IR 05000237/1985033

Submits Conclusions Based on Review of Info Presented at 851119 Enforcement Conference & in Re Violations Noted in Insp Repts 50-237/85-33 & 50-249/85-29.Escalated Enforcement Action Unwarranted.Notice of Violation Encl

ML17199H733
Person / Time
Site:	Dresden
Issue date:	12/26/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML17199H734	List: IR 05000237/1985033 IR 05000930/2010021
References
NUDOCS 8512300374
Download: ML17199H733 (3)

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Docket No. ~¥.S ;?,;"

Docket No. 50-2 111i5-D?-1 Commonwealth Edison Company ATTN:

Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

DEC 2 6 ~985 By letter dated November 14, 1985, (cop~ enclosed) Region III transmitted to you Inspection Reports 50-237/85033(DRS) and 50-249/85029(DRS). These reports documented the results of an unannounced safety inspection conducted between September 30 and October 21, 1985, to establish the adequacy of fire protectton program implementation at Dresden Nuclear Power Station, Units 2 and As ¥ discussed in the November 14 letter, two issues were identified during the f:.

inspection which were under consideration for escalated enforcement actions.~~

These issues were failure to install fire detectors on the refueling floor asr required by license condition and failure to effectively implement the fire protection program in accordance'with 10 CFR 50.48 as evidenced by numerous and, in some cases, ~ecurring deficiencie On November 19, 1985, an enforcement conference was held in the Region III office with you and members of your staff to review these issues and obtain additional information regarding their significance. A list of attendees is contained in Enclosure 2 to this letter~ During this conference, Region III management expressed concerns relative to your failure to satisfy an explicit license* condition requirement and your apparent failure to provide sufficient resources t~ effectively implement the Dresden Fire Protection Progra.

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In response to the concern expressed over your failure to comply with an explicit license condition, you presented information demonstrating that (1) failure to install fire detectors on the refueling floor was of minor technical sigpJficance based on the low fire loading and the lack of safe shutdown equi~ment in that area; (2) the Office of Nuclear Reactor Regulation had been infonned in a letter dated February 25, 1980, that fire detectors were not necessary on the refueling floor; and (3) you had undertaken a review of regulatory, commitment, and code compliance at your operating stations which had identified other issues requiring resolution and would likely have identified the failure to install the subject fire detectors. It was your contentiOn that item (2) above demonstrated that you were aware of and sensitive to the license condition requiring the installation of refueling floor fire detectors and that item (3) demonstrated your conmitment to ensuring that all required fire protection features had been implemente PDR ADOCK 05000237 Q

PDR

Commonwealth ~dtson Company 2 -

DEC 2 6 1985 In response f~\\~h~*:c~~~ern expressed over your apparent failure to effectively implement the fire protection program at Dresden, you presented information on the existing fire protection staffing and experience at Dresden but indicated that the matter was under review and that additional fire protection expertise may be indicate Your response to the issues discussed in the November 19 Enforcement Conference was supplemented in a letter dated December 2, 1985, submitted to the Office of Nuclear Reactor Regulation discussing the preliminary results of your review of the status of compliance with fire protection requirements at Dresden and Quad Cities. This letter identified several outstanding deficiencies, proposed methods for resolution, established completion dates, and requested approval of the proposed resolution Region III reviewed the information presented at the November 19 Enforcement Conference and contained in your December 2 letter and has reached the following conclusions: Failure to install fire detectors on the refueling floor and failure to effectively implement your fire protection program at Dresden are violations of NRC regulation.

Failure to satisfy a license condition is of significant regulatory concern; however, you have demonstrated that, in the case of the refueling floor fire detectors, the safety significance is low and that you were actively pursuing a program to ensure that compliance would have been achieved. Additionally, your December 2, 1985, letter provides us assurances that this and similar issues are being aggressively pursued in a timely fashio.

With regard to the failure to effectively implement the fire protection prograITT,'. at Dresden, you demonstrated that you had previously identified concern~ in that area and were pursuing resolution of those concerns *

. During the enforcement conference, you verbally committed to bring additional resources to bear in this are Based on the above, it is. concluded that while escalated enforcement action is not warranted. for your failure to install fire detectors on the refueling floor and your f~ilure to effectively implement the Dresden Fire Protection Program, issuance of a Notice of Violation is appropriate. Accordingly, Enclosure 1 to this letter transmits to you a Notice of Violation for which a written response is require In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Roo Commonwea 1th-- Edi son. Company

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DEC 26 1985

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The responses~."afrected by this 1 etter 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..

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Enclosures:

1. Notice of Violation November 19, 1985 Enforcement Conference Attendance List 3. *Letter dtd 11/14/85, NRC to Commonwealth Edison C cc w/enclosures:

D. L; Farrar,- Director of Nuclear Licensing D. J. Scott, Plant Manager DCS/RSB (RIDS)

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Licensing Fee Management Branch Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division RIII _

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Ramsey/mab 12/23/85 RIII 1%

Guld~mond l~>i.ilf~

Sincerely, James G. Keppler Regional Administrator

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