IR 05000430/2005002

Insp Repts 50-454/85-19 & 50-455/85-12 on 850430-0502 & 06-09.Violation Noted:Failure to Provide Adequate Control of Changes to Design Documents

ML20127L865
Person / Time
Site:	Byron, 05000430
Issue date:	05/17/1985
From:	Hawkins F, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127L840	List: IR 05000430/2005002 ML20127L834 ML20127L850
References
50-454-85-19, 50-455-85-12, NUDOCS 8505230109
Download: ML20127L865 (5)

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o U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-454/85019(DRS);50-455/85012(DRS)

Docket No. 50-454; 50-455 License No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: April 30, May 1-2, and May 6-9, 1985 Inspector:

kGhh H. A. Walker f[/')/rf Date (

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Approved By:-

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5 < 7/95

. C. Hawipt Quality As urance Programs Section Uit( /

Inspection Summary Inspection on April 30, May 1-2, and May 6-9, 1985 (Report Nos. 50-454/85019(DRS)

50-455/85012(DRS))

Areas Inspected: Unannounced inspection by one regional inspector of licensee action on previous inspection findings, QA program for startup testing, (Unit 1)

design changes and modifications, and QA program for preoperational testing-(Unit 2). The inspection involved a total of 70 inspector-hours onsit Results: Of the four areas inspected, no violations or deviations were identified in three areas; one violation was identified in the other area (failure to provide adequate control of changes to design documents - Section

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I 8505230109 850517 PDR ADOCK 05000454 e PDR l

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• A~. D. Britton, QA Inspector, Operations

• B. Burkamper, Operations QA Supervisor S. N. Campbell, Office Supervisor ,

• A. J. Chernick, Compliance Supervisor

• D. Flowers, Technical Staff W. Grozsko, Project Engineering Rf G. Gruber, QA Engineer W. Kouba, Shift Control Room Engineer

• J. E. Langan, Technical Staff - Compliance

• D. Pirnat, Technical Staff - Compliance

• R. J. Poche, Technical Staff - Compliance

• R. E. Querio, Station Superintendent D. E. St.- Clair, Technical Staff Supervisor

• R. P. Steder, Technical Staff R. C. Ward, Assistant Superintendent - Administration and Services US NRC

• J. M. Hinds, Jr., Senior Resident Inspector

• K. A. Connaughton, Resident Inspector P. G. Brochman, Resident Inspector Other personnel were contacted as a matter of routine during the inspectio * Indicates those attending the exit meeting on May 9, 1985.

2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (454/84-36-02(DRS)): Instructions for the-licensee's drawing control quarterly audit system were not followe During a previous followup on this item, the inspector had noted one instance where the quarterly audit system instructions were misinter-l preted. During this inspection, the inspector reviewed selected responses from the quarterly audit conducted April 23, 1985, using the revised instruction sheet. The accuracy of the selected responses was verified and no problems were noted. Discussions with individuals involved did not reveal any misunderstandings or misinterpretation (Closed) OpenItem(454/84-40-05(DRS)): Lack of operations and QA experience by site assigned operations QA personnel. The inspector reviewed current personnel assignments- to plant QA and noted that one senior reactor operator with five years QA experience is currently assigned. Other personnel, providing significant applicable exper-

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ience in this area, include (1) one individual with two years QA experience who has completed Westinghouse operator _ license training

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and is currently undergoing Byron specific operator training and (2)

three individuals who have several years previous Navy nuclear ;

operating or maintenance experienc ,

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. L(0 pen) 0 pen It'em (454/84-40-06(DRS)): Lack of a system to ensure that audits.of technical specification requirements are conducte LThe inspector reviewed the matrix which was prepared by QA to ensure audit coverage of technical specification requirements. In comparing-

this matrix to specific technical specification requirements, several inconsistencies were noted. This item will. remain open to allow QA i to: perform a review of'the matrix to ensure its accurac d . (Closed) . Unresolved Item (454/84-40-14(DRS)):. Lack of an adequate trending program. BAP 1250-7 (Deviation Trending. Procedure) wa q revised and reissued for use on April- 23, 1985. Cause code i categories have been-expanded and are now adequate. The inspector ,

- verified that several potential trends have been detected using the - l revised procedur * (Closed) Open Item (454/84-41-03(DRS)): Lack of_ independent verification requirements in plant calibration procedures. The inspector was informed that all plant calibration procedures had

'been revised to include independent verification requirements. The I inspector selected six calibration procedures and-verified that-the requirements were' include f.- (Closed)0penItem(454/84-41-04(DRS)): Lack of independent verifica- ,

tion requirements in plant surveillance procedures.- The inspector was -

informed that all plant. surveillance procedures had been revised to include independent verification requirements. The inspector: selected six plant surveillance procedures and verified that the requirements

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were include . :(Closed).Open Item (454/84-41-05(DRS)): Lack of individual signoffs for independent verification. The inspector noted that the twelve ,

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procedures, reviewed for open items 454/84-41-03 and.454/84-41-04~

required individual signoffs for independent verification.-. '(Closed) Unresolved Item (454/84-44-07(DRS)): Certificates of confor-mance:on emergency diesel generator spare parts did.not certify the

~ parts to the latest issue of the diesel generator specification. In reviewing this item,- the inspector verified that diesel generator spare !

. parts are ordered by specifying part numbers or catalog numbers obtained from the diesel generator parts list which is included in the diesel ge.nerator vendor manual. The original specification is usually noted as a reference. Specification changes which would result.in a

change to a diesel generator part would also result in the issuance of a new part number. As a result, certification of spare or replacement parts to the original specification or later revisions should have no-bearing on the acceptability of the part. The inspector has no additional concerns in-this are _ ____

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During'the review ci this item,-the inspector noted that the Sargent-and Lundy Specification F/L 2742 (Diesel Engine - Generator Sets),

o? 'being used to disposition discrepancy records (DRs) written on diesel

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• ! ', generator spare parts, was not the current issue. Specifically, 22 of these.DR's were dispositioned using Amendment 3 to the specifica-

tion. Amendment.4 had been issued for use on June 4, 198 m This . failure .to ensure that changes to design documents.are properly distributed and used is a violation of 10 CFR 50, Appendix B,' Criterion

'VI.(454/85019-01(DRS);455/84012-01(DRS)).

.The licensee took the following immediate action in this area:

(1) Removed the outdated copy of S&L specification F/L 2742 from us (2)- Reviewed Byron plant specifications in central files.to verify '

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that there.were no other outdated specifications. The inspector was informed that no other outdated specifications were foun (3) Reviewed Amendment 4 to Specification F/L 2742 and deterinine that the dispositions were not affecte The inspector verified that Specification F/L 2742 had been updated-

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to include Amendment 4. Eight specifications were selected from central files and verified as being current. The inspector reviewed a letter from the cognizant engineer to the Assistant Technical Staff Supervisor stating that Amendment 4 had no effect on the spare parts procured from Cooper Energ Actions taken on this item are complete and have 'been appropriately verified. The inspector has no further concerns on this item and it is considered closed. No response to this-item is require . -(Closed)UnresolvedItem(454/84-44-10(DRS)): Inadequate protection- ,

of QA. records being temporarily stored in central files. The inspector

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noted that central files now has a system to ensure that QA records '

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are' provided appropriate protectio :3. : Program Areas Inspected This inspection was conducted to verify compliance with regulatory requirements and operational QA program commitments. The inspection was performed by reviewing applicable procedures and records, conducting personnel interviews-and observing work activities. The inspection

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"results are documented in the'following-sections of the repor ' QA for Program Startup Testing The inspector reviewed the log of audits and surveillances conducted

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on the startup testing program during the past three months. The log indicated that coverage of startup testing was adequate. Five audits were selected and audit records were reviewed. No violations or deviations were note . .-_ _ _ _ _ _ ..____ ,_, __

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- Design Changes'and Modifications The inspector reviewed the implementation of the design change and l modification program. The modifications status log and seven completed safety-related modification packages were reviewed. The temporary alterations . log and a selected sample of safety-related temporary alteration records were also reviewed. The modification program has been properly implemented, and no violations or deviations were note Pre-operational Testing Program Review

- The inspector reviewed QA coverage of pre-operational testing of Unit 2 systems. At the time of the inspection, only six QA audits had been conducted on Unit 2 safety-related pre-operational testing activities. Records of these audits were reviewed, and no violations or deviations were note . Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)

at the Byron Plant on May 9,1985, and summarized the purpose, scope and findings of the inspection. The inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary.

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