ML20062K196
| ML20062K196 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/09/1993 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Lyster M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20062K199 | List: |
| References | |
| NUDOCS 9312210206 | |
| Download: ML20062K196 (4) | |
See also: IR 05000010/1993006
Text
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December 9, 1993
Docket No.50-010
Docket No. 50-237
Docket No. 50-249
Commonwealth Edison Company
Dresden Nuclear Power Station
ATTN: Mr. M. D. Lyster
Site Vice President
6500 N. Dresden Road
Morris, IL 60450
Dear Mr. Lyster:
This refers to the inspection conducted by Messrs. Robert Lerch, Isa Yin and
Ronald Langstaff of this office on October 20 through November 3,1993.
The inspection included'a review of authorized activities for your Dresden
Nuclear Power Station. At the conclusion of the inspection, the findings were
discussed with those members of your staff identified in the enclosed report.
Additional telephone conversations were held between Mr. F. A. Maura of.this
office and the Commonwealth Edison Company QA staff on November 16, 17, 29,
and 30, 1993.
The purpose of this inspection was to assess the quality control activities at
the plant. The inspection consisted of interviews of plant employees and
employees of Fluor Constructors International Inc. (Fluor), and reviews of a
sampling of problem reports and procedures.
This inspect. ion identified that independent verification of certain work
activities is performed on a random or sampling basis.
It is unclear how
verification performed on a random or sampling basis meets regulatory
commitments. We understand you will seek an inierpretation concerning
sampling from the American Society of Mechanical Engineers (ASME) Committee on
Nuclear Quality Assurance. You are requested to provide the NRC with a copy
of the interpretation within 30 days of receipt of the interpretation.
In
addition, you are also requested to provide your position on how regulatory
commitments for performing inspections are met for those areas-in which
inspections are performed on a random or sampling basis.
Based on the results of this inspection, certain of your activities appeared
to be in violation of NRC requirements, as specified in the enclosed Notice of
Violation (Notice). The first violation involved weaknesses in your program
for the control of measurement and test equipment (M&TE) regarding calibration
reverification evaluations performed for lost, broken, or out-of-tolerance
tools. These weaknesses included a lack of clear management expectations for
the quality of these evaluations, incomplete documentation, numerous reviews
and signatures which provided little benefit, and a lack of responsibility by
the staff. The second violation _ represented a significant failure to assure
the appropriate resolution of problems identified on Fluor quality control-
inspectors' observation reports.
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December 9, 1993
The quality verification organization failed to' identify either of these
problems despite audits conducted specifically in the M&TE area. Although
some good findings were identified, the scope of the audits was limited in
that the quality of M&TE evaluations was not included nor was the control of--
M&TE by site contractors.
The inspection also identified that the underlying message conveyed by
management to the Site Engineering and Construction (SEC) organization and the
Fluor International QC group, during the last outage,-lacked appropriate
balance between the production schedule and quality,'which resulted in an
adverse climate-for procedure adherence and the identification of problems.
A lack of involvement by station quality verification and quality control in
outage work by Station Engineering and Construction' appeared to be a
contributor to the lack of balance between schedule and quality. . It'is
requested that you respond in writing with your conclusions on this matter and
any corrective actions you deem necessary.
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.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, its enclosures, and your responses to this letter wil1~ 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.
Sincerely,
Original signed by Mark A. Ring
Mark A. Ring, Chief
Operations Branch
'
Enclosures:
1.
l
2.
Inspection Reports
No. 50-010/93006;
No. 50-237/93030;
No. 50-249/93030
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See Attached Distribution
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B. Burgess Hiland
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Commonwealth Edison Company
2
December 9, 19')3
The quality verification organization failed to identify either of these
problems despite audits conducted specifically in the M&TE area. Although
some good findings were identified, the scope of the audits was limited in
that the quality of M&TE evaluations was not included nor was the control of
M&TE by site contractors.
The inspection also identified that the underlying message conveyed by
management to the Site Engineering and Construction (SEC) organization and the
Fluor International QC group, during the last outage, lacked appropriate
balance between the production schedule and quality, which resulted in an
adverse climate for procedure adherence and the identification of problems.
Although no safety concerns were identified, a lack of involvement by station
quality verification and quality control in outage work by Station Engineering
and Construction appears to be a contributor.
It is requested that you
respond in writing with your conclusions on this matter and any corrective
actions you deem necessary.
You are required to respond to this letter and should follow the inspections
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and an 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.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, the enclosures, and your responses 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.
Sincerely,
Mark A. Ring, Chief
Operations Branch
Enclosures:
1.
2.
Inspection Reports
No. 50-010/93006;
No. 50-237/93030;
No. 50-249/93030
See Attached Distribution
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12/4/93
12/q/93
12/ 7 /93
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Commonwealth Edison Company
3
December 9.1993?
'
Distribution
,
cc' w/ enclosures:
'
L. O. DelGeorge,.Vice President
Nuclear Oversight and
Regulatory Services
i
Gary F. Spedl, Station Manager
1
J. Shields, Regulatory Assurance
4
i
Supervisor
D. Farrar, Nuclear Regulatory
Services Manager
OC/LFDCB
,
Resident Inspectors - LaSalle,
d
Dresden, Quad Cities
'
Richard _Hubbard
J. W. McCaffrey, Chief, Public
Utilities Division
'
Robert Newmann, Office of Public
.
Counsel, State of Illinois Center--
,
J. F. Stang, LPM, NRR
4
State Liaison Officer _
,
Chairman, Illinois Commerce
Commission
J. B. Martin, RIII
H. J. Miller, RIII
T. O. Martin, RIII
J. E. Dyer, NRR
,
M. J. Jordan, RIII
C. D. Pederson, RIII
S. Stasek, SRI, Davis-Besse
C. L. Vandernietr RIIIN
bec w/ enclosures:
PUBLIC-IE0l N
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