IR 05000254/1987030

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Insp Repts 50-254/87-30 & 50-265/87-30 on 871026-1105.One Violation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Implementation of QA Program in Areas of Design Changes & Mod & Maint
ML20237C673
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 12/17/1987
From: Jablonski F, Sutphin R, Tella T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237C648 List:
References
50-254-87-30, 50-265-87-30, NUDOCS 8712220067
Download: ML20237C673 (8)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-254/87030(DRS); No. 50-265/87030(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; No. DPR-30 Licensee:

Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Quad Cities Nuclear Power Station, Units 1 and 2 Inspection At:

Cordova, Illinois Inspection Conducted:

October 26 through November 5, 1987.

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/2//7[f7 Inspectors:

T. Tella Date R. N. Sutphin

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Approved by:

F. J J lonski,' Chief,

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Quality Assurance Programs Date /

Section Inspection Summary Inspection on October 26 through November 5, 1987 (Reports No. 50-254/87030(DRS);

No. 50-265/87030 (DRS)

Areas Inspected :

Routine unannounced inspection by two regional inspectors of licensee action on previous inspection findings, implementation of the QA program in the areas of design changes and modification, maintenance, surveillance (to a reduced scope), and other programs related to these areas.

The inspection was conducted using selected portions of Inspection l

Procedures 25578, 37702, 41400, 56700, 61725, 62700, and 62702.

Results:

One violation was identified:

failure to control software used to verify Technical Specification Compliance (Paragraph 3.C.(4)(b).

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l 8712220067 871217 PDR ADOCK 05000254

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DETAILS 1.

PersonsContacj.ed

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Commonwealth Ed yon Comp 3ny

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  • R. Bax, Station. Manager T. Crippes, Modifications Coordinator
  • D. Gibson, Quality Assurance Superintendent i'

M. Kooi, Regclatory Assurance Supervisor

  • E. Mendenhall, Technical Staff Engineer
  • C, Norton, Quality Assurance Engineer i

L. Petrie, Assistant Superintendent, Maintenance

  • R. Robey, Servires Superintendent (
  • G. Spedl, Assistant Superintendent, Technical Services

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Other personnel were contacted as a matter of routine during the inspection.

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  • Indicates those attending the exit meeting on November, 5 1987.

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2.

Licensee Action on Previous Inspection Findings

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(Closed) Open Items (254/85002-02; 265/85002-02't:

Clarification

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Audits tended to assess procedural compliance rather than ccepllance with the regt iremer.ts of the applicable codes and standards.

g The inspectors reviewed line items and references from aiselection of 16 audits performed during 1987.

Audited items included h;

N requirements from applicable industry codes and standards, NRC documents (Information Notices, NUREGS) and site specific documents y

such as Technical Specifications and procedures.

The inspectors determined that the effectiveness of the audits in addressing

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requirements of applicable codes and standards improved during 1987 Q

and was adequate.

This iten 'is closed.

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(Closed) Open Items (254/86010-C?; 265/86009-02):

Need to identify policy and procedure documents for the review and periodic update

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of the Master Equipment List (MEL).

The licensee was unable to

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identify a specific document that established the program for the-r

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periodic review, update, maintenance, control, and distribution of the MEL.

The inspectors reviewed Station Nuclear Engineering Division (SNED) Procedure Q.12.1, " Classification and Listing of Safety-Related Structures, Systems, Compour.ts, and ASME Section III Components for Dresden and Quad Cities Stations.," Revision 0.

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procedure established the methods for controlling entries to the g

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Safety-Related Classification Lists (5000 Specifically, Exhibit C.1 g

provided for the MEL update for mechancial/ electrical items, Exhibit D provided for structural items, and Exhibit E provided for monthly

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archi bci.-engineer updates.

The inspectors deteruined that the procedure. adequately providev for the periodic review, uodate, and control of the MEL.

This item is closed.

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(0 pen) Violation (254/87009-01; 265/87009-01):

The licensee failed to determine the root cause and take action to prcclude repetition on Licensee Event Reports (LERs) representing signi~icant conditions adverse to quality LER 50-265/86-007 wa:, a resu't of burnt contacts in a coatztor for Unit 2 Core Spray Rooic Cooler, LER 50-265/86-008 was a result of drive helt failures on the 2A Core Spray Room Cooler,

"ard LER 50-265/86-009 Sas a result of a rescat failure of the 2A Core Spray Room Cooler drivo belts.

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Th'e inspecteri reviewed the licensee's rruponse dated May 20, 1987,

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and additionai actions taken by the licensee.

F$ilures of the drive

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belts were determined by the licensee to have Lea caused by the use I

of variable pia 4 grooved pulleys and a misalignment that had developed over a period of time.

The room cooler pulleys have been replaced with fixed pitch pulleys that are expected to eliminate the excessive wuring of the cooler drive belts.

The inspectors consider this action to be satisfactory.

The failures associated with.the pitted and burned auxiliary contacts on the room cooler contactor were determined by the licensee to be caused by the auxiliary contacts hanging up and not allowing the l

contactor to fully close, which resulted in poor electrical contact l

end caused the pitting and burning of the contactor as described in l

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tne LER.

The li w see had reques'.ed SNED to study this problem and I

to recommend corrective actior.

This is licensee action Item l

No '26518086007.

This violation will remain open, pending review l

of the licenseets action.

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(Closed) Violation (254/87009-02; 2E5/87009-02):

The licensee did i

not have a documented procedure for processing and controlling LERs.

i No procedure existed that defined the methods tc be used for the i

investigation, preparation, review, and followup of LERs.

In addition, i

it app. eared that training in LER preparation and review was less than-l admuate. The inspectors m viewed the licensev s response dated l

May 20,-1087, and the new procedures prepared by the licensee as l

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a ;esult of this viola' tion includirig:

QAP 1200-3, " Licensee l

Event Report Investigation and Review process," Revision 1; I

QtP 1200-4, "Licensre Event Report (LER) Preparation ard Format Instruction." Re a is ion 1; and QAP 1200-T4, " Event Cause Codes,"

Revision 1.

In addition to thest new procedures, the licensee developed and presented training on Root Cause Analysir, to members of t e piant Administration, Technical Staff, Quality Asturance, Quali y Control, and Maintenan(e staffs.

The training was completed in Augst 1987.

The inspectors determined this to be an adequate

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response to the violation.

This violation is closed.

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Areas Inspected 2.i,

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Inspection Purpose The purpose of this iw:pection was to determine whether the licensee's

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QA program had been properly implemented in specific programmatic

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area 7 and to assess the licensee's effectiveness in the identification, soltt. ion, and prevention of safety significant problems.

The enforcement history, SALP ratings and LERs were reviewed in i

preparation for the inspection.

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_i Specific a'reas reviewed were design changes and modifications,

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surveillance, and maintenance.

Licensee QA audits, corrective actions, and aspects of records, document control, and calibration

act!vities associated with the above areas were also reviewed.

This i' inh ection evaluated the effectiveness of licensee management i

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involvement and control in assuring quality in the above areas, the Jappmach to resolution of technical issues, and responsiveness to

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/NRC' initiatives, The inspection also assessed licensee staffing,

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. training and qualifications, and compliance with regulatory requirements e.nd QA prdpam commitments.

The inspection was

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accomplished,by observation of work activities, interviews with s'

plant persornel, and review of applicable records and procedures.

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B.t Reference Documents s,

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CE-1-A, "Cononwealth Edison Company Topical Report," Revision 45.

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,\\x (2) QAP 500-1, " Maintenance Department Organization," Revision 8.

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(3) QAP 500-3, " Maintenance Procedures," Revision 5.

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(4) 'QAP 500-6, " Maintenance Records," Revision 1.

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(5) QAP 500-9, "Pleventive Maintenance," Revision 1.

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(6) QAP 500-15,," Conduct of Maintenance," Revision 2.

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' '(?); OAP 1270-1, "'4odif.ication Program," Revision 6.

(8) Qj. No. 3-51, "Desip Control for Operations Plant I,

Modifications," June 30, 1987.

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Q.P. No.12-51, "Certrol of Measuring and Test Equipment,"

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May 18, 1987:

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I (10) Q.R. No. 3l0; " Design Control," June 30, 1987 l'

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Results (1) QA Program Changes Licensee practices in implementing the QA program and its revisions were reviewed.

The licensee's QC department had initiated a computer data base.to verify and follow up on the station procedure revisions incorporating the changes to QA Topical Report CE-1A Revision 45, Quality Requirements, and Quality Procedures.

The licensee technical services department is responsible for the revisions of station procedures and had assigned a procedures coordinator.

No violations were identified.

(2) Design Changes and Modifications (a) The. inspectors reviewed the.following licensee audit reports in the area of design changes and modifications including:

QAA 04-86-22 and 56; QAA 04-87-11 and 52; and QAM 04-86-42.

The inspectors concluded that the licensee had identified several findings in this area and had taken prompt corrective actions.

Management was aggressive in the modification program, for example, a modification coordinator has been assigned to coordinate modification activities.

(b) The inspectors reviewed modification packages, in various stages of completion, including:

M-4-1-83-49; M-4-1-84-33; M-4-1-85-24, 37, 41; M-4-1-86-22; M-4-1(2)-86-12; M-4-2-85-43; M-4-2-86-10 and 16.

The modification packages had been adequately reviewed by in plant safety committee and SNED for adequacy of design and for 10 CFR 50.59 requirements, as required.

Equipment procured for the modifications was verified for 10 CFR 21 applicability.

The modified systems were adequately tested after completion of modifications, and the personnel involved appeared to be adequately qualified.

The modification packages, where modification work was completed in all aspects, generally contained all the relevant documents, except the affected drawings and station procedures which were separately controlled.

No violations were identified.

(3) Maintenance Programs and Routine Maintenance Activity (a) The inspector reviewed a selection of completed maintenance Work Requests (WRs) as follows:

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WRs Q 55458, Q 55492, and Q 55493, as an example of

safety-related equipment failure leading to a plant shutdown and LER 86-004.

WRs Q 56140, and Q 56146, as an example of

nonsafety-related equipment failure leading to a plant shutdown and LER 87-005.

WR Q 55646, as an example of equipment failure leading

to reduced capability of a safety-related system and LER 87-004.

WRs Q 24630, Q 25368, Q 41292, and Q 58308, as examples

of recurring safety-related equipment failures, and LER 87-012.

The inspector determined that maintenance activities associated with the above WRs were performed in accordance with established commitments and procedures.

(b) The inspector noted that the mechanical maintenance department discarded all the previous usage cards of M&TE soon after the receipt of a calibration report.

If a particular M&TE item was out of calibration in a later cycle, the trending of equipment could not be properly evaluated, as the objective evidence of its usage in previous calibration cycles was lost.

Pending further review, this is an open item (254/87030-01; 265/87030-01).

(c) The inspector also noted that the electrical maintenance department did not properly and completely review previous usage of a torque wrench determined after it was used, to be out of calibration.

Evaluation of the usage, as documented on a deficiency report, did not include the permissible tolerance for use of the torque wrench.

Failure to do so may have resulted in applied torque outside the specified limits.

Pending further review, this is an open item (254/87030-02; 265/87030-02).

No violations were identified.

(4) Surveillance (a) The inspector observed three surveillance tests being conducted during the period of inspection including:

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Diesel Generator Startup Test; QOP No. 6600-1,

" Diesel Generator 1(2) Preparation for Standby Operation," Revision 7.

High Pressure Core Injection Test; QOS No. 2300-13,

"HIPCI-Hot Fast Initiation," Revision 1.

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RCIC Pump Operability Test; Q05 No. 1000-2, "RHR

System Pump Operability Test," Revision 11.

The diesel generator startup test and RCIC pump operability test were observed.

The.HPCI test was observed partly during the initial stages of the test.

No major problems were identified by the inspector during these tests.

(b) The inspectors reviewed QA audits of station operation activities.

In a follow-up of the station QA audit of computer program controls, QAA 04-87-27, the inspector noted that the licensee currently uses (since 1982)

computer programs "AN0MVP" and "ANOM", for reactivity anomaly calculations, the results of which were used to satisfy requirements of Technical Specifications Section 3.3.E, " Reactivity Control".

Topical Report CE-1-A, Section 3.1 requires that procedures be established for the control of software.

The licensee developed Procedure Q.P. No. 3-54, " Design Control for Operations-Digital Computers and Software," Revision 1.

The licensee stated that this procedure was not applicable to any previously issued software such as

"AN0M."

As a result, the computer programs "AN0MVP" and

"AN0M" were not controlled by any station or corporate procedure.

No other method, except the programs "ANOMVP" and "ANOM" was used to calculate reactivity anomalies.

The licensee did not provide any other procedural or quality controls to ensure consistency with the design, software security, independent reviews and audits, proper documentation, and configuration management of these computer programs.

Any errors in the results obtained by these computer programs during the period 1982-1987, could have placed the reactor in a condition that exceeded Technical Specification limits.

Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality be prescribed by documented procedures.

Failure to develop a procedure to control the software used for meeting Technical Specification requirements is considered a violation of 10 CFR 50, Appendix B, Criterion V (254/87030-03; 265/87030-03).

One violation was identified.

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Conclusion Management was generally responsive to NRC concerns identified during

previous inspection.

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Management's approach to resolution of technical issues was generally

adequate; however, aggressive involvement is required in the area of

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software control to ensure usage of properly controlled software for quality related activities.

The licensee exclusively uses computer programs "AN0MVP" and " ANOMALY" to calculate reactivity anomalies.

These calculations were considered to be significant because any errors could place the reactors beyond Technical Specification limits.

Management attention is required to control M&TE usage and proper

evaluation of out of calibration equipment.

Except as noted in the areas of software control and M&TE, licensee

performance in the areas of modifications, surveillance, and maintenance was acceptable.

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Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspector, and involves some action on the part of the NRC or licensee or both.

Two open items disclosed during this inspection were included in Paragraphs 3.C.(3)(b) and 3.C.(3)(c).

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Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on November 5, 1987, at the Quad Cities Station and summarized the purpose, scope and findings of the inspection.

The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

The licensee did not identify any such documents or processes as proprietary.

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