ML20244A553
| ML20244A553 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/22/1989 |
| From: | Chrzanowski R COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20244A551 | List: |
| References | |
| 0133T, 133T, NUDOCS 8906120069 | |
| Download: ML20244A553 (16) | |
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) Commonwealth sPRion1TVRoutpih e..V 72 West Adams Street,Edison 7
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Chicago. Illinois Address Reply to: Post Offce FoT767~
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' t / sGA DR5-A, ht nss .. at t HEA 'E s PAR May 22,-1989.- FILE
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Mr.'A. Bert= Davis ,
1 Regional Administrator Region,III-U.-S. Nuclear Regulatory Commission <
.799-Roosevelt Road Glen Ellyn,-IL~ 60137 Subject *~ Byron Station Unit 1 and 2 Response to. Inspection Report Nos. 50-454/89009 and 50-455/89006 NRC Docket Nos. 50-454 and 50-455 Reference (a): April 13, 1989, letter from H. J. Miller to Cordell Reed
Dear Mr. Davis:
This letter is in response to the inspection conducted by Mr.
R.A. Hasse, Ms. A'M. Bongiovanni, and Ms. V.P. Lougheed from February 27 through March 16, 1989, of activities at Byron Station. Reference (a) indicated that certain activities appeared to be in violation.of NRC requirements. Attachment A provides the response to proposed violation
- 1. Attachment B provides the response to proposed violation 2.
Commonwealth Edison has reviewed proposed violation 3 and has
' concluded that this item does not represent a violation of 10 CFR Part 50, Appendix B, Criterion XI. Commonwealth Edison believes that the modification testing performed did confirm that the acceptance criteria had been fully met. In light of the information contained in Attachment C, Commonwealth Edison requests that the Staff recensider the issuance of this violation.
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B006120069 890602 PDR ADOCK 05000454 M AY z s 1989
.O PDC
A..U. Davis
," May 22, 1989 Reference (a) also requested a written response to two open items. Attachments D and E contain the responses to those open items.
Additionally, the inspection report requested a response to the problems that have occurred in view of the Modification Program enhancements.
Commonwealth Edison shares the concern about the problems.3dentified during the inspection. Many organizations are involved in the processing of a modification package from the design through installation.
Commonwealth Edison believes that the modification program is sound, however, more communications and training is needed in order to ensure that the personnel involved understand and implement the total program.
This is discussed further in the specific violation responses program.
Please direct any questions concerning this matter to this office.
Very truly yours, c L R.A. brzanowski Nuclear Licensing Administrator
/sc1:0133T 1-2 ces Resident Inspector-Byron NRC Document Control Desk l
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a ,. ATTACHMENT A
- 1. 10 CFR 50,< Appendix B,. Criterion III states, in part, that measures-shall be established to assure that applicable regulatory requirements and the design basis for safety related components and systems are correctly translated into. specification drawings, procedures, and .
instructions. These measures sha11' include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.~
-Design changes, including-fleid changes, shall be subject to design; f control measures. commensurate with those applied to the original design p and be approved by the, organization that performed the original design.
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Contrary to the above, design control measures did not ensure that the design basis for systems and components were correctly translated.into specifications,. drawings, procedures, and instructions'nor did they ensure that deviations from such standards were controlled.
Specifica11ys-
.a. ' Design calculation, COD 220559, was. incomplete in that it failed to:
i: _ seismically qualify sixteen valves installed in the safety related nitrogen charging pressure / testing manifold per Modification M6-1/2-84-118. (454/89009-01; 455/89006-01B)
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- b. The: Installing organization declared Modification M6-2-88-004 as non-safety.related and deleted engineering requirements that specified the' installation to be performed as safety related without prior engineering approval. (455/89006-01A)
- c. All design' requirements for Modification M6-2-87-166 were not implemented in that the requirement for periodic cleaning of relay contacts was not specified to plant personnel and thus, not incorporated into the preventive maintenance program.
(455/89006-01C) 1.a. Corrective Actions That Haye Been Taken And The Results Achieved:
L It was verified that design calculation CQD 220559 correctly applied as the bounding calculation to all 48 valves installed with this modification. The documentation was revised to indicate that it covered the 16 valves previously omitted from the list, and a copy was provided to the inspector during the course of the inspection.
Corrective actions that will be taken to avoid further violations:
l Sargent & Lundy Project Instructions regarding the use of " generic" or bounding calculations were reviewed and found to contain sufficient L guidance for listing the components for which a calculation is applicable. Therefore, the omirsion is considered to be an isolated case, and no additional corrective actions are deemed necessary.
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- Date when full complience will be achieved:
The Station is in full compliance at this time.
1.b. far.tective Actions That Hava_Reen_Inhen And The Results Achityd s Although the Engineering and Construction Department's-(ENC) treatment of the work as non-safety related did not require a OC inspection, it was verified that termination inspections were performed as part of the-user's walkdown required by the modification. These inspections, along with post-modification testing, verified proper' installation.
Cattactive actions that will be taken to avoid further violati2ns:
The installing organization, ENC, has been trained on compliance with the_ requirements of the Engineering modification approval letters.'
All issues identified in NRC Inspection Report 50-454/89009 and 50-455/89006 will be thoroughly discussed at the June Engineering staff- ,
meeting. All . commitments made by the PWR System Design organization will be discussed with all other Engineering organizations to ensure they understand the seriousness of the identified issues and incorporate into their procedures and practices the lessons learned from this inspection.
Date when full compliance will be achieved:
ENC training was completed May 11, 1989.
Engineering meeting to be held by June 30, 1989.
1.c. Corrective Actions That Have Been Taken And The Results Achieved:
The HTA151 relays installed under Modification M6-2-87-0166 were inspected and found to be in good working condition.
A random sampling of approximately 25% of the PWRE modifications, performed in the same time period as the modification in question, were reviewed to ensure there were no other.similar discrepancies. None were found.
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,, ', ' ' Corrective tgtions th S t will b7 taken to-evoid furth 2r__ylpJrijon
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L General Electric Co.'has provided Byron Station with instruction for the HFA151 relays installed on the diesel generator under Modification M6-2-87-0166. The appropriate periodic maintenance recommendations are l being incorporated in the 1/2 BVS DG-1. This surveillance is performed during refueling outages.
Dates when full compliance will be achitynd:
1/2 BVS DG-1, 18 month surveillance procedure, will be approved for use December 1, 1989. (AIR 454-225-09-0125) l l
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ATTACHMENT.B.
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)2.- -10 CFRI50.59(b)(1) states,:in part, that the licensee shall maintain 1
- records.of changes in the facility ... . and that these records'must k . include a safety evaluation which'provides the bases for the
- determination that the change does not involve an'unreviewed. safety' question'.
A l Contrary to;the above, safety evaluations did'not provide the bases for.
.the determination'that the change did not involve an unreviewed' safety
. question.. Specifically:
- a. 'The' Safety.Ev.tluation for Modification M6-2-88-004 did not' provide the' bases for the determination that the change did not involve an
, unreviewed safety question in that it dismissed the questions by claiming that the modification was non-safety related.
(455/89006-04A)'
b.- Additional examples-of the use of "non-safety related" as a justification as to why a change did.not constitute an unreviewed safety question were found in Temporary Alterations'88-1-008, 88-0-009, 88-0-019 and 88-0-35. . Temporary Alteration 88-1-51 dnswered the questions by reference to a letter by the architect-engineer. However, the letter did not address the concerns of 10 CFR 50.59 in any manner.
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o (454/89009-03; 455/89006-4D) 2.a~ C.9,rrective Actions That Have BE.ED_Jaken And The Results Achinyrd:
Modification M6-2-87-117 covered the basic design concept and work associated with changes to the P-8 permissive logic. This modification was submitted to the NRC for prior approval. ' Approval was received in a Safety Evaluation Report dated December 8, 1987. After modification M6-2-87-117 was closed, modification M6-2-88-004 was issued to incorporate a minor' change to'the s'pecific electrical contact points utilized. Because of the minor nature'of the change, the entire P-8 modification was not reevaluated for M6-2-88-004, although, the impact h of the electrical contact change was considered.
To resolve this item, the 10 CFR 50.59 Safety Evaluation has been re-reviewed for Modification M6-2-88-004 and a more thoroughly documented review sheet has been added to the file. The conclusion, however, remains unchanged in that-no unreviewed safety issues exist.
, A random sampling of the approximate 30 additional modifications, performed during the 1987 to 1988 time frame, has been reviewed to determine the adequacy of the documentation. No other responses using non-safety related as the sole justification were found. Eight of the safety evaluations reviewed have been supplemented as appropriate to provide better detail in support of the conclusion of no unteviewed safety questions.
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' CorrncNve rhetions thOt will' be taken to r3 void further vio1GLinns.9
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C r 'In'Febduary,of-1989,ja more defined,, instructive procedure.for-f comp 1etion' of 10 CFR 50.59 evaluations was Incorporated into' Engineering
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,Il , J Modification' Procedure-Q.6Las subprocedure.Q.6.1. . This procedurer and F\' accompanying' checklists,; have been developed using' the ' latest NUMARC
- guidance for performing 10 CFR 5'.59's.-
O In addition,-training-to.this
.new program has been started for personnel performing modification
- reviews.
I J JDate when' full como11ance will be__ achieved:
Training'ofEall Engineering Systems personnel to be completed by L . June 30, 1989.
2.b. Cnrrective Actions That Have Been Taken And'The Results Achigynds
.The subject Temporary Alterations wer'e reviewed to address the concerns.
of 10 CFR.50.59 and supplemented with more thorough documentation. The conclusion in each case' remained unchanged with no unreviewed safety.
Issue.
J Corrective act_8.ons that vill be taken to gyqid further violation:
All other Temporary' Alterations will be reviewed to ensure adequate 10 CFR 50.59 reviews were performed.
The Byron Station Technical Staff will be provided additional ~
10,,CFR.50.59 training.to ensure adequate understanding of requirements.
'Date'when' full' compliance will be achieved:
Temporary Alterations reviewed by July'1,~1989.
Technical Staff trained by May 31, 1989.
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ATTACID4ENT C
- 3. 10 CFR'50, Appendix B, Criterion XI states, in part, that a test program shall be established to assure that structures, systems, and components will perform satisfactorily in service . . . which incorporate the acceptance limits contained in applicable design documents.
Contrary to the above, the post-modification test performed for Modification M6-2-07-132 did not confirm that the acceptance criteria had been met in that the low pump suction pressure signal was not inserted after the pump had been running for the specified period of time. (455/89006-02)
Byron Station wishes to take exception to the above violation and provides the following statement:
The intent of Modification M6-2-87-132, as stated, in part, by the inspector, was to install a time delay (block) in the motor driven AFWp logic to prevent pump trip due .to a low suction pressure transient frequently encountered during pump start. It is during the first 2.5 seconds after a pump stnrts that there is potential for the pump to trip because the pump suction pressure has not recovered sufficiently. After.
the 2.5 second block the pump tripped as designed. Had the 2.5 second block not worked then the pump would have tripped somewhere between pump start and-the 2.5 seconds. During normal operation the pump will trip immediately on a low suction pressure signal. This was proven by the pump tripping as soon as the 2.5 second block expired. The capability of the low pressure interlock to trip the pump after a longer run time was not affected by this modification In that the pwnp tripped immediately after the 2.5 second delay.
The violation states "the post-modification test performed for Modification M6-2-87-132 did not confirm that the acceptance criteria had been met in that the low pump suction pressure signal was not inserted after the pump had been running for the specified period of time".
In order to ensure the low suction pressure trip block functioned properly, the low pressure signal had to be in place prior to the start of the pwnp. The block was effective for 2.48 seconds (2.5 3 .75 acceptance time). The block timed out at 2.48 seconds and the pump tripped. The trip was within the acceptable range of 2.5 s .75.
'The inspector stated "....the timo delay would occur regardless of when the low suction pressure signal initiated". This statement is in error. The low pressure interlock will immediately cause the pump to trip anytime during pump operation except for a start condition.
Pre-operational Test 2.3.60 tested the immediate trip function. This circu!try was not affected by the modification. The blocking modification applies only during a start condition.
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.- Tha contributing factor, in what wa b311cva to ba a misundsretending by the inspector, was a Block Logic Diagram which contained erroneous information. This Logic Diagram was considered as reference material only. The Electrical Schematic and Wiring diagrams were the gcVerning documents for this modification for installation and testing. These
" controlled" diagrams reflected the correct installation of this modification.
Byron Station'has thoroughly reviewed the modification test. We believe the modification testing proved the acceptance criteria. We request that the inspector withdraw the violation at this time and have further
' discussions with the station in order that the station can more clearly understand his concerns. The following pages provide more detail of the modification (M6-2-87-132). This information is being provided to assist your further review of this' concern.
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. MODIFICATION M6-2-87-133
'* DETAILS i i
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To better understand the testing performed in Modification M6-2-87-132 and to properly address the NRC concerns regarding this testing, the scope of the work performed in the modification should be clearly identified. The Design i intent lof_ the modification' was to provide " protection against unnecessary trips of the. Unit'2 Motor Driven Auxiliary Feedwater Pump, 2AF01PA, and unwarranted transfer'of 2AF01PA suction source to Essential' Service Water ;
-(SX), due to suction pressure transients encountered during pump start. This j
" protection" was provided by incorporating a 2.5 second time delay-in the Low ~l (12.5. psia) Suction Pressure trip circuit for 2AF01PA and by installing a 4 j second time delay in the Low (14.1 psia) Suction Pressure actuation circuit ]
responsible for " arming" the AF SX Suction valves to auto-open when received )
coincident with an ESF signal. The modification testing demonstrated that the !
.12.5 psia Low Suction Pressure trip signal to 2AF01PA was blocked for 2.5 l seconds after pump start anci demonstrated that, in the presence of this trip !
signal, the pump would trip after the 2.5 seconds time delay was met. The l Modification Test demonstrated that the Low Suction Pressure signal arming the AF SX Suction. Valves was blocked to 4 seconds af ter start of 2AF01PA and demonstrated that, in the presence of this trip signal, these valves were 1
" armed" 4 seconds after pump start.
Modification Testing and Modification documentation provide redundant
. verification that wiring was installed per the Electrical Schematic and Wiring l diagram changes detailed in the Design Change Package for the Modification. I The wiring verification was performed redundantly using several verification !
methods. The installer, CECO Substation Construction, performed visual j inspections to verify wiring was installed per design. Independent visual j verification that wiring is in accordance with design documentation was performed by the CECO Quality Control Department. Prior to turnover to the Byron Technical Staff for testing, wiring was verified to be in'accordance with Electrical Schematic diagrams by the Operational Analysis Department.
, Prerequisite step 6.2 of the Modification Test required and documented the completion of a " User's Walkdown" prior to performance of testing. The
" User's Walkdown" consisted of a pre-test walkdown of the modified wiring by the Technical Staff System Engineer, a representative from Electrical Maintenance Staff, an Operations department representative, and a representative from Substation Construction.
The circuits affected by the modification work can be represented in three circuits (see Addendum A for circuit description). The following is a description of how the Modification Test verified the wiring to be in accordance with the Electrical Wiring and Schematic Diagrams in the PECN (Post Fuel Load Engineering Change Notice): !
Wiring changes made in Circuit #1 (Addendum A) were verified to be correct by closing the 2A AF Pump breaker via a test EST actuation signal (test steps 9.2.5 & 9.3.3) and verifying that the coil in both of the time delay relays, installed by this modification, are energized.
Verification of coil energization was made in steps 9.2.6. 9.2.9, 9.3.3 ;
& 9.3.6 and the associated recorder t z aces by ver if ying r elay contact j closure after the time delay relays had " timed out". Coil energization l in both relays verifies that electrical continuity was maintained from the power supply through the relays and the wiring of Circuit #1, l
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MODIFICATION M6-2-87-133-DETAILS (continued)
Wiring changes made in Circuit 42 (Addendum A) were verified to be correct by demonstrating that current is supplied through the 1-5 contacts of the AFIAX1 (Pump Trip Time Delay) relay. With the 5-7 contacts of the PSAF51X relay (Low Suction Press. Pump Trip Aux. Relay) jumpered closed, closure of the 1-5 contacts of the AF1AX1 resulted in immediate trip of the pump as documented on steps 9.2.9 and 9.2.10.
This demonstrated that electrical continuity was maintained from the power supply through the AF1AX1 relay contacts, the trip coil, and the wiring of Circuit #2.
Wiring changes made in Circuit 43 (Addendum A) were verified to be correct by demonstrating that current is supplied through the (1-3) contacts of relay AF1AX2 (AF Suction Transfer to SX Time Delay). With the 2PSL-AF051 (2A AF Pump Low Suction Pressure Switch) contacts that are in circuit #3 closed, closure of AFIAX2 contacts resulted in energization of relay PSAF51X1 as documented in step 9.3.7 of the Modification Test. This demonstrated that electrical continuity was :
maintained from the power supply through the AP1AX2 relay contacts, the j 2PSL-AF051 switch contacts, and through the coil of the PSAF51X1 relay.
In the " Post' Modification Testing" section (Section 3.b(2) of the Inspection Details) of the NRC Inspection Summary, dated April 12, 1989, i the Inspector identified concerns with regard to Modification M6-2-87-132. The concerns are two-folds (1) that a discrepancy existed l in the Logic Diagram included in the Design Change Package and (2) that l the Modification Test as performed could not distinguish between the i erroneous logic of the Logic Diagram and the Logic depicted in the Electrical Schematic Diagram. As stated by the inspector, one of the Design Change Documents (PECN P-808) for the modification incorrectly changed a Control Logic Diagram. This Control Logic Diagram was an j "Information Only" document used for reference only. This Logic Diagram ;
was not a " Controlled" document and was not used to perform work l
! activities involving temporary or permanent changes to plant equipment and wiring. These Logic Diagrams are block diagrams only and could not serve as a wiring / component installation and/or alteration document. 2 The Electrical Schematic and Wiring Diagrams included in the f modification package are " Controlled" docwnents and are the governing j documents used at Byron for testing and installation / alteration activities involving permanent plant equipment. A Drawing Change Request was initiated to correct the logic diagram. To prevent any additional confusion in the future, Sargent & Lundy has been instructed not to issue "information only" documents in the Design Change Package (PECN). !
l The erroneous logic depicted on the Logic Block Diagram showed that ]
running of the 2A AF Pump in conjunction with a Low Pwnp Suction Pressute signal would result in initiation of a 2.5 second time delay af ter which pwnp trip would occur. The electrical schematic shows the i correct time delay logic. The correct logie is that the low suction ]
pressure trip is blocked for 2.5 seconds after the pump start to prevent i inadvertent trip of the pump during start. This time delay is initiated independent of the suction pressure switch. Therefore, if a low suction l
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. . i MODIFICATION M6-3-87-132 f DETAILE (continued) {
I pressure trip signal received anytime after the 2.5 seconds time delay relay i
times out, the punp will trip immediately. The inspector's concern is that I the test as performed could not distinguish between these two logics. In order for the incorrect logic to be installed, the Low Suction Pressure Auxiliary Reley, PSAF51X, contacts (5-7) would have to be in series with Pump Breaker Stationary Auxiliary Switch contacts (19-20), providing power to the time deley relays (only in this type of circuit would satisfaction of both permissives be required prior to initiation of the time delay for the Low Suction Pressure trip). In order for this proposed erroneous circuit to be l
possible the physical wiring would have to be in contradiction to the Electrical Schematics and Wiring Diagrams, the " User's Walkdown", the installation documentation provided by Substation Construction and the circuit check as performed by the Operational Analysis Department. The modification test as written tests the possible logic combinations that might be altered given the wiring changes actually made and their resultant schematical representation.
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MODIFICATION M6-2-87-132 DETAILS (continued)
ADDENDUM A The circuits affected by work performed in Modification M6-2-87-132 can be more easily understood by representing the changes made in three circuits.
The first of these circuits consists of a set of contacts on the Breaker Stationary Auxiliary Switch S-2 inseries with two parallel time delay relays. The feed for this circuit is supplied by the 125 VDC output of the 2A Auxiliary Feedwater (AF) Pump switchgear. The circuit operates as follows:
When the 2A AF Pump breaker closes, the contacts of the Stationary Auxiliary Switch, an integral part of the breaker assembly, are closed.
Closure of these contacts allows supply power to be provided to the two parallel time delay relays, energizing the relays.
The installation activities required to create this circuit was as follows:
- 1) A wire was installed between an existing terminal point from the positive supply of 125 VDC power and terminal pt. 19 of the existing 19-20 contacts of Stationary Auxiliary Switch S-2.
- 2) A wire was installed from the other side (term. pt. 20) of switch S-2 (19-20) contacts to the positive terminal of the coil for time delay relay AFIAX2 (Time Delay Relay for AF Suction Transfer to SX).
- 3) A wire was installed from the negative terminal of the AFIAX2 coil to an existing terminal point at the negative supply of 125 VDC power.
- 4) A jumper was installed from the negative and positive terminals of AFIAX2 to the negative and positive terminals of the coil for AF1AX1 (Time Delay Relay for the AF Pump Trip).
The second of the circuits consists of a set of contacts from Auxiliary Relay PSAF51X in series with a set of contacts from time delay relay (AFIAX1), a set of breaker compartment rack in/out contacts, and the pump trip coil. The feed for this circuit comes from the 125 VDC output of the 2A AF Pump switchgear.
The circuit operates as follows:
When a low pressure (12.5 psia) signal is received from the suction of the Motor Driven AF Pump, the contacts of auxiliary relay PSAF51X close. When the pump starts, the time delay relay (AF1AX1) is energized as described in " Circuit #1" above. AFIAX1 contact closure occurs after the 2.5 second time delay is complete. The low pressure signal input a.:d the breaker closure with its associated time delay input come from independent circuits. When both inputs are present, the trip coil is energized and the Motor D11ven AF Pump trips.
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^#$*;J' A _ MODIFICATION M6-2-87-1321 !
p, [ DETAILS (continued)' i W, t E
.The installation activities required.to create this circuit were as'follows:
b 1)- . Lift the existing wire running-from relay PSAF51X term.,pt.'7 to. j
< breaker. compartment <" rack-in/out" switch <YF term. pt. 5'at the.YF--
termination.
'2)4 Reland lifted lead from (1) at time delay. relay contacts
( t e rm . ' pt . 1. ) . -)
3): Run'a. wire from the other side of time. delay contacts mentioned in (1) above (term.:pt. 5) to breaker compartment." rack in/out" switch' YF-term. p t '. .5; j I
'The third circuit consists of a. set of contacts"from 2PSL-AF051 in series with j F
. time delay. relay AFIAX2 contacts and the co11Lof relay PSAF51X1. The~ feed for' l P' 'this circuit comes,from the'120 VAC power feed at MCC 231X3. The circuit.
s ? operates-as follows:
o L When a low pressure signal (14.1 psla) is received from the suction of ,
the. Motor Driven AF Pump, the contacts of 2PSL-AF051'close. When the 2A. !
'AF Pump starts,the time delay relay (AFIAX2).~is energized as described ;
in Circuit il description. After a 4 second time delay, relay AFIAX2-contact closure occurs. The low' pressure signal input and the breaker closure with associated time' delay input come from independent circuits.. When both Inputs are present,' relay-PSAF51XI is energized, arming both of the 2A AF Pump Essential Service Water suction valves,.
2AF006A and 2AF017A. ,1 The installation activities required to create this circuit were as followst'
- 1) Lift the wire originally running from the 120 VAC power supply at MCC.231X3, Compt. B4 to 2PSL-AF051 at the point that the wire ~ exits
.the MCC. ;
2)- Run a wire from:the 120 VAC power supply at MCC 231X3, Compt. B4 to- 'l contacts (term. pt. 1) of the'AF1AX2 relay.
- 3) Run a wire from the other side of AFIAX2 contacts (term. pt. 5) to 1 point where wire was lifted in step (1). j I
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ATTACHMENT D Open Item 454/89009-02; 455/89006-03 For Modification M6-2-88-004, the engineering organization specified only that a modification test be done with no consideration of operability testing.
Onsite review also did not require any operability testing. The installation was performed as non-QA with no verification of the installation, although it was in a safety-related cabinet. Since no operability test was specified, the inspector was concerned that a reactor protection trip function may have inadvertently been affected with no means to detect it. When questioned, the licensee was able to show that the normal reactor protection trip surveillance were performed after the modification had been completed.
However, the general concern (whether adequate post-modification operability testing is being specified) remains.
During review of the engineering evaluation (via checklists) for Modification M6-2-85-128, it was noticed that certain tests were marked as being required.
Particularly these were testing for the presence of sneak circuits and testing for valve failure position on loss of power. These tects were not included in the modification approval letter, and were not performed. Since the site personnel do not see the engineering checklists, it is necessary for any required testing to appear in the modification apprcval letter. In a discussion with the licensee, it was stated that the sneak circuit testing was considered to be included, although not specifically addressed, and that testing on loss of power was not necessary, since this function had not been altered by the modification. The inspector's concern is that there is a
" disconnect" between the engineering checklist requirements and the actual testing.
Ennnnuse A review of modification approval letters provided to the station in the last six months shows a trend to inclusion of more detailed testing criteria. In addition, the latest revision Engineering Modification Procedure 0 6 has better definition of tests to be performed. All required testing shown on the testing checklist will be included in all future modification letters.
During the month of May, a group meeting of both sections of the PWRE Systems Design organization will be held to discuss, among other issues, the necessity for identifying all testing requirements in the modification approval letter.
Greater emphasis on the testing issue, including modification and installation, as well as system operability tests, will also be addressed during the modification kickoff meetings.
We believe that these actions will preclude the potential of inadvertently overlooking any required testing.
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ATTACHMENT E
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"Open Item 454/89009-04; 455/89006-05 Station Procedure BVP 100-2, " Classification / Procurement of Parts / Components"
- contained no program for the dedication process with respect to identification and verification of critical characteristics. The present system consists of
.an informal, process of jotting instructions for QC receiving on the back of the procurement form. This is not consistent with the requirements of the recently revised Quality Assurance Procedure QAP 4-51, Section 3.4 of the corporate QA manual which requires the identification of critical characteristics and the means for verifying them.
Ec. spans 1 The open item contends the Q.P. 4-51, Attachment A, paragraph 3.4, requires that " critical" characteristics be identified for commercial grade procurement dedicated for safety related applications, and that these requirements are not reflected in Station procedures.
The existing Company program for commercial dedication relies on Certificates of Conformance and a physical inspection of the item (quality receipt inspection) to ensure the appropriate level of quality is maintained. This is in accordance with Q.P. 4-51, Attachment A.- paragraph 3.2, which states in part:
"...(commercial grade items) can be purchased from a supplier or manufacturer listed on the Company commercial Approved Bidders List and be accepted and upgraded to safety-related (this reclassification is called dedication) at the plant site by documented receipt inspection
. based on:
(1) the supplier's or manufacturer's certificate of conformance or (2) a fixed indication of the item (s) positively traceable or identifiable to e catalog-item technical description or to a drawing specification or Standard to which the item (s) was made by the manufacturer."
It should be noted that Paragraph 3.4, is entitled " Dedication Process Guidance" and is further described as:
"...As to the dedication process to a basic component as defined in 10 CPR Part 21, the following guidance it provided..." This paragraph also states "... Dedication requires specification, recognition and verification of these particular characteristics which are important to the safety-related application".
l As presently written, Paragraph 3.4 furnishes guidance for implementing a dedication process. Additionally, the reference to " critical characteristics" in the inspection report apparently refers to the "particular characteristics which are important to the safety-related application". Dyron Station's dedication process as implemented in BVP 100-2 meets the requirements of Paragraph 3.2 and the intent and guidance of Paragraph 3.4. The Commonwealth Edison Quality Assurance / Nuclear Safety Department agrees with this position.
Commonwealth Edison, through the Nuclear Engineering Department, has been chartered with addressing the commercial grade dedication issue. The Nuclear Engineering Department has been reviewing NUMARC and EPRI guidance to develop and implement a company wide program to address these issues, with full implementation by December 31, 1989.
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