ML19242D483

Responds to NRC 790613 Ltr Re Violations Noted in IE Insp Repts 50-237/79-13 & 50-249/79-11.Corrective Actions: Valve & Breaker Switch Alignment Checklists Are Being Reviewed & Corrected

ML19242D483
Person / Time
Site:	Dresden
Issue date:	07/03/1979
From:	Reed C COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17173B039	List: ML19242D483
References
NUDOCS 7908150299
Download: ML19242D483 (3)

Text

, Commonwealth Edison *-

One First National Plaza. CNcago. Ilknois Address Reply to Pest Omce Box 767 Chicago, Ilhnois 606%

July 3, 1979 Mr.. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

SUBJECT:

Dresden Station Units 2 and 3 Response to IE Inspection Report Nos. 50-237/79-13 and 50-249/79-11.

NRC Docket Nos. 50-237 and 50-249 REFERENCE (a): June 13, 1979 letter from R. F. Heishman to Byron Lee, Jr. transmitting IE Inspection Report Nos. 50-237/79-13 and 50-249/79-11

Dear Mr. Keppler:

Reference (a) contained the results of an inspection by Messrs. R. D. Walker and J. L. Barker of your office on May 2 - 18, 1979 of activities at Dresden Station Units 2 and 3. During this inspection, certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's response to the item of noncompliance is contained in Attachment A to this letter.

Please address any additional questions that you might have concerning this matter to this office.

Very truly yours, Cordell Reed

• Assistant Vice-President Attachment JUL 6 1979 '330211 7908150 [ N (

NRC Docket Nos. 50-237/249  :

ATTACHMENT A Infraction

. Technical Specification 6.2.A.l. requires that detailed written procedures, including applicable checklists covering normal startup, operation, end shutdown of the reactor and other systems and components involving nuclear safety of the facility, shall be prepared, approved and adhered to.

10CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Commonwealth Edison Company Quality Assurance Manual Quality Requirement 5.0, paragraph 5.1 states "The quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists." Quality Procedure 5-51 of the same manual states " Checkoff lists are included for complex operations and documentation. These lists delineated in detail the steps an operator must follow in order to complete an operation."

Contrary to the above, the applicable valve / breaker / switch alignment procedures for the High Pressure Coolant Injection System, the Core Spray System and the Emergency Core cooling Keepfill System contain numerous discrepancies with respect to the lineups stipulated in current Piping and Instrumentation Drawings (P & ID's). The discrepancies included: valves omitted, valves misaligned, and misnamed or unnamed valves, breakers and switches.

Corrective Action Taken and Results Achieved The valve and breaker / switch alignment checklists which were considered inadequate are used after an extended shutdown period to provide directions for returning all the valves in the systems to their desired position prior to operation'. Actual valve positions were verified during the inspection to be correct such that-the valves could fulfill their intended function. Commonwealth Edison agrees, however, that the checklists should be consistent with the Piping and Instrumentation Drawings (P & ID's) and has initiated a priority prog::am to review each of these checklists against the P & ID's and to make corrections as necessary to both documents.

600212

'. NRC Docket Nos. 50-231/249 ,

ATTACIIMENT A corrective Action Taken and Results Achieved (Cont'd)

In addition, the actual position of all important valves and , breakers / switches in these systems is checked much more frequently by other procedures. For example, DOP 040-5 currently requires a daily check of important manual and motor operated valve positions, pump status, and diesel generator alignment necessary for automatic operation of-all ECCS systems, the Isolation Corienser, and the Standby Licuid Control System. Other procedures are used to ensure that these systems are returned to operable conditions after mainten-ance activities through tests and surveillances.

Corrective Action to be Taken to Avoid Further Noncompliance As previously indicated, Commonwealth Edison has initiated a priority program to campare each of the ECCS systems mechanical and electrical checklists with the appropriate Piping and Instrument-ation Drawing and to initiate corrections, if necessary, to both documents. This program will include a field verification of the valve and breaker numbers of accessible components, the identifica-tion tags attached to them and, where applicable, any locking devices which might be attached. Numbers will be assigned to those instrument stop valves which are currently unnumbered. Since the checklists reflect valve and breaker alignments while shutdown and the P & ID's show positions during normal operation, some differences should and will continue to exist between them, but these differences will be reviewed to ensure that they properly reflect the desired position infoamation.

Date of Full Comoliance The reviews will be completed by August 1, 1979, for accessible ecuipment, and the applicable procedure changes and/or drawing change renuests will be prepared and approved by September 1, 1979. The reviews of inaccessible equipment will be completed and the necessary procedure changes implemented prior to,startup following the next refueling of each unit. -

. 690213