ML17177A547
| ML17177A547 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/22/1992 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A546 | List: |
| References | |
| 50-237-92-14, 50-249-92-14, NUDOCS 9207280324 | |
| Download: ML17177A547 (2) | |
Text
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_ _,,_*-~~-"**~***""'~*---~----~----....._----:
NOTICE OF VIOLATION*
Commonwealth Edison Company Dresden Station, Units 2 and 3 Docket Nos.
50-237; 50~249 Li tense Nos. DPR-19; DPR-25.
During an NRC inspect.ion conducted on May 29, 1992, through July 6, 1992, violations of NRC requirements were identified.. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10.CFR Part 2, Appendix C {1992), the violations are listed below:
I.
10.CFR Pari 50, Appendix B, *c~iteririn V, "Jnst~uctions, Procedures. and Drawings," requires, in part, that activities *ffecting quality be prescribed by documented instructions, procedures, or drawings_, of a type appropriate to the circumstances, and be accomplished in.accordance with these instructions, procedures, or. drawirlgs.
- Contrary to the above:
- a.
On June 23, 1991, surveillance procedure SP 91-6-70, emergency diesel generator full load rated four hour fuel consumption te~t~
was not of a type appropriate to the circumstances in that it specified a range of 2500 ""' 2600 Kw instead of only the full load
- b.
rating of 2600 kW.
- On November 8, 1991 and April 28, 1991, an activity.affecting.
quality was not accomplished in accordance with the p~escribed*
Dresden administrative procedure {OAP).
Specifically, the acceptance criteria contained in procedure oos* 6600-1 were.altered by temporary change requests91-320 and 92-201, although OAP 9-06, "Temporary Changes to Procedures," sections 8.3 and 4,*did not
- a 11 ow the intent of a proc~dure to be changed through a temporary change.request.
. c.
On November 8, 1991 and April 28, 1992, an activity ~ffecting
. quality was not atcomplished in acctirdance with th~ prescribed administrative procedure. Specifically, no safety evaluati~n was performed when procedure DOS 6600-1 was revised by temporary change requests91-320 and 92-201, although OAP 10-02, "IO CFR 50.59 Review, Screening and Safety Evaluation," form 10-2A, steps I and 7, requires the user to perform a safety evaluation when a change to a procedure involving tests or experiments was made, unless the change was strictly editorial in nature.
- d.
On April 2, 1992, an activity affecting quality was not accomplished in accordance with the prescribed administrative procedure. Specifically, the 2/3 diesel generator's d*ay tank drain valve, a locked valve, was not verified locked closed after being manipulated, although OAP 7-14, "Control and Criteria for Locked Equipment and Valves," requires final valve position for a locked valve to be independently verified by.two individuals and documented in the unit lcig book.-
This is a Severity Level IV violation {Supplement I) 9207280324 920722" PDR *.
ADOCK 05000237 G
~-
2:
10 CFR Part 50, Appendix ~' Criterion V,
~Instructions, Procedures, ~rid**
Drawings,n requires, in part, that.activities. ~ffecting quality be _ -
prescribed by* documented instructions, procedures, or drawings, of a
- type appropriate to the.circumstances, and be accomplished in accordance
. with these instructions, procedures, or drawings..
Contrary to the above, on June 19, 1992, replacement of the.Unit 2 high
.pressure coolant injection auxiliary oil pump motor, *an activity affecting quality, was not prescribed by documented instructions or procedures appropriate to the circumstances as shown by the following.
examples:
- a.
The procedure improperly directed the motor leads to be reversed.
at the motor control center.
- b.
The procedure* provided no direction on how to assemble the flange connection for the oil pump's strainer.
- c.
No out-of-service instruction was provided prior to draining the HPCI oil tank.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR2.201, Conunonwealth Edison is hereby required to submit a written statement or explanation to the_ U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington D.C. 20555, with a copy to the U.S. Nuclear Regulatory Conunission, R~gion Ill, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the NRC Resident Inspector at the Dresden Nuclear Station within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
~l) the reason for the violation or, if contested,.the basis for disputing the violation, {2) the corrective steps that have been taken ~nd the results achieved, (3) the cor~ective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a demand for information may be issued as to why the license*
should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.;
Dated at Glen Eilyn, Illinois this ;l,1"!! day of..:r... ~ 1992