ML20217K164
| ML20217K164 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/21/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-21, BYRON-98-0134, BYRON-98-134, NUDOCS 9805010114 | |
| Download: ML20217K164 (4) | |
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Q,mnymwealth Idison G>mpany 11yron Generating $tation 4150 North German Church Road Hyron,11. 61P: 3979 i Tel 8152.4 6-5 4 41 April 21, 1998 i
LTR:
BYRON 98-0134 FILE:
1.10.0101 U.S. Nuclear Regulatory Commission' Washington, DC 20555 Attention: Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/97021 NRC Docket Numbers 50-454 l
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Reference:
John A. Grobe letter to Mr. Kingsley dated l
March 26, 1998, transmitting NRC Inspection Report 50-454/97021 l
Enclosed is Commonwealth Edison Company's response to the Notice of l
Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited one (1) Severity Level IV violation i
requiring a written response.
Comed's response is provided in the j
attachment.
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9805010114 980421 Y
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Byron Ltr. 98-0134 April 21, 1998 Page 2 I
If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully, f
K.
L. Grae ' r Site Vice resident Byron Nuclear Power Station KLG/DB/rp Attachment (s) cc:
A.
B.
Beach, NRC Regional Administrator - RIII J.
B. Hickman, Byron Project Manager - NRR E.
W.
Cobey, Senior Resident Inspector, Byron M.
J.
Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS l
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t ATTACHMENT I s
r VIOLATION (454/97021-01) l 10 CFR 50, Appendix B, Criterion V, " Instruction, Procedures, and Drawings,"
states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances c;d shall be accomplished in accordance with these instructions, procedures, or drawings.
Bechtel Engineering, nondestructive examination procedure PT(SR)-ASME III/XI, Liquid Penetrant Examination, Section 8, describes the required technique for performing the liquid penetrant examinatior. This technique complies with Section V, Article 6 of the ASME Boiler and Pressure Vessel Code, paragraph T-620 which specifies the procedure requirements for liquid penetrant examination.
Contrary to the above, on January 6, 1998, a licensee contracted Level II l
liquid penetrant examination (LPT) examiner incorrectly performed liquid i
penetrant examination of the steam generator "A" field weld #1 hot leg, outside diameter (OD).
Specifically, the examiner violated an essential portion of the examination by removing.the developer, reeleaning, and reapplying developer without repeating the examination in full, This departure from procedure requirements could result in not identifying a weld f
defect in excess of Code allowable.
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This is a Severity Level IV Violation (supplement I),
(50-454/97021-01(DRS))
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(ILEASON FOR THE VIOLATION j
l We agree with the violation. The cause of the violation was a failure to l
follow procedure by the examiner. This was considered an isolated personnel j
error due to the examiners' lack of understanding of the procedural i
requirements associated with the performance of a liquid penetrant l
examination.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
Bechtel Power Corporation, a subcontractor to Comed, initiated a Non-Conformance Report (NCR BY-071) to document the improper liquid penetrant examination. The weld was re-examined by a different Level II certified examiner in full compliance with the requirements of the procedure and was found acceptable.
2.
As required by NCR BY-071, the contractor inspector was retrained in the requirements of the procedure. This retraining was conducted by the contractors' ASNT SNT-TC-1A tartified Level III examiner.
3.
The contractor inspector was counseled in procedural adherence expectations.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION This was considered an isolated event.
Oversight of other steam generator NDE activ.;;es resulted in no similar occurrences.
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e QATE WHEN FULL COMPLIANCE WILL BE A".MIF'IED Full compliance was achieved on January 9, 1998, when the examination was reperformed and found acceptable, and the examiner was retrained / counseled in the procedural requirements.
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