IR 05000373/1985023

Revised Pages 5 & 10 to Safety Insp Repts 50-373/85-23 & 50-374/85-18,correcting Tracking Numbers

ML20135H917
Person / Time
Site:	LaSalle
Issue date:	09/16/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135H914	List: IR 05000373/1985023 ML20135H913
References
50-373-85-23, 50-374-85-18, NUDOCS 8509250010
Download: ML20135H917 (2)

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10 CFR Part 50, Appendix B, Criterion VI, as implemented by the licensee's Quality Assurance Manual, Quality Requirement states, "A document control-system will be used to assure that documents such as specifications, procedures, instructions, and drawings are reviewed for adequacy and approved by authorized

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personnel...such documents will be distributed to and used at the locations where the prescribed activity is perfomed."

Contrary to the above, measures did not assure that the design change document, Field Change Request 85-123, issued to correct an error in Modification M-1-2-84-136, was distributed to and used at the location where the prescribed activities were perfonned. This is considered to be a violation (374/85018-01C(DRP)). Inadequate Inspection In addition to the error in the _ design drawings, the contractor's-quality control did not have inspection hold points for either electrical or piping connections on any of the 22 instruments replaced by modification M-1-2-84-136, including 2821-N037AA and 2B21-N037AB. Because of the lack of witness points, the adequacy of the installation was not verified against the design documents. Such a verification could have detected the failure to implement the design drawing change or the configuration error of the installatio CFR 50, Appendix B, Criterion X, as implemented by the licensee's Quality Assurance Manual, Quality Requirement 10.1 states, " Quality Assurance inspection and testing will be conducted....at the site during.... modification activities to verify conformance to applicable drawings, instructions..."

Contrary to the above, the program for inspection of activities affecting quality was inadequate and did not verify conformance of the M-1-2-84-136 activity to documented instructions and drawing This is considered to be a violation (373/85023-01D(DRP);

374/85018-01D(DRP)). Inadequate Modification Test Control

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In addition to the problems discussed above, the licensee's opera-tional function test of the instruments, after the completion of the modification, failed to detect the inoperability of 2821-NO37AA and 2B21-NO37AB. The test performed, LIS-NB-204, only verified the

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pennissive and initiation calibration set points and did not

demonstrate the operability of the system in light of the work actually performed by modification M-1-2-84-13 The modification had re-routed the reference and variable legs to the instruments, replaced the instruments with a different manufac-turer component (Static 0-Ring replaced the initially installed Barton), and re-connected the electr' cal connections. The test functionally verified only the instrument and electrical connection In light of the the work actually perfomed, the piping configuration 8509250010 850916 -

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The followup inspection addressing items a. through e. was completed in

Inspection Report 374/8502 The following actions were also to be taken by the licensee after startup

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! Prior to initiation of any further safety-related modifications by a !

contractor, review and revise, as required, the current Quality Control guidance for safety-related modifications in the areas of i i drawing updates, QC hold points, and operability tests, and assure

that the contractor involved has complied with these changes. This 1

[ will be followed by open item (374/85018-03(DRP)).

l By August 1,1985, review all contractor Quality Control programs to I

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assure that program modifications in the areas of updating field !

! drawings, QC coverage during installation, and conduct of adequate '

construction tests are instituted by all . contractors in light of lessons learned during this event. This action will be followed by openitem(374/85018-04(DRP)).

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i Subsequent to the additional problem identified on Unit 1 on July 17, 1985, another Confirmatory Action Letter was issued on July 19, 1985 to address the additional actions to be taken prior to startup of either

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unit:

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, Revie.<theentirelistofDrawingChangeRequests(DCR's)and

! determine those DCR's that have been rejected or cancelled l (373/85023-03(DRP);374/85018-05(DRP)).  ;

i Review all rejected or cancelled DCR's and detennine the status of s j theirdisposition(373/85023-04(DRP);374/85018-06(DRP)).  !

! For those DCR's which have been rejected or cancelled or for which

the dispostion is unknown, verify that critical drawings onsite are j

properly annotated to show the present status of the associated system and/or that drawing aperature cards show they are affected by i

! a DCR. All remaining open DCR's will be reviewed within two weeks :

i of startup. Completion of this action will be tracked as open item

(373/85023-05(DRP);374/85018-07(DRP)). ,

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! Implement a documented review of all EQ work requests prior to

performing the work to ensure that qualification is preserved. This j

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review applies to all EQ work requests initiated subsequent to July ,

19, 1985, and will continue until the maintenance procedures have '

j been updated to reflect EQ requirements. Completion of this action j

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will be tracked as open item (373/85023-06(DRP); 374/85018-08(DRP)).

1 Implement a documented review of surveillances on EQ equipment prior

to performance.to ensure that qualification is preserved. This i review applies to all surveillances on EQ equipment initiated

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subsequent to July 19, 1985, and will continue until the surveillance j procedures have been updated to reflect EQ requirements. Completion j

i ofthisactionwillbetrackedasopenitem(373/85023-07(DRP);

374/85018-09(DRP)).

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