ML19291C165

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Responds to NRC Re Violations Noted in IE Insp Repts 50-010/79-22,50-237/79-26 & 50-249/79-24.Corrective Actions:Valves Correctly & Prominently Labeled & Fuel Pool Fill Valves Locked
ML19291C165
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 12/17/1979
From: Peoples D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19291C163 List:
References
NUDOCS 8001230053
Download: ML19291C165 (4)


Text

Commonwealth Edison one First National Ptara. Chicago. Ittinois Address Reply to: Post Office Box 767 Chicago Illinois 60690 December 17, 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 1, 2, and 3 Response to I.E.

Inspection Report Nos. 50-10/79-22, 50-237/79-26, 50-249/79-24, NRC Docket Nos.

50-10/237/249 Reference (a) :

R. Heishman letter to C. Reed dated November 21, 1979

Dear Mr. Keppler:

The following is in response to an inspection conducted by Mr. J. Barker on October 1 - November 2, 1979, of activities at Dresden Nuclear Power Station Units 1, 2, and 3.

Reference (a) indicated that one item appeared to be in non-compliance with NRC requirements.

Attachment A to this letter contains Commonwealth Edison Company's response to the identified item of non-compliance.

Reference (a) further requested information concerning the duties of operations personnel, the delineation of qualification standards for non-licensed operators, and a description of our actions to preclude the recurrence of an unqualified person from performing activities affecting quality in the absence of supervision.

The duties of operations personnel are specified in Administrative Procedure DAP 7-1.

This procedure is currently undergoing revision to meet the requirements of NUREG-0578.

However, the current procedure and the new revision both specify that the Shift Engineer is responsible for operating the plant in compliance with Station Procedures.

A Shift Foreman supervises operations under the Shift Engineer and is responsible for the supervision of assigned Equipment Attendants in the training program.

Equipment Attendants perform valving operations as directed by the Shift Foremen.

Station Administrative Procedures are being revised to require that unqualified personnel may only perform evolutions in the presence of qualified personnel 1791 168 B oo2 2 3o b DEC 2 01978

Commonwealth Edison NRC Docket Nos. 50-10/237/249

,- or after specific approval of a Shift Supervisor.

Attachment A further describes corrective actions to prevent a recurrence of this event.

Very truly yours, Q.

4 D.

L.

Peoples Director of Nuclear Licensing RFJ: rap Attachment 1791 169

6 ATTACHMENT A NRC Docket No. 50-10 COMMONWEALTH EDISON 50-237 ATTACHMENT 50-249 RESPONSE 13 NOTICE OF VIOLATION The items of non-compliance identified in Appendix A with the NRC letter dated November 21,1979, are responded to in the following paragraphs.

1.

Unit 3 Technical Specifications, Section 6.2.A requires that detailed procedures involving operation of components involving nuclear safety of the facility be prepared, approved, and adhered to.

Licensee procedure DOP 2000-2-M1, "A & B Waste Collector Filters Manual Valve Line-up Checklist," delineates the proper valve line-up for A & B Waste Collector System Operations.

Contrary to the above, on October 25, 1979, a licensee employee (an unqualified Equipment Attendant) failed to make valving evolutions in accordance with DOP 2000-2-M1, which resulted in the overfilling of the Unit 3 spent fuel pool and subsequent contamination of the Unit 3 Reactor Building with low level radio-active material.

Corrective Action Taken and Results Achieved The valving error occurred when an unqualified Equipment Attendant was removing the "A" Waste Filter in the Unit 2/3 Rad-waste system from service and placing the "B" Waste Filter in-service.

The Equipment Attendant in training received directions which were not adequately precise and explicit and he assumed, incorrectly, that he was operating the proper valves.

The Equip-ment Attendant, instead, opened a six inch condensate system fill valve to the Unit 3 fuel pool (Valve 3-1904-5-27).

The valve was open for about thirty-five minutes and resulted in approximately 2000 gallons of low level contaminated water overflowing the fuel pool and contaminating various levels of the Unit 3 reactor building.

No personnel were contaminated and there was no release of activity outside the reactor building.

The affected areas were properly roped off, and access to those areas was controlled.

All contaminated areas were decontaminated by October 27, 1979.

The circumstances leading to this event were investigated by a Professic7alism Committee Investigation Team, and the follow-ing corrective action was recommended.

The committee determined that the valves in the radwaste corridor were poorly labeles.

These valves and the remaining valves in the corridor have now been correctly identified and promineitly labeled.

Further, the fuel pool fill valves from the condensate system have been locked shut.

Because the Radwaste Control Room Operator gave imprecise 1791 170

. Docket Nos. 50-10 50-237 50-249 I

instructions, and the Equipment Attendant further assumed that he was operating the correct valve, the Radwaste Control Room Opera-tor and the Equipment Attendant were admonished by the Assistant Superintendent for Operations to ensure that valving and switching operations are precisely conveyed and that positive identification of equipment is made prior to performing any operation.

Corrective Action To Be Taken to Avoid Further Non-Compliance To avoid recurrence of similar events, Administrative Procedure DAP 7-2, " Conduct of Operating Shift Routines" is being revised to require apprcval by a Shift Supervisor before an un-qualified Equipment Attendant trainee is permitted to operate independently of another qualified operator.

Also, the training program for Equipment Attendants will be reviewed to ensure proper emphasis is placed on directing personnel not to assume anything in their actions.

A " Good Operating Practices" manual, which has been under development for some time, has now been finished and distributed to all operators.

The book emphasizes that it is in-cumbent upon all personnel to follow approved procedures, to give and receive precise instructions, and to properly identify equip-ment prior to performing evolutions.

Date When Full Compliance Will Be Acheived The valve tags for the valves in this corridor have been installed.

The review of the training program to assure adequate emphasis on proper equipment identification and the revision to DAP 7-2 will be completed by February 15, 1980.

1791 171