ML19340A631
| ML19340A631 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/26/1977 |
| From: | Bolger R COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19340A630 | List: |
| References | |
| NUDOCS 8009020578 | |
| Download: ML19340A631 (6) | |
Text
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Commonwe:lth Edison One First National P!aza. Chicago. Illinces Address Reply to: Post Office Box 7~'
Chicago, Illinois 60690 September 26, 1977 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Dresden Station Units 1, 2 and 3 Response to IE Inspection Report Nos. 50-10/77-23, 50-237/77-21, and 50-249/77-21 NRC Docket Nos. 50-10/237/249 Reference (a) :
G. Fiorelli letter to B.
Lee, Jr.,
dated September 2, 1977.
Dear Mr. Keppler:
Attached to this letter is Commonwealth Edison's response to the items of noncompliance noted in Appendix A of Reference (a).
Please direct any additional questions concerning this matter to this office.
Very truly yours,
/
44 R. L. Bolger Assistant Vice President Attachment
.8009020 ShS SEP5y1977
Commonwealth Edison NRC Docket Nos. 50-10 50-237 Attachment 50-249 Infraction 1, Part 1:
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Contrary to 10 CFR 50, Appendix B, Criterion V, and the licensee's Quality Assurance Program, the licensee failed to follow quality procedures.
A non-safety-related component was installed and used in a safety-related system on Unit 3 without a proper review and justification for use as required by quality procedure 15.52.
Discussion:
On June 7, 1977, scram pilot valve serial #94474P was installed on Unit 3 CRD E-9.
Later that day, the maintenance foreman brought safety-related work package #5500 to Quality Control for the Quality Control release as required by QP 3-52.
At that time, the QC Inspector noted that the work package did not contain proper documentation.
The ASCO valve that was used was not indicated to be a safety-related valve.
Upon investigation, it was determined that the valve used was in fact identical to all the ASCO valves in use.
Further investigation into stores records revealed that the valve in question was ordered for this system from General Electric Company in 1969 before the Quality Assurance Program was instituted.
There also were two identical valves in the safety-related area of the storeroom purchased in 1975 with a product quality certi-fication from General Electric.
Corrective Action:
Because the valve in question was obviously identical to the ones already in use and to the two in the storeroom, it was decided by Quality Control, Quality Assurance and the store-room to make a visual inspection and issue a receiving inspection (RIN) and accept the valve with the receipt inspection as docu-mentation.
In order to further document the situation, Quality control issued an observed deficiency per DAP 11-7 to the store-raom for having a safety-related item in an uncontrolled area of the storeroom.
Lcmm:nw:alth Edison NRC Docket E The review and justification for accepting the nondocumented valve was the visual inspection of the valv, i
a satisfactory scram test of CRD H-9 to assure proper ope:
i A QC hold point was placed in the work package t CRD H-9 scram test.
On June 11, 1977, CRD H-9 was scram i and the test was witnessed by Quality Control and Quality This was so documented in the work package and the receivt inspection.
Upon ccmpletion of the RIN, a red two part tag f valve under the original 1969 purchase order was placed in work package to provide traceability to the receipt inspec the CRD was declared operable.
Unit 3 was started up late day on June 11, 1977, after successful completion of the s Corrective Action to Avoid Recurrence:
The solenoid valve used for work request 5500 wa.
obtained from the storeroom as a non-safety-related item.
occurred because of a mistake made by the storeroom on a cc change.
The solenoid valve was classified non-safety-relat until 1976: at that time, the material was transferred to i safety-related alpha code.
not removed.
The bin label at the old locati Subsequently, an unused solenoid valve was returr to the storeroom with a material credit form and the item
, improperly placed in the old location.
A new warehouse pre (DWP-lO) has been written detailing the transfer of materia i
a non-safety to a safety-related code.
This should minimiz possibility of recurrence.
Date of Full Compliance:
The new warehouse procedure (DWP-lO) will be in e; by October 28, 1977.
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Crmemnw dth Edison NRC DockGt Non. 50-10 50-237 50-249 Infraction 1, Part 2:
Contrary to 10 CFR 50, Appendix B, Criterion V and the licensee's Quality M rance Program, the licensee failed to follow quality prom.iures.
Instruments used to properly set safety relief valves for Unit 2 were not properly calibrated or' included in a cali-I bration program as identified in quality procedure No. 12-52.
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Discussion:
The noncompliance item states that the licensee failed to follou Quality Procedures, i.e.,
safety valves were set using improperly calibrated instruments.
Upon subsequent review of station records, the following items were found:
The Maintenance Department has a procedure for operation of the safety valve test facility (DMP-510).
As a prerequisite to initiating the procedure, the instruments associated with the test boiler are calibrated.
A l'et of the specific instruments is included in the procedure.
Additionally, the frequency of cali-bration is specified.
This fulfills the requirements of a cali-bration program, i.e.,
'nstrument by nm a r and calibration frequency requirement.
The instruments were all calibrated on 9/11/76, per the procedure which states that the instruments will be calibrated prior to each testing phase.
The term " testing phase" is defined as the complete testing of all valves associated with a given outage.
The valve whose test was questioned was l
tested on 2/14/77.
This valve had been returned from the vendo:-
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'following repairs and since the outage valves had been tested as late as 11/18/76, recalibration of the instrumentation was not considered necessary.
A question was also raised as to the responsibility for 4
assurance that the instruments have been calibrated prior to testing.
It is the responsibility of the Maintenance Foreman to assure the calibration of the instruments prior to testing.
The safety-related work request package which accompanies each valve for testing has a checklist requiring sign-off by the Maintenance Foreman for each instru aent requiring calibration.
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Commonwealth Edison NRC Docket Nos. 50-10 50-237 4-50-249 It is his responsibility to request calibration of instruments in accordance with the criteria in the work request
- package, i.e.,
prior to each testing phase.
It is the responsi-bility of the Instrument Engineer tc u 1.ibrate the instruments as requested by the Maintenanct Foreman anL to maintain records of tha t calibration for future ruZ.a ence.
In the case of the safety valve in question, this procedure was, in fact, followed and calibration records dated 9/11/76 are in place for all instruments.
The individual stickers on the instruments are not considered official records and are never used as documentation of testing or calibration.
As such, the January, 1975 date referenced in the noncompliance item is not the date the instruments were calibrated.
Corrective Action and Corrective Action to Avoid Recurrence:
Since the safety valve test facility is used only infrequently for short periods of time, the Station believes that
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a rigid calibration frequency would not serve a useful purpose, however, DMP-510 will be revised.
If a testing phase extends longer than three months, the procedure will be revised to require recaliFraLion at least once every three months.
Date of Full Compliance:
An instrument calibration will be performed on the safety valve test facility prior to use during the present Unit 2 outage.
Procedure DMP-510 will be changed prior to the Unit 3 outage in
, February, 1978.
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m, Commonwealth Edison FRC Docket Nos. 50-10 50-237 50-249 Infraction 2:
Contrary to 10 CFR 50, Appendix B, Criterion V and the licensee's Quality Assurance Program work was performed on Unit 1 and 2 safety-related components without identifying the work as safety-related and without testing the ccznponents prior to returning the equipment to service.
In both cases, the work was repacking and/or tightening packing on several containment isolation valves.
These valves are required to operate within a specified time frame.
Discussion:
The inspector identified the fact that certain power-operated safety-related valves were repacked under non-safety related work requests without a test requirement specified.
However, in the majority cf cases which involve the repacking of power-operated safety-related valves, the work is considered safety-related and test requirements of (1) cycling open and closed 3 times and (2) technical specification closure times must be satisfactorily completed.
Correcive Action and Corrective Action to Avoid Recurrence:
In the future, a more detailed review of wc,rk requests will be made by the Operating Engineers and the Quality Control group to insure the proper classification of safety-related work.
Date of Full Comoliance:
The Station believes full compliance has been achieved.
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