ML17252B313
| ML17252B313 | |
| 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: ML17252B313 (3) | |
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Commonwealth Edison 0 NE FI RS T NAT I 0 N A.L PLAZA
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I LL I N 0 I S
.t.ddiesi Jl~lr to:
POST OFFICE BOX 767.* CHICAGO, llllNOIS 60690 Mr. Lawrence D. Low, Director Division of Compliance U.S. Atomic Energy Commission Washington, D.C.
20545
Dear Mr. Low:
December 14, 1970 The purpose of this. letter is to advise you of corrective action:s taken in connection witH certain of our activities stated in the encto-sure to your1letter of November 19, 1970.
Th~se activities were iden~
tified as not being in full compliance with the requirements of AEC Facility License No. DPR-19.
Our responses are numbered in the same format as in your letter of November 19 and are. as f~llows:
A.1 In order to prevent a reoccur~en~e ~f the event identified in this item, the following corrective actions have been taken:
a) b)
Operating procedures have been revised to prohibit venting, of the dry we 11, except durin'g inerting and de-i.ne rting, unless the pressure is less than.2 psig.
This procedure revision will remove the option of bypassing the hi'gn d;ywell pressure sensors in order to allow use of the drywell coolers to reduce pressure.
The fact that Technical Specification requirements are not to be bypassed has been reemphasized to operating personnel during their review in preparation for Unit 3 reactor operator licensing.
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- ,_. \\i'f A.2 In reference to parts (a), (c) and (d) of this item, the applicable~'
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 operation.
These pro-cedures, along with all existing Unit 2 procedures, are being reviewed and updated in preparati.on for issuance of operating_ procedures for r
Unit 3.
These updated/procedures will be issued tiy December 15, 1970.
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- ln reference to part \\ aj of this item, the applicable abnorml.
operating procedure has been revised to ensure that adequate surveJ_lY_ Ii.
will be taken before venting of the drywell.
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. i In reference to part {b) of this item, the system design require~
that the drywell sumps be pumped, when high level in the sumps is*
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- actuated, directly to underground storage tanks in the Radwaste f~c~iilf t p
At this point, outside of the primary containment, normal survey ~r~~.
cedures are followed to sample and analyze the content of these tarlirs before discharg~ to the environment.
This pumping from the sumps td Radwaste is prohibited by interlocks when Containment Isolation sig~als are p~esent. It i~ our intent not to bypass isolation signals, exc~~t as permitted in the Technical Specifications.
(Please note our response to item A.1.)
Therefor~, the sumps will only be pumped to Radwast~
when the signals causing isolation of these sumps are not present.
A.4 All station admin'is.trative personnel have been made aware of the requirem~nt 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 irl Technical Specifications, Section 6.6.A.
B.1 Through an oversight, t_he required control rod exercisi'ng stated in this 'item was not perfor,med.
In. order to help prevent similar situations from developing *in the future, an engineer has been added to the station staff to'. oversee compli-an£e with surveillance require*
ments of the Technical Specifications.
In addition, for the period of the abnotmally heavy work load of the startup period, another engineer has been added to the station staff to serve as an internal auditor of survsillance requirements, Station Review Board activities; and performanc~ of pre-operational and startup testing.**
B.2 Thro~,.gh an oversight, the incident noted in this item w~s 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 Board did fail to detect the incidents men-tioned in items B.1, B.2 and B.3.
This failure was caused by human -
error~
We feel that the addition of the internal auditing identified in the response to item B.1 will substantially reduce the occurrence of such incidents in the future.
In addition to the above responses, your letter also requested information on corrective measures being implemented to improve the effectiveness of the m~ri~gement system for assuring compliance with the provisions 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
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Board (NRB) has reqµested that a telephone report of an incident or abno~mal occurrence should be mad~ to th~ Chairman or one of the two'.****~ i~
NRB members assigned to the Station Review Board (SRB) at the.. time,, :;.~
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of the "iricident or occurrence.
Regular NRB monthly meetings have be~n 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 Board and the Assistant to the President, Manager of Production, and Superintendent of Dresden have been increas~d, so as to transmit promptly the debisions and recommendations of the NRB to these management personn~l rather than wait for the NRB minute~
to be prepared and distributed.
It is felt that by implementing the ;..
above, the Nuclear Review Board and, hence Company management will ha~e better coverage of Dresden Station operation.
SUBSCRIBED ar;td swo~.~ to' before_,,.JJJe this t%
day of
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, 1970.
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I Very truly yours,
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- l Byron Lee, Jr.
Assistan~ to the President
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