IR 05000454/1997021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-21 & 50-455/97-21 on 980326

ML20247E243
Person / Time
Site:	Byron
Issue date:	05/05/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-454-97-21, 50-455-97-21, NUDOCS 9805180259
Download: ML20247E243 (3)

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May 5, 1998

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l Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lli

1400 Opus Place, Suite 500 l Downers Grove,IL 60515 SUBJECT

NOTICE OF VIOLATION (NRC INSPtECTION REPORT NO. 50-454/97021)

Dear Mr. Kingsley:

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This will acknowledge receipt of your letter dated April 21,1998, in response to our letter )

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dated March 26,1998, transmitting a Notice of Violation associated with the above mentioned

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inspection report at the Byron Generating Station. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during i

future inspections.

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Sincerely, original /s/ J. A. Grobe John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-454;50-455 Enclosure: Ltr dtd 4/21/98 from K. L. Graesser, Comed to USNRC See Attached Distribution

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cc w/o encl: M. Wallace, Senior Vice President j D. Helwig, Senior Vice President l G. Stanley, PWR Vice President l J. Perry, BWR Vice President

! D. Farrar, Regulatory l Services Manager 1. Johnson, Licensing Director l

DCD - Licensing l K. Graesser, Site Vice President

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! K. Kofron, Station Manager L D. Brindle, Regulatory Assurance Supervisor l cc w/ encl: Richard Hubbard l Nathan Schloss, Economist l Offico of the Attorney General i State Liaison Officer l l State Liaison Officer, Wisconsin ]

! Chairman, Illinois Commerce l Commission i

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i Distribution:

SAR (E-Mail)

Project Mgr., NRR w/enci A. Beach w/ encl J. Caldwell w/enci B. Clayton w/encI SRI Byron w/ enc!

DRP w/ encl TSS w/ enc!

DRS w/enct Rill PRR w/enct PUBLIC IE-01 w/enci

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Docket File w/enci GREENS DOCDESK (E-Mail)

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, April 21, 1998

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LTR: BYRON 98-0134 FILE: 1.10.0101 i

U.S. Nuclear Regulatory Commission Washington, DC 20555 I

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

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Reference: John A. Grobe letter to M dated March 26, 1998, transmitting NRC Inspection Report 50-454/97021 Enclosed is Commonwealth Edison Company's response to the Notice of violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited one (1) Severity Level IV violation requiring a written response. Comed's response is provided in the attachment.

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! I I I Byron Ltr. 98-0134 April 21, 1998 Page 2 i

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If your staf f has any questions or comments concernir.c this letter, please refer them to Don Brindle, Regulatory Assurance Supcrvisor, at (815)234-5441 ext.2280.

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Respectfully, l

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K. L. Grae r

Site Vice resident Byron Nuclear Power Station KLG/DB/rp Attachment (s)

cc: A. B. Beach, NRC Regiolal 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 I

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e ATTACHMENT I VIOLATION (454/97021-01)

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 and 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 tha required technique for performing the liquid penetrant examination. 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 liquid penetrant examination (LPT) examiner incorrectly performed liquid 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 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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REASGN FOR THE VIOLATION We agree with the violation. The cause of the violation was a failure to fol? ow procedure by the examiner. This was considered an isolated personnel error due to the examiners' lack of understanding of the procedural requirements associated with the performance of a liquid penetrant 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 certified 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 activities resulted in no similar occurrences.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED ,

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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