IR 05000237/1981015
| ML17252A675 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion, LaSalle  |
| Issue date: | 05/22/1981 |
| From: | Baker K, Holzmer M, Schultz R, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17252A673 | List: |
| References | |
| 50-237-81-15, 50-249-81-09, 50-249-81-9, 50-254-81-07, 50-254-81-7, 50-265-81-07, 50-265-81-7, 50-295-81-10, 50-304-81-06, 50-304-81-6, 50-373-81-16, NUDOCS 8106090433 | |
| Download: ML17252A675 (8) | |
Text
'.t U.S. NUCLEAR REGULATORY COMMISSION
. OFFICE OF INVESTIGATION AND ENFORCEMENT
REGION III
Reports No. 50-237/81-15, 50-249/81-09, 50-373/81-16, 50-254/81-07, 50-265/81-07, 50-295/81-10, 50-304/81-06 Docket Nos. 50-237, 50-249, 50-373, 50-254, 50-265, 50-295, 50-304 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Licenses No.:
DPR-19, DPR-25, DPR-39, DPR-48, DPR-29, DPR-30 CPPR-99 Facility Name:
Dresden, LaSalle, Zion, Quad-Cities Inspection At:
Corporate Offices, Chicago, IL Inspection Conducted:
April 20-21, 1981 Inspectors:j°R'-~ _
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Approved By:. Baker, Chief Management Program Section Inspection Summary Inspection on April 20-21, 1981 (Reports No. 50-373/81-16, 50-254/81-07,
' 50-265/81-07; 50-249/81-09, 50-237/81-15; 50-295/81-10, 50-304/81-06 Areas Inspected:
Announced routine inspectio*n of the licensee's implemen-tation of the Quality Assurance Program in the following areas:
Offsite support staff, offsite review committee, quality assurance training, procurement control, and audit The inspection involved a total of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of inspection at the licensee's corporate office by two NRC inspector Results:
Of the five areas inspected, no apparent items of noncompliance or deviations were identified in four areas, one item of noncompliance was identi-fied in one area (failure to reference applicable regulatory requirements and quality assurance program requirements in procurement documents - Paragraph 2).
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DETAILS Persons Contacted H. Stolt, Senior Design Engineer - SNED
- E. Martin, Quality Assurance Coordinator - SNED J. Boesen, Purchasing Agent
- G. Marcus, Director of Quality Assurance - Engineer and Construction W. Shewski, Manager of Quality Assurance W. Koester, Engineer - Reliability and Design G. Adamaitis, Senior Equipment Analyst
- R. Jortberg, Director of Nuclear Safety W. Kiefer, Assistant to the Director of Nuclear Safety F. Morris, Senior Offsite Review Participant, Dresden Station N. Wandke, General Purchasing Agent A. Zolfo, Purchasing Agent W. Eck, Quality Control Supervisor - SNED W. Stierle, Manager - SNED *
A. Saller, Quality Assurance Training Coordinator The inspectors also interviewed other licensee employees including engineering and administrative personne *Denotes those present at the exit intervie.
Procurement Program The procurement program was reviewed to ascertain its conformance with regulatory requirements and commitments in the operational quality assurance progra Procurement documents were checked for technical* requirements, QA program requirements, 10 CFR 21*provisions, specific identification of items, and basis for classification of procurement item Procedures were reviewed to determine if respon-sibilities were assigned in writing for:
(a) initiation of proc~rement documents; (b) review and approval of procurement documents; (c) making changes to procurement document Documentation Reviewed Quality Assurance Manual, February 16, 1981, Q.R. No. 4.0, Procurement Document Contro Station QA Manual, February 16, 1981, Revision 63, Procurement Contro Station QA Manual, February 16, 1981, Q.P. No. 4-51, Procurement Document Control for Operation - Processing Purchase Document Station QA Manual, February 16, 1981, Q.P. No. 7-51, Control of Purchased Materials - Equipment and Services for Operation -
Supplier Evaluation.
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Station Quality Assurance Manual, February 16, 1981, Q.P. No. 4-1,
, Request for Bid, Proposal Evaluation and.Recormnendatio Station Quality Assurance Manual, February 16, 1981, Q.P. No. 4-2, Evaluation of Contractors Quality Assurance Progra * Findings Noncompliance (50-254/81-07-01, 50-265/81-07-01, *S0-373/81-16-01 10 CFR 50, Appendix B, Criteria IV, states, "Measures shall b.e es-tablished to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably referenced in the documents for procurement of material, equipment and services, whether purchased by the applicant or by its contractors or subcontractor To the extent necessary, procurement documents shall require contractors or subcontractors to provide a*quality assurance program consistent with the pertinent provisions of this appendix."
CoDBDonwealth Edison Company's Quality Assurance Program Topical Report, CE-1-A, Revision 14 and 15, Section 4 - Procurement Document Control, states in part concerning procurement documents, "Quality Assurance Program requirements are included as are regulatory, code, standard and design requirements."
C'ontrary to the above, instances were identified where procurement documents £ailed to impose the quality assurance program require-ments of 10 CFR 50 Appendix B, and other procurement documents which do not impose the applicable regulatory requirements of 10 CFR 2 Numerous purchase order documents were reviewed for the LaSalle County and Quad-Cities Station Those classified as safety-related and not ordered under the criteria of the A~E Code requirement did not reference quality assurance program requirements in regards to 10 CFR 50 Appendix The following purchase orders are examples where 10 CFR 50 Appendix B requiremeµts were not imposed:
Purchase Order N Date Item Failure to Impose 228218-LS 8/17/78 Instrument Fit-10 CFR 50, Appendix B tings 500976-LS 6/4/80 Shaft 10 CFR 50, Appendix B 237921-QC 7/3/79 Valves for Nuclear 10 CFR SO, Appendix B Instrumentation 730365-QC 1/22/80 Diaphram for 10 CFR 50, Appendix B Target Rock Valves 501365-QC 1/15/80 Studs 10 CFR 50, Appendix B
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251480-QC 251673-QC 1/22/81. Plug Valves 2/3/81 LPRM Replacement Parts 10 CFR SO, Appendix B 10 CFR SO, Appendix B The 10 CFR 21 regulatory requirements were included as part of the above purchase order The following purchase orders are examples where 10 CFR 21 require-ments were not imposed:
Purchase Order N Date Item Failure to Impose 235123-QC 4/2/79 In-Core Flux 10 CFR 21 Monitor Seals 248649-QC 8/19/80 Detectors for SRM 10 CFR 21 The above two items cannot be classified as commercial grade items
- according to the definition of commercial grade in 10 CFR*21.3, since they are unique to facilities or activities licensed pursuant to Parts 30, 40, 50, 70, or 71 of 10 CFR and are not used in applica-tions other than facilities or activities pursuant to Parts 30, 40, SO, 70, or 71 of 10 CF Therefore, the required regulatory statement must appear on the procurement documents in accordance with 10 CFR 21 Paragraph 21. 3 Discussion:
The applicability of 10 CFR 21 to procurement documents in relation to items that may be considered "off the shelf" but unique to the nuclear industry was discussed with the license The inspector informed the licens~e that items purchased, which fall under the def in~tion of. basic components and are* unique to facilities or ac-tivities licensed pursuant to Parts 30, 40, 50, 70, or 71 of 10 CFR, must have the required 10 CFR 21.31 statements as part of the procurement documen Dresden Nuclear Station The inspector identified two procedural discrepancies which the licensee agreed to revis One procedure, Q.P. No. 4-51, Pro-curement Document Control for Operations - Processing Purchase Documents, stated on page 9 of 12, "The Buyer may authorize shipment of spare parts and equipment for use and installation without purchasing documentation providing the vendor supplies with the shipment an interim document of conformance complying with the conditions described on Form 4-51-2 and agrees to transmit the purchasing documentation to the station by a date acceptable to the General Supervisor, Production Stores." This discrepancy involves the authority of the buyer to release items for use and installation. The licensee agreed that the buyer should only authorize shipmen.. 4 -
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The other procedure, Q.P. No. 15-51, Nonconforming Materials, Parts and Components for Operations - Spare Parts and Materials, stated on page 3 of 15, "In the case where a discrepancy is identified based on design requirements and involving many locations, but it is felt the design requirements need to be evaluated prior to proceeding with the inspection and identification of the deficiencies, the inspection and placing of the Hold Tag may be def erred until Engineering disposition has been provided on the Discrepancy Record."
The discussion on this issue involved the responsibility which is *
delegated to engineering, and the possible consequences which could occur if engineering did not respond in an adequate time frame on a design requirement which may have adverse effects on the safe oper-ability of the plan The licensee stated that they would either remove this statement or include a qualifying statement, taking into
- account such factors as safe operability, with the concurrence of the technical staff supervisor and/or quality assurance lead engineer This is considered an open item pending verification of the procedure revision (50-254/81-07-02, 50-265/81-07-02, 50-373/81-16-02, 50-237/81-15-01, 50-249/81-09-01, 50-295/81-10-01, 50-304/81-06-01)
The methods and criteria involved in determining if a supplier or vendor can be placed on the approved bidders' list for safety related material was di,scusse It appeared that uniform or standard criteria have not been developed for determining technical acceptability of a vendo In many cases, records could not be produced justifying the technical acceptability of a vendor or supplie The licensee agreed to implement a program that would standardize the technical accept-ability criteria for suppliers of safety related material and to retain records justifying the approva This is considered an open item pending verification in a.future inspectio (50-254/81-07-03, 50-265/81-07-03, 50-373/81-16-03, 50-237/81-15-02, 50-249/81-09-02, 50-295/81-10-02, 50-304/81-06/02) Audit Program The licensee's audit program was reviewed to ascertain whether the licensee has developed and implemented a program that is in conform-ance with regulatory requirements and applicable industry. guides and standard The inspection included verification of the following:
scope.of the program is consistent with Technical Specification re-quirements; responsibilities for overall management of the program have been assigned; and methods for identification and resolution of audit findings have been define Documentation Reviewed Quality Assurance Program Topical Report, CE-1-A, Revision 14 and 15, Section 16, Corrective Actio Quality Assurance Program Topical Report, CE-1-A, Revision 14 and 15, Section 18, Audit.5 -
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Technical Specification, Section 6.1, Organization, Review Investigation, and Audi Quality Assurance Manual, February 16, 1981, Q.R. No. 18.0 - Audit Quality Assurance Manual, February 16, 1981, Q.R. No. 16.0 -
Corrective Actio Station Quality Assurance Manual, February 16, 1981, No. 16-51 - Corrective Action for Operations - Corrective Action Syste Station Quality Assurance Manual, February 16, 1981, Q.P~
No. 18-51 - Quality Assurance Program Audit Station Quality Assurance Manual, February 16, 1981, No. 18-52 -*Audit and Surveillance of Maintenance, Spare Parts and In-Service Inspection Activitie Station Quality Assurance Manual, February 16, 1981, Audi QAP-1220-3, Revision 1, September 5, 1975, Corrective Action for Non-Conforming Items and Operational Discrepancie QAP-1250-1, Revision 2, July 19, 1976, Action Item Progra QAP-1250-2, Revision 1, September 5, 1975, Action Item Status Repor QAP-1250-3, Revision 6, December 1, 1979, Action Item Procedure Findings No items of noncompliance were identifie Discussion The licensee's audit program was satisfactory with respect to scope, preparation, planning, objective evidence, disclosure of defi-ciencies and concerns, corrective action, follow-up and close-ou.
Offsite Review Function The inspector reviewed the offsite review functions to ascertain if it is being conducted in accordance with Technical Specification requirement The inspection included a review of membership and qualifications, subject matter, quorom requirements, safety evalua-tions and recormnendations, and frequency of meeting Documentation Reviewed (1)
CECo General Company Order No. 43 - Nuclear Safet \\.
(2) Nuclear Safety Department Organization and Administration Manua (3)
Dresden Technical Specific~tions, Section 6.1. (4)
LaSalle Technical Specifications, Section 6.1. (5)
Quad-Cities Technical Specifications, Section 6.1. (6)
Zion Technical Specifications, Section 6.1. Findings No apparent items of noncompliance were identifie Discussion:
Qualifications of the Off site Review Group (ORG) members in the Reactor Operatio~s discipline were not written specifically enough to allow determination of an individual's ORG qualifications in that disciplin Five years experience in nuclear power plant operations is required by Technical Specification The Nuclear Safety Department Organization and Administration Manual further lists four categories under the requirement for five years of experience in "Reactor or NPP operations:"
(1) Reactor Operator (RO)
(2) Senior Reactor Operator (SRO)
(3)
U.S. Navy Experience (4)
Other Discussion with the Nuclear Safety Department '.s Director and staff revealed disagreement about whether a total of five years in the categories above was implied, or whether five years of operations ~xperience was required and some of it had to be in one of the.four categorie The licensee agreed to provide clarification and revision if necessary, of the Department in-structio A closely related matter is the qualification of a member of the ORG in the Reactor Operations Discipline (none of the other dis-ciplines in which he is qualified are being questioned).
For his reactor operations experience, only the SRO block was checked, and in the detailed listing of his experience, he did not have five years of licensed experience (SRO license was issued on January 31, 1977, and he appeared* to have no previous RO license or Navy expe*
rience).
Upon clarification and any necessary revision to the department instruction, the licensee agreed to re-evaluate the individual's ORG qualification in the Reactor operations disciplin This area will be re-inspected in the near futur *'
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Open Item (50-254/81-07-04, 50-265/81-07-04, 50-373/81-16-04, 50-237/81-15-03, 50-249/81-09-03 50-295/81-10-03, 50-304/81-06-03) Offsite Support Staff The inspector reviewed the administrative controls which describe the responsibilities, authority, and lines of communication of the offsite support staff in the areas of design, technical support, Quality Assurance, Construction and Procuremen In addition, the qualifications and Quality Assurance training of the offsite support staff were reviewed for conformance with ANSI 18.1-1971 and with Company Procedure The results of Quality Assurance audits of the offsite support,staff were also reviewe Documentation Reviewed (1)
CECO Quality Assurance Manua (2)
CECO SNED Procedures Manua (3)
Procurement training record (4)
SNED training record (5) Quality Assurance Department training records and Qual1fication Matrice Findings No apparent items of noncompliance were identifie Discussion QA training is given in the Purchasing Department on a yearly.basi Newly hired buyers or purchasing Agents are not administratively prohibited from working on QA related purchase orders until having received this trainin New buyers generally have no authority to sign for any purchases for up to six months, and are closely super-vise The licensee has agreed to spedfy in writing that new hires be prevented from working on QA related purchase orders until having received QA trainin This area will be re-inspected in the near futur Open Item Exit Interview (50-254/81-07-05, 50-265/81-07-05, 50-373/81-16-05, 50-237/81-15-04, 50-249/81-09-04, 50-295/81-10-04, 50-304/81-06-04)
The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on April 22, 198 The inspectors sununarized the purpose, scope and findings ~f the inspectio