ML20199H881

Notice of Violation from Insp on 981124-990104.Violation Noted:From 871029 to 981123,test Controls for Stroke Time Testing of AFW Pump Discharge Valves Were Not Properly Established

ML20199H881
Person / Time
Site:	Byron
Issue date:	01/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199H862	List: IR 05000454/1998025 ML20199H856 ML20199H881
References
50-454-98-25, 50-455-98-25, NUDOCS 9901250364
Download: ML20199H881 (2)

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l NOTICE OF VIOLATION i Commonwealth Edison Company Docket Nos. 50-454;50-455 I Byron Station, Units 1 and 2 License Nos. NPF-37; NPF-66 l

During an NRC inspection conducted on November 24,1998, through January 4,1999, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcernent Actions," NUREG-1600, Revision 1, the violation is listed below:

10 CFR Part 50, Appendix B, Criteria XI, " Test Control," requires, in part, that a test program shall be established to assure that all testing required to demonstrate that '

structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. I Updated Final Safety Analysis Report (UFSAR) , Section 10.4.9.3 1 specifies, in part, that an auxiliary feedwater pump can deliver at least 160 gpm to each of three unfaulted l steam generators within 1 minute without operator action.

Technical Specification Surveillance Requirement 4.7.1.2.1.c.(1) requires that each auxiliary feedwater pump be demonstrated operable at least once per 18 months during shutdown by verifying that each automatic valve in the flowpath actuates to its correct position upon receipt of an auxiliary feedwater actuation test signal.

Byron Engineering Surveillances (BVSs) 1BVS 7.1.2.1.b.1-1, " Unit 1 Auxiliary Feedwater Valve Emergency Actuation Signal Verification Test," and 2BVS 7.1.2.1.b.1-1, " Unit 2 Auxiliary Feedwater Valve Emergency Actuation Signal Verification Test," satisfy Technical Specification Surveillance Requirement 4.7.1.2.1.c.(1) and demonstrate that the open stroke time of the auxiliary feedwater pump discharge valves,1/2AF004A/B, support the auxiliary feedwater flow requirement specified in UFSAR, Section 10.4.9.3.1.

Contrary to the above, from October 29,1987, through November 23,1998, the test controls for the stroke time testing of the auxiliary feedwater pump discharge valves, ,

1/2AF004A/B, were not properly established, in that, the test conditions specified in i 1BVS 7.1.2.1.b.1-1 and 2BVS 7.1.2.1.b.1-1 would not demonstrate that the valves would perform satisfactorily in service. Specifically, the stroke time testing of 1/2AF004A/B was preconditioned, not tested under suitable environmental conditions, in that the stroke time measurement was not performed on the first open stroke of the valves.

This is a Severity Level IV Violation (Supplement 1). (50-454/455-98025-03(DRP))

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in NRC Inspection Report 50-454/98025(DRP); 50-455/98025(DRP). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein l

9901250364 990119 PDR ADOCK 05000454 G PDR

Notice of Violation does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation," and send it ,

to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region ill, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 dase of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possibe, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes euch information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 19* day of January 1999 i