ML17180A635
| ML17180A635 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/11/1994 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Lyster M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17180A636 | List: |
| References | |
| EA-94-048, EA-94-48, NUDOCS 9403220047 | |
| Download: ML17180A635 (3) | |
See also: IR 05000237/1994002
Text
,, .
Docket No.
50-237; 50-249/1tf~~
EA 94-048
Commonwealth Edison Company
ATTN:
Mr. M. Lyster
Site Vice President
Dresden Station
6500 North Dresden Road
Morrisi IL 60450
SUBJECT:
(NRC INSPECTION REPORT NOS. 237/94002; 249/94002}
,.,Dear Mr. Lyster:
Enclosed are the results.of our inspection conducted by M. Leach, A. M. Stone,
and D. Chyu of this office on January 11 through February 22, 1994.
The*
inspectors reviewed activities authorized for your Dresden Nuclear Station,
Units 2 and 3. At the conclusion of the inspection, the inspectors discussed
the findings with members of your staff.
The areas examined during the inspection are identified in the report. Within
these areas, the inspection consi~ted of selective examinations of procedures
and representative records, interviews with personnel, and observation of
activities in progress.
The purpose of the inspection was to determine
whether activities authorized by the license were tonducted safely and in
accordance with NRC requirements.
Based on the results of this inspection, certain of your activities appeared
to be in violation of NRC requirements, as specified in the enclosed Notice of
Violation (Notice}.
The violation was cited for the failure to submit
1icensee event reports for repetitive failures of the reactor water level
instruments. This violation is of concern because it is important that
repetitive generic failures be recognized and reported to the NRC.
One apparent violation regarding inadequate and untimely corrective actions
regarding recurring drift and failures of reactor water level instruments was
i dent i fi ed.
For example, over the last. 8 months, 17 failures of Unit 2 level
instruments occurred.
We are concerned with the apparent lack of response to
these failures. This issue is being considered for escalated enforcement .
action in accordance with the "General Statement of Policy and Procedure for
NRC Enforcement Actions" (Enforcement Policy}, 10 CFR Part 2, Appendix C.
Accordingly, no Notice of Violation is presently being issued for this
inspection finding.
Please be advised that the number and characterization of
apparent violations described in the enclosed inspection report may change as
a result of further NRC review.
940322004
ADoc~ 0940311
G
5000237
MAH 1 l 1994
Commonwealth Edison Company
2
An enforcement conference to discuss this apparent violation has been
scheduled for 2:00 p.m. (CST) on March 21, 1994, at the Region III.office in
Lisle, Illinois. The decision to hold ah enforcement conference does not mean
that the NRC has determined that a violation has occurred or that enforcement
action will be taken.
The purposes of this conference are to discuss the
apparent violation, its cause and safety significance; to provide you the
opportunity to point out any errors in our inspection report;* and to.provide
an opportunity for you to present your proposed corrective action.
In
particular, we expect you to discuss why your eq4ipment dedication process did
not identify the manufacturing flaws in the Unit 2 instruments installed in
1993.
We also expect you to address your actions to ensure other previously
known or current emerging safety significant issues are identified,
appropriately prioritized, and corrected.
In addition, this is an opportunity for you to provide any information
concerning yourperspectives on 1) the severity of the violation, 2) the
application of the factors that the NRC considers when it determines the
amount of a civil penalty that may be assessed in accordance with Section
VI.B.2 of the Enforcement Policy, and 3) any other application of the
Enforcement Policy to this case, including the exercise of discretion in
accordance with Section VII.
You will be advised by separate correspondence
of .the results of our deliberations on this matter.
No response regarding the
apparent violation is required at this time.
Certain other activ.ities appeared to be a deviation from your commitments in
response to Generic Letter 89-13,
11Service Water System Problems Affecting
Safety Related Equipment,
11 as specified in the enclosed Notice of Deviation.
This deviation occurred because an operator failed to strictly adhere to a
procedure, and the required maintenance ~cti~n to restore the chemical
injection system was untimely. This deviation demonstrated that management
expectations regarding procedure adherence were not clearly conveyed.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notices when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to the
Notices, including your proposed corrective actions and the results of future
inspections, we will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,
11 a copy of
this letter, its enclosures, and your response will be placed in the NRC
Public Document Room .
Commonwealth Edison Company
3
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as retjuired
by the Paperwork Reduction Act of 1980, Pub. L. No. 96 .. 511.
Sincerely,
~- .. :-*: ~
-=~r
.....
Edward G. Greenman, Director ~-'I./
Division of Reactor Projects-~
Enclosures:
2.
Notice of Deviation
3.
Inspection Report
Nos.
50-237/94002(DRP);
50-249/94002(DRP)
cc w/enclosures:
L. Del George, Vice Pres.ident, Nuclear
Oversight & Regulatory Services
G. Spedl, Station Manager
J. Shields, Regulatory Assurance
Supervisor
D. Farrar, Nuclear Regulatory Services
Manager
OC/LFDCB
Resident Inspectors, Dresden
LaSalle, Quad Cities, Clinton
R. Hubbard
J. Mccaffrey, Chief, Public
Utilities Division
Licensing Project Manager, NRR
State Liaison Officer
Chairman, Illinois Commerce Commission
J. Lieberman, OE
J. Goldberg, OGC
J. Callan, NRR
bee:
PUBLIC - IEOl
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