ML17202U894
| ML17202U894 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/07/1990 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202U893 | List: |
| References | |
| 50-237-90-23, 50-249-90-23, NUDOCS 9012130320 | |
| Download: ML17202U894 (3) | |
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APPENDIX
As a result of the.inspection conducted. on September 24 through *... *
- November 16; 1990, and in accordance with the "Ge.neral Policy and Procedures for NRC Enforcement Action~," 10 CFR Part 2, Ap~endix C (1990), the following violations were identified:
. 1.
- .10 CFR 50, Appendix B, Criterion* II, *as implemented by. Commonwealth.
. Edison's "Quality )\\ssurance. Program" requires indoctrination and.tra*i.ning of per~onnel. performing activities affecting quality as necessary to*
- assure that suitable* proficiency is achieved and maintained.*
Contrary to the above,* indoctrination and training.of 'pers*onnel
- performing a~tivities affecting quality was *i.nadequate* in a'ssuring proficiency was.achfoved arip mafntained as to adm1nistrative requirements as indicated. in the following examples:
. a. *Lack of operations personnel knowledge of Dresden *Admfnistrative Procedure*(DAP) 7-5, "Ope~atirig Logs arid Records," Revision~;* ~nd Dresden Operating Abnormal (DOA) Procedure~P2-5 G-2~ Revision 3,.
. requi~ements for maintaining the Control Rod Drive Accumulato~ High
- Water I.Low Pressure Alarm Log (AHWLPAL) resulted. in the AHWLPALs
- for both units not being maintained between Apr.i 1: 1990 and August 3, 1990.
As such the licensee's program to identify repeat failu~es of accum~lator,alarms was ~ot effective during that time period.
(50-237/90023-0la (DRP) ).
- 'b.
Lack of technical siafi personriel kn6~1~dge regarding recognfzfng
- and processing conditions adverse to quality resulted in a fail~re to properly identify a procedural nonadherence involving maintenance
- of the AWHLPAL when discovered in M~y 1990.
Because df this,
- correttive actions to prevent recurrence were no( taken'~t that time~ ( 50-237 /90023-.0lb (DRP))
This is a Severity_ Level IV violation (Supplement 1).
- 2.
- io CFR 50, Appendix B, Criterion V, *as implemented by Commonwealth Edison Company's Quality Assurance Program, requires_that activities affecting quality be accomplished in accordance with documented instructions, procedures or drawings.
Contrary ~o.the above, activ*ities affecting quality were not accomplished in ac*cordance with *documented instructions; procedures, or drawings in the following ex~mpl~s:
- a.
Dresden Operating Procedure (DOP) _ 1900-3, "Reactor Cavity-Dryer Separator Storage Pit Fill and Operation of the Fuel Pool Cooling and Cleanup System During Refueling," Revision 8, requires constant communication between the refueling.floor ~nd the control room while filling the reactor vessel. Constant communication between the refueling floor and the contrbl room was riot maintained while
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.2 filling the Unit 2 reactor.vessel on October 14,. 1990, resulting in the overfilling of the* vessel into the ventilation *ducts and contamination of various areas of th~ third ~nd fourth.floor~ of.the.
reactor building. '(50-237/90023-02a (ORP)l b~,.Specific practices required by OAP 3-5; "ci~t of Service and Personnel Protection Cards, Revision 22, wer~ not follo~ed as to preparation, review, appto~al, documentation ~nd independ~nt verificati6ri in the removal and return to service bf the Unit 2 diesel fuel oil day tank drain va 1 ve on October 29, 1990.
Th'i s resu 1 ted in the i nadve*rtent draining of the day tank when the d~ai~ valve ~as placed in the incorrect position.
(50:237/90023-02b (ORP))
- c.
riAP7~14, "Control and.Crite~ia For ~ocked Equipm~~t and'Val~es,~
Revisiori 2~ requir~s manual'valves iri.the flciwpath of systems reqµired for plant shutdowrrduring post~accident s~tuatioris br*which provide a controlled path t~ the envircins, including primary and secondary containment isolation.valves to be locked.
Prior to November 1990, manual valve~ including the Units 2, 3 and 2/3 diesel generator service water ~hree-way ~alyes and the Units 2 and *3 drywe.11 manifold sampling*system containment isolation valves were not locked or designated ~o be locked.
(50-237/90023~02c (ORPJ).
d:
OAP 15-6, "Prepafation*and Control of.Work Reque~ts;".Revision 0, requires work to be performed per re~aif manual(s), t~avelers/
procedures, or work instructions provided in.the work package.
On October 15, 1990, work presct'.'ibed for disassembly of the Outbo.ard Containm~nt Isolatiori Feedwater Check Valve 220~62B was performed
- instead on Outboa~d Containment Isolation Feedwater Check Valve 220-62A.
(50-z°37i90023-02d {ORP))
- e.
OAP 15-6i "Preparation and Cbntrol of Work Requests," Revision 0,
-requirements. were violated on August 8; i990, when work prescribed for calibration of Unit 3 Torus to Reactor B~ilding Vacuum Break~r A
- 'Pressure Transmitter DPT-1622A was performed instead on Pressure Transmitter OPT-1622B~ This resulted in advertant opening of.the Unit 3 Reactor Building Vacuum Breaker B.
(50~237/90023-02e (ORP))
This is a Severity Level IV violatio~ (Supplement 1).
- 3.
10 CFR.SO, Appendix B, Criterion XVI, as implemented by Cqmmonwealth Edis6n's "Quality Assurante Program~" requires that conditions adverse to quality be promptly identified and corrected and~ in the case of
- significant conditions, the measures assure the cause is determined and corr~ctive action taken to prevent repetition.
Contrary to the above, following the fuel bundle mispositioning events of January 10 and 12, 1989, corrective ~ction~ were insufficient to prevent repetition in that similar events occurred on October 1, 1990 and October 2, 1990.
( 50-237 /90023-08 ( ORP))
.NotiCe of Violation.. *
- This is a Severity Level IV violatioh (Supplement 1).
P~r~uant to the provisions of 10 tFR 2.201, you are ~equi~ed to submit to thi~
office within thirty days of the date of thii Notice a written statement.or explanation in reply, including for each violation:
(1) corrective* action.
taken and the results achieved; (2) corr~ctive action to be takeri to avoid.
- further violations; and l3) the date when. full compliance wi 11 be achieved.:
Consideration may be given to extending your response* time for good cause
- shown.
- lz /:01190 Date l
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