ML20235U994
| ML20235U994 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/01/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3661K, NUDOCS 8710140374 | |
| Download: ML20235U994 (4) | |
Text
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M Comm:nw: lth Edison l
. One First National Plaza, Chicago, Illinois 4
j C
'<'7 Address Reply to: Post Office Box 767 l
Chicago, Illinois 60690 - 0767 October 1, 1987 i
Mr. A. Bert Davis Regional Administrator Region III.
U. S. Nuclear Regulatory Commission I
799 Roosevelt Road Glen Ellyn, IL,60137
Subject:
Braidwood Station Unit 2 Response to Inspection Report No.
50-457/87-021 E Docket No. 50-457 N
Reference (a):
C. W. Hehl letter to C. Reed l
dated September 3, 1987 l
Dear Mr. Davis:
This letcer is in response to the inspection conducted by Messrs.
A. Dunlop and R. Mendez on June 8 through August 20, 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,
' b MA
\\
L. D. Butterfield Nuclear Licensing Manager Enclosure cc: NRC Resident Inspector - Braidwood NRC Document Control Desk k
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ENCLOSURE COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 457/87021-01 Violation 10 CFR 50, Appendix B, Criterion XI, " Test Control", as implemented by the Commonwealth Edison Quality Assurance Manual, Quality Requirement 16.0 and the Braidwood Startup Manual (BwSUM) states that testing will be performed in accordance with written test procedures, a.
Section 4.6.3.3 of the BwSUM states, "The steps within a section may not be reordered unless specifically authorized by the test procedure."
Contrary to the above, on July 16, 1987, steps in BwPT RC-50 were performed out of sequence without specific authorization in the procedure to do so, b.
Section 3.5.2.2 of the BwSUM states, " major changes shall be approved by the Test Review Board and Project Engineering."
Contrary to the above, on October 20, 1986, major Test Change Request No. 7 was incorporated into BwPT DO-52.1 without being approved.
c.
Section 4.6.3.2 of the BwSUM states, " initial conditions are satisfied before the test starts," and "may not be ignored unless specifically authorized by the test procedure."
Contrary to the above, on October 28, 1986, Initial Condition 7.2.2.1 of BwPT VQ-51 was not verified or deleted prior to performing Section 9.3 as required by the procedure.
RESPONSE
Commonwealth Edison Company agrees that the examples cited above do, technically, constitute violations of administrative procedures. However, because the root cause(s) of each of the deviations identified in the examples are different in nature, we do not believe that this is indicative of apparent disregard for administrative procedures by our System Test Engineers (STE).
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
a.
BwPT RC-50, the Integrated Hot Functional sequencing test procedure, allows a number of test steps to be performed concurrently and out of the written sequence (by notes in the test). A miscoordination between the STE and the Operations Department contributed to the temperature being increased prior to step signoff. Because of these factors, this deficiency was caused by an oversight by the STE, not an intended disregard for adminis-3661K
trCtiv] proc;durC3.
Th2 Proj ct TO:t Director (PTD) stopp;d th2 temperature increase at 380*F because of a chemistry problem in the Feed and Condensate Systems. During this period, the oversight was identified and the PTD immediately instructed the STE to write a Test Change Request (TCR) to amend the test procedure. Corrective action was completed with the incorporation of TCR No. 14 into the test procedure. The temperature increase prior to step signoff had no affect on the test results.
b.
As stated in the NRC inspection report, this item had been identified by Finding #1 of Commonwealth Edison's Quality Assurance (QA) Department Audit Q.A.A. 20-86-DO52.1-1 and was a result of post-license Test Administration changes being made, concurrent with the BTE's attempts to obtain approvals for TCR No. 7.
This resulted in a delay of the approval of TCR No. 7 and highlighted the STE's error of entering the TCR into the test procedure before it's approval.
It should also be noted that TCR No. 7 could have been a minor TCR or a deficiency could been written because BwPT DO-52.1 had no affect on Unit I until entry into Mode 3.
Once the administrative procedure changes were approved, the STE took the appropriate actions to bring BwPT DO-52.1 into compliance with the Startup Manual requirements.
Finally, at the time of.the QA Audit the test had already been updated to the current administrative y
procedures and TCR No. 7 had been evaluated and found to have no affect on the test results. Based upon the above, we recognized the l
fact that the STE did make a mistake in entering TCR No. 7 into the test procedure, but we do not believe that this item constitutes a disregard for administrative procedures, c.
We concur that during the execution of BwPT VQ-51 the STE involved did disregard administrative procedures. This item was identified by QA and was addressed by the post-test Test Review Board (TRB).
The TRB evaluated this violation of administrative procedures and found it had no affect on the test results. We believe that item was a result of poor judgment on the part of the STE and that it was an isolated incident.
In addition, the individual involved is no longer on-site.
In light of the circumstances surrounding the items cited in the violation, we believe that overall the STEs are adequately l
I implementing administrative procedures. Our established program of multi-level checks and reviews (i.e. Group Leader, TRB, Project Engineering Department, and QA) is identifying and correcting administrative errors. We also have implemented the additional actions outlined below to minimize possibility of further occurrences.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION A training session was conducted with the STE's on August 25, 1987.
This training included a discussion of the corrective actions and events surrounding the violation including adherence to administrative requirements.
Additional corrective actions implemented include evaluations of affects 3661K
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.on test results by the TRB and one-on-one training for minor infractions and disciplinary action for extreme cases. Actions taken to date have involved re-execution of test sections under the guidance / supervision of independent observers, removal of the STE from further preoperational testing, and termination of employment. Finally, the TRB has been directed to pay particular attention to STE's compliance with administrative procedures during their post-review. They have also been directed to document and evaluate any deviations'and recommend appropriate additional documentation or testing / retesting required.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved, i
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