ML17201J323

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Forwards Safety Sys Outage Mods Insp Rept 50-249/88-200 on 880222-26 & 0307-11.Inspectors Found Improvements in Procedures,Programs & Physical Conditions of Plant & No Addl Violations or Deviations Identified
ML17201J323
Person / Time
Site: Dresden Constellation icon.png
Issue date: 06/23/1988
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Reed C
COMMONWEALTH EDISON CO.
Shared Package
ML17201J324 List:
References
NUDOCS 8807110365
Download: ML17201J323 (6)


See also: IR 05000249/1988200

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

June 23, 1988

Docket No. 50-249

Mr. Cordell Reed, Senior Vice President

ColTITionwealth Edison Company

P.O. Box 767

Chicago, IL

60690

Dear Mr. Reed:

SUBJECT:

DRESDEN UNIT 3 - SAFETY SYSTEMS OUTAGE MODIFICATIONS

CORRECTIVE ACTIONS INSPECTION 50-249/88-200

This letter conveys the report for the followup inspection to the Safety

Systems Outage Modifications Inspections (SSOMis) performed by an- NRC

Headquarters team during February 22-26 and March 7-11, 1988 at the Dresden

Unit 3 station. The inspection team was composed of personnel from the NRC's

Office of Nuclear Reactor Regulation and consultants. At the conclusion of

the inspec,tion the findings were discussed with members of your staff identi-

fied in the enclosed report.

.

This SSO~I followup assessed the corrective actions taken by the Corrmonwealth

Edison Company in response to the initial Dresden Unit 3 SSOMI findings

documented in inspection reports 50-249/86-009 and 50-249/86-012, and closed

some items that remained open after the original inspections. The specific

areas reviewed included deficiencies, unresolved items, and observations from

those two reports~ and the corrective actions taken to resolve them.

The inspectors found improvements in procedures, programs and the physical

condition of the plant, and did not identify any additional violations or

deviations .. However, the team was unable to close a number of items that had

been opened by the previous SSOMis, because the root causes had not been

adequately determined or corrective actions that addressed the root causes

were inadequate. Actions had not yet been taken to prevent recurrence of

a number of concerns. Weaknesses identified by the. team are discussed in

the enclosed inspection report and su11111arized in the enclosed executive

summary.

A response to this letter is not required.

The rec011111ended actions for

closing the open items discussed in this report have been reviewed with Region

I I I personne 1. The regi ona 1 office wi 11 notify you of any further responses

that its personnel consider necessary with regard to the open items. The

regional office will also notify you of any enforcement actions which result

from this inspectio~.

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In accordance with 10 CFR 2.709(a) a copy of this letter and the enclosure

will be placed in the NRC Public Document Room.

Should you have any questions concerning this inspection, we would be pleased

to discuss them with you.

Enclosures:

1 .. Executive Summary

2.

Inspection report 50-249/86-200

cc w/enclosures:

See next page

Sincerely,

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Dennis M. Crutchfield, Director

Division of Reactor Projects - III, IV, V

and Special Projects

Office of Nuclear Reactor Regulation


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'cc w/enclosures:

Michael 1. Miller, Esq .

Sidley and Austin

One First National Plaza

Chicago, Illinois 60602

Mr. J. Eenigenburg

Plant Superintendent

Dresden Nuclear Power Station

Rural Route #1

Morris, Illinois 60450

U.S. Nuclear Regulatory Conunission

Resident Inspectors Office

Dresden Nuclear Power Station

Rura 1 Route #1

Morris, Illinois 60450

Chainnan

Board of Supervisors of

Grundy County

Grundy County Courthouse

Morris, Illinois 60450

Regional Administrator

U.S. Nuclear Regulatory C001T1ission, Region III

799 Roosevelt Road

Glen Ellyn, Illinois 60137

Mr. Michael E. Parker, Chief

Division ~f Engineering

Illinois Department of Nuclear Safety

. 1035 Outer Park Drive, 5th Floor

Springfield, Illinois 62704

Institute for Nuclear Power Operations

1100 Circle 75 Parkway

Atlanta, Georgia

30339

June 23, 1988

... *

EXECUTIVE SUMMARY

The reviews and improvement programs undertaken by the licensee for the Dresden

Unit 3 Nuclear Generating Station as a result of the SSOMis and subsequent

Region III and headquarters inspections were extensive.

The follow up inspec-

tion noted improvements in a number of CEC.o engineering and Dresden site

procedures and programs, and with the physical condition of the plant. Discus-

sions with the licensee on the individual items revealed in some cases that,

although not discussed in the official response to the Notice of Violation,

actions had been taken which resolved the items.

The written response to the

NRC's Notice of Violation from the SSOMis was, in many cases, not complete or

did not address the concern described in the inspection reports.

The team noted

weaknesses in the following areas:

1.

Root Cause Corrective Actions

Although a CECo task force, established as a result of the SSOMis, tdentified

employees' failure to adequately follow procedures as a major root cause for

the SSOMI findings, the corrective actions taken were not comensurate with the

significance of the problem.

The team did not find evidence that a management

philosophy of strict procedural adherence extended beyond the operations

department.

2.

Safety Evaluation Corrective Actions

The SSOMis identified in a number of cases that evaluations done in accordance

with 10 CFR 50.59 were not adequately justified or were not performed at all.

The followup inspection team found that the safety evaluations performed to

address the SSOMI findings were also deficient. The safety evaluation for the

reactor. building penetration modification was reperfonned because di mens ions*

in the original analysis did not match the actual installation. The team

found that the analysis used for the new safety evaluation still referenced

incorrect location dimensions.

The SSOMI team found that the safety evalu-

ations for analog trip system modifications did not address the effects that

significant chang~s made by the modifi~ations would have on the system.

The

reevaluations performed as* a result of the SSOMI finding did address the

specific effects identified in the SSOMI report.

However, the evaluations

were reviewed and approved even though they identified a potential degradation

of safety-related equipment.

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