ML19324B719
| ML19324B719 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities |
| Issue date: | 10/26/1989 |
| From: | Galle D COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1902B, NUDOCS 8911080075 | |
| Download: ML19324B719 (3) | |
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Commonwealth Edison QD F
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22710 206 Avenue North Cordova. Illinois 61242 9740 i
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October 26, 1989 l
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Mr. A. Bert Davis
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Regional Administrator U. S. Nuclear Re?ulatory Commtssion
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799 Roosevelt Road kiY I
Glen Ellyn, IL 60137
SUBJECT:
Quad Cities Station Unit 1 NRC Observation of Drywell Maintenance 1
Activities on October 24, 1989 NRC Docket No. 50-254 l
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REFERENCE:
Conference Calls between CECO Senior Management and Region III Personnel Concerning the Subject Concerns Conducted on October 24-26, 1989 4
Mr. Davis:
As requested by W. D. Shafer, this letter is intended to address the concerns i
identified by the NRC inspectors during observation of Stone and Webster j
maintenance activities in the drywell.
Extensive interviews were performed by Commonwealth Edison 5 (CECO)
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Engineering and Construction (ENC) organization and Stone and Webster Engineering Company (SWEC) management.
The investigation substantiated the NRC's observations that the job did not progress in an efficient and effective manner. Commonwealth Edison believes, however, that any errors would have i
been identified and subsequently corrected in the required inspections and sign-offs which were specified in the work package.
The investigation of the event identified several weaknesses which were related to maintenance work performed by SWEC.
The specific weaknesses are as follows:
Worker famillarity with the specific job to be performed Detail of work instructions l
Location of work instructions l
Either better familiarity with the specific job or detailed on-hand work I
instructions would have prevented the poor work practices, i
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A. Davis October 26, 1989 Page 2 0
Corrective actions to address the weaknesses are as follows:
CECO personnel will review all SWEC maintenance work packages to verify adequate work instruction detail and inclusion of appropriate hold points.
If the work package is determined to contain inadequate detailed instructions, the instructions will be enhanced or an augmented contractor and/or CECO overview function will be assigned to assure quality job performance.
Prejob briefings will be required for SWEC maintenance work and will include CECO personnel involvement, as appropriate.
The briefings should enhance knowledge by craft personnel for the maintenance work to be performed. SWEC will develop an administrative procedure for prejob briefings to ensure uniform i
application by October 31, 1989.
Critical work instructions will be required to be on hand at the job site.
Completed SHEC maintenance work package documentation will be reviewed (i.e., detailed work instructions and hold points) to assess the impact of the previously described weaknesses on the work. A sample of the packages, which are believed to have been impacted, will be reviewed for quality of work instructions, hold points and adequacy of testing.
If assurances via documentation review is not achieved, the job will be reinspected, as appropriate.
If significant problems are identified, all SWEC maintenance packages will be reviewed and/or inspected, as necessary.
All identified problems will be resolved prior to Unit I startup.
CECO will augment current overview functions to include individuals from ENC and the Station.
ENC will provide a senior, expertenced individual to conduct independent observations of work performance on selected jobs in progress to ensure quality work practices.
In addition, a senior expertenced CECO individual will conduct independent observations of selected maintenance activities to ensure corrective actions are effective.
This overview will be conducted to the end of the outage.
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'A.' Davis October 26, 1989 l
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An additional concern identified by the NRC Resident Inspector was the potential harassment of the Quality Control Inspector at the work site.
CECO and SWEC do not tolerate harassment of QC/QA Inspectors for any reason.
The longstanding policy statement on inspector harassment will be iterated by the ENC Site Superintendent to the SWEC Project Manager.
If you have any questions regarding this matter, please contact me or N. J.
Kaltvianakis of.this office.
I-Very truly yours, b
l0 Z6 ws3 D. P. Galle Vice President BWR Operations RAR/djb j
cc:
W. Shafer Senior Resident - Quad Cities R. Lerch T. Ross - Project Manager, NRR i
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P 19028
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