ML17194A238
| ML17194A238 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/29/1981 |
| From: | Swartz E COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17194A237 | List: |
| References | |
| NUDOCS 8110290337 | |
| Download: ML17194A238 (4) | |
Text
... e Common Ith Edison One First Na I Plaza, Chicago, Illinois Address Rep y to: Post Office Box 767 Chicago, Illinois 60690 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Re~ulatory Commission 799 Roosevelt Road G *1 en E l l y n, I L 6 0 l 3 7 July 29, 1981
Subject:
Dresden Station Units l, 2 and 3 Response to I.E. Inspection Report No. 50-10/81-06, 50-237/81-13, and 50-249/81-08 NRC Docket Nos; 50-10/237L249 Reference (a):
R. F. Heishman letter to Cordell Reed dated July l, 1981.
Dear Mr. Keppler:
Reference (a) transmitted the results of an inspection conducted bY Messrs. T. M. Tongue and M. J. Jordan of your office on April 4 through May 8, 1981, of activities at our Dresden Nuclea~
Yower Station Units l, 2 and 3.
Appendix A to Reference (a) identified two items of non-compliance with NRC requirements and r~quested a written response within thirty (30) days.
The Commonwealth Edison Company responses to those items of non-compliance are provided in Attachment A to this letter.
To the best* of my knowledge and belief, the statements contained herein and in the attachment are true and correct.
In some respects, these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
'Please address any further questions that you may have concerning this matter to this office.
cc:
Region III Inspector - Dresden SUBSCRIBED AND SWORN to before me this J'.!J.~day of tt,
1981.
e&=l:J.We~
Notary Public 2348N
~~~0290337 811023 Q
ADOCK 05000010 PDR
ATTACHMENT A DRESDEN STATION UNITS l, 2 and 3 RESPONSE TO NOTICE OF VIOLATION The items of non-compliance identified in Appendix A of the Reference (a) NRC letter dated July l, 1981, are presented here and responded to in the following paragraphs.
- l.
10 CFR 50 Appendix 8, Criteria XIV requires that measures be established for indicating the operating status of structures, systems, and components of the nuclear power plant ****., such as tagging valves and switches to prevent inadvertant operation.
It also requires measures to be established to indicate the use of markings such as stamps, tags, etc., the status of tests performed.
Dresden Administrative Procedure (DAP-3-5) states it's purpose in part, "This procedure will provide a record of the equipment status before, during, and after an outage so that a b n o rm a l s y s t em c o n f i g u r a t i o n s c a n b e e v a l u at e d. "
C E C o *Q u a l i t y Assurance Manual Procedure 3-52 states the Shift Engineer will take appropriate action and remove equipment from service and when satisfactory, clear the outage.
Contrary to the above, on Apri,l 15, 1981, the status of equipment in the Control Rod Drive Hydraulic System (CRDH) was not controlled in accbrdance with the equipment outage checklist controlling the work in that the drain valves for two CRDH accumulators were left in the closed position and were tagged and verified ope~ as required by DAP-3-5.
This item is a repeat occurrance of the conditions resulting in the Notice of Violation reported in Inspection Report 50-249/81-02, dated March 23,. 1981.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED When it was discovered that the drain valves were closed and not in the* positioh as specified on the outage checklist, the valves were opened and the accumulators drained properly.
Also, the entire *equipment outage was then rechecked to ensure that all other valves which were included in the outage were in their proper position.
No further discrepancies were identified.
Following proper draining of the accumulators, the solenoid valves were replaced as intended..
The personnel who were in charge of taking the equipment out of service and with the independent verificaton of the outage were admonished to ensure by physical hands-ori verification, when possible, that valves and equipment outages are in the intended position.
In this event, the equipment operator and the shift foreman both believed that the drain valves were in the proper
ATTACHMENT A position, but they apparently made that determination erroneously.
While this event and the event referenced in Inspection Report 50-249/81-02 dated March.23, 1981, both involved equipment outages, we feel that the circumstances leading to both events were sufficiently different to assure us that this event was not strictly a repeat of the previous non-compliance.
In the previous case, valves which were originally not included in the equipment outages were later added* to the equipment outage improperly.
In this event, however, all valves which should have been included jn the outage were correctly identified and OOS tags were correctly hung to ensure that the valves were not re-positioned during the maintenance.
Becaus.e we believe that this event was a singular occurrence of oversites by the personnel establishing and verifying the outage, we feel that our corrective action is sufficient t-0 prevent recurrence.. The equipment OOS procedure DAP-3-5 has been feviewed, and no deficiencies were identified as a result of this review.
Additionally, the equipment outage whi.ch is routinely used for taking these accumulators out of service was reviewed and was also determined to be correct.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NON-COMPLIANCE See response above.
DATE WHEN FULL COMPLIANCE HAS BEEN ACHIEVED All the corrective actions have been accomplished, and the Station believes it is now in full compliance.
e ATTACHMENT A 3 -
e
- 2.
Technical Specification 6.2.A.7 requires detailed written procedures including applicable check off lists covering *...*
...* Surveillance and Testing requirements.
Dresden Chemistry Procedure DCP-10, for sampling torus water on Unit 3, requires notification of the control room operator of the intent to sample and the completion of sampling.
This procedure further p~escribes that the sample path for sampling the Unit 3 torus is via a piping tap off of the ECCS fill system pump.
Contrary to the above, on April 17, 1981, while walking down the Unit 3 control room panels, the SRI noted an actuated alarm indicating high water level in the torus which was found to be due to a sample bei~g drawn via an instrument line rather than through the ECCS fill system pumps discharge.
It was also found that the control room had not been informed of the sample being taken.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On April 17, 1981, the Senior Residerit Inspector noted that the Unit 3 torus water high level alarm was actuated.
The cause of this alarm was found to be an* attempt by a Rad-Chem technician to obtain a sample from a torus water level instrument line.
The technici~n failed to notify the control room prior to sampling and obtained his sample from a location other than that
- specified in his procedure.
To prevent a recurrence of this type of incident, the Rad-Chem Department has identified the systems which have the potential to actuate an alarm in the control room when a sample is being obtained.
A sign has been posted at each of the proper sampling locations directing the technician to notify the control room prior to sampling.
By directing the technician io the proper sampling location and reminding him to notify the control room before obtaining his sample, these signs should serve to prevent the recurrence of an event such as that of April 17, 1981.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NON-COMPLIANCE See Response Above.
DATE OF FULL COMPLIANCE The signs have been posted and the station is now in full compliance.
2348N