IR 05000237/1986005
| ML17199F710 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/28/1986 |
| From: | Hawkins F, Smeenge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199F707 | List: |
| References | |
| 50-237-86-05, 50-237-86-5, 50-249-86-08, 50-249-86-8, NUDOCS 8604020543 | |
| Download: ML17199F710 (8) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION.. III Reports No. 50-237/S6005(DRS); 50-249/86008(0RS)
Docket Nos. 50-237; 50~249 Licenses No.. DPR-19; DPR-25
.Licensee:
Commonwealth Edison Company P. 0. Box 767
- thicago, Il 60690 Facility Name:
Dresd1an Station, Units 2 and 3
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l nspect ion At: * * Dfesden' Site\\ Morri ~>'TL,. ',
lnspect,.i~,n ~~du?teo: J M~~ch 11.-13:, 1986.
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Inspector: * R.. *smeenge
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- Approved By:* F. Hawkins, Chief Quality Assurance Programs Section Inspection Summary Inspection on March 11-13, 1986 (Reports N :237/860~5(DRS);
50-249/86008(DRS))
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Date
Areas Inspected:
(Jrianno!Jnced, routine safety inspection by one -regional inspector of document contro 1,- audit program, 'test a_nd measuring equipment, and QA prog~am annual r~view activitie *
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Results:
No violations or deviations were irlentified.
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8604020543 860328
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.' POR * ADOCK 05000237
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- DETAILS Persons Contacted Commonwealth Edison Company (CECo)
- J. Wujeiga, Production Superintendent R. Flessner, Service Superintendent J. Brunner, Assistant Superintendent, Technical Service
- D. Adams, Compliance Administrator
- J. Doyle, QC Supervisor
- R. Stobert, QA Inspector
- J. Williams, QA Inspector
- R. Potts, Central File Supervisor USN RC
- S. Stasek, Resident Inspector In addition to the above, the inspector interviewed and talked with other licensee personnel during this inspectio *Denotes those attending the exit interview on March 13, 198.
Action on Previous Inspection Findings (Closed) Unresolved Item (237/85029-01; 249/85024-01):
A safety-related snubber load pin was replaced with stock material without prior technical evaluation to determine that the stock material was an acceptable substitute. The licensee committed to review a selected sample of completed modification and maintenance work request packages to provide reasonable assurance that other material or part substitutions had not been installed in safety-related equipment without a technical evaluation for acceptabilit The NRG inspector examined the results of the licensee's review documented in a memorandum to file dated December 27, 198 This memo provided a summary of the documentation reviewed for 42 safety-related modifications (completed between April 1983 and March 1984) and 17 safety-related work requests (completed between January 1983 and June 1983).
The licensee reported the following:
(1)
No material or parts substitution were identified in the work request documentation perio (2) Three modification packages identified part substitution; however, two had documented evidence of a SNED evaluation and approval for the substitution. The third modification identified that the parts ordered and installed were vendor upgrade replacements for the parts identified in the original modification documentatio SNED ordered the vendor upgrade parts for the modification without revising the modification documentatio *
- (3)
Complete documentation for 6 of the 42 modification packages could not be locate.
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During this inspection, the NRC inspector reviewed the vendor upgrade part substitution identified in (2) abov The vendor, Agastat, changed coil insulation in the environmentally qualified (EQ) time delay and auxiliary relays to provide extended life. The licensee did have the necessary documentation (test report data and vendor certi-fications) to support this substitution of EQ equipmen The NRC inspector had no additional concerns regarding this matte The missing documentation for five of the six modification packages identified in (3) above was found in central files under supplemental record The NRC inspector reviewed this information and found it to be satisfactory. During the course of this inspection, the licensee was unable to locate additional documentation for modification Ml2-2-83-l. This modification removed short pieces of one inch pipe that were stubbed into the four inch and eight inch scram discharge header piping in four place The one inch stub openings, on the larger pipes, were then plugge The NRC inspector examined the completed work and by verification of materials from the plug's heat numbers, established that the work had been completed using materials in accordance with the directions of the modification packag Inability of the licensee to locate original work package data for this 1 out of 42 modification packages reviewed is considered an isolated case. Other plant records, such as material heat numbers and welder ID numbers, can be used to substantiate that the modification was completed correctl The NRC inspector had no additional questions in this are (Closed) Violation (237/85029-02; 249/85024-02):
Failure to provide for the indoctrination and training of plant personnel relative to Quality Assurance Manual (QAM) revisions within 60 days as required by Procedure No. QP2-5 The NRC inspector reviewed the training records for the June 5, 1985 (basis for violation), and the November 20, 1985, revisions of the QA The records documented that the delinquent licensee personnel had completed training for the June 5, 1985, revision and that the training had been completed within 60 days for the November 20, 1985, revision of the QA QAM revision training is the responsibility of the individual department The licensee's training department is now responsible for tracking and maintaining records for the completion of this departmental training. The corrective action implemented by the licensee should prevent repeats of this violatio The NRC inspector had no additional questions in this are (Closed) Unresolved Item (237/85029-03; 249/85024-03):
Licensee's Master Classification List (MCL) and P&ID Index updates were overdu The licensee was consolidating these items into a single list which had not been completed at the time of the inspectio The licensee did not resolve this item by providing an updated consolidated list of the MCL and P&ID Inde The MCL has since been updated a number of times with the latest update issued January 30, 198 The P&ID Index was updated September 6, 1985, and is currently on a yearly update schedule. DAPll-4, "Control of the Classification List of Safety-Related (SR), Non Safety-Related (NSR) and American Society of Mechanical Engineers (ASME) Code-Related Systems, Structures and Components," Revision 3, released February 5, 1986, specifically identifies that the P&IDs are not included in the MC The method used to resolve this item is different from the method the licensee identified would be used at the time this item was identified. The results did, however, provide the required updates of the MCL and the P&ID Inde The NRC inspector had no additional questions in this are.
Documentation Control (39702) The NRC inspector verified that the licensee had implemented a quality assurance program for documentation control. Distribution, control of obsolete drawings and incorporation of changes were examined during this inspection. Revisions of drawings on the stick file in the control room were compared with the revisions identified in the central file The following control room drawings were selected for this comparison: (1)
M-355, Revision MR with DCR 85-70 (2)
M-353, Revision W (3)
M-345, Revision AC (4)
M-173, Revision T (5)
M-39, Revision VV with DCR 86-13 (6)
M-35, Sheet 1, Revision BG (7)
12E-2303, Revision H (8)
12E-2313, Revision M (9)
12E-2328, Revision B (10) 12E-2430, Revision AL with DCR 85-135 The drawin9s with a Drawing Change Request (DCR) identified were marked-up (using red ink) to maintain the drawing at the level of the as-built plan The red ink signified that plant changes had been completed; however, a revised drawing had not been release The records in the central file identified that the drawings in the control room had been marked-up to show the DCR The f9llowing discrepancies were noted:
(1)
M-345, the central file drawing was one rev1s1on higher (AD).
This revision added safety flags (notes) on the drawing (2)
M-173, the central file drawing was two revisions higher (U and V).
Revision U was an enhanced drawing (redrawn without change)
and Revision V added safety flags (notes).
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In a discussion with the personnel in central file and the individual responsible for maintaining the control room critical drawing file current, the licensee stated that M-345 and M-173 were in the process of being reviewed by the--modification group prior to distributio These discrepancies were in documentation and did not affect the safety or operation of the plan The NRC inspector noted that the licensee's system for revision identification is uniqu The revision number on the drawing identifies the latest change complete At the time a modification or change is identified, the revision number to incorporate that change is assigned. A number of these pending changes may be identified on the records for the drawing in the central fil When a drawing is revised, the highest revision for completed work is identified on the drawin Work on the lower revisions may not have been completed; however, the change is shown on the drawin The copy of the drawing in the control room is then marked-up, using green ink, to show the lower revision changes which are proposed but the work has not been complete In the interview with personnel from the central file and the individual responsible for the control room critical drawing file, it was evident to the NRC inspector that these individuals understood the syste In late February 1986, the NRC resident inspectors issued a non-response Notice of Violation (237/86001-02(DRP); 249/86001-02(DRP))
for failure to control the issuance of documentation, including changes theret As corrective action for this Notice of Violation the licensee has established a program to evaluate their document control progra Areas to be evaluated are as follows:
(1)
Accurate and timely update of control room drawings as well as other copies of other safety-related drawing (2) Accuracy of the drawing inde {3)
Drawing revisions caused by plant modification which have not been completed and issue of later revisions on the same drawin (4)
Issuance of drawing revised for enhancemen This evaluation has not been complete Pending a NRC review of the procedural changes and implementation of the changes resulting from this licensee evaluation, this is considered an open item (237/86005-0l(DRS); 249/86008-0l(DRS)). Audit. Program (40702)
The NRC inspector reviewed the licensee's audit program to verify compliance with regulatory requirements and QA program commitment Audit records, schedules, auditor qualifications and actions for resolution of findings were reviewe. '
The following audit record packages were selected by the NRC inspector for review:, Station Procedure Controls, Maintenance Activities, Inspection and Test, Jumper and Lifted Lead Control, Calibration-Portable Test Instruments, Station QA Program., Environmental Test Specs/NPDES, Class IE Electrical Environmental Quals, Corrective Action Program All packages were found to be complete. Audits were performed using approved check lists. Items audited, findings and resolutions were documente The qualification and certification records of the auditors and lead auditors performing these audits were reviewe All the lead auditor qualification records had not been updated to show an annual evaluation of the auditor during the last 13 months. *The licensee updated these records with evaluations completed during February 198 The NRC inspector reviewed the three year schedule for licensee audits of technical specification requirements. Audits of these areas had been performed on schedule during 1985 and the schedule identified the 1986 plan for areas to be audite No violations or deviations were identified in this are.
Test and Measurement Equipment (35750)
The NRC inspector reviewed the licensee's quality assurance program for control of test and measuring equipmen Calibration records, identification of calibration status, recalls and the identification of equipment to perform work were reviewed during this inspectio The licensee performs a calibration check of test and measuring equipment prior to use and after the work has been complete Each piece of equip-ment is recalled for calibration traceable to the National Bureau of Standard on a six month or a one year schedul Calibration records for test equipment identified on 11 completed safety-related work request packages were examined by the NRC inspector. All records reviewed were curren Of the 14 pieces of equipment reviewed, only a 0-2000 pound pressure gauge (ID No. BDL-22186) and its associated calibration records could not be locate The NRC inspector interviewed the technician identified on the work reques At the time of use, this gauge was ne *
Its calibration was checked prior to use and later, during the calibration check, was found to have an out-of-tolerance (due to a sticky movement) in the midrang An evaluation of the work performed, using only the high range of this gauge, clearly showed that reinspection was not require Because of the sticky movement, the gauge was removed from plant servic The only reords located for this gauge was a copy of the before and after calibration check found in the work request packag The inspector has no further questions regarding this issu No violations or deviations were identified in this are.
Quality Assurance Program Annual Review (35701)
The NRC inspector reviewed current revisions to Administrative (DAPs),
Maintenance (DMPs) and Quality Program (QPs) procedures which implement the licensee's qualification assurance progra These revisions were reviewed to verify that changes did not alter or violate the docketed quality assurance progra Revisions to the following procedures were reviewed by the NRC inspector: OAP 7-2, "Conduct of Shift Operations," Revision 12, dated January 9, 198 OAP 11-6, "Request for Purchase and Receiving Inspection Guidelines,"
Revision 2, dated January 30, 198 OAP 11-8, "Non-Destructive Testing (In-Service Inspection),"
Revision 3, dated August 19, 198 OAP 12-5, "Control and Disposition of Non-Contaminated Waste Materials," Revision 2, dated January 21, 198 OAP 12-7, "Dresden Station ALARA Program," Revision 2, dated January 7, 198 DAP 13-11, "Station Access," Revision 8, dated October 17, 198 OAP 15-1, "Work Requests," Revision 16, dated January 21, 198 DMP 040-6, "Safety-Related Motor Operated Valve Data and Settings,"
Revision 4, dated December 17, 198 DMP 300-15, "Control Rod Drive Accumulator Disassembly and Maintenance," Revision 1, dated August 1, 198 QP2-2, "Training of Personnel to Meet Quality Assurance Requirements," Revisions of June 5, 1985 and October 20, 198 QP2-53, "Quality Assurance Program for Operations - Classification of Structures, Systems and Components." QP3-2, "Design Change Control." QP4-2, "Eva 1 uation of Contractor's Qua 1 ity Assurance Program,"
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~* QP12-5, "Control of Measuring and Test Equipment for Operations - Portable Test and Measuring Equipment."
No violations or deviations were identified in this are.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involves some action on the part of the NRC or licensee or bot An open item disclosed during this inspection is discussed in Paragraph 3 of this repor.
Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violatio.
Exit Interview The Region III inspector met with the licensee representatives, denoted under Paragraph 1, at the conclusion of.the inspection on March 13, 198 The inspector summarized the purpose and findings of the inspectio The licensee acknowledged this informatio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during this inspectio The licensee did not identify any such documents/processes as proprietar