ML17252B312
| ML17252B312 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/14/1970 |
| From: | Brian Lee Commonwealth Edison Co |
| To: | Low L US Atomic Energy Commission (AEC) |
| References | |
| Download: ML17252B312 (3) | |
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- o'.-1 Commonwealth Edison Company
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Address Reply to, POST OFFICE BOX 767 *CHICAGO, ILLINOIS 60690 Mr. Lawrence D. Low, Director Division of Compliance U.S. Atomic Energy Commission Washington,, D.c.
20545 Bear Mr. Lo_w.:.
December 14, 1970 r7
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The purpose of this letter is to adv*~e you of corrective actions taken in connection with certain of our ac ivities stated in the enalo-sure to your letter o~ November 1 t970 1hese activities were iden-tified as not being in full ~omplia~ce wfth the requirements of AEC Facility License No.
DPR~19.
0ur responses are numbered in the same format as in your letter of November 19 and are as follows: *,
A.1 In order to prevent a reoccurrence of the event identified in this item, the following corrective actions ha*ve.been taken:
a)
Operating procedures have been revised to prohibit venting of the drywell, except during inerting and de-inerting~
unless the ~ressure is less than 2 psig~- This procedure revision will remove the optio~of bypassing the high drywell pressure sensors in order to allow.~se of the d.~ywel'l coolers to reduce pressure.
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b}
The fact that Technical Specificatio~ requirements are not to be bypassed has been-reemphasized to operating pe~~onnel during their review in preparation for U~it 3 reactor
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operator licensing.
A.2 In reference to p~rts (a), (c) and (d) of this item,.the appli*cable operating procedures have been revised during July, 1970 to reflect procedures for securing emergency core cooling systems,. for venting the drywell atmosphere and for containment spray operati~n.
Thea~ pr6-cedures, al-ong wi-th all existing Unit 2 procedures, are being reviewed and up~ated in preparation for issuance of operating procedures for Unit 3*~
These updated procedures. will be issued by December 15, 1970.
In reference to part (b) of. this item, it is not intended that
. the bypassing of the high drywell p~essu~e sensors will be allowed except as is stated in the Te~hnical Specifications.
Please note the response to item A.1.
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lommonwealth Edison Comp' Mr. Lawrence D. _Low 2 -
December 14, 1970 A. 3 - In reference-to part (a) of this item, -the* applicable abnormal operating procedure ha~ been revised to ensure that adequate surveys will be. taken before venting of the dryw_ell.
In reference to part (b) of this item, the system design requires that the drywell sumps be pumped, when high level in the sumps is actuated, directly to underground storage tanks in the Radwaste facility.
At this point, o\\ltside of the primary containment, normal. surv-ey pro-cedures are f*ollow'ed* to sample and analyze the content of these tanks before discharge to the environment.
This pumping from the sumps to Radwaste is prohibited by interlocks when Containment Isolation signals are present. It is our intent not to bypass isolation signals, except as permitted in the Technical Specifications.
(Please note our response to item A.1.)
Therefore, the sumps will only be pumped to Radwaste when the signals causing isolation of these sumps are not present.
A.4 All station administrative personnel have been made aware of the requirement of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification by telegram as well as by telephone in cases requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AEC notification as stated in Technical Specifications~ Section\\6.6.A.
B.1 Through an oversight, the required control rod exercising stated in this item was not ~erformed. In order to help prevent similar
_situations from developing in the future, an engineer has been added to the station staff to oversee compliance with surveillance require-ments of the.Technical Specifications.
In addition, for the period of the abnormally heavy work load of the startup period, another engineer has bee~ added to the station staff to serve as an internal auditor of surveillance requirements, Station Review Board activities and performance of pre-operational and startup tei;i:ti_ng.
B.2 Through an oversight, the incid~nt noted in.this item was not promptly reported to the AEC.
We feel that the addition of the inter-nal auditing identified in the response to item B.1 will substantially reduce 'the occurrence of such incidents in the future.
B.4 The Station Review B~~rd d~d fail to ~etect the incidents men-tioned in items*B.1*,*B-.2 an.d,B.3 *. This failure was caused by human error.
We ~eel that the addiiiori of'the int*rnal auditing identified in the response to item B.1 will* substantially reduce the occurrene*
of such *incidents in the future.
In addition to the above responses, your letter also ~equested information on corrective measures being implement~d to improve the effectiveness of the management.system for assuring compliance.with the pr.ovisions of the operating license and* for auditing the safety operations at the Dresden facility.
In order.to follow more effec-tively the operation of the Dresden facility, the Nuclear Review Board (NRB) has requested that a telephone report of an incident or abnormal oc6urrence should be made to the Chairman or one of the two NRB members *assigned to the Station Review Board (SRB) at the time*
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lommonwealth Edison Comp" Mr. Lawrence December 14, 1970 of the incident or occurrence.
Regular NRB monthly meetings have been set up and held so as to review incident reports rather than wait for the semi-annual audits.
Personal communication between the Chairman of the Nuclear Review BC>ard and the Assis.ta~t to the President, Manager of Production, and Superintendent of Dresden have been increased, so as to transmit promptly the decisions and rec0mmendations of the NRB to these management personnel rather than ~ai~ for the NRB minutes to be prepared and distributed. It is felt that by implementing the above, the Nuclear Review Board and, hence Company management will have better coverage of Dresden Station.o.peration.
1 SUBSCRIBED and SWOR~ to before.....UJe this /Y day of
~R<'*zi~,, 1970"
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~)f:~J;U Notary Public Very truly yours,
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Assistant to the President