ML17194A401
| ML17194A401 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/24/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17194A400 | List: |
| References | |
| NUDOCS 8201150253 | |
| Download: ML17194A401 (4) | |
Text
-.
e Commonwea di son One First Nationa
- a. Chicago. Illinois Address Reply to: Post Office Box 767 Chicago. Illinois 60690 December 24, 1981 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforc~ment - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Dresden Station Units 1, 2.and 3 Response to I.E. Inspection Report Nos. 50-10/81-14, 50-237/81-28, and 50-249/81-21 NRC Docket Nos. 50-10/237/249 Reference (a}:
R. L. Spessard letter to Cordell Reed dated November 24, 19~1.
Dear Mr. Keppler:
The following is in response to the inspectioQ conducted by Mess~s. T. M. Tongue and M. Jordan on September 5, through October 2, 1981, of activities at Dresden Nuclear Power Station, Units 1, 2 and 3.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requ1rements.
Our response to the one item of noncompliance is provided in the attachment to this letter.
The inspection summary also discussed a discrepancy in the tag-out system which was identified by Dresden Station personnel on the nonsafety related Unit 3 feedwater system.
As described in the attachment to this letter, special tailgate sessions will be held with appropriate station personnel to further emphasize the importance of management control of equipment outages.
In addition, to assess the effectiveness of these tailgate sessions, random verifications of outages will be performed over the next three months.
We believe that these actions will improve management control of the outage tag~out system.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these stat~ments are not based on my person~l 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.
8201150253 820111 PDR ADOCX 05000010 J
PDR OEC 2 8 1981*
Cl...
4t J. G. Keppler 2 -
December 24, 1981 Please direct any questions you may have concerning these matters to this office.
Attachment lm Very truly yours.
J./.. "
~ \\. *.
/' i L
- o. Del George Director of Nuclear Licensing cc:
Region III Inspector - Dresden SUBSCRIBED AND SWORN to bef~e me this,!l/~J _, day of~~981.
~tl.~
Notary Public 3095N
Attachment A Commonwealth Edison Company Response to Notice of Violation The item of noncompliance identified in Appendix A of the NRC letter, dated November 24, 1981, is responded to in the following paragraphs:
10 CFR 50, Appendix B, Criterion V, requires that instructions, procedures, or drawings of a type appropriate to the circumstances be used. for activities affecting quality.
Commonweal th Edison "Quality Assurance Program for Nuclear Generating Stations:, Topical Report, CE-1-A, January 1976, Revision 18, July 21, 1981, (Approved by the NRC-NRR to meet the criteria of 10 CFR so-Appendix B),
Section 5 in regard to Instructions, Procedures, and Drawings states, "Generating Station operations, procedures, and instructions will be provided by the Station Superintendent and will be included in the Station Procedures Manual in a timely manner consistent with NRC license requirements for administering the policies, procedures, and instructions from the time that the operating license is issuea through the life of the station.
These procedures and instructions include:
Administrative Procedures,... "
Dresden Administrative Procedure OAP 7-4, Revision 5, May 1981, states, "This procedure provides guidance to assure that adequate control of the use of jumpers or lifted leads is maintained."
Contrary to the above, adequate control of the use of jumpers or lifted leads was not maintained in that the 0
senior resident inspector identified three lifted leads in control room panels that were identified with caution tags but not entered in the "Jumper and Lifted Lead Log", and one thermo~ouple lead that was tagged b0t not entered in the log.
Subsequently. the licensee conducted a review of the Caution Card Log and identified and corrected several other leads that should have been listed in the Jumper ~nd Lifted Lead Log.
Corrective Actions and Results Achieved As indicated by the inspection* summary contained in your letter dated November 24, 1981, a review was made of the Caution Card Logs to determine if other items existed that should be added to the Jumper and.Lifted Lead Log.
Those additional items found in the Caution Card Logs were listed in the Jumper and Lifted Lead Log as required.
- Corrective Actions Taken to Avoid Further Noncompliance The items found not to be in the Jumper and Lifted Lead Log as required are items which occurred some time ago.
Since the establishment of the requirement that Shift Control Room Engineers (SCREs) perform verification of entries*into the Jumper and Lifted Lead Log, such instances as these have not occurred.
This requirement of the SCRE is contained in OAP 7-1, and we feel it is sufficient corrective action to prevent recurrence.
Therefore, we believe that full compliance is achieved at this time.
Response to Open Inspection Item (50-237/81-28~03i 50-249/81-21-03)
In order to provide additional management control of equipment outages, tailgate sessions are planned to be held with all operating shift pers6nnel an~ with the maintenance foremen personnel.
These tailgate sessions have.been held with the operating personnel during their training sessions conducted at six week intervals.
Tailgate sessions with maintenance personnel will be completed by January 15, 1982.
These tailgate sessions provide guidance on the proper practices and methods that should be adhered to in taking equipment in and out of service.
To assess the effecti~eness of these tailgate sessions. random independent walkdowns or verification of outages will be performed over the next three months.