IR 05000237/1985029
| ML17195A957 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/18/1985 |
| From: | Hawkins F, Smeenge R, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195A955 | List: |
| References | |
| 50-237-85-29, 50-249-85-24, NUDOCS 8509240176 | |
| Download: ML17195A957 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report Nos. 50-237/85029(DRS); 50-249/85024{DRS)
Docket Nos. 50-237; 50-249 Licensee:
Commonwealth Edison Company P. 0. Box 767 Chicago, Illinois 60690 License Nos. DPR-19; DPR-25 Facility Name:
Dresden Nuclear Power Station, Un.its 2 and 3 Inspection At:
Morris, Illinois Inspection Conducted:
August 15, August 19-28, and September 3, 1985 Inspector: i~~
R. Smeenge ~
- 1hp;;P r
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Approved By:
F. Hawkins, Chief Quality Assurance Programs Section Inspection Summary Ins ection on Au ust 15, Au ust 19-28, and Se tember 3, 1985 (Re art No DRS ; 50-2 9 8502 DRS Areas Inspected: Unannounced, routine safety inspection by two regional inspectors of calibration, tests and experiments, QA program, QA/QC administration, and records progra The inspection involved a total of 85 inspector-hours onsite and-22 inspector-hours of in-office procedure and records review Results:
One violation was identified in the QA pr6gram area (failure to provide required training - Paragraph 5.b).
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- DETAILS Persons Contacted Commonwealth Edison Company (CECo)
D. Scott, Station Manager
- J. Wujciga, Production Superintendent
- R. Flessner, Service Superintendent J. Brunner, Assistant Superintendent Technical Service P. Lau, QA Supervisor R. Dyer, Modification Supervisor H. Waclaw, Instrument Maintenance J. Wtlliams, Senior QA Inspector R. Stabert, Senior QA Inspector USN RC
- F. C. Hawkins, Chief, Quality Assurance Programs Section T. M. Tongue, Senior Resident Inspector E. Hare, Resident Inspector
- S. Stasek, Resident Inspector
- Denotes tho~e attending the exit interview on September 3, 198.
Action on Previous Inspection Finding~
(Closed) Open Item (237/85008-03; 249/85007-03):
Backlog and improper storage of work request packages awaiting processin The ba~klog has been cleared and records are now being properly store.
Calibration The inspector verified that the licensee had implemented a program to*
control the calibration of components and equipment associated with safety-related systems and functions that was in conformance with the requirements of the Technical Specification and approved guides and standard Documents Reviewed ( 1)
DMP 010-1, "Plant Performance Monitoring Instrument Calibration and Schedule, 11 Revision 0 (2)
DMP 100-2, "Control of Measuring and Test Equipment,
Revision 1 (3)
DIS 201-1, "Reactor Vessel 600 PSI Scram Bypass Pressure Switches Calibration," Revision 3 (4)
DIS 500-1, "Reactor High Pressure Scram Sensor Calibration," Revision 1
( 5)
DIS 500-2, "Reactor Vessel Low Water Level Scram and Low Low Water Level Isolation," Revision 5 (6)
DIS 500-6, "Condenser Low Vacuum Scram, 11 Revision (7)
DIS 700-3, 11SRM Rod Block Calibration Check,
Revision 6 (8)
DIS 700-4, 11 IRM Rod Block/Scram Calibration Test,
Revision 6 (9)
DIS 700-6, 11APRM Flow Biased Scram Rod Block and Downscale Calibration," Revision 8
(10) DIS 700-8, "Rod Block Monitor Calibration, 11 Revision 9 (11) DIS 1500-4, 11Containment Spray Interlock, Drywell Pressure Switches Calibration," Revision 1 (12) DIS' 1600-2, 11Drywell High Pressure Scram Switches Calibration," Revision 2 (13) DIS 1600-4, 11Drywell Pressure Switches (ECCS)
Calibration, 11 Revision 2
- (14*) DIS 1700-7, 11Reactor Building Ventilation and Refueling Floor Radiation Monitor Functional Test, 11 Revision 8 (15) DIS 2300-.3, 11Master Trip.Unit Calibration
(16) 85-3-29, 11HPCI Turbine Permissive Master Trip Unit Calibration, 11 Temporary Procedure Inspection Results The computerized calibration schedule, procedures, completed test and data sheets which were reviewed provided evidence that the licensee had performed scheduled calibration within the minimum test and calibration frequency requirements of the Technical Specification. Test and data sheet records for work completed during 1985 were also found to be satisfactor The inspector witnessed the performance of calibrations in accordance with procedures 85-3-29, DIS 2300-3, DIS 700-3, DIS 700-4, and DIS 1700- Interviews with.the technicians, as they performed the calibrations, found them to be knowledgeable and qualified for the work they were doin Calibrations were performed in accordance with the approved procedure Testing devices were calibrated and traceable to the National Bureau of Standard *.
Licensee audits had been performed annually in this area. Audit reports QAA 12-84-39 and QAA 12-83-42 for 1984 and 1983 were reviewe No deficiencies were identified by the licensee in these audits, and both audits had been close No violations or deviations were identifie.
Tests and Experiments The inspector reviewed the licensee's tests and experiments program to verify that it was in conformance with regulatory requirements, commitments and the applicable industry guides and standard Documents Reviewed (1)
QP 3-51, "Design Control for Operations - Plant Modifications," Revision 12 (2)
OAP 5-1, "Modifications," Revision 12 (3)
OAP 11-6, "Request for Purchase and Receiving Inspection Guidelines," Revision 1 (4)
OAP 11-7, "Technical Evaluation of Parts Used in Safety-Related Components," Revision 1
- Modification Packages Reviewed (1)
M12-3-83-47, "ISO Condenser Snubbers Nos. 1, 2, 3
(2)
M12-2-84-8, "Replace Various HGA-11 Relays in Response to GE Service Advisory No. 721-PSM-174-1
(3) M12-2-84-7, "Replace Vacuum Breaker Packing with Bronze Bushing and Ethylene Propylene 0-Ring" (4) M12-2-85-70, "To Remove the Transformer 22 Lockout Relay Contacts from the Closing -Circuitry of Breakers 2101, 2205, 2303 and 2413 11 Inspection Results The inspector verified that the four modification packages had been reviewed by the licensee to determine whether they were described in the FSAR, or involved either an unreviewed safety question or a change in the Technical Specification Modification M12-3-83-47 replaced pneumatic snubbers in the isolation condenser system with mechanical snubber The work request identified that the load pin supplied with snubber M119D-76 did not fit, and it was replaced with 1-inch diameter round carbon steel stock materia At the time of installation,
the licensee did not perform a technical evaluation to determine if the stock material (ANSI 1018 CW steel) was a suitable substitut The snubbers were replaced during March 198 During March the licensee issued procedure OAP 11-7, 11Technical Evaluation of Parts Used in Safety-Related Components.
This procedure was*
issued as a result of a previously identified NRC violation where a vendor supplied substitute replacement part, installed during maintenance, failed to meet specification requirement Procedure OAP 11-7 requires a technical evaluation of substitute parts to be performed. Prior to completion of this inspection the licensee performed a technical evaluation of the load pin installed in snubber M119D-76 and determined that an acceptable safety margin existe To provide reasonable assurance that other part substitutions had not been installed in safety-related equipment without technical evaluation for acceptability, the licensee committed to perform a sampling review of completed modification and maintenance work request December 31, 1985, was established as the target completion date for the revie Pending NRC review of the sampling plan and its results, this matter is considered unresolved (237/85029-01; 249/85024-01). QA Program - Annual Review The inspector reviewed recent rev1s1ons to the licensee's Quality Assurance Program (QAP) to verify that personnel responsible for the identification, communication, training, and implementation of the changes were familiar with them and had taken appropriate action to communicate and implement the The inspection included the review of applicable QAP procedures and documents, the conduct of interviews with selected personnel and a review of record Documents Reviewed (1) Quality Assurance Manual (QAM) and Revision Notice of June 5, 1985 (2)
Dresden Organization Chart of June 30' 1985 (3)
QAM Figure 1-0, 110rgani zati on. Chart Related to Quality Assurance" (4)
QAM Figure 1-1, 110rganization Chart-Quality Assurance" (5)
QAM Figure 1-7, "Station Production Department Organization
(6)
QAM QP No. 2-1, 11Procedure for the Revision of the Quality Assurance Manual - Engineering, Construction and Operation
5
(7)
(8)
(9)
(10)
( 11)
{12)
{13)
{14)
Dresden Administrative Procedure (OAP) Manual, Copy No. 28 QAM QP No. 2-52, "Quality Assurance Program for Operations - Conduct of Training in the Production Area" QAM QP No. 2-2, "Training of Personnel to Meet Quality Assurance Requirements
OAP 9-1, "Station Procedures" OAP 9-2, "Procedure Preparation" OAP 9-3, "Procedure Review and Writing" OAP 10-1, "Onsite Review and Investigative Function" OAP 10-9, "Selection of Onsite Review Participants" (15) QAM QP No. 18-51, "Audits for Operations - Quality Assurance Program Audits" (16) QP Form 18-51.1, "Audit Checklist.and Record Sheet"
{17) Audit Reports:
12-85-02, 12-85-07, 12-$5-13, 12-85-23, 12-85-35, 12-83-54, 12-84-8 (18) NSD Directive NSDD-T-03, Quality Assurance Training Program and Matrix
{19) DPP-11, Revision 4, "Dresden Station Quality Control Department - Training and Certification Requirements of Quality Control Inspectors" (20) Dresden Audit Schedule for 1985 (21) CECo Topical Report CE-1-A, 11 Qual ity Assurance Program for Nuclear Generating Stations" Results of Inspection The inspector verified that the licensee had provided.for the indoctrination and training of site personnel on changes to the quality assurance program and administrative control procedures to ensure that suitable proficiency was achieved and maintaine The trainin~ of personnel on revisions to the Dresden administrative procedures (OAP), resulting from changes in quality assurance program (QAP) commitments, was found to be effectively implemented in accordance with the applicable site policie The inspector also attempted to verify that similar requirements pertaining to training on changes to the quality assurance manual
- .
(QAM) were being me During that review, the inspector determined that the licensee had failed to provide the appropriate personnel indoctrination and training within 60 days as required by Procedure No. QP 2-52. Specifically, seven out of ten persons in the site Quality Control (QC) organization and several other persons in 18 other site and production area job classifications had not been apprised of the QAM revisions. This failure to provide for the indoctrination and training of personnel to ensure that suitable proficiency is achieved and maintained is considered in violation of 10 CFR 50, Appendix B, Criterion II (237/85029-02; 249/85024-02). QA/QC Administration Program The inspector reviewed the licensee's Quality Assurance/Quality Control (QA/QC) Administration Program to verify that the (1) QA program documents clearly identify and define those structures, systems, components, parts, materials, items, documents, and activities to which the QA program applies, (2) procedures and responsibilities have been established and implemented for making changes to these items to which the program applies, and (3) licensee periodically reviews the overall effectiveness of the QA progra Documents Reviewed (1)
(2)
(3)
(4)
QAM QP No. 2-53, 11Qua 1 ity Assurance Program for Operations Classification of Structures, Systems, and Components
QAM QP No. 3-3, 11Classification of Systems, Components, Parts and Materials
Dresden Administrative Procedures (OAP) Manual, Copy No. 28 OAP 11-4, 11Control of the Classification List of Safety-Related (SR), Non Safety-Related (NSR) and American Society of Mechanical Engineering (ASME)
Code-Related Systems, Structures and Components
(5)
OAP 11-5, 11Classification of Non Safety-Related (NSR)
Subcomponents/Parts Used On/In Safety-Related (SR)
Systems, Structures and Components
(6)
OAP 11-7, 11Technical Evaluation of Parts Used in Safety-Related Components
(7) Audit Reports:
12-83-51, 12-84-47 (8)
M-11 P&ID Index, dated June 19, 1984 (9)
Three Classification Parts lists:
(a)
SR Electrical Equipment List (b)
SR Masonry Walls (c)
ASME,Section III Valve and Equipment List
(10) As-Built Critical Drawing List of August 14, 1985 Inspection Results The inspector verified that the licensee had appropriate prov1s1ons, procedures, and methods to accomplish the objectives of the QA/QC administration progra During the review the inspector identified that the licensee's classification lists and P&IDs were overdue for their periodic updatin Licensee personnel stated that they had initiated a program early in 1985 to consolidate the lists, that this program was in its final stages and would result in new lists being issued in September 6, 198 Pending the licensee's completion of this consolidation effort this is considered an Unresolved Item (237/85029-03; 249/85024-03). Records The inspector reviewed the records program to verify that it was is in conformance with regulatory requirements, commitments, and industry guides and standard Documents Reviewed (1)
QAM QR No. 17-0, "Quality Assurance Records" (2)
QAM QP No. 17-1, "Quality Assurance Records" (3)
QAM.QP No. 17-51, "Quality Assurance Records for Operations - Control of Station Records" (4)
QAM QP No. 18-51, "Audits for Operations - Quality Assurance Program Audits" (5)
. ( 6)
QAM QP No. 18-52, "Audits and Surveillance of Maintenance, Spare Parts and Inservice Inspection Activities" 1985 Audit Plans for Audits of Document Control, Records, and Reports Inspection Results The inspector verified that the records program activities were in accordance with requirement.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation Unresolved items disclosed during this inspection are presented in Paragraphs 4.c and.
Exit Interviews The inspectors met with licensee representatives (denoted in Paragraph 1)
and summarized the purpose, scope, and findings of the inspectio The inspectors discussed the likely informational content of the inspection report with regards to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents or processes as proprietar