ML20235J588
| ML20235J588 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/23/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3613K, NUDOCS 8710020023 | |
| Download: ML20235J588 (4) | |
Text
____
.'N Comrhonrealth Edison r
$ j]/ One Firet Natiord Plaza Chicago, Illinois
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U Address Rip'y to: Post Offios Box 767
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i Chicago Illinois 60690 0767 September 23, 1987 Mr. A. Bert Davis Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road 3-Glen Ellyn, IL 60137 5
b
Subject:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/87-025 and 50-457/87-024 c">
NRC Docket Nos. 50-456 and 50-457 vs Reference (a):
C. W. Hehl letter to C. Reed dated August 25, 1987
Dear Mr. Davis:
This letter is in response to the inspection conducted by Mr. C. A.
VanDenburgh on July 13 through August 6, 1987 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in violation with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, (h
L. D. Butterfield Nuclear Licensing Manager es Enclosure i
cc: NRC Resident Inspector - Braidwood
]
Document Control Desk I
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PDR ADOCK 05000456 G
EMCLOSURE COMMONWEALTH EDISON COMPANY i
RESPONSE'f0 INSPECTION REPORT 456/87-025 VIOLATION (456/87025-05) 10 CFR 50, Appendix B, Criterion XI, " Test Control," as implemented by the Commonwealth Edison Quality Assurance Manual and the Braidwood Startup Manual, requires that a testing program be established and that test results be documented and evaluated to ensure that the test requirements have been satisfied.
Contrary to the above, the test requirements of BwSU RC-33,
" Reactor Coolant System Leak Test," were not accurately demonstrated to have been satisfied because of an inaccurate startup test deficiency resolution which resulted in an incorrect calculation of the Reactor Coolant System leakage.
RESPONSE
Commonwealth Edison acknowledges that the value for water density provided in the resolution of Deficiency 3-D-1 was incorrect. However, the value provided in the resolution of Deficiency 3-D-1 was an error in the conservative direction.
Since the error was made towards a more conservative value, there is no safety significance with respect to the incorrect value.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The correct values for pressurizer fluid densities have been calculated based on the difference of the steam and water tables. An addendum to BwSU RC-33 " Reactor Coolant System Leak Test" Test Review Board (TRB) approval will be issued to document the correct water density corresponding to the pressurizer temperature measured in the test.
CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATION Surveillance 1BwoS 4.6.2.1.d-1, "RCS Water Inventory Balance" will l
be revised to expand the temperature / density values provided in Table B, l
" Saturated Fluids / Gases".
l This Notice of Violation will be reviewed by all cognizant System i
I Test Engineers (STE) and a training session will be held to emphasize the importance of verifying all external surveillance which provide input to Startup Test procedures.
TRB members will also review this Notice of Violation and will be cautioned on the iraportance of scrutinizing all technical details of startup test results.
1 In addition, to further STE and TRB member training, during periods of high startup test activity, dedicated teams of TRB members will perform the review function. Teams of Tn6 members will be designated on a weekly basis to provide consistency and direct attention to test reviews.
These corrective actions also apply to Unit 2.
1
)
DATE OF FULL COMPLIANCE l
The corrective actions are expected to be complete by October 31, 198~1.
Dedicated TRB membership will be implemented on an as-needed basis, s
4
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VIOLATION (456/87025-09) 10 CFR 50, Appendix B, critrion IX, " Test Control", as implemented by the Commonwealth Edison Quality Assurance Manual and the Braidwood Startup Manual, requires that a test program be established to assure that testing required to demonstrate that systems will perform satisfactorily in service is performed in accordance with written test procedures which incorporate the requirements of applicable design documents.
contrary to the above, the licensee's test control program did not assure that the applicable design requirements of the Reactor Protection System were incorporated into startup test procedure BwSU RP-30.
BwSU RP-30 as written and performed was not consistent with the basic design of the Train 2 Undervoltage Diode and Output Module. As a result, BwSU RP-30 as originally performed did not demonstrate the proper performance of the Reactor Protection System.
RCSPONSE Commonwealth Edison Company acknowledges that BwSU RP-30 was initially performed in a manner not consistent with the basic design of the Train 2 Undervoltage Diode and Output Module. However, because a review of the original test identified and corrected the incorrect testing there was no direct safety significance to this specific occurrence.
CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACHIEVED The testing inconsistency was identified, corrected, and the applicable portions of the test were acceptably reperformed.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION This Notice of Violation will be reviewed by all cognizant Gystem Test Engineers (STE) and a training session will be held to reiterate the importance of using controlled design documents and providing adequate justification for all test changes. This session will further stress the importance of performing test steps slow and deliberately.
Test Review Board (TRh) members will also review this Notice of violation and will be cautioned on the importance of scrutinizing every technical detail of a test change request prior to approval.
In addition to further STE and TRB member training, during periods of high startup test activity, dedicated teams of TRB members will perform the review function. Teams of TRB members will be designated on a weekly basis to provide consistency and direct attention to test reviews.
These corrective actions also apply to Unit 2.
DATE OF FULL COMPLIANCE Additional STE and TRB member training is expected to be conplete by October 31, 1987. Dedicated TRB membership will be implemented on an as-needed basis.
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