ML20080G657
| ML20080G657 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/19/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080G637 | List: |
| References | |
| 7824N, NUDOCS 8402130554 | |
| Download: ML20080G657 (7) | |
Text
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t Commonwasith Edison One First National Plaza. Chicago. Illinois Address Reply to: Post Office Box 767 Chicago, lilinois 60690 December 19, 1983 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission - Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station Unit 1 IE Inspection Report No. 50-454/83-47 NRC Docket No. 50-454 Reference (a):
November 19, 1983, letter from J. F.
Streeter to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided the results of the inspection conducted at Byron Station by Messrs. M. Ring and C. VanDenburgh in September and October, 1983.
During that inspection certain activities appeared to be in noncompliance with NRC requirements.
Commonwealth Edison's response to the Notice of Violation appended to reference (a) is provided in Attachment A.
The response to Violation 1 will be provided within two weeks.
This violation involves an apparent misunderstanding of our commitments regarding the qualification of System Test Engineers.
We are seeking resolution through NRR and expect to provide a satisfactory response.
In the interim, there appear to be no serious concerns regarding the performance of the System Test Engineers.
After close review of the circumstances associated with Viola-tions 3 and 4, we do not agree that they have been properly classified as items of noncompliance.
For the reasons described in Attachment A, we request that they be withdrawn.
We are available to discuss these matters further at your convenience.
Please contact this office if further information is required.
To the best of my knowledge and belief tne statements contained herein and in the attachments 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 emp'loyees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yoursg g/
O.
L.
Farrar Director of Nuclear L censing TRT/lm Q
9tD Attachment h2h O
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7, 9-ATTACHMENT A Response to Notice of-Violation Violatien 2 10 CFR 50, Appendix B, Criterion XIII, states in part, " Measures shall'be established to control the handling, storage, shipping, cleaning-and preservation to material and equipment in accordance with' work and inspection instructions-to prevent damage or deterioration."
..The Commonwealth Edison Company Quality Assurance Program contains in Quality Requirement QR 2.0- a commitmentL to the regulatory position of Regulatory _ Guide 1.39, Revision 2 which endorses the requirements of ANSI N45.2.3-1973.
ANSI N45.2.3 describes requirements of cleanliness zones.
Byron Project Construction ~ established a cleanliness zcne II area on the_ Unit.1 refueling floor area and postad the area with signs describing requirements for all personnel and material entering and exiting the area to be. signed in and out at the entrance,. use of. shoe coverings and head' coverings, and no use-of tobacco, eating or
- drinking.
Contrary to the above, on October 18, five individuals were observed entering the area without complying with the posted requirements.
The individuals did'not sign in or out or put on shoe coverings or head coverings.
At that time, no provisions for ensuring compliance with the posted-requirements (such as personnel posted to sign material in'and out). appeared to-be in place.
Corrective ~ Action Taken and Results Achieved l Prior to the ECCS' Full Flow Test, walls were erected around the reactor cavity area, the area was cleaned and signs establishing zone II
- cleanliness requirements-were posted.
Zone II cleanliness requires controlled access of personnel and material, head and _ shoe coverings, and no eating or smoking.
The ECCS Full. Flow Test was completed with zone II cleanliness requirements -being satisfied.
At this point personnel were noflonger postedito' control access and enforce other requirements because zone II cleanliness:was no longer needed.
The sit s designating the area es' zone II.were,-however, not removed.
Upon notification of this discre-pancy,:the signs were promptly removed.
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Currective-Action Taken To Avoide Further' Noncompliance Appropriate Project Construction personnel that identify areas as
-requiring ~special cleanliness zones will be reinstructed in the proper method of changing. zone requirements to a less stringent level.
contractors will be notified to inform their employees to follow the -
All site special zone cleanliness requirements as posted even if personnel are not
- present to enforce these requirements.
Date When-Full Compliance Will Be Achieved
-January 6, 1984.
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. Violation 3 10 CFR 50, Appendix B, Criterion XII, states in part, " Measures shall be established.to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
The Commonwealth Edison Company Quality Assurance Program contains in Quality Requirement 2.0 aLcommitment to the regulatory position of Regulatory Guide 1.33 Revision 2 which endorses the requirements ANSI N18.7-1976.
Appendix A of the Byron /Braidwood FSAR also states the applicant complies with Regulatory Guide 1.33.
In paragraph 5.2.16,." Measuring and Test Equipment", ANSI N18.7 states, in part, "When calibration, testing, or.other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of -devices previously tested from the time of the l
previous calibration."
Contrary to the above, the licensee's program for calibration of permanent plant instrumentation did not provide for an evaluation concerning the validity of previous tests for which an instrument was used when that. instrument was found to be out of calibration tolerance.
Several permanent plant instruments have been used to obtain acceptance criteria data in several preoperational tests.
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Response.
l The following programs ensure that measuring and test equipment and permanent plant instrumentation used during pre-operational tests is
- properly calibrated and resultant data is reviewed for validity and L
acceptablity.
1)
Instrument Discrepancy-Reports Prior to turnover for test, all instruments required for the test have been calibrated in accordance with BIP 2000-3 or 4, with the exception of instruments that have problems, which are described on the Instrument Discrepancy Reports (IDR's).
For those IDR's that cannot be resolved prior to turnover, turnover deficiencies are initiated, which are resolved prior to performing the associated test l
activities.
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g 2)j 18-Month Calibration Frequency
- Asia result of previous NRC. concerns regarding the condition and
- accuracy'of permanent plant' instrumentation during pre-operational testing, Byron' Station implementedoa' requirement in the. Fall of'1982, to-calibrate
- all' measuring and test equipment and permanent plant instrumentation which is.used to-collect acceptance criteria data
~within"181 months of the time-that the instrumentation is used.- This' Erequiremant ensures thatrequi'pment is properly calibrated in accord-cance.with the Commonwealth Edison Quality Assurance Manual and Commonwealth Edison;Q.A.~ Topical' Report, CE-1A, prior to use in the test-program.
- 3)- Expected' Values / Ranges 1
.' Byron Station'hascalso--implemented-a. program.to ensure that data collected in(a test-has<an; expected valueuor expected range.- This n
commitment? involves datazcollectedifor test acceptance criteria as 4
well as other data taken'in_the" test to ascertain that system design requirements ~are met..'These expected values'are reviewed by the T
LStation Test Review--Board (TRB) and Project Engineering (PED) during
-Pre-Test-Review-and Post Test Review.
A change.has been submitted to
-the Byron Startup Manual concerning.this review of expected values to reflect er written commitment for 'this review by Project Engineering.
During the' conduct of'a test as well as during post test ~ review, the g'
'STE. reviews' data-obtained from instrumentation against the expected value or acceptance criteria requirement.
Test'deficiercles are Lwritten for data that doesinat_ meet'the expected result.
This deficiencyois'either corrected and retested immediately or held.for further reviewLthe TRB and PED.
By review and approval of all test data against the expected valueaor acceptance criteria, we can deter-
.mine;whether an instrument is discrepant or not.
Programmatically, r
~by comparing all' test data, i.e.-flow, pressure, total developed
' head, temperature,lTRB.and PED'can ascertain that test results are 1 satisfactory..
.We believe that the programs and measures implemented to date
.andsdiscussed"above adequately ensure that permanently installed plant iinstrumentation'is properly' calibrated and that' instrumentation later f roundioutfof1 calibration is reviewed to assure that test results are not
- affected.'
The-violation'also addresses Regulatory Guide 1.33 and ANSI N18.7
- requirements to have a-program implemented to assure measuring and test
- equipment--is calibrated and an evaluation of instrumentation found out of
.~calibrationfis conducted.
Regulatory Guide 1.33, Rev. 2 endorses ANSI 18.-7-1976ffor general quality assurance program " requirements" for the
- " operation" phase.
Regulatory Guide 1.33 states that "this standard g
containsicriteria for administrative controls and quality assurance for
- ;nu'elear power _ plants /during the operational phase of plant life 'and that athis phase-is generally-considered to commence with initial fuel loading, a.
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- except for certain preoperational activities.
In this regard, a separate regulatory guide addressing the quality assurance program for the preoperational phase will be issued.
Other regulatory guides may be issued or this regulatory guide may be revised, if necessary, to amplify the general requirements contained in this standard."
Compliance with ANSI N18.7 regarding test and measuring equipment is presently ongoing for portable test equipment.
A new Byron Instrument Procedure, BAP 2000-8, is being written and will be implemented prior to fuel load to address instrument discrepancies regarding installed plant instrumentation.
Given the program of test review and implementation of ANSI N18.7-1976 requirements as delineated above, we request that this item of noncompliance be withdrawn and followup of our program be addressed as an open item.
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--6 Violation'4
- 10 CFR 50, Appendix'B~. Criterion XI, states in part, "A test program shallrbe: established to assure;that.a11' testing required to
' demonstrate that structures,, systems and components will perform
. satisfactorily in service-is'identifled=and performeo in:accordance
- with written test procedures-which
- incorporate' the-requirements and
-acceptance >1'imitsLeontained in' applicable design documents."
Table-14.2-6 of ~ the: Byron FSAR specifies that. the - acceptance
' criterion for'the Reactor.l Protection? Test ~be in accordance in=Section 7.2-of the FSAR.
-Contrary to theTabove, test procedure RP 68.10, " Reactor Protection l Time: Response" was not-written to incorporate-the acceptance-limits contained in the applicable-design document,'in that not all13f the
- rsector trips which are specified in Section 7.2 of the FSAR'were included in the-test / procedure as Acceptance Criterion.
-Respon'se Section 114.2 of the FSAR, in describing the RP test, refers to Section~7.2for the=FSAR forLacc'eptance criteria.
Section 7.2.1.2.4 o f the FSARLspecifically. refers, in turn, to Chapter 16.(tech-specs).of the
'FSAR'and= indicates 1that this chapter. defines-the limits, margins ~and-tsetpointsLih accordance with the requirements :of Chapter 15 of the FSAR.
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The: tech' specs list response-time values for those parameters which have.
_ acceptance criteriaLin the approved test procedures and no others.
The other parameters in'Section 7.2 and in the; test objective section were n
' included' asLa matter of' good -practice.
m Since'the FSAR commitment was satisfied, it is' requested that this violation beLwithdrawn.
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