ML20080G650

Responds to NRC Re Violations Noted in IE Insp Rept 50-454/83-47.Corrective Actions:Qualification Program for Sys Test Engineers Reviewed & Found Acceptable.Fsar Will Be Revised to Address Qualifications

ML20080G650
Person / Time
Site:	Byron
Issue date:	12/30/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080G637	List: ML20080G639 ML20080G642 ML20080G650 ML20080G657
References
7896N, NUDOCS 8402130543
Download: ML20080G650 (6)

Text

. .

,' , ['N Commonwealth ECson

/ ) One First Nitional Plaza. Chicago, Ilknots

( C 7 Address Reply to: Post Office Box 767 N ,/ Chicago. Ilknois 60690 December 30, 1983 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Generating Sta. ' nit 1 I&E Inspection Report No. 30-454/83-47 NRC Docket'No. 50-454/83 References (a): November 19, 1983 letter from J. F. Streeter to Cordell Reed (b): December 19, 1983 letter from D. L. Farrar to J. G. Keppler

Dear Mr. Keppler:

This letter completes Commonwealth Edison's response to the Notice of Violation issued in Reference (a). Responses to three of the four items of noncompliance were provided in Reference (b). The response to Violation 1 is provided in Attachment A to this letter.

As indicated in Attachment A, this violation was apparently issued because of a misunderstanding of our FSAR commitments regarding the qualifications of personnel involved in directing the preoperational and startup test programs. To the inspector, the FSAR appeared to contain a commitment for one year's experience for personnel assigned to the position of System Test Engineer.

Actually, the FSAR and the documents it references indicate that this is the minimum experience level requirement for the Technical Staff Supervisor, who directs the preoperational test program.

The qualifications and minimum experience level for a System Test Engineer are establised in other documents. Those requirements have proven to be effective in assuring that preoperational tests are conducted properly.

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G JAN 3 504

Our qualification program for System Test Engineers has been reviewed with NRR personnel and found acceptable. The FSAR will be revised to explicitly address STE qualfications.

Inasmuch as the FSAR does not presently address STE qualfications, no noncompliance is involved. Accordingly, it is requested that Violation 1 be withdrawn.

We would be pleased to discuss this matter further. Please

. direct questions to this-office.

Very ruly yo C

wm D. L. Farrar Director of Nuclear Licensing Attachment f

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Attachment A Response to Notice of Violation-Violation 1

1. 10 CFR 50, Appendix B, Criterion V states in part, " 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."

Commonwealth Edison Company's response to question 423.2 of the Byron /Braidwood FSAR describes the minimum qualification requirements for personnel that " supervise or direct the conduct of individual preoperational tests" in the following manner:

"For each of the tasks listed above at least one individual performing that task will meet the following qualification requirements:

1.

a. Bachelor of Science degree (or equivalent) in the Sciences or Engineering or 4 years of related technical experience (power plant or task related); and

b. 1 year of nuclear power plant experience".

The Byron Startup Manual states in part 2.4.4.6.5, "The System Test Enoineers shall... Conduct Pre-op and Startup Tests" and in part 4.7.3.1, "The . System Test Engineer directs the test."

Contrary to the above, the licensee failed to prescribe appropriate instructions for qualifications in that a Byron Administrative Procedure'was issued and in use which specified lesser requirements F

than the FSAR in that, Byron Administrative Procedure BAP 500-4, Rev.

0, " Technical Personnel Qualifications", only requires the following t.

for personnel that write and perform preoperational' tests:

"1. Two' years experience.

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2. High school graduation and one and one half years experience.

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3. Equivalency of two years college completion, or continuing college level work leading to an associated degree and six months experience.

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4. Four year college graduation and three months experience."

Examination of 6 personnel files showed that 3 individuals were certified as qualified test engineers in accordance with BAP 500-4 and performed as test engineers directing tests without meeting the requirements described in the FSAR.

Response

The response to FSAR question 423.2 indicates the minimum qualifications of personnel who supervise or direct the conduct of tests. It also indicates that the personnel who perform test functions are identified by title in FSAR chapter 17. Resumes for these personnel are provided in FSAR chapter 13.

FSAR chapter 17 references the Commonwealth Edison Company QA topical report, CE-1-A, " Quality Assurance Program for Nuclear Stations." This report and the Quality Procedures which it references assign responsiblity to the Technical Staff Supervisor to conduct the preoperational tests. His resume is provided in FSAR Attachment 13A. In practice, the Technical Staff Supervisor supervises Group Leaders, who, in turn, supervise System Test Engineers. The response to FSAR question 423.2, however, does not contain any commitments regarding the minimum qualifications of Group Leaders or System fest Engineers.

Administrative procedures specify the minimum qualifications for Group Leaders and System Test Engineers. BAP-500-4 requires that the System Test Engineers meet the following training requirements.

a. Two Years Experience, EE

b. High school graduation and one and one half years of experience, EE

c. Equivalency of two years college completion, or continuing college level work leading to an associate degree and six months experience.

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d. Four year college graduation and three months experience.

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'They also all must pass s' test on the provisions of the " Byron Startup Manual" pertaining to testing activities.

All of the Group Leaders meet the following requirement:

a. Bachelor of Science degree (or equivalent) in the Sciences or Engineering.or 4 years of related technical experience (power plant or task related); and b.- 1 year of nuclear power piant experience.

The effectiven3ss of these minimum qualification requirements.has been reviewed by I&E and found acceptable.

Inspection Report 50-454/80-23 examined the Byron pre-operational test organization, test program administration and the coordination of the conduct of testing as well as methods to assure that test The inspectors personnel were knowledgeable of test procedures.

determined thatLthe above area's were addressed adequately.

Inspection Report 50-454/81-06 reviewed the licensee commitment The to

-keep written' records of-training for pre-opfad test personnel.

report states that'the'11censee has formalized his training programthe inspector requirements into a procedure. In report'50-454/82-02, witnessed test performance and determined that personnel possessed

adequate knowledge of.the system and test procedure and the conduct of testing was satisfactory. In report 50-454/82-21 the inspector observed the pre-operational test program in order to that During ascertain that administrative controls had been implemented. eviewed and inspection, responsibilities of key test personnel were found. adequate.

In addition to these inspection reports, the Station has a

. formal procedure approved in September 1982 for the qualification of test personnel and in response to an inquiry by NRC inspectors issued a technical staff memorandum in August 1982 stating that Group Leaders are responsible-to ensure that STE's who direct pre-op tests (1) have.previously_ conducted a system demonstration or a pre-operational test:or (2) have acceptable testing experience as determined by the TSS or (3) have the test monitored continously by the Group Leader, a pre-op coordinator, or someone who qualifies

-under (1)'above.

The qualifications of testing personnel have been reviewed by:NRR'also. .The response to FSAR questionRecently423.2 was reviewed and accepted-in preparation of the Byron SER. our training and qualification practices have been reviewed again by NRR and found satisfactory.

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The Byron program for qualification of testing personnel have been in place since March 1981 when preoperational testing The began. Many improvements have been made to the program.

existing FSAR commitments, however, do not delineate These requirementsthe minimum have been requirements-for reviewed and found acceptable. System Test Engineer.They will be added to the FSAR at the earliest opportunity.

On the basis of the information presented here we conclude that no violation of NRC requirements is involved. It is requested that this Violation be withdrawn.

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