ML17177A612
| ML17177A612 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/02/1992 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A611 | List: |
| References | |
| 50-237-92-09, 50-237-92-9, 50-249-92-09, 50-249-92-9, EA-92-088, EA-92-88, NUDOCS 9209090091 | |
| Download: ML17177A612 (5) | |
Text
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NOTICE OP VIOLATION Commonweal th Edison )'.
- Docket,Nos.
50-237 *C)lnd 50".'"249.
Dresden Nuciear station License' *Nos:* DPR-19 and DPR-25
.EA.92-088 Uni ts 2 and 3.
During an NRC inspection conducted on March 23 througn May 1, 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:
A.
Technical Specification 3.5.A.5 states, in part,- that from and after* the date that the*low pressure coolant injection (LPCI) subsystem is made or found to be inoperable for any*
reason, reactor operation is permissible only during the succeeding seven days unless it is sooner made operable.
Technical Specification 3.5.A.8 states, in part, that. if the' requirements of 3.5.A cannot be met, an orderly shut.down of
- the reactor shall be initiated and the reactor shall be in_
theCold Shutdown condition within*24 hours.
Contrary to the above, from.January. 4, 1991, unii1*.
. Augus~ 10, 1991, for periods greater than seven days, reactor.operations *continued with.the LPCI system inoperable, in that, reactor recirculation valve 2-202-5A, a motor operated valve (MOV) required to close to ensure LPCI injection into the reactor vessel following*a loss-of~
coolant accident, was incapable of.performing its safety function due to a~ incorrectly set torque switch on the MOV,
- and the licensee did not initiate _an orderly shutd9wn of the.*
- reactor and place it in cold shutdown.within.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Th.is is a Severity. Level. III violation (Supplement I.)
- B.
10 CFR_Part 50, _Appendix*B, Criterion V~ "Instructions~
Procedures,** and Drawings, " requires; in part, that activities.affecting quality be prescribed by doclimented instructions*, procedures, or drawings of a type appropriate to the circumstances.
- Contrary to' the above, as of May 1, 1992, engineering deveiopment and submittal of thrust values to support-the.
motor operated valve testing program at Dresden, an i:icti vi ty affecting quality~ was not prescribed.by any procedure.
Also as of May 1, 1992, no procedure existed to describe corporate engineering required actions when a condition adverse to quality was-ident*ified within the. motor operated**
valve program.
This is a. severity Levei IV violation (Supplement I) 51 ()~~ Qt!JC/,,
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September 2s 1992
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10 CFR Part_. 50, Appendix -B,... cri;te.rion XVI,
~*corr~ctive.
. Action, II. requires, in part,' that measures 'be "established 'to assure that.conditions.adverse to quality, such as deviations and nonconformances, are. promptly identified and corrected.
In the.case of significant conditions adverse to quality, the measures sh~ll assure that the cause of.the condition is determined and corrective action taken*to
- preclude repetition.
The identification of the significant..
- condition adverse to quality, the.cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Contrary to the above; *on Auqust-20. 1 1991, corporate engineers identified that the zero points _on 17 motor operated valves (MOVs) deviated from their previously*
selected values, *the thrust.valves on 4 MOVs did not conform to the thrust windows provided to Dresden Station, and the.*
causes and corrective action taken for these nonconformances were not d.ocumented.
This is a Severity Level IV violation (Supplement I).
- o.
10 CFR Par~ 21.21(a}(l} (i). requires, in part, that.each
- individual,. corporation,* or other entity* subject to the
. regulations in this part adopt appropriate procedures to
.. provide for evaluating* deviations.
Contrary to the above, as of.February 5, 1992, the licensee failed to adopt appropriate procedures to provide for evaluating deviations.
Specifically, Dresden Administrative*.
Procec;lure OAP 2-a, "Deviations," did not provide sufficient quidanceto ensure the evaluation of' deviations involving software programs, methodologies, arid training.
. This is a severity Level IV violation (Supplement VII). *
- 10. CFR so, Appendix B,. Criterion V requires, in part,. th.at activities affecting quality shall be prescribed by
- documented instructions; procedures, or drawings, of a type appropriate to the circumst~nces*and.shall be accomplished in accordance with these instructions, procedures, or drawings.
. 1.
Dresden Administrative Procedure (OAP) 9-11~."Procedure
.usage and Adherence," Revision 3, step C.2.e(J),
requires, in part, that if unexpected responses occur then certain applicable information will.be documented on a Procedure Comment Supplement,.Form 9:...11A.
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OAP 9-11~ Revision 3, Step C.5.o(4), requires, in part, that if other than direct observation is utilized, then
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September 2~ 1992
., the init~als of *th~ person* pe'rform~ng the. observation must be included with the* initials of the person actually performing the step.
OAP 7-14, "Control and criteria for Locked Equipment and Valves," Revision 2, Step *a.3.a,* requires, in part,
- 'that if plant conditions require* a* locked valve to be.
- positioned in a manner other than that indicated on the locked equipment. checklist, the valve may *be unlocked
- and repositioned either by an approved procedure or an outage checklist..If a valve is to be unlocked without*
.a corresponding procedure or an -outage checklist an*
operator is required to be in contimipus att.endance.
Contrary to the above:
- a.
On March 7, 1992, during performance of Dresden Operating Surveillance (DOS) 6600-03, the Unit 2/3 emergency diesel gener_ator failed to. trans_f er to.
Unit 3 power when expected.* Forin 9~11A, Procedural Comment Supplement, was not.completed in accordance with OAP 9-11, Revision* 3, step C.2~e(3), although* the unexpected system* response requ,ired it to be used.
- b..
On March 7, 1992, duririg performance of DOS 6600- *..
03, the test leader failed to document the initials of the individuals actually performing the survelllance steps as required by DAP. 9-11,.
- Revis.ion.3, step c.. s~o(4).
- c.
- on March 20, 1992, the requirements established in DAP 7-14, Revision 2, Step B.3.a, were not implemented when the standby liquid contro~
storage.tank air sparge inlet valve was opened and unlocked *. Personnel did not use an approved procedure or outage checklist, and an operator was not in continuous attendance~
This is a Severity Level IV violation (Supplement I).~.
F.
10 CFR 50.72(b)(2)(ii) requires, in part, that the licensee notify the NRC as soon as practical and in all cases, within four hours of the occurrence ~f any event or condition th~t
- results in *manual or automatic actuation of any engineered safety feature (ESF)
- Contrary to the abo.ve:.
- 1.
On March 14, 1992, the high pressure coolant injection (HPCI) suction valve u:hexpectedly opened during the
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.. Unit 3 int~grated lea~ J:"at~.~est -\\l!hen high
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Shift operations management failed-to recognize the.
- . valve opening as an unplanned ESF actuation, and did not report it until March 18, 1992~
I.*
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On April 19,* 1992*,* at 6:40p.m., the low pressure coolant injection (LPCI) minimum flow valve unexpectedly closed twice during*the p~rformance of.
surveillance DOS 1500-1 on Unit 3.
- Shift operations management did not recognize the closings of the minimum flow valve as an unptanned ESF actuation, and did* not report the closures Until April 20, 1992,* at
- 10:16 a.m.
This a*severity Level IV violation (Supplement I).
G.
OAP 10~(>2,. "10 CFR _so. 59 Review Screening and Safety Evaluation I " Revision 5, Step F. 1. c ( 5),- requires in part, that the 10 CFR 50.59 safety evaluation/screening preparer ref er to Checklist 5 (Worksheet) for supplemental help in fil-ling out the so. 59 safety evaluation/screening form.
Checklist 5 asks if safety related circuits.are isolated and separated* from non-safety related circuits.
Contrary to the above, Checklist 5 was not used by the
- preparer on March 19, 1992, when performing a safety
. evaluation for the installatiori of measuring and test equipment under a temporary alteration to monitor voltage on the auxiliary compartment of ESF 4160 VAC Bus 34-1.
The temporary alteration provided an indirect interface between Class lE electrical equipment and nonsaf ety measuring and test eq\\.tipment.
This is a Severity Leve_l IV violation* (Supplement I).
Pursuant to the.provisions of*10 CFR 2.201, commonwealth Edison company (Licensee) is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, 'ATTN: *Document Control Desk, Washington, o.c. 20555 with a copy to the Regional Administrator, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy* to the NRC
~esident Inspector at the.Dr.esdeh 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 sho\\llq i.nclude for.each violation: -(1)
- _the reason for.the vioTatfori,-- or, if contested, the basis for*
disputing.the violation, (2) the corrective steps that* have been taken and the results achieved, (3) the corrective steps that
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Notice of Vi6lation 5
Septemb~r t, 1992 will be taken to *avoid further violati~ns,, and (4) the q~te when full compliance will be achieved.
If an adequate reply is not received within the. time specified in.this Notic:;:e, an order or a
- demand for information may be isf?tied as to why the license should not be modified, sus*pended, or revoked or why such. other actfon.
as may be proper.should not be taken.
Where good cause is shown,
- consideration may be given t_o extending the response tini.e.
Under the authority of Section 182 *of the Act,. 42 U.S.C. °2232, this *
. response Sh(ill be submitted under oath or affirmation.
FOR THE NUCLEAR REG~TORY COMMISSION a~ tL_JJc;; ~
A. Bert Davis Regional Administrator Dated.~t Glen Ellyn, Illinois*
this 2nd day of September 1992
.-.