ML17180A975

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Forwards Insp Repts 50-237/94-16 & 50-249/94-16 on 940815- 0916 & Notice of Violation.Violations of Concern Because Two Examples of Post Modification Testing Identified.Concern Also Noted Re Potential Failure of safety-related Equipment
ML17180A975
Person / Time
Site: Dresden  
Issue date: 10/21/1994
From: Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Jamila Perry
COMMONWEALTH EDISON CO.
Shared Package
ML17180A976 List:
References
NUDOCS 9410260084
Download: ML17180A975 (4)


See also: IR 05000237/1994016

Text

Commonwealth Edison Company

ATTN:

Mr. J. Stephen Perry

Vice President

BWR Operations

Executive Towers West III

1400 Opus Place, Suite 300

Downers Grove, IL

60515

Dear Mr. Perry:

October 21, 1994

This refers to the system based instrumentation and control inspection (SBICI)

conducted by Mr. D. S. Butler and others of this office from August 15 through

September 16, 1994.

The inspection included a review of activities authorized

for your Dresden Nuclear Power Station, Units 2 and 3. This inspection

focused on the design and configuration of selected instrumentation and

control systems and components.

We discussed our inspection findings with

Mr. E. D. Eenigenburg and others of your staff at the conclusion of the

inspection on September 16, 1994.

Areas examined during the inspection are identified in the report.

The team

assessed the design, implementation, and engineering and technical support

(E&TS) relative to selected instrumentation and control (I&C) systems.

The

inspectors selectively reviewed the setpoint program, design calculations,

relevant procedures, representative records, installed equipment, and

interviewed engineering and technical support staff.

The team considered the design and operation of the I&C systems reviewed and

I&C engineering technical support to be adequate.

The team identified several

positive attributes. The most notable was that the recent setpoint

methodology used was technically sound and reflected current industry

practices.

The team identified weaknesses in I&C design control, specifically setpoint

calculations.

In addition, the team noted that efforts in ensuring the proper

integration of design, construction and system engineering in the I&C area

appeared minimal.

Ownership of I&C systems, including system design, was not

well defined due to ineffective communication and weak interaction between the

various engineering departments.

One noticeable consequence of this lack of

integration was the observed slow progression from program conception to

implementation of engineering initiatives. For example, engineering was slow

in identifying and correcting performance problems with the Yarway level

switches.

In addition, following the exit meeting, it was brought to the

team's attention that Dresden's instrument and control mechanics (IMs) had

altered safety related air line routings during field installations. The IMs

did not notify engineering about the changes.

The failure to follow approved

installation drawings could have resulted in safety related equipment failure.

This concern is under review by the resident staff.

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9410260084 941021

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Addressees -

Lette~ Dated

October 21, 1994

cc w/encls: J. C. Brons, Vice President

Nuclear Support

T. Nauman, Acting Station Manager

Unit 1

E. 0. Eenigenburg, Station

Manager, Unit 2

R. Bax, Station Manager

Unit 3

P. Holland, Regulatory Assurance

Supervisor

D. Farrar, Nuclear Regulatory

Services Manager

Richard Hubbard

Nathan Schloss, Economist

Office of the Attorney General

State Liaison Officer

Chairman, Illinois Commerce

Commission

Distribution:

Docket File w/encl

PUBLIC IE-01 w/encl

OC/LFDCB w/encl

DRP w/encl

RI II PRR w/encl

RI, Dresden, LaSalle,

Quad Cities w/encl

LPM, NRR w/encl

J. S. Perry

2

October 21, 1994

During this inspection, certain of your activities were in violation of NRC

requirements, as specified in the enclosed Notice. This violation is of

concern because two examples of inadequate post modification testing (PMT)

were identified. The first example involved unverified PMT acceptance

criteria that was not based on applicable design documents.

The second

example involved a testing method that failed to detect other relay contact

success paths (parallel contacts) during testing.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In your

response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence. After reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

We also

request that you respond in writtng to inspection followup items

237/249/94016-01, -04, -05, -06, and -07 in this report.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter, its enclosures, and your response to this letter will be placed

in the NRC Public Document Room.

The respenses directed by this letter and the accompanying Notice are not

subject to the clearance procedures of the Office of Management and Budget as

required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

/s/ D. S. Butlei (for)

G. C. Wright, Chief

Engineering Branch

Docket No. 50-237

Docket No. 50-249

Enclosures:

1. Notice of Violation

2.

Inspection Reports

No. 50-237/94016(DRS);

No. 50-249/94016(DRS)

See Attached Addressees

SEE ATTACHED CONCURRENCES

DOCUMENT NAME:

G:DRE94016.DRS

T

ive a copy of this document, indicate in the box: 'C = Copy without attachmentjenclosure 'E" = Copy with attachment/enclosure N" = No copy

E

RIII :DRS

RI II :DRS

RIII:DRS

RIII :DRP

Butler kjc

Winter

Gardner

Hiland

10/ /94

10/ /94

10/ /94

10/d-1 /94

OFFICIAL RECORD COPY


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--

J. S. Perry

2

October 21, 1994

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In your

response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence. After reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

We also

request that you respond in writing to inspection followup items

237/249/94016-01, -04, -05, -06, and -07 in this report.

Following the exit meeting, it was brought to the team's attention that

Dresden's instrument and control mechanics (IMs) had altered safety related

air line routings during field installations. The IMs did not notify

engineering about the changes.

The failure to follow approved installation

drawings could result in safety related equipment failure. This concern is

under review by the resident staff.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter, its enclosures, and your response to this letter will be placed

in the NRC Public Document Room.

The responses directed by this letter and the accompanying Notice are not

subject to the clearance procedures of the Office of Management and Budget as

required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

Docket No. 50-237

Docket No. 50-249

Sincerely,

G. C. Wright, Chief

Engineering Branch

Enclosures:

1.

Notice of Violation

2.

Inspection Reports

No. 50-237/94016(DRS);

No. 50-249/94016(DRS)

See Attached Addressees

DOCUMENT NAME:

G:DRE94016.DRS

TJ

ive a copy of this document, indicate in the box: "C' = Copy without attachment/enclosure "E' = Copy with attachment/enclosure "N' = No copy

RIII:DRS

RIII:DRS

II RIII :DRS

RIII:DRP

RIII :DRS

Butler kjc

Winter "'RW

Gardner /A I'

Hiland

Wri ht

10/[M/94

10/.Zo/94

10/tu/94

10/ /94

10/ /94

OFFICIAL RECORD COPY


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