ML17195A764
| ML17195A764 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/18/1985 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195A763 | List: |
| References | |
| 50-237-85-10, 50-249-85-09, 50-249-85-9, NUDOCS 8505020610 | |
| Download: ML17195A764 (2) | |
See also: IR 05000216/2003028
Text
Commonwealth Edison Company
Dresden Nuclear Power Station
Appendix
Docket No. 50-237
Docket No. 50-249
As a result of a special inspection conducted during the period of February 16
through March 28, 1985 at the Dresden Nuclear Power Station, and in accordance
with the General Policy and Procedures for NRC Enforcement Actions (10 CFR
Part 2, Appendix C), the following violations were identified:
1.
Technical Specification 3.5.C.1 states in part that "the HPCI subsystem
shall be operable whenever the reactor pressure is greater than 90 psig
and irradiated fuel is in the reactor vessel."
Technical Specification Definition 1.0.0 defines Operability for a
subsystem to include all auxiliary equipment that are required for the
subsystem to perform its function(s), are also capable of performing
their related support function(s).
Contrary to the above, on February 22, 1985, the service water to the
High Pressure Coolant Injection (HPCI) System room cooler was found
valved out.
The licensee determined that this situation had existed for
approximately 29 to 38 days.
Therefore, this resulted in the room cooler,
and by definition, HPCI, to be considered inoperable for that period of
time.
A technical evaluation conducted by a licensee contractor showed
that the HPCI would be functional for a period of time sufficient to take
alternative actions.
This is a Severity Level IV violation (Supplement I).
2.
Technical Specification 3.7.2 states in part, that primary containment
integrity shall be maintained at all times when the reactor is critical
- or when the reactor water temperature is above 212° and fuel is in the
reactor vessel.
Contrary to the above, on March 2, 198S, the lice~see found a torus water
sample line open.
This allowed for a direct flowpath for torus water from
primary containment to secondary containment via the reactor building floor
drain sump.
It should be noted that this leakage path would still have
been in existence during an accident situation and would have allowed for
a calculated flow rate of approximately 40 gpm maximum, unless one loop of
the core spray system was intentionally isolated to prevent it.
The licen-
see subsequently determined that the valves had been open for a period of
approximately five shifts.
This is a Severity Level IV violation (Supplement I) .
8505020610 850418
~DR
ADOCK 05000237
Appendix
2
3.
10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings"
requires that activities affecting quality shall be prescribed and accom-
plished by appropriate instructions, procedures, and drawings.
10 CFR 50 Appendix B, Criterion XIV, "Inspection Test and Operating
Status", requires that measures be established for indicating the oper-
ating status of .... systems and components of the nuclear power plant
such as by tagging .... to prevent inadvertent operation.
Commonwealth Edison Company, Topical Report CE-1-A, "Quality Assurance
Program for Nuclear Generating Stations", implements 10 CFR Appendix B.
Dresden Operating Surveillance Procedure DOS 6600-5, "Bus Undervoltage and
ECCS Integrated Functional Test for 2(3) Diesel Generator", Prerequisites,
Step 13, calls for an equipment line up in accordance with the attached
loadlng and Caution Card check lists.
Contrary to the above, while preparing to conduct Dresden Operating Sur-
veillance, DOS 6600-5, "Bus Undervoltage and ECCS Integrated Functional
Test for 2(3) Diesel Generator", on the Unit 2 emergency diesel generator
on February 16, 1985, mislabeling and misapplication of the Caution Cards
resulted in the removal of the ability of the Unit 3 low pressure emergency
core cooling systems to respond under a loss of off site power condition
if they had been called upon.
The condition existed for about four and
one half minutes while the Cnit was at full power and it was recognized
and corrected through the prompt response of control room management per-
sonnel.
It is recognized that the low pressure emergency core cooling
systems could have responded as designec as long as offsite power was
available.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this
office within thirty days of the date of this Notice a written statement or
explanation in reply, including for each item of noncompliance:
(1) corrective
action taken and the results achieved; (2) corrective action to be taken to
avoid further noncompliance; and (3) the date when full compliance will be
achieved.
Consideration may be given to ex~ending your response time for good
cause shown.
Dated
C. E. Norelius, Director
Division of Reactor Projects