through FSAR Amendment 45 which was submitted to the NRC in June 1984.
We considered our response to FSAR Question Q22.7, which had been accepted by the NRC, as a waiver of the Type B test.
However, during the NRC inspection it was stated that only an Appendix J exemption letter from the NRC would obviate testing of the fuel transfer tube bellows.
In response to this, a Type B test of the fuel transfer tube bellows was performed for Unit One on July 17, 1986 to satisfy the NRC concerns regarding the integrity of this penetration.
Testing was done while Unit One was in Mode 5 prior to Startup to Power Operations.
A leak rate of less than 0.4 SCFH was measured.
Unit Two start-up personnel performed a Type B test of the Unit Two fuel transfer tube bellows on August 29, 1986.
(subsequent to the Type A test).
A leakage rate of less than 0.4 SCFH was measured for this Unit Two penetration.
The individual Type B leakage rate results for both units, when added to their respective Unit's Type B & C totals and overall Integrated Leakage Rates, are within the 0.60 La and 0.75 La limits, respectively.
Item b)
As stated in Item (a.), for Unit 1, only a pre-operational Type A test had been performed.
For Unit 2, a
pre-operational Type B retest was performed in addition to the pre-operational Type A test after the inspector brought the Type B testing concern to the Startup Group's attention.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS l
Item a)
The incorporation of the fuel transfer tube Type B test j
into the periodic Tech Spec Surveillance Local Leak Rate l
Test program and Integrated Leakage Rate Test procedure for both units will preclude any further violation.
Item b)
The pre-operational test program is now complete and will therefore not be addressed.
The incorporation of the type B fuel transfer tube bellows test in Byron's Surveillance program by January 1, 1987 will prevent further violations.
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7-DAT,E WHEN FULL COMPLIPNCE WILL BE ACHIEVED Item a)
As of August 29, 1986, all corrective actions for this item were completed.
Item b)
The Unit 2 pre-operational Test Program was amended to include Type B testing of the fuel transfer tube bellows on August 29, 1986.
The periodic tests and schedules for Byron Unit 1 and Unit 2 will be updated to include fuel transfer tube bellows type B testing by January 1, 1987.
This is being tracked by AIM 6-8 6-19 3.
2360K i
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