ML20067D070
| ML20067D070 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/18/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20067D049 | List: |
| References | |
| 5245N, NUDOCS 8212100330 | |
| Download: ML20067D070 (5) | |
Text
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N Commonweelth Edison
[
__ / one First N:tional PI:za. Chic go. Illinois 7 Address Reply to: Post Office Box 767 (Q Chicago, Illinois 60690 Octobe r 18, 1982 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enfo rcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 I&E Inspection Report No.
50-454/82 Reference (a):
September 10, 1982,' letter from C. E. Norelius to Co rdell Reed.
Dea r Mr. Keppler:
Re ference (a) provided the report o f an inspection conducted by Messrs. M. A.. Ring and D.
L.
Robinson during June 1982 of activities at Byron Station.
During that inspection certain activities were identified es not complying with NRC requirements.
Attachment A to this letter con-tains Commonwealth Edison's response to the Notice of Violation appended to reference (a).
It is requested that the severity level assigned to Violation 1 be reviewed.
The failure to document our evaluation has no safety significance.
This should have been a Severity Level V violation.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based on my personal knowledge but upon informa-tion furnished by other Commonwealth Edison and contractor employees and consultants.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address further question regarding this matter to this o f fice.
Ve ry truly yours, 1
8212100330 821207 A
PDR ADOCK 05000454 L. O.
De1Geo rge G
PDR Director o f Nuclea r Licensing im Attachment SUBSCRIBED ond SWORN [to before me this
/fA, day of 8h 1982
~~MeII d-Notary Public 0g g $61 5245N
ATTACHMENT-A Response to Notice-o f-Violation V IOL AT IO N - 1 10 CFR 50, Appendix B, Criterion XVI states, " Measures shall be estab-11shed to assure that conditions adverse to quality, such as failures, malfunctions.... and nonconformances are promptly identified and corrected.... the measures shall assure that the cause of the condition is determined....
The identification o f the significant condition adverse to quality, the cause of the condition.... shall be documented and reported to appropriate levels o f management."
The Commonwealth Edison Company Quality Assurance Manual, Q.P. No. 15-2, paragraph 5.1.5 states the following:
"The Site Construction Superinten-dent or Project Engineer and/or the applicable Project Engineering or Station Nuclear Engineering Project Engineer will have an evaulation conducted of the factors involving each identified, or vendor or outside organization reported, deficiency and defect to determine if it consti-tutes a (1) reportable deficiency or (2) a defect.
The evaluation must be documented by the cognizant Engineer.
Contrary the above:
Following the 1A Emergency Diesel Generator crankcase explosion on March 6,
1982, the licensee did not document their evaluation of the event, and at the time of the inspection had not determined the cause o f the explosion, even though the licensee had determined that the event was not reportable per 10 CFR 50.55(e).
Corrective Action Taken and -Results Achieved l
Administrative procedures were revised to include the use of a new form which is to be used for communicating test problems encountered by the operating staf f to the construction staf f and the engineering staf f for evaluation as potentially reportable deficiencies.
The crankcase explosion was the first event to be documented using this form.
The evaluation performed by engineering personnel resulted in the determination that this event was not reportable.
The root cause o f the f ailure was never determined conclusively but no evidence o f a generic problem was found.
It is presumed that this was a random mechanical failure.
Ex tensive repairs were not required.
Corrective Action Taken to Avoid Further Noncompliance The BAP-1250 procedure described above will be used to assure that test problems are properly evaluated for reportability.
These j
evaluations will also be better documented.
A checklist evaluation form has also been developed to provide the basis for a standardized evaluation process for determining 50.55(e) reportability and to i
l provide a record of this evaluation.
In using this checklist
J cognizant personnel will answer yes/no questions to evaluate both the safety impact and significance of construction deficiencies.
When used, the completed form will be included with the appropriate reporting system record (i.e. :
Nonconformance Report, Preop Test De ficiency, or CECO Audit Report).
Performance deficiencies in preop and startup test reports will also be evaluated by engineering personnel using the criteria established in the forms.
Ap pr cpria te written instructions will control the use of the evaluation forms.
If this system works satisfactorily, consideration will be given to implementation at other CECO construction sites.
Da te -When Full Compliance Will Be Achieved The checklist evaluation form will be in trial use by October 27, 1982.
Appropriate written instructions will be implemented by December 1, 1982.
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, V IOL AT IO N - 2 10 CFR 50, Appendix B, Criterion V states, " Ac tivities a f fecting quality j
shall be prescribed by documented instructions, procedures.... and _ shall, be accomplished in accordance with these instructions, procedures...."
10 CFR 50, Appendix B, Criterion XV states, in part, that nonconforming items shall be repaired or reworked in accordance with documented procedures.
Chapter 7 of the Startup Test Manual states in part that if a system has been turned over for test and requires maintenance or repair, the Project Construction Department will document the work by an Out-Of-Service Request, CAR, or deficiency.
Production instruction No. 1-3-A-1 states, in part, that Out-O f-Service cards are provided for holding equipment out of service for the protection of people or equipment and that when Generating Station equipment is to be taken out of service, Out-Of-Service cards must be placed on the main switch, main valve, and other devices which will isolate the equipment.
Lontrary to the above, procedures were not followed and a reactor coolant pump motor upper bearing cooling water outlet isolation valve, ICC9493A, was reworked without Out-Of-Service tagging and without the knowledge or concurrence of the Systems Test Engineer on June 25, 1982.
Corrective-Action Taken -and Results Achieved This isolated violation of the Out-O f-Service procedure was reviewed with the craft supervision and workers involved.
The work performed was reviewed to insure that the proper installation documentation had been completed.
Corrective Ac tion Taken to Avoid Fu rther Noncompliance Craf t personnel and supervisors were reinstructed to obtain outages from the Project Construction Department prior to the performances o f work on systems under Re-entry Control.
These Outages on equipment are needed for the following reasons:
1.
To prevent injury to personnel 2.
To prevent damage to equipment 3.
To provide notification to Project Construction and Technical Staf f personnel that work needs to be perforned on a system undar re-entry control.
They in turn initiate proper documen-tation (deficiency or CAR) to track the completion and retest o f the af fected portion o f the system.
Date When Full Compliance Will Be Achieved July 9, 1982.
_4_
V IOL AT ION - 3 10 CFR 50, Appendix B, Criterion XV states, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include.... procedures for identifi_
cation, documenation,....and notification to a f fected organizations. "
Contrary to the above, procedures established by the Startup Test Manual cere insuf ficient to ensure proper identification and documentation o f nonconforming materials, parts, or components as evidenced by work performed on a reactor coolant pump motor upper bearing cooling water outlet isolation valve, ICC9493 A, on June 2 5, 1982 and on penetration cooling check valves, ICC060 and ICC061, without deficiency documentation cnd without the concurrence of the of the Systems Test Engineer.
Corrective Ac tion - Taken and -Results Achieved The System Test Engineer was notified o f the work and a deficiency was written.
The work was completed before testing was resumed.
Corrective-Ac tion Taken-to Av oid Fu rther -No ncompliance Revision 9 to the Byron Startup Manual was written to clarify documentation required for work performed after Turnover for Test.
Da te When -Full Compliance Will-Be - Achieveo July 20, 1982.
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