ML20138K623

Submits Monthly Update of Activities Re Confirmatory Action Ltr RIII-96-16

ML20138K623
Person / Time
Site:	Dresden
Issue date:	12/30/1996
From:	Jamila Perry COMMONWEALTH EDISON CO.
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CAL-RIII-96-16, JSPLTR-96-0251, JSPLTR-96-251, NUDOCS 9702190072
Download: ML20138K623 (4)

Text

• Commonweahh lifiwn Company Drexten Generating Station h[

d 65(N) North Dresten Road Morris,11. G)l50 Tel HI49 42-2920 m

December 30,1996 JSPLTR 96-0251 Mr. A. Bill Beach Regional Administrator Region III U. S. Nuclear Regulatory Commission 801 Warremille Road Lisle, IL 60532-4351

Subject:

Confirmatory Action Letter Action Item Update Docket Nos.50-010,50-237, and 50-249

Reference:

NRC Confirmatory Action Letter Rill-96-016, A. Bill Beach to J. S. Perry dated November 1996

Dear Mr. Beach:

fN The purpose of this letter is to provide the monthly update of activities identified in your Confirmatory b}

t Action Letter (CAL)(Reference).

The first monthly meeting to provide the status of activities to the NRC was conducted on December 19,1996 at Dresden Station. At this meeting the status of the CAL action items Special Site Quality Verification (SQV) Audits, and the progress of the twelve system key parameter screening and the Dresden Engineering Assurance Group (DEAG) were discussed.

Dresden Encincerine Assurance Groun Activitics The DEAG was formed on November 11,1996 with four full-time members and three pan-time members.

To date the group has reviewed issues identified by the Independent Safety Inspection relating to the Low Pressure Coolant Injection / Containment Cooling Sersice Water System, the High Pressure Coolant injection System, and the 125/250 volt direct current batteries. Additionally, the DEAG has also reviewed the Operability Determination performed for the Control Room, 'ae 3B recirculation motor movement, inspection, and testing, the feedwater logic change, and certain setpoint changes.

Based on the above resiews the DEAG observed that Engineers do now validate design inputs. However, several engineering products reviewed by DEAG required corrections to strengthen design input assumptions or evaluate secondary efTects and system interactions. To date, there have been no major deficiencies noted in the engineering products reviewed. Additionally, SQV performed an independent resiew of the DEAG documentation for the reviews perforraed and agreed with the above conclusions.

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A. Bill Beach

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t December 30,1996 Page 2 Q)

Twelve Misk Sienificant Key Parameter Screenine Status

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The 12 systems most important frorn a risk perspective for the Dresden Station are as follows:

. Safety Related 125/250 VDC e 4 kV/480 VAC Distribution (excluding diesel generators) j e Low Pressure Coolant Injection (LPC V) e Automatic Depressurization System (ADS) e Containment Cooling Senice Water (CCSW) e Isolation Condenser (including makeup water) i e Feedwater/ Condensate

. Turbine Building Closed Cooling Water (TBCCW) e Main Steam Safety and Relief Valves ,

2 . Service Water i e High Pressure Coolant injection (HPCI) j i e Emergency Core Cooling System (ECCS) Initiation Logic i l

l A matrix identifying preliminary key sylem parameters for the 12 systems has been developed. A t.:am for validating the system key p :rameters has been formed. This team consists of senior non-Cor4Ed and Comed engineers. Comed is working to complete the system key parameter screening by February 28,1996.

Special Audits of Architect /Encineers and Vendors.

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In December 1996 an special audit of design control issues at Sargent & Lundy was completed. The audit of Sargent & Lundy (S&L) identified six findings and six recommendations as well as one finding for q Comed Corporate Engineering, and one recommendation for Comed Nuclear Oversight. The findings relating to Sargent & Lundy were:

t e instances of failcre to promptly identify and correct a non-conforming condition e calculations contained inappropriate, unverified, incorrect assumptions, and design inputs

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e the independent review process failed to identify some concerns noted in an audit i

e internal audits were programmatic in nature and failed to identify certain design control problems

e completed calculations were not always distributed or microfilmed j e Quality Assurance control concerns for piping analysis program The recommendations were

e S&L should clarify and provide additional detail to support the October 30,1996 safet- '

significance position on the Containment Cooling Service Water / Low Pressure Coolant l Injection (CCSW/LPCI) hydraulic calculations.

. S&L should develop a governing procedure and flowchart for the corrective actions program elementalinterrelationships e S&L needs to define Nuclear Engineering Procedures (NEP) and Equipment Qualification (EQ) relationships in their procedures.

. S&L should provide procedural guidance for performance of third party reviews.

. S&L should document on Calculation Cover Letters the affect on other calculations and

[] e documents.

S&L needs to perform a formal resiew of files when utilizing computer calculation fields.

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_ m Mr. A. Bill Beach Page 3 December 30,19%

! The Comed Corporate Engineering finding was: j e Safety related design activities ofits architect engineer (Sargent and Lundy) were not properly controlled.

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[ The Comed Nuclear Oversight expectations and audit findings were:

e Comed expects that its vendors will adhere to their Comed approved Q.A. Program and meet the intent of NQA-1 and 10 CFR 50 Appendix B as they apply to their activities. This l is expected to include a technical review as well as a programmatic resiew of their activities during their internal audits and self assessments.

. On Nov.12-19,19% Nuclear Oversight performed an audit of S&L (audit # AE %-17) and identified several areas of concern, all of which have been discussed with Region III of the NRC. All of the issues found during the audit are documented on Corrective Action Records (CARS) and require a written response from S&L to the Audit Team Leader no lat:r than January 20,1997. These responses are required to contain answers to the following questions; !) Root Cause of the deficiency, 2) Corrective Actions taken to correct the issue, and 3) Actions to prevent recurrence, once these responses are received and resiewed, Nuclear Oversight will be in a position to identify the areas to monitor and frequency. As a minimum, all of these Corrective Actions will be reviewed and statused to ensure timely completion and effectiveness in accordance with Comed's approved Q.A. Program.

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's e Comed has initiated an Action Plan o ensure that future Audits of A/E type vendors include a resiew, verification and assessment of the effectiveness of the following areas to preclude a similar occurrence; 1) Interfaces between Comed and the Vendor, 2) the Design Control Process with a focus on Calculations and 3) Problem Identification and Notification.

Overall, this should give Comed a more detailed view of the effectiveness of the Q.A.

Program being implemented by that vendor for the Safety-Related D: sign work they are performing for Comed.

The schedule for the following audits is being developed:

e Bechtel Engineering

• Duke Engineering e Westinghouse (fuel and Nuclear Steam Supply System) e GE (Nuclear Steam Supply System) e Siemens (fuel) e S&L follow-up

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Mr. A. Bill Beach Page 4 December 30,19%

i j If you have any questions concerning this letter please contact Russell Freeman, Dresden Station Engineering Manager at (815) 942-2929, ext. 3700.

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, Sincerely, l

! . tep n Perry l i Site Vice President  !

Dresden Station i cc: U. S. NRC Document Control Desk

} L F. Stang, Project Manager NRR l C. L. Vanderniet, Senior Resident Inspector - Dresden Station l

Office of Nuclear Facility Safety - IDNS

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