ML17177A645
| ML17177A645 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/15/1992 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hubbard R MHB TECHNICAL ASSOCIATES |
| References | |
| NUDOCS 9209220253 | |
| Download: ML17177A645 (6) | |
See also: IR 05000237/1991036
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
Docket No.
50-237
License No. DPR-19
MHB Technical Associates
ATIN:
Mr. Richard Hubbard
Vice President
1723 Hamilton Avenue, Suite K
San Jose, CA, 95125
REGION Ill
7H AOOSEVEL T ROAD
GLEN ELLYN, ILLINOIS 50137
SEP 1 5 1992
References: 1)
Letter from MHB Technical Associates to NRC Region III dated
February 18, 1992, Concerning NRC Inspection Report
50-237/91036(DRP)
2)
3)
Dear Mr. Hubbard:
Letter from NRC Region III to MHB Technical Associates dated
March 13, 1992, Providing Interim R~sponse
Letter from MHB Technical Associates to NRC Region III dated
September 3, 1992, .Concerning Final Response to MHB's Letter
of February 18,1992
In Reference 2 we advised you that we would provide our complete response to
your co11111ents once we had completed our review. This letter provides our
response.
Our Inspection Report (50-237/91036),*and its cover letter, should have more
clearly reflected that some of the issues discussed in the report were stHl
being pursued. At the time of your letter, we were continuing inspection *
effort to address the issues in the unresolved item mentioned in the
. inspection report. The issues requiring 110re review were (1) Co11111onwealth
Edison Company's (the licensee's) completion of a 10 CFR Part 21 review, and
subsequent NRC review, (2) NRC review of the licensee's corrective actions
program, and (3) NRC review of the licensee's calculational controls program.
These issues encompassed two of your conments.
Ve also performed a more
intensive review of the other weaknesses identified in the inspection report
to determine if violations of quality assurance requirements existed. The
results of our further review were discussed in Inspection Report
50-237/92009(DRP); 50-249/92009(DRP) (Enclosure 2).
The three issues mentioned above were left as an unresolved item because more
information was.needed in order to determine whether or.not they were
.. violations. Therefore, it would have been premature to issue violations with
Inspection Report 50-237/91036. However, as previously stated, clearer
wordingc should have ,been used~ -in_Jnspection_ Repo.rt 59::-?17 /~lO~~ ~n-~. its cover
letter to--indicate that the NRC was not finished with its review: * - *
9209220253 920915. -- -- .
PDR . ADOCK 05000237
.
G
- .
..
MHB Technical Associates
2
SEP.1 5 1992 *
Inspection Report 50-237/92009(DRP); 50-249/92009(DRP) stated that portions of
- the unresolved item involved apparent violations of NRC requirements. Those
concerns, and others, were discussed with the licensee in an enforcement
conference held June 4, 1992. Following the enforcement conference, NRC
evaluated the safety significance and characterization of the apparent
. violations,* including those referenced in your letter. The results of our
deliberations are contained .in our letter to the licensee transmitting a
Notice of Violation dated September 2, 1992. A copy of that letter is also
enclosed (Enclosure 3).
The remainder of your conments were again reviewed to determine if we had
overlooked any issue.
We found that they all were addressed, as documented in
Enclosure 1 to this letter. Finally we reviewed the issues raised by your
conments as contributors to the low pressure coolant injection (LPCI) system
inoperabil ity. Our final determinat.ion was that, even 1f these issues had not
occurred, the reactor recirculation valve VOTES trace would have been
misinterpreted, resulting in the LPCI 1noperability. The root cause of the
LPCI tnoperability was vendor-supplied training inadequacies on the motor-
operated-valve (MOY) testing system being used, due to the emergent nature of
MOY testing methodology. This resulted in misinterpretation of the reactor
recirc_ulation valve's unusual diagnostic test data. Therefor,, none of the . . .
. issues discussed in your letter were considered to be contributors to the LPCI
inoperability.
If you have additional questions, please do not hesitate to call.
Enclosures:
1. Detailed Discussion
of MHB Technical
Associates Conments
2. Inspection Report
50-237/92009(DRP);
50-249/92009(DRP)
3. Cover Letter Transmitting
See Attach~d D1str1but1on
Sincerely,
µ(hi._
Brent Clayton, Chief
Reactor Projects Branch 1
-*
. .
- ' *
MHB Technical Associates
cc w/enclosures:
C. Reed, Senior Vice President
D. Galle, Vice President, BWR
Operations
T. Kovach, Nuclear Licensing
Manager
C. Schroeder, Station Manager
R. Radtke, Regulatory Assurance
Supervisor
DCD/DBC (RIDS)
OC/LFDCB
Resident Inspectors, Dresden-
LaSalle, Quad Cities
J. Mccaffrey, Chief, Public
Utilities Division
R. Newmann, Office of Public
tounsel, State of Illinois Center
Licensing Project Man~ger~ NRR
State Liaison Officer
C. J. Paperiello, Rill
SEP 1 5 1992
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- '.
.*.
Enclosure 1
Detailed Discussion of 1118 Technical Associates CClllllents
(a)
failure of the licensee to maintain records documentirig statipn *and-
corporate personnel qualification to NOD-MA.I nquirements.
.
(b)
- As discussed in Inspection Report 237(249)/92009, section lO~A. records
documenting station personnel qualification to NOD-MA.I requirements
. were available, and satisfied the requirements of the C011111onwealth
Edison quality assurance program. Similar records were not available
for corporate personnel, as identified in the licensee's internal audit.
Criterion II *Quality Assurance Program* to 10 CFR Part 50, Appendix B,
requires that the quality assurance program provide for indoctrination
and training of personnel performing activities affecting quality, as
necessary to assure that suitable proficiency ts achieved and
maintained. The failure of the corporate office to maintain records of
motor-operated valve training to assure that suitable proficiency was
achieved and maintained was in violation of Criterion II requirements.
"owever the violation met the requirements specified in Section Y.6.1 of
the 1991 Enforcement Policy, in that it was identified by the licensee,
was of minor safety significance because the personnel were adequately
trained, was isolated, an~ actions were taken to correct the violation *
Therefore, the violation was not cited.
Use of a non-safety-related consulting service to perform safety-related*
work.
As discussed in Inspection Reports 237/91036 and 237(249)/92009; the
contract to procure engineering services of a motor operated valve
industry expert was let as a non-safety-related contract. Criterion IV
- procurement Document Control* to 10 CFR Part 50, Appendix 8, requires
in part that measures.be established to assure applicable requirements
necessary to assure adequate quality are suitably included or referenced
in documents for procurement of services. The procurement of
engineering services via a non-safety-related contract fi11ed to assure
that the applicable requirements necessary to assure quality were
included in the procurement document, and was in violation of the
requirements of Criterion IV.
.
- The inspectors concluded.that the actual procurement of the contract as*
non-safety-related did not affect the quality of the engineering
services in regard to the reactor recirculation valve. This was because
the contractor involved was a recognized industry expert and the *
contract was treated in accordance with the contractor's approved
Quality Assurance Program. Therefore, the violation met the
requirements specified in Section Y.A of the 1991 Enforcement Policy, in
that the violation was of minor safety significance, was isolated, and
the contract was reissued as safety-related prior to the end of the
inspection. Therefore, the violation was not-c1-ted.
- ' *
Enclosure 1
(c)
Neither the work package nor the testing procedure delineated anv
quantitative or gualttatiye acceptance criteria related to the YOTES
diagnostic. the as-foynd or as-left torque switch settings. pr the yalye
thrust windows.
.
(d)
As part of the review documented in Inspection Report 237(24)/92009, the
inspectors looked into how motor-operated-valve torque switch settings
were set. The inspectors determined that no value for torque switch
settings ts normally provided, rather the torque switches were adjusted
to obtain a desired thrust value. This desired thrust value was
obtained as output from the VOTES traces, which used calculated target
thrust values, obtained from the corporate engineering office. The work
package contained target thrust values to be used, along with a letter
from the corporate engineering office stating that use of thrust values
outside the target values required corporate approval. *Additionally, *
the test package contained qualitative testing criteria that the valve
was to be stroked to the full open and full closed positions *.
Therefore, the inspectors concluded that quantitative acceptance
criteria, in the form of target thrust values, and qualitative
acceptance criteria, in the fonn of valve. stroking, were contained in
the work package, and that Inspection Report 237/91036 overstated the
lack of acceptance criteria. Criterion V *Instructions, Procedures, and
Drawings* to 10 CFR Part 50, Appendix B, requires in part that
instructions,. procedures, or drawings include appropriate quantitative
or qualitative acceptance criteria. This requirement was met in this
case, and no violation occurred.
The MOY coordinator's concerns about select1nq the zero point on the
yalve and use of industry expert seryices were not documented.
As discussed in Inspection Report 237(249)/92009, the test engineer
failed to follow the requirements of a Dresden administrative procedure
which could have been interpreted to require documentation of the valve
anomalies and the use of a consultant in determining the final thrust *
values to be used.
Criterion V *Instructions, Procedures, and Drawings* to 10 CFR Part 50,
Appendix B, requires in part that activities affecting quality be
documented in instructions, procedures, or drawings, and accomplished in
accordance with these instructions, procedures, or drawings. The
administrative procedure required that the engineer document any
discrepancies encountered during the VOTES test. Although the engineer
bad trouble reading the VOTES trace, and enlisted the aid of an outside
consultant, this was not documented as required by the procedure. 'This
was in violation of the requi.rements of Criterion V.
2
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Enclosure 1
The failure to document the problems encountered during the VOTES test
occurred in December 1990, a time when Connonwealth Edison recognized
that there was a problem with adherence to administrative procedures,
because of previous NRC violations, and was taking steps to correct
them.
For this reason, and because the actual failure was of *inor
safety significance, this item met the requirements of Section V.G.2 of
the 1991 Enforcement Poltcy, and no violation was cited.
(e) Failure to document reanalysis of YOTES tests by the corporate Nuclear
Engineering Deoartment and failure to coQ1Dunicate to the station that
discrepancies were identified and bow they were resolved.
(f)
As discussed in Inspection Report 237(249)/92009, several deficiencies
were identified in the method that the corporate Nuclear Engineering *
depart~nt handled nonconfonning conditions on the motor operated valve
program. This item, and the following one, were considered for
escalated enforcement and were discussed in an enforcement conference
with the licensee on June 4, 1992.
Following.the enforcement conference, NRC deliberated on the.safety
significance of the items'and.determined that the root cause of the
violations was the lack of a procedure addressing the motor-operated
valve program. Therefore the NRC determined that the requirements of
10 CFR Part 50, Appendix 8, Criterion V, *instructions, Procedures, and
Drawings* were not met, .and a violation was issued accordingly.* This
conclusion was documented in a letter to the ltcensee dated September 2,
1992; which transmitted a Notice of Violation (Enclosure 2).
. ..
NED failed to document torqyi switch adtystment calculations for safetv~
related yalyes.
As stated above, this issue was considered for escalated enforcement and
was discussed with the licensee in the June 4, 1992, enforcement
conference. Following the conference, NRC determined .that the root
cause of the failure to document the adjustment calculations was again a
procedural deficiency. Therefore, this item was included in the
violation.of 10 CFR Part 50, Appendix 8, Criterion Y described above.
Finally, your letter stated that these violations contributed to the
. tnoperability of the low pressure coolant injection (LPCI) system for $even
110nths. Our final determinatton was that, even tf the minor violations had
not occurred, the reactor recirculation valve VOTES trace would have been
misinterpreted, resulting tn the LPCI tnoperability. The root cause of .the
LPCI tnoperability was vendor-supplied training inadequacies on the motor-
operated-valve (MOV) testing system being used, due to the emergent nature of
MOV testing technology. This resulted in misinterpretation of the reactor
recirculation valve's unusual diagnostic test data. Therefore, none of the
issues discussed to your Jetter were considered to be contributors to the. LPCI
tnoperability.
3