ML20245J231
| ML20245J231 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/11/1989 |
| From: | Chrzanowski R COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20245J229 | List: |
| References | |
| NUDOCS 8908170588 | |
| Download: ML20245J231 (2) | |
Text
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g,,,onwrIth Edison:
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l._. X) 72 West Adams Street. Chicago. Illinois _
V Address Reply to. Post Office Box 767 A
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d ' Chicago, Illinois 60690 e 0767 -
I July 11, 1989.
Mr. A. Bert Davis
.i Regional Administrator
.U'.S. Nuclear Regulatory Commission Region..III f
799 Roosevelt Road
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' Glen Ellyn,.IL. 60137
~l Subject Byron Station ~ Unit 2 l
Additional Information to Notice Of.
E
' Violation 455/89006-02 liRC Docke_t.Jm 50-455 Dear Mr. Davist-l This letter contains the additional information that~ was discussed I
with Mr. G. Wright of your staff in a teleconference held on June 21, 1989.
i i
The discussion centered around the acceptance criteria written by the design engineer and the modification test performed by the station system
- engineer. Commonwealth l Edison provided the staff with,the explanation of,the three type, tests that are completed for each modification-the' construction test,'the' modification test,'and the operational test. 'Furthermore, we discussed the present modification program and the improvements that have been made in the area of testing and communication between the design'.and system engineers. ~The revisions to the modification program are described below.
l In February 1989, a revised modification engineering review / approval procedure was issued for engineering use.(NSED Procedure 0 6, Rev. 0).
This procedure is now applied for all modification that require nuclear Engineering
. assistance.
This revised procedure incorporates a better-defined testing checklist that' appears as subprocedure 0 6.4.
The improvement in the revised procedure is that the responsible design engineer now is required to. identify and differentiate all Construction Tests, Modification Tests, and Operational.
Tests'necessary to complete the modification. The applicable test criteria to be satisfied by each test is also identified on the test checklist and in the modification approval letter.
R$UW The identification and operating of Construction Tests are enhanced with the issue of forma 13 zed Electrical Construction Test Procedures (ECTP's) for electrical testing completed by nAD personnel. These procedures have been.
reviewed by engineering and station management, and they are being used at all e6 CECO nuclear stations. When tha design engineer requires electrical testing CDO te be completed as a construction test, the specific ECTP is referenced in the aC design engineer's modification approval letter and the results are documented 3.
On the ECTP data form which is incorporated into the modification test O
. package. As a result, confusion is eliminated regarding the role of construction tests in satisfy 3ng the testing criteria specified by the
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responsible design engineer.
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. (Dn.o L_____-_________.
1 Mr. A.
B. Davis July 11, 1989 In hddition to the above, the revised NSED Q.6 procedure series require's the cognizant engineer to contact the cognizant station engineer to discuss the test requirements prior to completion of the testing checklist.
In addition, the revised 0 6 procedure guidelines requires that test requirements are discussed during the pre-modification kickoff meeting involving Engineering, Tech Staff, Maintenance, Operating, and Construction personnel. The kickoff meeting is a requirement for all CECO modifications.
As discussed with Mr. Wright, Commonwealth Edison satisfied the acceptance criteria for Modification M6-2-87-132 by taking credit for the construction testing of the installation and the modification test that ensured the design changes functioned properly. The construction test included walkdowns and circuit checks to verify proper installation of the modification and that the existing circuitry continued to function as originally designed and installed. Documentation in this modification package, however, did not include a specific reference to the construction testing as satisfying a portion of the acceptance criteria as specified by the design engineer. This clarification was presented to Mr. Wright during the teleconference. Additionally, the design engineer and the station system engineer had numerous discussions to ensure that proper testing was performed to satisfy the intended acceptance criteria.
Nevertheless, the changes made to the modification program will ensure that the design engineer identifies the specific tests that are required to satisfy the individual criterion.
Commonwealth Edison requests further consideration regarding withdrawal of the level IV violation after considering the previous corrective actions taken to improve the modification program and the specific information presented to address this concern.
Please direct any further questions regarding this matter to this office.
Very truly yours, M
R.A.
hrzanowski Nuclear L censing Administrator I
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G. Wright Resident Inspector-Dyron l
Office of Facilities Nuclear-IDNS i
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