ML17191A620
| ML17191A620 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17191A618 | List: |
| References | |
| 50-237-98-13, 50-249-98-13, NUDOCS 9804270397 | |
| Download: ML17191A620 (27) | |
See also: IR 05000237/1998013
Text
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U.S. NUCLEAR REGULATORY COMMISSION
Docket Nos:
License Nos:
Report No:
Licensee:
Facility:
Location:
Date:
Inspector:
Approved by:
REGION 111
50-237, 50-249
50-237/98013(DRP); 50-249/98013(DRP)
Commonwealth Edison Company
Dresden Nuclear Station, Units 2 and 3
6500 N. Dresden Road
Morris, IL 60450
March 18, 1998
R. Lerch, Project Engineer
M. Ring, Chief
Reactor Projects Branch 1
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Report Details
- I. Operations
A Summary of the Enforcement Conference
On March 18, 1998, members of the NRC Region Ill staff and members of Commonwealth
Edison Company, with NRC Nuclear Reactor Regulation staff and Office of Enforcement staff
members by telephone, met in the Region Ill office to discuss the issues summarized below.
These issues were originally identified in Inspection Report No. 50-237/97006; 50-249/97006 and
the apparent violations were identified in Inspection Report No. 50-237/98006; 50-249/98006.
A summary of events is as follows:
During discussions with another Commonwealth Edison nuclear facility on February 21,
1997, the Dresden staff became aware of a design basis issue associated with inerting or
deinerting*of the containment. If, during these activities, a loss of coolant accident
occurred when the drywall was directly connected to the atmosphere of the pressure
suppression chamber (torus), a percentage of the containment pressure suppression
function would be bypassed until the system was automatically realigned to the
suppression pool. On March 28, 1997, the NRC observed that the Unit 3 drywall and the
torus atmosphere were directly connected while Dresden operators were deinerting the
Unit 3 containment with the plant in power operation. Subsequent discussions between
the NRC and *the Dresden site management team resulted in Dresden management's
acknowledgment that deinerting with this system configuration was not addressed in the
Dresden licensing basis and that additional engineering evaluations were required to
determine if this was an acceptable practice. On April 10, 1997, questions by the NRC
prompted the Dresden site management team to postpone a preplanned evolution to
connect the Unit 2 drywall to the torus atmosphere and deinert the Unit 2 containment
while the unit was in power operation.
During the discussion at the meeting, the licensee agreed with the issues as described in the
inspection reports, provided a summary of the causes and corrective actions planned and taken,
and provided a review of the safety significance of the issue. A copy of the licensee's handouts
is attached to this report.
Following subsequent review and discussion, the NRC staff concluded that two violations had
occurred.
03
Operations Procedures and Documentation
03.1
Drywell and Torus lnerting and Deinerting Practices (71707)
The first violation pertains to 10 CFR Part 50, Appendix B, Criterion Ill, "Design Control," which
required Commonwealth Edison to establish measures to assure that the design basis of a safety
system be correctly translated into procedures. This requirement was not met due to the failure
of the Dresden staff to place procedural restrictions on the deinerting or inerting processes to
ensure that the containment pressure suppression function was not degraded during these
activities. During the predecisional enforcement conference, the Dresden Staff members
provided sufficient information to demonstrate that the containment design pressure would not
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likely be exceeded and that the containment would function under accident conditions while
operators were deinerting the plant. However, this violation demonstrated that the Dresden
engineering and operations staff failed to translate design information into procedures when
deinerting and inerting procedures were initially written. In addition, the Dresden engineering and
operations staff failed to ensure this information was incorporated during subsequent procedure
reviews and revisions. The failure of the Dresden staff to incorporate design requirements into
procedures is a violation of regulatory requirements that have more than minor safety
significance. (50-237/98013-01; 50-249/98013-01)
07
Quality Assurance in Operations
07.1
Licensee Self-Assessment Activities (40500)
The secon~ violation pertains to 10 CFR Part 50, Appendix 8, Criterion XVI, "Corrective Action,"
which required Commonwealth Edison to assure that conditions adverse to quality are promptly
resolved. This requirement was not met because of the Dresden Staff failure to promptly resolve
an issue that was adverse to quality pertaining to the deinerting or inerting of the containment
while the drywell was directly connected to the torus atmosphere. This issue was first identified
to the Dresden Staff by the staff at LaSalle, another Commonwealth Edison nuclear facility. In
addition, subsequent to that notification this issue was reemphasized to the Dresden staff and
site management team by the NRC when NRC inspectors found that operators had placed Unit 3
in this configuration on March 28, 1997. Subsequently, on April 10, 1997, operators had planned
to place Unit 2 in this configuration. This violation demonstrated a lack of management oversight
to ensure that prompt corrective action was taken when a condition adverse to quality was
identified. In addition, this violation is a concern to the NRC because of the extensive amount of
NRC involvement that was required before the site management team acknowledged that a
condition adverse to quality required resolution. The failure of the Dresden staff to assure that a
condition adverse to quality was promptly resolved is a violation of regulatory requirements that
. have more than minor safety significance. (50-237/98013-02; 50-249/98013-02)
08
08.1
08.2
08.3
08.4
Miscellaneous Operations Issues (92700)
(Closed) EEi 50-237/98006-01; 50-249/98006-01: Potential to Bypass Containment
Suppression due to Inadequate Safety Evaluation and Review of Procedures: The issues
and associated corrective actions were reviewed in Inspection Report No. 50-237/97006
and this report. Further action will be tracked by the items opened in this report.
(Closed) EEi 50-237/98006-02; 50-249/98006-02: Deinerting 'the Drywell and Torus. The
issues and associated corrective actions were reviewed in Inspection Report
No. 50-237/.97006 and this report. Further action will be tracked by the items opened in
this report.
(Closed) Unresolved Item 50-237/98006-03; 50-249/98006-03: Potential failure to make a
four hour report of an unanalyzed condition. The four hour report was made after
prompting by NRC inspectors. The necessity for NRC involvement was the subject of the
corrective action violation in this report. The timeliness of the report issue was not
significant. This item is closed.
(Closed) Violation 50-237/98013-01: 50-249/98013-01: Failure to incorporate the design
requirement for torus pressure suppression into containment inerting and deinerting
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procedures. This was an old design issue addressed by the licensee in
LER 50-237/97-011. No further actions were required; this item is closed.
V. Management Meetings
X1
Meeting Summary
Licensee managers met with Region Ill managers in an enforcement conference in the
Region 111 office on March 18, 1998. The licensee acknowledged that corrective actions
for the inerting issues had been initiated at the prompting of NRC inspectors, but that the
potential for the event and its safety significance were extremely low. No proprietary
information was identified.
Attachment: Licensee's Handout
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PARTIAL LIST OF PERSONS INVOLVED IN THE CONFERENCE
Licensee
J. Perry - BWR Vice President
D. Helwig - Senior Vice President NGG
J. Heffley.- Dresden Site Vice President
R. Freeman - Dresden Engineering Manager
F. Spangenberg - Regulatory Assurance Manager
S. Kuczynski - Operations Staff
D. Winchester - Q&SA Manager
A Beach, Regional Administrator, Region Ill
M. Dapas, Deputy Director Division of Reactor Projects
R. Lerch, Project Engineer, DRP Branch 1
K. Riemer, Senior Resident Inspector, Dresden
J. Heller, Enforcement Coordinator, Riii
B. Berson, Regional Council
NRC by telephone
R. Capra, Director, Project Directorate 111-2, NRR
T. Reis, Enforcement Coordinator, Office of Enforcement
J. Stang, Project Manager, NRR
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LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-237/98013-01; 50-249/98013-01 VIO
50-237/98013-02; 50-249/98013-02 VIO
Closed
50-237/98006-01; 50-249/98006-01 EEi
50-237/98006-02; 50~249/98006-02 EEi
50-237/98006-03; 50-249/98006-03 URI
50-237/98013-01; 50-249/98013-01 VIO
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Design Control of Drywell inerting
Corrective Action for Drywell inerting
Design Control of Drywell inerting
Corrective Action for Drywell inerting
Timeliness of 50. 72 report
Design Control of Drywell inerting
EEi
LER
NTS
LIST OF ACRONYMS USED
Division of Reactor Projects
Escalated Enforcement Item (Apparent Violation)
Licensee Event Report
Loss of Coolant Accident
Nuclear Tracking System
Operating Experience
Problem Identification Form
Plan-of-the-Day
Safety Evaluation Report
Unresolved Item
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- ComEd Dresden Station
Containment Pressure Suppression Bypass
Pre-Decisional *
Enforcement Conf ere nee
March 18, 1998
Agenda
Opening Remarks
Technical Background
Discussion of Apparent Violations
- Chronology*
- Causes and Corrective Action
Safety Significance *
Corporate Perspective
- closing Remarks
M. Heffley
R. Freeman
F. Spangenberg
R. Freeman
. D. Helwig
M. Heffley
2
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Opening Remarks
- Expectations
- Ownership
- Communications
- Lessons Learned
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-
Technical Background
21
Rx
310'
Chimney
APCV_l
7505-B
23
62
Standby Gas Treat~ent System
63
18" Vent/Purge
24
to Chimney
4
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Discussion of Apparent
Violations/Unresolved Item
- Apparent Violations:
- Failure to Translate Design Information to
- Procedures
- Failure to Promptly Correct Procedure
Deficiencies
- Unresolved Item:
- Timeliness of Emergency Notification System
Report
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Chronology
Thursday
2/20/97
LaSalle SBGT Issue Identified
Friday
2/21/97
LaSalle A.M. Call Report
Wednesday
3/5/97 .
Engineering P~er Group Meeting
Thursday
3/20/97
. ISEG Initiates OPEX Review of Oyster
Creek Potential Bypasses
Monday
3/24/97
LaSalle LER Issued; ISEG Identifies
Potential Bypass Associated with "Hard
Cards"
Friday
3/28/97
.Inspector Questions Dresden Unit 3
Operators About LaSalle Issue
Saturday
3/29/97
Shift Manager E-Mails Plant Engin*eering
Supt. Regarding SBGT Problem
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Sunday
3/30/97
Monday
3/31/97
Friday*
4/4/97
Monday
4/7/97
Chronology
Shift Manager Meets with Plant
Engineering Supt. Regarding LOCA with
Vent Valves Open
NRC Inspector Asks Shift Manager About
Follow-up on LaSalle Issue; SER Provided
NRC Inspector Recommends LaSalle LER
be Reviewed; Assigned to Design
Engineering
Engineering Begins LaSalle LER
Investigation; ISEG Oyster Creek Review
Identifies Second Potential Bypass
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Friday
Monday
Wednesday
Chronology
4/7-11/97
4/11/97
4/14/97
4/16/97
4/14-25/97
Engineering Resolves Recombiner and
SBGT Issues; ISEG Review Identifies
Additional Bypass Pathways
Inspector Questions Operators
Regarding LaSalle Issue; Operators
Delay Evolution
PIFs Initiated
. PIF Screened-Assigned to Design ..
Eng.ineering
Procedures Revised to Prevent Partial
Suppression Pool Bypass*
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- Chronology
Friday
4/25/97
PORC Review and Approval of
Actions for Bypass Issue*
Tuesday
4;2*9;97
Decision .to Report Under
Wednesday
4/30/97
ENS Report (50.72(a)(2)(i))
Saturday
5/10/97
ISEG Independently Reviewed
. Deinerting Procedures
Thursday
5/29/97
Dresden LER Filed
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Chronology - Conclusions
- Missed Opportunities
- Lack-of Ownership
- Understanding of Issue
- Thirty Days From LaSalle LER to Resolution
- *Application of Reporting Criteria
- ISEG Reviews
'II*
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- -Issue, Cause & Corrective Actions
Issue #1:
- Failure to Translate Design Information Into Procedures
Cause:
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- Understanding of Design Basis Requirements When Procedures Were Written and
During Subsequent Review
Corrective Actions:
Immediate Action:
- Revised Operating Procedures to Eliminate Potential Bypass
Action to Prevent Recurrence:
- Design Basis Recon~titution
- Dresden Engineering Assurance Group
- 50.59 Training
- Engagement of Corporate Engineering
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Issue, Cause & Corrective Actions
Issue #2:
- Failure to Take Prompt Corrective Action
Cause:
- Lack of Management Oversight to Correct Problem
- Effectiveness of Process for Responding to ComEd OPEX
Information
- Communication Weaknesses
- PIF Timeliness
Corrective Actions:
Immediate Action:
- * The Four Operating Procedures Were Revised to Prevent Potential
Bypass
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Issue, Cause & Corrective Actions
Issue #2 (continued):
Actions to Prevent Recurrence:
- Nuclear Operations Notification (NON) Process
- New Corrective Action Process Training (PIF Thresholds)
- Operations Process for Follow-up of Inspector Questions
- Corporate Engineering Oversight
- Engineering Performance Improvement Training
-
PIF Threshold. and Initiation Expectat~ons .
-
Expectations for Engineers
-
Professional Practices
- Expectations for Engineers Handbook
- SVP Communicated _Expectations on Problem Follow-up
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All Hands
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Engineering, Regulatory Assurance and Operations
c.'
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Issue,* Cause & Corrective Actions
Issue #2 (continued):
Future:
- * A Dresden Case Study Will Be Developed To Provide
Lessons Learned Training for Operations, Engineering and
Regulatory Assurance. (April 30, 1998)
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Issue, Cause & Corrective Actions
Issue #3:
- Timeliness of ENS Report
Discussion:
- Application of Reportability Requirements .
Actions:
- Regulatory Assurance and Operations Training on
Reportability Requirements and Their Application
(7 /1/98)
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Safety Significance
- Low Safety Significance
- Valves Opened Infrequently and for Short Periods
- Probability of Conditional Event Extremely Low (<<lxI0-6)
- Containment and Suppression Pool Would Have Performed
Safety Functions
- - Design, Test and Analyzed Post-LOCA Pressures Not
Exceeded
-
- Radiological Consequences Bounded
....
I
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Formal Review Required
NSSS & Other Vendor Letters
Westinghouse NSALs, TBs, etc.
NRC - INs, IEBs, GLs
Initial Sc-
for Review
NTS Entry
to Document
& File
Cognizant
Dept(s)
Action
Plan
Industry OPEX
Information Only
NRC-Daily Event Reports,
HQ Daily Report
Initial Screen
N
Discard/File
y
Cognizant
Dept(s)
Dept
Head
Coo rd
lose Revie
TS Item
- .*
- *
- '
<
NTS ltem(s)
Track Follow-up
Actions
17
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INPO Findings
NO Vs
From Other
Sites
~**
NONs
OPEX Coordinator
Distributes for INFO &
Appropriate Action
SME/
______
..,
Cognizant Dept
Head
'1..
- *
t
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Internal ComEd
NTS
Item
Ni
Distribute for
Information/
- Discard
y
Coordinator
Generates PIF
Enter
Corrective
Action
System
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OPEX Program
Changes Planned for 1998
- Revise the OPEX Process to Incorporate NON
Require~ents
- Require NON Log to Record Disposition of All
NONs
- Change Significant Even~ Notifications (SENs) to
"Formal Review Required"
- Other Improvements Under Development
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Closing Remarks
. Overall Response Weak
Systems Not Degraded or Incapable of Performing
Intended Safety Functions
Site Specific and Corporate Action
A
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