ML20135F315
| ML20135F315 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/06/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JSPLTR:-97-0045, JSPLTR:-97-45, NUDOCS 9703120045 | |
| Download: ML20135F315 (6) | |
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Commonwealth 1:dnon Company
', Dresden Generatmg Station 4 656) North Drex!cn Road Morris, ll. 60 ISO Tel H I 5-912-2920 March 6,1997 JSPLTR: 97-0045 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
Subject:
Dresden Nuclear Power Station Units 2 and 3 Reply to a Notice of Violation Inspection Report 50-010; 237; 249/96014 u NRC Docket Numbers50-010,50-237, and 50-249
Reference:
J. L. Caldwell letter to J. S. Perry dated February 4,1997, transmitting NRC Inspection Report 50-010; 237; 249/96014 and Notice of Violation ,
The purpose of this letter is to provide Comed's reply to a Notice of Violation transmitted in the reference letter. Specifically, the violation involved an emergency diesel generator technical manual which was missing information.
This violation is attributed to a System Engineer's failure to take action to update the technical manual when a new component was installed in the diesel engine in January, ,
1996. Furthermore, when this engineer subsequently reviewed the diesel technical manual in April,1996, he failed to recognize that the manual still described the old component.
Dresden Station recognizes that there have been weaknesses within the VETIP, including the process weakness identified by this event. Accordingly, Dresden has taken the following actions to strengthen the program:
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- A recovery plan implemented in July,1996 is on schedule to complete the processing of the backlog of safety related publications by May 30,1997. To date over 700 manuals have been reviewed. [
. Technical manual changes received in 1996 have been processed and reviewed for ;
conformance with installed equipment.
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The VETIP has been strengthened with the issuance and revision of procedures that provide clear direction about which sources of new information should be reviewed for inclusion in the VETIP manuals. Specifically, Nuclear Engineering Procedure (NEP) 07-04, "VETIP Process Control," , which requires a review documents other than those issued by.the original vendor, was issued during July,1996. Additionally, Dresden Administrative Procedure (DAP) 02-10, " Control of Vendor Equipment Technical Information," was revised to incorporate NEP 07-04 requirements, A recent assessment conducted in August,1996 by Dresden's Independent Safety Engineering Group (ISEG) determined that VETIP is now meeting all programmatic requirements. ISEG examined the results of the first phase of the backlog reduction _
program and assessed the adequacy of the next phase of the recovery effort. The completed phase was found to be satisfactory. ISEG identified two concerns about the next phase, the ability to. sustain the backlog reduction schedule and actions to prevent recurrence of the backlog. VETIP addressed both of these concerns and has
' demonstrated to date that the current plan is not only effective in reducing the backlog to schedule, but in preventing a backlog from recurring.
The attachment to this letter provides Dresden's reply to the Notice of Violation along with corrective actions to preclude recurrence. ,
This letter contains the following new commitment:
Although departments have previously been directed to turn in any VETIP '
information held in local files, another review will be directed. In parallel with the station's commitment to retrieve all vendor technical manuals and control them from a central library, system / component engineers and maintenance personnel will be required to review local files and forward to VETIP for processing any locally held information that is a candidate for inclusion in a vendor technical manual. This review will be tasked by station manager letter and formally acknowledged by department head signature that it has been accomplished. This action will be completed in May,1997. (NTS# 2371009601402A) l l
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. USNRC Page 3 March 6,1997 If there are any questions concerning this letter, please refer them to Mr. Frank Spangenberg, Dresden Station Regulatory Assurance Manager, at (815) 942-2920, extension 3800.
Sincerely, teph n Perry Site Vice President Dresden Station cc: A. Bill Beach, Regional Administrator, Region III P. L. Hiland, Branch Chief, Division of Reactor Projects, Region III J. F. Stang, Project Manager, NRR (Unit 2/3) 1 Senior Resident Inspector, Dresden Office of Nuclear Facility Safety - IDNS File: Numerical l
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ATTACIIMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-010: 237: 249/96014 VIOLATION:
During an NRC inspection conducted on October 21 through December 6,1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
1 Dresden Technical Specification 6.2.A required, in part, that written procedures shall be implemented covering the activities referenced in Appendix A of Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2, February 1978. Administrative and maintenance procedures were referenced in RG 1.33. )
J Dresden Administrative Procedure (DAP) 02-10, " Control of Vendor Equipment l Technical Information," Revision 5. Section E.5 required that existing, uncontrolled, and (
incoming Equipment Technical Information shall be reviewed and added to VETIP so that the latest or most applicable information is avi sable for station use.
Nuclear Engineering Procedure (NEP) 07-04, "VETIP Process Control," Revision 0, Section 5.2.1.2, required that the person receiving new vendor manual revision data shall forward the information to the VETIP Coordinator attached to the VETIP Authorization i Form or suitable equivalent.
Contrary to the above, on May 29,1996, new emergency diesel generator test valve technical information was not forwarded to the VETIP coordinator nor incorporated into the controlled manual.
1 REASON FOR VIOLATION:
This violation was caused by a System Engineer's failure to follow Dresden Administrative Procedure (DAP) 02-10, " Control of Vendor Equipment Technical Information." Specifically, the engineer failed to take action to update a technical manual when a new component was installed in the diesel engine in January,1996. In addition, the station VETIP procedure that was effective at the time of the violation did not contain the detailed instructions to assure timely technical manual revisions.
i At a vendor conference in June,1994, the station System Engineer for the site diesel engines obtained a vendor bulletin that advertised a cylinder indicator valve that would provide improved test data collection and trending capabilities resulting in earlier indication of cylinder degradation. This valve could be used in lieu of the cylinder test
- valve currently installed in the engine. This System Engineer initiated a work request in October,1995 to replace the existing cylinder test valve with the valve from the bulletin.
- This modification was accomplished in January,1996. (Note
- The revised vendor information should have been incorporated into the technical manual by this time. This l date differs from that cited in the violation.) The vendor technical manual for this diesel engine containing the pre-modification cylinder test valve description was routed to and approved by the same System Engineer in April,1996. When verifying the technical r manual, the System Engineer failed to recognize that the manual pictured and discussed the "old" style cylinder test valve. Furthermore, the System Engineer kept the technical
, information on the new valve cylinder in a local file instead of the control file repository.
Following an incident in November,1996 where the new type cylinder test valve was
- separated from Unit 3 diesel during engine operation, the NRC identified the mismatch .
between the technical manual and actual equipment installed.
Dresden Administrative Procedure (DAP) 02-10, " Control of Vendor Equipment Technical Information," Revision 5 was in effect at the time of the violation. Section E.5 required all station personnel to " submit new or revised VETI (Vendor Equipment Technical Information) for potential inclusion in the VETI Program." However, this requirement was vague and open to user interpretation when describing what sources initiate changes to be included in the VETI Program.
The vendor has not issued a revision to the technical manual that describes the "new" type cylinder indicator valve. When contacted in February,1997, a vendor spokesperson stated l
- that no technical manual change will be issued addressing the replacement valve as new diesels will be delivered with the "old" style cylinder test valve installed.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Upon identification of the discrepancy between the technical manual and the diesel, an investigation was conducted to determine the cause.
The technical manual was updated with the parts bulletin by VETIP and approved by the System Engineer on December 2,1996.
The System Engineer was counseled on the importance of following station procedures.
The engineer now understands the importance of procedural compliance. Additionally, this engineer was cautioned on the need to capture technical information associated with equipment upgrades that come from sources other than the original equipment vendor.
s" CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
The station's VETIP program has been mngthened with the issuance of new/ revised procedures to provide clear directions as to what sources to review for information to be included in the VETIP manuals. Specifically, NEP 07-04, l "VETIP Process Control," was developed and implemented during July,1996. i NEP 07-04 clearly points out what sources initiate changes to the VETIP manuals and provides a timeline for inclusion of the changes into the manuals. Also, DAP 02-10 was revised in July,1996 to direct station use of NEP 07-04.
Although departments have previously been directed to turn in any VETIP information held in local files, another review will be directed. In parallel with the station's commitment to retrieve all vendor technical manuals and control them from a central library, system / component engineers and maintenance personnel will be required to review local files and forward to VETIP for processing any locally held information that is a candidate for inclusion in a vendor technical manual.
This review will be tasked by station manager letter and formally acknowledged by department head signature that it has been accomplished. This action will be completed in May,1997. (NTS# 2371009601402A) l DATE WHEN FULL COMPLIANCE WILL BE ACIIIEVED:
Full compliance was achieved on December 2,1996, when the parts bulletin related to the new style cylinder valve was added to the diesel generator VETIP manual. As previously committed all safety related vendor technical manuals will be reviewed and update by May 30,1997 l
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