ML112211045
| ML112211045 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 08/09/2011 |
| From: | James Keppler NRC/RGN-III |
| To: | Arnold D Iowa Electric Light & Power Co |
| References | |
| Download: ML112211045 (12) | |
Text
UNITED STATES CENTRAL FILES NUCLEAR REGULATORY COMMISSION REGION 1I 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 Iowa Electric Light and Power Do cket No. 50-331 Company ATTN: Mr. Duane Arnold, President IE Towers P. 0. Box 351 Cedar Rapids, Iowa 52406 Gentlemen:
This acknowledges your letters dated July 28, 1976, September 1, 1976, and September 7, 1976, informing us of the steps you have taken to correct the noncompliance, deviation, and other items requiring further management attention which we brought to your attention in our letter dated July 12, 1976.
We wish to emphasize that we continue to be concerned with the quality of your Quality Assurance Program and its ability to solve, in a timely manner, the problems occurring at the Duane Arnold site. Due to the general nature of your response, we will examine, in depth, during subsequent inspections your detailed procedures covering the scope and implementation of
- 0 the audit program to determine that they are consistent with the regulatory requirements and your commitments.
We will gladly discuss any questions you have concerning this inspection.
Sincerely yours, James G. Keppler Regional Director cc: Mr. G. G. Hunt, Chief bcc wiencls:
Engineer Central Files Mr. Lee Liu, Vice Reproduction Unit NRC 20b President - 'Engineering PDR Mr. J. A. Wallace, Vice Local PDR President - Generation NSIC TIC 0 \UT/04 ,
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IOWA ELECTRIC LIGHT AND POWER COMPANY General Q/jfice CEDAR 1APIi)S,IoWA September 7, 1976 IE-76-1319 Mr. Gaston Fiorelli ,Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re: Duane Arnold Energy Center
Subject:
Response to letter from G. Fiorelli to D. Arnold dated July 12, 1976 Ref: 1) Letter IE-76-1150 to G. Fiorelli from L. Liu and J. Wallace, same subject, dated July 28, 1976
- 2) Telecon to J. Wallace from R. Knop on August 13, 1976 File: Q-72, Inspection Report 76-15
Dear Mr. Fiorelli:
In response to the concerns of the reference (2) telecon, the following information is submitted. The captions below are the same as in the NRC IE Inspection Report 76-15 and are followed by information that is in addition to that submitted in the reference (1) letter.
C. Deficiencies When a functional audit is performed, the documents ( in cluding Directives) that provide the criteria for the function being audited are reviewed prior to applying them to the activity involved. Relating Directives to higher echelons of documentation and lower levels of do cumentation and a function/activity is an ideal set of circumstances to verify if a Directive is adequate to perform its function in the particular spectrum of docu ments. As the functional audit continues, it would be determined if the lower echelon documents and activities complied with the Directives.
There is no current plan to delete any Directives. How ever, in the event that in the unforeseen future we do consider it to be practical to delete a Directive, all the Directive contents of consequence or substance will be incorporated into one or more Directives.
SEP 9 1976
Mr. G. Fiorelli ' September 7, 1976 Management Interview Concern No. 1 The establishment of an audit plan scheme as prescribed by ANSI N45.2.12 - 1974 will enhance the scope of each audit and give a mechanism to help assure that appropriate areas are included in one or more audits. This formalized plan will take into account the requirements of the Directives on the matter of audit scope, in addition to other matters.
The audit plan will contain provisions to cause the auditor to be sensitive to the need to try and determine the generic con cern or problem and the generic cause of each finding.
Management Interview Concern No. 2 The audit plan scheme and procedural instructions will give the auditor guidance on the direction of his efforts to help obtain meaningful results.
Subsequent to the auditor's efforts to determine the generic con cern or problem and the generic cause, his findings will be re viewed and sdrutinized by the Quality Assurance Manager as a further step to try and determine the source of each problem.
Sincerely yours, Lee Liu Vice President-Engineering LL:D cc: D. Arnold J. Wallace L. Root G. Hunt G.. Cook H. Rehrauer Eo Hammond J. Newman 01
. IOWA ELECTRIC LIGHT AND POWER COMPANY General Qf/uee CEDAR RAT'IDS. IOWA JAM:- A. WALLACE September 1, 1976 VICE PRSIDENT- GENERATION Mr. James G. Keppler, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Response to phone call from Dick Knop to James Wallace on August 13, 1976 File: A-110b, Inspection Report 76-15
Dear Mr. Keppler:
This letter is in response to Mr. Knop's request for a review and revision to our response dated July 28, 1976 to Inspection Report 76-15, Infraction Items B.1 and B.2.
Mr. Knop commented on our failure to address the inspector's find ing that additional emphasis must be placed on adequate review by supervisory personnel to ensure that the startup checklists are sufficiently completed with valid information prior to authorizing startup. To meet this require ment, all Shift Supervising Engineers shall be reinstructed to follow the procedural instruction for completing the checklist and to give it a thorough review prior to signing it off as being completed. In addition, the startup checklist instructions shall be revised to require the Shift Supervising Engineer to review all the checklists for proper completion prior to signing the Ready for Startup signature block. These corrective actions shall be completed by October 1, 1976.
In addition to the above revisions to our inspection report reply, our commitment to ensure that all valves required to be locked are actually locked has been revised by a phone call from Bob York to Dick Knop. There are valves within the drywell and in high radiation areas which cannot be in spected at this time. The valves inside the drywell will be inspected the next time the drywell is purged and the valves in high radiation areas will be inspected when the radiation levels decrease sufficiently to allow entry.
SEP :3 1976
Mr. James G. Keppler September 1, 1976 It is our understanding that Mr. Lee Liu will answer the comments Mr. Knop directed to the Engineering Department.
Very truly yours, J. A. Wallace President-Generation JAW/MS/ar c.c. Mr. D. Arnold Mr. L. Liu Mr. L. Root Mr. G. Hunt Mr. E. Hammond Mr. H. Rehrauer Mr., G. Cook 0
IOWA ELECTRIC LIGHT AND POWER COMPANY General Q2ffice CEDAR RAPIDS. IOWA July 28, 1976 IE-76-1150 Mr. Gaston Fiorelli, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re: Duane Arnold Energy Center
Subject:
Response to letter from Gaston Fiorelli to Duane Arnold dated July 12, 1976 File: A-110b Inspection Report 76-15
Dear Mr. Fiorelli:
This letter is in response to your letter of July 12, 1976 con cerning an inspection of activities at the Duane Arnold Energy Center con ducted on June 9-11 and 15, 1976. The following responses indicate the actions which have been or shall be taken to correct the infractions, defi ciencies, deviations, and other items noted in your letter when appropriate.
Infraction No. 1 Contrary to Tecinical Specifications, Section 6.8.1, the licensee failed to adhere to plant operating procedures as follows:
- a. Certain items of the Plant Prestartup Master Checklist were not complied with during the startup after refueling in April 1976.
Response
- 1. Corrective action taken and results achieved.
Not applicable
- 2. Corrective action to be taken to avoid further noncompliance.
The Prestartup Master Checkoff List shall be revised to correct the discrepancies noted in the inspection report.
In the event a startue is required prior to the completion of the corrective action, temporary procedures shall be issued to prevent further noncompliance. All operators shall be reinstructed to adhere to plant operating procedures.
AUG 5 1976
Mr. G. Fiorelli IE-76-1150 Page 2
- 3. Date when full Compliance shall be achieved.
Corrective actions shall be completed by September 1, 1976.
- b. Contrary to Operatinq Instruction (01) 53, the sodium pentaborate tank sparging valve (V-24-11) was found unlocked.
Response
- 1. Corrective action taken and results achieved.
The operators were made aware of the infraction and the valve was immediately locked.
- 2. Corrective action to be taken to avoid further noncompliance.
An inspection of all locked valves was made prior to the next startup and several other valves were found to be unlocked.
All valves were in-,pected and verified to be in the locked position. All operators will be instructed to adhere to plant operating procedures when operating systems and valves.
- 3. Date when full compliance shall be achieved.
The corrective action will be completed by September 1, 1976.
Infraction No. 2 Contrary to Technical Specifications, Table 4.1-1, functional testing of the APRM Flow Bias was not perf'ormed within the specified period prior to startup on April 15, 1976.
Response
- 1. Corrective action taken and results achieved.
Not applicable
- 2. Corrective action to be taken to avoid further noncompliance.
Startup Checklist Table II.E.8 shall be revised to clearly indicate the period of time prior to a startup that a previously run surveillance test: orocedure shall be considered valid.
- 3. Date when full compliance shall be achieved.
The revision of Table II.E.8 shall be completed by September 1, 1976.
Mr. G. Fiorelli IE-76-1150 Page 3 Infraction No. 3 Contrary to 10CFR5O, Appendix B, Criterion V, the licensee failed to adhere to the Administrative Control Procedure for Jumper and Lifted Lead Control (ACP 1404.6) in that on May 3, 1976 the leads to a Main Steam Line High Temperature sensor were lifted without proper documentation in the Jumper and Lifted Lead Log Book,
Response
As stated in your letter of July 12, 1976 paragraph D of the Site Management Interview, this item of noncompliance was identified and corrected by the licensee; therefore, no further response is required.
Deficiency No. 1 Contrary to 10CFR50, Appendix B, Criterion V, the licensee failed to adhere to Quality Assurance Directive 1318.2, paragraph 5.1 in that audits of corrective actions (QAD 1316.1) and Plant Investigations and Reporting Ac tivities (QAD 1316.2) have not been performed as required.
Response
Subsequent to implementation of QA Directive 1318.2 it became evident that auditing on a directive basis as implied in paragraph 5.1 was impractical and was not the most efficient way to function.
The applicable directives have been, and will continue to be, re viewed as. part of the preparation for, and during performance of, functional audits. For this reason the requirements of paragraph 5.1 of QAD 1318.2 will be revised to present this philosophy. This revision should be completed by November 1, 1976.
Deviation No. 1 Contrary to the Duane Arnold Final Safety Analysis Report, Appendix D, Amendment 7 and Amendment 10:
- 1. The licensee failed to conduct quality assurance audits in the prescribed areas at least twice per year.
Response
As a result of experience gained during the initial phase of plant operation it became apparent that the audit frequency indicated in the FSAR was not practical or reasonable. The plans presented in
Mr. G. Fiorelli IE--76-1150 Page 4 the FSAR were prepared well in advance of plant operation and the audit frequency was subsequently changed to once a year to permit a more indepth investigation of more functions. The FSAR was not revised at the time due to lack of knowledge regarding the require ment to amend the QA Program material. The FSAR Amendment 10 and the QAD 1318.2 will be revised to indicate an annual audit fre quency. QAD 1318.2 should be revised by November 1, 1976 and the FSAR Amendment 10 should be revised by January 1, 1977.
- 2. The licensee failed to prepare Quality Assurance Directives for all the subjects listed in the FSAR.
Response
The series of fifty-one directive titles currently in the FSAR was prepared in advance of plant operation and subsequent activity revealed that the FSAR contained redundant and/or ill defined titles and also failed to present pertinent titles of directives that have been established. A study is underway at the present time to determine which titles should be presented in the FSAR as requiring the preparation of Quality Assurance Directives. Sub sequent to this study, the FSAR will be revised by January 1, 1977.
Directives shall also be prepared for each title in the revised series.
- 3. The licensee failed to include planned audits for several subjects committed to in the FSAR.
Response
- a. Report Detail Paragraph 6.b.(2).(a) and (b)
A study is underway to formulate a current list of audit topics for inclusion in the FSAR. This list should be developed by September 1, 1976 for inclusion in an FSAR change submittal which is expected to be submitted before January 1, 1977.
- b. Report Detail Paragraph 6.b.(2).(c)
This list will indicate those subjects which will be audited on a calendar basis and those subjects that will be audited on a periodic basis dependent on plant activities.
Mr. G. Fiorelli IE-76-1150 Page 5
- c. Report Detail Paragraph 6.b.(2).(d)
The FSAR Amendment 7 response to question D1.7 (on page 7-D1o7-1) was intended to convey the message that the QA staff would review instructions, procedures, and drawings for inclusion of activities affecting quality, and assure that these requirements are being implemented, during the course of func tional orientated audits. The concept of auditing procedures per se is inefficient since without reviewing the spectrum from requirements to accomplishments, determination of inclu sion of activities affecting quality lacks an adequate base.
Accordingly, the FSAR will be revised to clarify that instruc tions, procedures, and drawings have been, and will continue to be, reviewed as part of the preparation for, and during the performance of, functional audits. The response to question D1.7 will be revised by January 1, 1977.
Management Interview Concern No. 1 Scope of audits including those areas not presently being reviewed.
Response
Corporate Quality Assurance has plans to implement and use the Audit Plan concept as presented in ANSI N45.2.12-1974. This ap proach will systematically provide for determining the scope of the audits and areas to be audited. The Audit Plan Preparation Procedure will be initiated no later than during the fourth quarter of 1976.
Management Interview Concern No. 2 Review the audits and ensure that the findings and recommendations are ade quately defining the problems and proper corrective actions are being develop ed to solve the problems.
Response
More attention will be given by the individual auditor and his supervision to define the underlying problems and to analyze the proposed corrective action to better assure an adequate solution.
Management Interview Concern No. 3 Provide a quality assurance training program which includes all personnel with quality assurance responsibilities.
Mr. G. Fiorelli fE-76-1150 Page 6.
Response
- 1. Corporate Quality Assurance Training Program Quality Assurance training is planned for all levels of per sonnel associated with DAECO Quality Assurance personnel attend out-of-Company training courses to perfect their parti cular areas of responsibility and audits under surveillance.
Engineering support people attend training seminars conducted yearly.
- 2. DAEC Quality Assurance Training Program
- a. Quality Department Training The Quality Department has a training program for its personnel which has been in existence for two years and is fully documented and satisfies NRC requirements.
- b. Training of all other department personnel.
A quality assurance training program shall be incorporated into the training program already committed to in the re sponse to Infraction B.1 of Inspection Report 76-01.
Management Interview Concern No. 4 Provide a visible evaluation of the program effectiveness including indicators of quality trends. Evaluation of unfavorable trends should specify corrective actions on a generic basis.
Response
Plans are being studied relative to the development of a QA Program Evaluation Procedure. Existing events and activity reporting docu ments will be utilized to generate statistical data upon which to evaluate effectiveness. This activity will be corporate QA func tion. The procedure will be developed and implemented by January 1, 1977.
> a Sincerely yours, Lee Liu James A. Wallace Vice President-Engineering Vice President-Generation
. cc: See attached
-Mr. G. Fiorelli IE-76-1150 Page 7 cc: D. Arnold L. Liu J. Wallace L. Root G. Hunt G. Cook H. Rehrauer E. Hammond J. Newman 0.