Text

Forwards Insp Repts 50-237/98-21 & 50-249/98-21 on 980714- 0825 & Notice of Violation Re Failure to Recognize Conditions That Required Entry Into TS Limiting Conditions for Operation
	ML17191A896
Person / Time
Site:	Dresden
Issue date:	09/24/1998
From:	Grant G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O; COMMONWEALTH EDISON CO.
Shared Package
ML17191A898	List: ML17191A896; ML17191A899; ML17191A900;
References
	50-237-98-21, 50-249-98-21, NUDOCS 9810020051
	Download: ML17191A896 (5)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION Ill

Mr. Oliver D. Kingsley

President, Nuclear Generation Group

Commonwealth Edison Company

ATTN: Regulatory Services

. Executive Towers West Ill

1400 Opus Place, Suite 500

Downers Grove, IL 60515 *

Dear Mr. Kingsley:

801 WARRENVILLE ROAD

LISLE, ILLINOIS 60532-4351

Septem~er 24, 1998

SUBJECT:

DRESDEN INSPECTION REPORT 50-237/98021(DRP); 50-249/98021(DRP)

AND NOTICE OF VIOLATION

Dear Mr. Kingsley:

On July 14, 1998, through August 25, 1998, the NRC performed an inspection at your Dresden

Nuclear Power Station. The enclosed report presents the results of this inspection.

During the inspection per-iod, a safety-conscious approach characterized the overall conduct of

activities at the Dresden station ... However, several issues showed that challenges to smooth

operation remained at the station.

Twice during this inspection period, operators failed to recognize conditions that required entry

into Technical Specification Limiting Conditions for Operation (LCOs). These failures

represented an emerging negative trend in operator performance, first documented in our prior

Inspection Report (50-237/98019; 50-249/98019). *These failures were of concern because

they represented a breakdown In the fundamental expectation that operators be able to

correctly maneuver through the Technical Specifications as conditions warrant. In our prior

'(,

report, we documented examples where although the operators failed to recognize entry into a

particular Technical Specification, the requirements themselves were not violated. However,

. during this inspection period, one of the failures to recognize an entry condition directly

... resulted in a failure to comply with the requirements of the Technical Specification.

Based on the results of this Inspection, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice)

and the circumstances surrounding them are described in detail in the subject inspection

report.

The first violation is of concern because it represents a continuing trend of operators failing* to

recognize and manage Technical Specifieations and LCOs. *Our previous inspection report,

issued August 7, 1998, treated this issue as a noncited violation because we understood that

the Dresden staff had Identified the Issue and had developed corrective actions to prevent

further occurrences. On August 6, 1998, the first of the two examples of operators not

recognizing Technical Specification LCOs occurred. At this point, we had not yet issued the

inspection report documenting the noncited violation and your corrective actions may not have

9810020051 980924

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0. Kingsley

-2-

been in place for sufficient time to be fully effective. Therefore, the NRC is refraining from

issuing a violation in this case. However, the problem of operator recognition and

management of Technical Specification LCOs caused the failure to comply with Technical

Specifications on August 21, 1998. In addition to addressing the violation of Technical

Specifications, your response to this violation should address why your corrective actions did

not prevent the events of August 6 and 21, 1998, and the larger issue of operator recognition

and management of Technical Specifications and LCOs.

The second violation is of concern because it resulted in an unexpected half scram, disabled a

protective system input, and was not prevented by your independent verification practices. We

are also concerned with the potential generic aspects of this issue. We recognize that your

staff identified the potential generic independent verification concerns prior to NRC

identification of the specific example cited in the enclosed report. However, this violation is

being cited consistent with NRC Enforcement Policy (NUREG 1600) which states that licensee

identification credit is not warranted when a .licensee identifies a violation as a result of an

event where the root cause of the event is obvious. In addition, the inspectors concluded your

investigation of the event was inadequate and initial corrective actions defaulted to the easy fix

of coaching individuals. Subsequent corrective actions were considered acceptable. The

NRC has concluded that information regarding the reason for this violation and the corrective

actions taken and planned to correct the violation and prevent recurrence is already

adequately addressed on the docket in this inspection report. Therefore, you are not required

to respond to this violation unless the description the.rein does not accurately reflect your

corrective actions or your position. In that case, or if you choose to provide additional

information, you should follow the instructions in the enclosed Notice.

Your are required to respond to this letter and should follow the instructions specified in the .

enclosed Notice when preparing your response. In accordance with 10 CFR 2. 790 of the

NRC's "Rules of Practice," a copy of this letter, the enclosures, and your response will be

placed in the NRC Public Document Room.

Docket Nos.: 50-237; 50-249

License Nos.: DPR-19; DPR-25

Enclosures:

1.

.Notice of Violation

Sincerely,

~ ?. J

GJ~Y k ~ire

1

~

Division of Reactor Proj~

2.

Inspection Report 50-237/98021(DRP);

50-249/98021 (DRP)

See Attached Distribution

0. Kingsley

-2-

been in place for sufficient time to be fully effective. Therefore, the NRC is refraining from

issuing a violation in this case. However, the problem of operator recognition and

management of Technical Specification LCOs caused the failure to comply with Technical

Specifications on August 21, 1998. In addition to addressing the violation of Technical

Specifications, your response to this violation should address why your corrective actions did

not prevent the events of August 6 and 21, 1998, and the larger issue of operator recognition

and management of Technical Specifications and LCOs.

The second violation is of concern because it resulted in an unexpected half scram, disabled a

protective system input, and was not prevented by your independent verification practices. we*

are also concerned with the potential generic aspects of this issue. We recognize that your

staff identified the potential generic independent verification concerns prior to NRC

identification of the specific example cited in the enclosed report. However, this violation is

being cited consistent with NRC Enforcement Policy (NUREG 1600) which states that licensee

identification credit is not warranted when a licensee identifies a violation as a result of an

event where the root cause of the event is obvious. In addition, the inspectors concluded your

investigation of the event was inadequate and initial corrective actions defaulted to the .easy fix

of coaching individuals. Subsequent corrective actions were considered acceptable. The

NRC has concluded that information regarding the reason for this violation and the corrective

actions taken and planned to correct the violation and prevent recurrence is already

adequately addressed on the docket in this inspection report. Therefore, you are not required

to respond to this violation unless the description therein does not accurately reflect your

corrective actions or your position. In that case, or if you choose to provide additional

information, you should follow the instructions in the enclosed Notice.

Your are required to re~pond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. In accordance with 10 CFR 2.790 of the.

NRC's "Rules of Practice," a copy of this letter, the enclosures, and your response will be

placed in the NRC Public Document Room.

Docket Nos.: 50-237; 50-249

License Nos.: DPR-19; DPR-25

Enclosures:

1.

Notice of Violation

Sincerely,

/sf Geoffrey E. Grant

Geoffrey E. Grant, Director

Division of Reactor Projects

2.

Inspection Report 50-237/98021(DRP);

50-249/98021 (DRP)

See Attached Distribution

See Previous Concurrences

DOCUMENT NAME: G:\\DRES\\DRE98021.DRP

To receive a copy of this document, Indicate In the box "C" = Copy without attachment/enclosure "E" = Copy with attechment/enclo1ure

"N" = No co

OFFICE

Riii

NAME

RLerch:co

MRin

Cla

on/Heller

DATE

09/ /98

OFFICIAL RECORD COPY

0. Kingsley

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been in place for sufficient time to be fully effective. Therefore, the NRC is refraining from

issuing a violation in this case. However, the problem of operator recognition and

management of Technical Specification LCOs continued and manifested itself in the failure to

comply with Technical Specifications on August 21, 1998. In addition to addressing the

violation of Technical Specifications, your response to this violation should address the failure

of your corrective actions to prevent the events of August 6 and 21, 1998, and the larger issue

of operator recognition and management of Technical Specifications and LCOs.