ML17199V110
| ML17199V110 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/18/1988 |
| From: | Silady J COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8804060315 | |
| Download: ML17199V110 (5) | |
Text
Commonwealth Edison e
One First National Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 - 0767 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 March 18, 1988
Subject:
Dresden Nuclear Power Station Unit 2 Response to Notice of Violation APRM Downscale Trip Operability NRC Docket Nos. 50-237
Reference:
Letter from W.L. Forney to Cordell Reed dated February 18, 1988, transmitting Inspection Report Nos. 50-010/88-002, 50-237/87040 and 50-249/87039
Dear Mr. Davis:
Enclosed is the commonwealth Edison Company response to the subject Notice of Violation which was received in reference.
We understand the significance of the issues identified especially the need for effective corrective actions to prevent recurrence.
Because the current Technical Specification requirements on APRM downscale trip operability are not needed to assure compliance with any safety analyses in our licensing bases, an amendment has been prepared to remove the trip and associated requirements.
We expect to submit this amendment within the next few weeks.
It should be noted that the APRM downscale trip feature was deleted from later BWR product lines and at least one earlier. plant has received NRC approval to remove it from their Technical Specifications.
8804060315 880318 PDR ADOCK 05000237 Q
A.B. Davis 2 -
March 18, 1988 Until the amendment has been reviewed and approved, additional corrective measures have been taken at both Dresden and Quad Cities to avoid further noncompliances with the existing Technical Specification requirements.
Please contact this office should further information be required concerning this matter.
Very truly yours, 9~
J. A. Silady Nuclear Licensing Administrator lm Attachments cc:
M. Grotenhuis.- NRR NRC Resident Inspector - Dresden 4378K
ATTACHMENT A COMMONWEALTH EDISON COMPANY REPLY TO NOTICE OF VIOLATION DISCUSSION As a result of a routine NRC inspection conducted on December 9, 1987
- through January 29, 1988, of activities at Dresden, the station received a notice of violation because inadequate.corrective actions failed to prevent recurrence of a previous Technical Specification violation.
Technical Specification 3.1.A addresses the required Reactor Protection system (RPS) trip functions and setpoints as a function of operating mode.
Specifically, with the mode select switch in the Run position, two APRM downscale trip functions are required to be operable.
This requirement was not satisfied on December 18, 1987, when the Unit 2 Operator placed Average Power Range Monitor (APRM)_4 in* bypass concurrent with Intermediate Range Monitor (IRM>' 16, which effectively reduced the number APRM downscale trips to one.
A similar event involving the same unit occurred several months earlier.
on August 18, 1987.
The corrective actions implemented as a result of this previous event were not sufficient in preventing the December 18th violation.
VIOLATION 10 CFR 50, Appendix B, criterion XVI, as implemented by CECo Topical Report CE-1-A, * ;:Quality Assurance Program for Nuclear Generating stations",
and CECo Corporate Quality Assurance Manual, Nuclear Generating Stations, "QUality Requirement Section 16.0", requires that corrective actions identified from nonconformances, incidents and deviations are verified for satisfactory completion to preclude repetition.
9AUSE OF VIOLATION In accordance with the Station's Personnel Error Reduction Program, a Personnel Error Investigation was initiated since personnel error was identified as a probable cause of the Technical Specification violation.
The investigation involved personnel interviews along with a review of operating logs, computer alarm output and station procedures.
It was concluded that the root cause of the event was personnel error, mainly because all individuals involved with the event had received training on the August event and were aware of the significance of the APRM/IRM bypass restrictions.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
- Althougn the violation occurred on December 18, 1987, it was not discovered until the following day when the Unit 2 operator responded to an alarm in APRM channel 4.
Upon discovery, the NSO immediately placed APRM 4 to operate.
This placed the unit in a condition allowed by Technical Specifications.
The noncompliance had lasted 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> and 18 minutes.*
- ACTIONS TAKEN TO PREVENT RECURRENCE The personnel error investigation identified several corrective actions to prevent recurrence.
These include:
- 1.
A letter dated December 22, 1987, was issued to all licensed personnel describing the event and emphasizing the significance of the APRM/IRM bypass configuration.
Furthermore, a similar letter, dated March 3, 1988, was issued following the notice of violation from the NRC.
- 2.
A procedure change to Appendix A (Shift Turnover) was* fssued to
This will ensure any bypass configurations not allowed by Technical Specifications are detected early.
- 3.
The operator involved with the event was counseled on the Technical
.s~ecification ~nd the required compliance to it.
4~
A cover, in the form of a plexiglass tube, will be placed on the APRM.
and IRM bypass joysticks to serve as an operator aid in reminding shift personnel of the importance of the joystick configuration prior to bypassing an APRM or !RM.
- 5.
General Electric was requested.to evaluate the safety significance of removing the APRM downscale trip from the Technic~l Specification.
This evaluation concluded that no unreviewed safety questions arise as a result of removing this particular trip function.
In fact, this trip is not included on later *model BWR's.
A pr'oposed amendment has been prepared and will be submitted for NRC Staff review within th.e next few weeks.
DATE WHEN FULL.COMPLIANCE WILL BE ACHIEVED FOR ALL ITEMS Fu.ll compliance with the applicable.LCO requirements was achieved when APRM 4 was* placed in service on December 19, 1987, at 0923.
(
3 -
All action items identified above have been completed except Items 4 and 5.
Item 4 currently awaits part pr~curement. It is expected this item will be implemented by March 31, 1988.
- Procedure changes associated with the Item 5 license amendment must, of course, await review and approval by the NRC of the proposed change to the Technical Specification.
4378K