ML17191A943
| ML17191A943 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/21/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17191A939 | List: |
| References | |
| 50-237-98-23, 50-249-98-23, NUDOCS 9810270194 | |
| Download: ML17191A943 (3) | |
Text
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Commonwealth Edison Company Dresden Station, Units 2 and 3 NOTICE OF VIOLATION Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 During an NRC inspection conducted on August 31, 1998 through September 23, 1998, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
- 1.
10 CFR 50, Appendix B, Criterion V, *instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Dresden Administrative Procedure (OAP) 05-08, *control of Temporary System Alterations; Revision 8, dated August 14, 1998, is required to be used for all temporary alteration installations and provides guidance for controlling and documenting temporary alterations.
Step C.21 of OAP 05-08 defines a temporary alteration as an alteration to the approved design configuration of plant structures, systems, or components that do not conform to approved drawings or other design documents.
Step F.1.e.(14) of OAP 05-08 requires that if the duration of a temporary alteration is expected to go beyond 90 days, then initiate form 05-080, *Extended Installation Justification.*
Step F.6.c of OAP 05-08 requires that on a quarterly basis, the temporary alteration program owner shall coordinate a walkdown of all installed temporary alterations with the cognizant engineers to verify the current configuration against the original design.
Contrary to the above:
- a.
On September 16, 1998, a temporary alteration was identified that had not been controlled in accordance with OAP 05-08. Specifically, the Unit 2 station blackout diesel generator battery room door was propped open with a portable fan installed to supply temporary ventilation.
- b.
On September 17, 1998, temporary alterations with an expected duration beyond 90 days without an extended installation justification review were identified. For example, temporary alteration 3-08-98 to plug a leaking traversing incore probe indexer tube was installed on May 10, 1998 with an expected removal date of Dresden Refueling Outage 15 which exceeded 90 days. However, an extended installation justification form was not completed as required by Step F.1.e.(14) of OAP 05-08. In addition, temporary alteration 1-02-98 to place a pipe clamp on a 9810270194 981021 PDR ADOCK 05000237 a
Notice of Violation leaking fire protection header was installed on May 30, 1998 with an expected removal date of November 20, 1998. However, an extended installation justification form was not completed as required by Step F.1.e.(14) of OAP 05-08.
- c.
As of September 1, 1998, quarterly walkdowns of installed temporary alterations had not been performed as required by Step F.6.c of OAP 05-08.
This is a Severity Level IV violation (Supplement 1 ).
- 2.
Dresden Unit 2/3 Technical Specification 4.0.E.1 states that inservice testing of American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(f), except where specific written relief has been granted by the Commission.
ASME Code,Section XI, IWP-1100, *pump Testing: references Operations and Maintenance Standard Part 6 (OM-6) for pump testing. Section 5.2, -rest Procedure.* of OM-6 states that an inservice test shall be conducted with the pump operating at specified test reference conditions. In addition, Section 5.2(b) states that the resistance of the system shall be varied until the flow rate equals the reference value. NUREG-1482, *Guidelines for lnservice Testing at Nuclear Power Plants; permits a 2 percent tolerance band around the reference value.
ASME Code,Section XI, IWV-3522, *Exercising Procedure; states that check valves should be exercised to the position to fulfill their function. The Dresden inservice testing program identified that service water check valve 2-2399-252 has a closed safety function to prevent diversion of flow from the containment cooling service water (CCSW) pumps to the emerg~ncy core cooling system room coolers. NUREG-1482 states that verification that a check valve is in the closed position can be performed by ensuring the valve is sufficiently leak tight such that the required design flow through other portions of the system can be met.
Contrary to the above:
- a.
As of September 22, 1998, Dresden Operating Surveillance (DOS) 1500-02,
- containment Cooling Service Water Pump Test and lnservice Test; Revision 28, dated July 7, 1998, required operators to establish flow for the Unit 2 CCSW pump between 3621 and 3721 gallons per minute (gpm) although the reference flow for CCSW pumps A, B, C, and D were 3620, 3615, 3612, and 3604 gpm, respectively. As a result, on May 14, 1998, the flow established during the surveillance of the *o* CCSW pump was 3705 gpm which was outside the 2 percent tolerance band permitted by NUREG-1482 and therefore failed to satisfy the requirements of OM-6 and Technical Specification 4.0.E.1.
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As of September 22, 1998, the acceptance criteria associated with DOS 1500-02 to verify the closed safety function of service water check valve 2-2399-252 was established as 50 gpm to the room coolers although the design flow through the coolers was 87 gpm. As such, the acceptance criteria failed to verify that the valve was sufficiently leak tight to meet the design flow requirements for the system as discussed in NUREG-1482 and therefore failed to satisfy the requirements of TS 4.0.E.1.
This is a Severity Level IV violation (Supplement 1 ),
The NRC has concluded that information regarding the reasons for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report No. 50-237/249/98023(DRS). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a *Reply to a Notice of Violation,* and send it to the U.S. Nuclear Regulatory Commission, ATIN: Document Control Desk, Washington, D.C. 20555 with.a copy, to the Regional Administrator, Region Ill, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter tra_nsmitting this Notice of Violation (Notice).
If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Dated this 21st day of October 1998