ML17174B013
| ML17174B013 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/29/1991 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| EA-91-164, EA-91-165, NUDOCS 9112090021 | |
| Download: ML17174B013 (4) | |
Text
UNITED STATES NUCLEAR 'REGULATORY COMMISSION REGION Ill
- \\;dd l~os, _50 237; 50 *249 Licenses No. DPR-19; DPR-25 EA Nos.91-164; 91-165 Commonwealth Edison Company ATT~: Mr. Cordell Reed Senior Vice President Opus *west I I I 1400 Opus Place Dowr.ers Grove, IL 60515
Dear Mr. Reed:
799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 NOV 2 9 This confirms our plans as discussed between Robert Lerch of this 6ffice and Perry Barnes of your staff to conduct two enforcement conferences beginning at 9:00 a.m.. CST on December 10, 1991, at the _Holiday Inn, 1250 Roosevelt Road,
_Glen Ellyn, Illinois.
The purpose of this meeting is to discuss the findings of inspections performed at Dresden Station which identified apparent violations of NRC
- requirements *. The fitst conference is to discuss our conclusions regarding four recent events which, in aggregate, indicate a sig~ificant management
- breakdow:i.
The secor:c' conference is to address a failure to maintain primary containment requirements; and, additionally, a failure to maintain secondary containment requirements via a trackway door.
Inspection ~eports will be provid~d to you prior to our scheduled meeting; summaries of the apparent violations and concerns are provided in two enclosures for your review.
At each enforcement conference, you should be prepared to provide an oral presentation and a concise written handout addressing the root causes and contributing factors for the apparent violations and any corrective actions you have taken or planned.
If you have any questions regarding this meeting, please contact Robert Lerch at (708) 790-5500.
Enclosures:
As stated See Attached Distribution Sincerely, W~'~Oi'-_-
~
Edward G. Gr~;~;c~
Division of Reactor Projects 00..,1 911129 911209
Commonwealth Edison Company Distribution cc w/enclosure:
D. Galle, Vice President - BWR Operations T. Kovach, Nuclear Licensing Manager Dresden Station Manager DCO/DCB (RIDS)
OC/LFDCB Resident Inspectors LaSalle, Dresden, Quad Cities Richard Hubbard
. J, W. McCaffrey,.Chief, Publ~c Utilities Division Robert Newmann, Office of Public Counsel, Stite of Illinois C~nter Licensing Project Manager, NRR Nov 2 9 1991 2
ENCLOSURE 1 Operations.
This enforcement conference will address the apparent violations and our concerns related to four events at Dresden *. Those events were the torus heatup, the*out-of-sequence rod scram, the fuel handling error, and the' hydraulic control unit (HCU) spill. More specifically the issues are:
- 1.
- In regards to -the torus heatup event, we noted a number of instances where individuals failed to adhere to procedures including inadequate logs, inadequate turnovers, *;nadequate upward communications in the operations chain of command, and in~dequate oversight of plant conditions.
In addition, procedures for interim turnovers were found inadequate.
- 2.
- In regards to the HCU Spill, the procedure for maintaining an out-of-service bounda.ry was found inadequate and adherence to procedures by equipment attendants was ~lso inadequate.
- 3.
In regards to the out-of-sequence rod scram, two instances of failure to follow the procedure were identified along with operators "working around" equipment deficiencies.
- 4.
In regards to the fuel handling error, the problem began wit~ a failure to follow procedures. A lack of safety perspective on the part of the workers compounded the event when fuel moves were continued after da!llaging
- the mast and some fuel bundle bails. The supervisor was unaware of the need to promptly communicate an abnormal occurrence to management.
The lack of adequate abnormal procedures associated with fuel handling activities was a contributing factor.
- 5.
Common to these events is.a failure by workers to meet management expectations such that events l He thes.e are avoided or minimized.
In the aggregate, these events are considered to represent a management failure to take adequate corrective actions to assure that \\"orker performance will meet management expectations.
ENCLOSURE 2.
Containment This enforcement conference will address the apparent violations and our concerns regarding the inoperability of containment isolation valve 3-1601-24
- and the* 1ack of design control regarding the addition of an active retract.able seal to the Unit 2 outer trackway door.
Valve 3-1601~24 is an outer containment isolation valve on the drywell/torus purge system.
During the last operating* cycle on Unit 3, this valve was inoperable in that the valve was partially open when the valve operator was fully closed.
If a loss of coolant accident along with a single failure of one of the inner cont~inment isolation valves on that line had. occurred during the previous cycle, a direct path to atmosphere would have existed.
A retractable seal was installed on the outer trackway door for Unit 2. This*
retractable seal replaced a passive seal and was installed under the auspices of a work package. It was not. recognized as a modification by your staff. *..
After post installation testing, the seal was left retracted while secondary*
containment was required.
With the seal retracted, the required secondary containment negative pressure could not be maintained while*the inner trackway door was open.,
In additi~n to your discussion on the root cause and contributi~g facto~s for these violations, you should be able to discuss whether the corrective actions from the escal~ted 10 CFR 50.59 violation involving the Dresden sample valves (EA 90-168) should have identified the unauthorized modification that occurred on the trackway door* sea 1.
.. :* I
.;. :