ML20207T601
| ML20207T601 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/20/1987 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20207T590 | List: |
| References | |
| 2750K, NUDOCS 8703240172 | |
| Download: ML20207T601 (5) | |
Text
-
e- s
- _l l. - . ',,\ .
m
-c.* _ _ _ One Frat Nabonel Plaza. Chca00, lHinois' Address Reply to: Post Ollice Box 767 Ctucapo. Iginois 60000 - 0767 February 20, 1987
-Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Unit 2 IfiE Inspection Report 50-455/86041 NRC Docket No. 50-455 Reference (a): January 21, 1987 letter from C.J. Paperiello to Cordell Reed 1
Dear Mr. Keppler:
Reference (a) provided the results of an inspection on October 18 to November 14, 1986 of activities at Byron Station Units 1 and 2. During this inspection, certain activities appeared to be in violation of NRC requirements. Attachment A of this letter contains comunonwealth Edison's response to the Notice of Violation enclosed with reference (a).
Our review of the items contained in the Notice of Violation has not concluded these items represent violations of NRC requirements. In light of this, we request that you reconsider whether these items should be classified as violations based on the information presented in Attachment A.
please direct any questions regarding this matter to this office.
Very truly yours, G703240172 870320 PDR ADOCM 05000454 * -
G PDR A Ter D. L. Farrar Director of Nuclear Licensing 1m Attachment cc: Byron Resident Inspector 2750K FEg 2 3 g
w - -
4; .
3 AT M A VIOLATION 1 10 CPR 50.59, " Changes, Tests and Experiments" requires that a licensee maintain records of tests and experiments carried out pursuant to 10 CPR 50.59(a) which "shall include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question."- Byron Administrative Procedures BAP 1210-5, "10 CFR 50.59 Safety Evaluation Procedure", Revision 3, and BAP 1310-T19, "10 CFR 50.59 Format for Safety Evaluation," which implement the_above require that the following be recorded on procedure checklists and forms: 1) the specific reasons justifying the decision that an unreviewed safety question does or does not exist, 2) the review of potential system interactions, and 3) the review of applicable sections of the FSAR, technical specifications, and other potentially applicable documents.
Contrary to the above, the safety evaluations for the 2B Diesel Generator Preoperation Test (DG 22.62) and two retests (R-2020 and R2021),
Containment Purge Retest (R-2067), Diesel Generator Ventilation Retest
'(R-2049) and the Main Steam Power Operated Relief Valve Component Demonstration (C-2061) did not provide the bases for the determination that unreviewed safety questions were not involved in the performance of the tests nor did they include the information required by the above licensee procedures.
RESPONSB Performance of the Unit 2 preoperational tests and retests listed above in violation 1 did not represent a change in the Unit 1 facility or procedures as described in the safety analysis report, nor did it represent a test or experiment conducted on Unit 1. For these reasons, and since Unit 2 was not a licensed facility when these activities took place, 10 CFR 50.59 did not apply. Therefore, we request the NRC to reconsider whether this item involves a violation of 10 CFR 50.59.
We recognize that Byron Administrative Procedure BAP-1210-5 requires a 10 CFR 50.59 evaluation be performed in connection with the execution of a Unit 2 preoperational or startup test to assure no adverse affects will occur on Unit 1. In light of this commitment, we have taken the following actions to enhance the quality of the 10 CFR 50.59 safety evaluations being performed for the Unit 2 test program.
A department meeting was held on October 23, 1986 to disseminate the proper method of performing safety evaluations in accordance with Byron administrative procedures. Emphasis was placed on the need to provide sufficient justification for the determination that unreviewed safety questions were not involved in the performance of the test. In addition,
d at .-
,o
' VIOLATION 2 10 CPR 50, Appendix B, Criterion XVI, as implemented by the Cossoonwealth Edison Company's Quality Assurance Manual, requires that conditions adverse to quality be-identified and corrected in a manner that precludes repetition.
. Contrary to the above, for Preoperational Test PS 61.60, " Process Sampling Primary", there were two cases in which deficient conditions were
. resolved during Byron Unit 1 preoperational testing but the resolutions were.
not incorporated into the Byron Unit 2 preoperational test. As a result, Unit 2 testing encountered the same deficiencies. In one case, a test acceptance criteria required that the temperature difference between the
. component cooling inlet temperature and the sample coolers effluent temperature be no greater than 6'F. However, the combined instrument tolerances of the instruments used to measure the temperatures in question was greater than 6*F and consequently the acceptance criteria could not be verified using these instruments. In the other case, a sample purge flow rate specified in the test was found to be based on an improper design pressure.
RBSPONSE Two programs were put in place by Commonwealth Edison to govern the writing of test procedures for Byron Unit 2 and Braidwood. One of them, the Byron Lessons Learned Program, was designed to review Byron Unit 1 test program problems, including test deficiencies that impact acceptance criteria, and then make changes to the test procedures for the remaining units that would remove the problem.
The second program that was in place involved a " sameness" criteria. The " sameness" program was intended to make the test procedures for the units as close to identical as possible, after correcting all errors found in the Byron Unit 1 tests. This would allow a comparison of data among the units to find and isolate potential design flaws quickly and with a high degree of confidence.
The first priority regarding the transferring of lessons learned from Byron Unit I was the correction of test procedures that resulted in retests to verify PSAR commitments. If a Byron Unit 1 test was discovered to be deficient, in that an FSAR commitment could not be shown to be met, then the test steps would be rewritten and that portion of the test would be performed again. A secondary priority of the Lessons Learned Program was to eliminate " nuisance" deficiencies that, while not impacting a FSAR commit-ment, would make the test procedure more easily reviewed and approved.
y 8 .
Tech Staff Memo #ST04/01, Rev. A, " Unit 2 S/U TEST-POST REVIEW" dated January 15, 1987 incorporated additional checklist parameters to provide additional emphasis to scrutinize the executed test for proper implemen-tation of the Byron administrative procedures for safety evaluations.
Based on the foregoing, we request the NRC to consider reclassifyjng this item to a deviation from a commitment.
2750K
.,w . ,
'l We consider the deficiencies listed in violation 2 above for test- 1 PS 61.60 to fall into the second priority discussed above. The deficiencies
.were dispositioned properly in the Unit 1 test and found to have no impact on FSAR commitments. They did, however, result in repeat deficiencies in the Byron Unit 2 test and had to be dispositioned again.
These deficiencies did not result in poor test results that could not be dispositioned and consequently, we believe these items did not represent conditions adverse to quality. Therefore, we request the NRC reconsider whether these items represent a violation of criterion XVI of 10 ,
CPR 50, Appendix B. We recognize that these items could be considered a deviation from our commitment to the Lessons Learned Program, however we do not expect major deviations from this commitment that would adversely affect the quality of test results. Therefore, no further action is considered necessary regarding these items.
Me 2*iSOK
- _ _ . _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ., _ _ __._ _ _ ..,___ _