ML19340A546
| ML19340A546 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/23/1975 |
| From: | Bolger R COMMONWEALTH EDISON CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19340A544 | List: |
| References | |
| NUDOCS 8008270805 | |
| Download: ML19340A546 (10) | |
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' s' Co' monwealth Edison m
One f erst National Ptara. Chicago,3nois Address Reply to: Post Office Box 767 Ch.cago, lihnois 60690
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December 23, 1975 Mr. G. Fiorelli, Chief Reactor Operations and Nuclear Support Branch U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Dresden Station Units 1, 2, and 3 NRC Operating License Nos. DPR-2, DPR-19, and DPR-25, Response to IE Inspection Report Nos. 50-10/75-17, 50-237/75-23, and 50-249/75-20 NRC Dkts. 50-10, 50-237, and 50-249 Dear Mr. Fiorelli.
This is in response to your letter dated December 1, 1975, which referred to the inspection conducted by Messrs. Johnson and Harpster of your office on October 6-10, 15-16, 21-22, 28, 30, and November 3, 1975.
The inspection reports referenced above included items which were found to be in apparent violation of the NRC's re-quirements.
Included in Attachment A of this letter are written state-ments which reply to the specific items requiring a response which were identified in the Enforcement Action Section of the inspection report.
Any questions concerning these replies should be directed to this office.
Very truly yours,
?
R. L. Bolger Assistant Vice President Attachment
,8008270 7
Commonwealth Edison Company ATTACHMENT A Infraction A.1
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A.l.a:
Dresden Unit 1 reactor high pressure scram switches "as found" and "as left" reset points left outside Dresden Station's procedural limit.
Discussion:
The reactor high pressure scram switches have separate trip and reset adjustments which are addressed in the surveillance proce-dure.
Although there are no requirements to verify the reset action in the Technical Specifications, it was included in the procedure as a form of administrative control to assure that the switch would re-set.
The reset action of this switch has no safety consequence.
Therefore, the "as found" and "as left" setpoints, which were recorded on the March 1975 surveillance, were not considered to be a sufficient deviation to warrant repeating the surveillance test.
Corrective Action:
The reset action on the reactor high pressure scram switches was ad justed to conform with procedure requirements during the next scheduled surveillance on June 28, 1975.
Cor rective Action to Avoid Recurrence:
our responsibility to follow procedures is recognized.
The following steps will be taken to prevent future recurrences:
1.
The instrument mechanics involved will be made aware of the infraction and given specific directions pertaining to procedure requirements.
2.
The Instrument Department supervisors will be directed to verify that all procedural requirements are met prior to approving a surveillance as being completed.
Date of Full Compliance:
Full compliance was achieved when the subsequent surveillance was completed satisfactorily on June 28, 1975
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J Attachment A~
Page 2 I'
Infraction A.1 i
i A.l.b:
Dresden Unit i neutron high flux trip setpoint above value allowed by procedure.
j Discussion:
I The high neutron flux scram surveillance of September 30, 1975, indicates that the trip point was left at 123% which is above the 1144 to 116% required in the procedure.
A discussion with the instrument mechanic involved indicated that the 123% value was the value of the test current signal not the trip point.
This apparent recording mistake was verified by the fact that the next scheduled surveillance on October 20, 1975, found the setpoint at 114%.
This infraction resulted from two errors.
First, the instrument mechanic l
involved wrote the wrong number on the surveillance, and second, poor i
surveillance review allowed an apparent error to go uncorrected.
j Corrective Action:
i The next scheduled surveillance on neutron flux high scram found the trip to be within specifications.
Therefore, i; is con-cluded that no setpoint violation existed and no corrective action is required.
Corrective Action to Avoid Recurrence:
(Same as Infraction A.l.s.)
Date of Full Compliance:
Full compliance was achieved when the subsequent surveillance was completed satisfactorily on October 20, 1975.
Infraction'A.1 A.1.c:
The HPCI quarterly flow test data indicated flow less than required by the Technical Specification.
Discussion:
The HFCI quarterly flow test performed on September 9, 1975, indicated a measured. flow of 4920 gpm at pump test pressures of 500 and 900 psig,. contrary to the 5000 gpm requirement specified in para-i graph 4.5.C.1 of the Technical Specifications.
Flow data logged at test pressures of 300 and 1200 psig, at this time, revealed flows of 6000 and.5040 gpm respectfully.
No notation on the data sheet by the
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' Attachment A Page 3
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operator or shift engineer was made of the unacceptable performance at the two test pressures, although it was signed and reviewed by both.
i Correctivo Action:
No corrective measures were made at the time of the' test.
However, subsequent review of-the data indicated the HPCI system operation was satisfactory,and an error on tb? part of the operator l
in interpre' ting the percent indicated flow from a flow-indicating i
controller was responpible for the unacceptable flow results.
The HPCI pump speed, HPCI turbine, and pump pressures from the data are i
indicative of a satisfactory test.
Additional data from the quarterly j
tests performed prior to and following this test revealed similar j
turbine and pump performance with flow data within the required parameters.
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The occurrence was the result of improper interpretation of the flow indication by the operator and improper review by management of the test results.
The operator and shift supervisor involved with the flow test have since reviewed the test and concur that the in-terpretation of the.contro'ller was in error.
Improper review by management personnel allowed the data to go uncorrected at the time of the test.
Corrective Action to Avoid Recurrence:
Corrective action included, besides review with personnel in-volved, new administrative procedure DAP 11-3 written and presently being presented in training to management personnel.
The new proce-
,4 dure strengthens and clearly defines the responsibility for surveil-lance reyiew.
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Date of Full Compliance:
Full compliance with paragraph 4.5.C.1 of the Technical Spe-cifications.was completed with a subsequent flow test on November 27, 1975, when all data were documented satisfactory..
Infraction A A.l.d:
Dresden Unit 3 control' rod' drive friction testing on three drives not in full compliance with procedure.
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" Attachment A Page 4 Discussion:
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The control rod drive (CRD) friction tests are not required by the Operating License No. DPR-25 or the Technical Specifications.
The tests are conducted as a Station policy to insure proper drive performance prior to conducting pre-startup scram testing.
Failure of a CRD to meet the friction test guideline does not necessarily indicate serious drive problems.
A drive experiencing problems during friction testing is normally exercised and subsequently scram tested.
The scram test results *:e considered the final demonstra-tion of operability.
The three CRD's addressed in the noncompliance letter,had been scram tested following the friction tests and were found to be well within the specified limits.
Corrective Action:
No immediate corrective action was taken since the CRD's in question were proven to be " operable" in compliance with the Techni-cal Specifications.
Corrective Action to Avoid Recurrence:
The action taken to prevent a recurrence was to modify the existing procedure to specify notification of the operating engineer and technical staff supervisor when the test results are outside the guidelines.
Additionally, the personnel involved in the CRD testing will be cautioned to observe and report any test results outside the guidelines.
Date of Full Compliance:
Full compliance with the Technical Specifications was achieved with satisfactory completion of scram testing.
Infraction A.2 Surveillance partially completed due to plant conditions and not sub-sequently completed prior to returning system to normal.
Discussion:
This infraction addresses instrument surveillance which must be performed with the reactor mode switch in the Run position.
If
' Attachment A Page 5 the mod e switch is in refuel or shutdown, the procedure cannot be followed as written due to the abnormal relay position.
The infraction specifically addresses four incomplete sur-veillances:
1.
Reactor coolant high pressure performed on March 22, 1975.
At this time, the reactor was in the shutdown mode.
The pressure switch setpoint and safety system relays were satisfactorily checked.
Several downstream relays were not checked because they were already in the tripped condition as a, result of the mode switch being in refuel.
Corrective Action:
The downstream relays were checked on April 17, 1975, which was 11 days after the reactor came out of the refuel mode.
2.
Neutron flux high scram performed on September 30, 1975.
On this date, Dresden Unit 1 was in refuel and the in-strument is not required to be operable.
Corrective Action:
The surveillance will be performed in its entirety prior to placing the mode switch in Run after the initial criticality following the present refueling outage.
3.
Reactor vessel low water level scram performed on September 18, 1975 The reactor was in shutdown at this time which prevented several downstream relays from being checked.
The trip point and safety system relays and alarm were verified which satisfied the calibration requirement, j
Corrective Action:
The downstream relays will be verified prior to the mode switch being placed in the Run mode after the present refueling outage.
4.
Reactor vessel low water level scram performed on March 24, 1975.
At this time, the reactor was in shutdown and several downstream relays could not be i
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Attachment A
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checked.
However, the safety system relays and alarm were checked and found operable.
The unchecked down-stream relays were checked on April 2, 1975, prior to the mode switch being placed in the startup mode on April 5, 1975.
Corrective Action:
None required.
Corrective Action to Avoid Recurrence.:
A system will be developed to control surveillance to verify that if they are not completed as scheduled, they will be completed in a timely manner when plant conditions allow.
Date of Full Compliance:
Item 1 - April 17, 1975.
Item 2 - No infraction.
Item 3 - No infraction.
Item 4 - No infraction.
Infraction A.4 No Hold or Reject Tags on two nonconforming unit control rod drive accumulators.
Discussion:
Commonwealth Edison Quality Procedure 15-53 states that a nonconforming item will be tagged with a Quality Assurance Hold Tag and a Discrepancy Record will be initiated.
The two control rod dirve accumulators in question were removed from the system during maintenance.
The inside of the accumulators were pitted.
They were going to be cut up and destroyed.
There would be no infraction if the accumulators were destroyed.
1 Corrective Action:
The corrective action taken was to initiate Discrepancy Record No. 75-92 and attach Quality Assurance Hold Tags to the accumulators.
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Attachment A Page 7
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Corrective Action to Avoid Recurrence:
The deviation from the requirements of Company Quality Assurance Procedures will be reviewed with the maintenance foreman responsible for the control rod drive accumulator repair work.
Date of Full Compliance:
Full compliance to Q.P. 15-53 was met when Part 1 of the Discrepancy Record was filled out and the Quality Assurance Hold Tags were attached to the accumulators.
The date of this action was November 3, 1975.
Deficiency B.1 Fuel cask temperature and leak test data were not recorded for four fuel shipments made from Dresden Unit 2 in early September 1975.
Discussion:
The cask handling procedure in effect at the time of the deficiency in question, SOP-8, was written to comply with general license 10 CFR 71.12 and Certificate of Compliance No. 9001 Revision 2, and specifically provides for connection of temperature monitoring apparatus.
However, specific instructions regarding this connection and subsequent operation of the temperature recording device were not provided in the procedure.
Guidance in this regard was to be pro-vided by the General Electric field engineer, as this was the first required use of such temperature-monitoring equipment, and no written instructions for its use were available from General Electric at the time.
No instructions were obtained and the step requiring connection of the recording device was skipped without a procedure change in accordance with Dresden Station's procedures.
Corrective Action:
Since the deficiency was realized subsequent to the com-pletion of the fuel shipments, no corrective action was appropriate.
Corrective Action to Avoid Recurrence:
This was the first fuel shipment using the IF-300 spent fuel shipping cask.
Many irregularities existed in the Procedure SOP-8, and several improvements were indicated by the experience gained.
Attachment A Page 8 o
Prior to the next use of the IF-300 spent fuel shipping cask,
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the cask handling procedure will be revised, incorporating more de-tailed instructions on the connection and operation of the temperature monitoring equipment.
Also, the procedure format will.bc haproved to emphasize the importance of these steps.
The fuel handling foremen involved were informed of this de-ficiency and made aware of the importance of. temperature monitoring.
Date of Full Compliance:
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Procedure revisions will be completed prior to the next use of the IF-300 spent fuel shipping cask.
Deficiency B.2 Lack of documentation of hydrostatic test following replacement of Unit 3 recirculation bypass lines.
Discussion:
A 1120 i 10 psig hydroctatic test was performed on August 30, 1975, subsequent to replacement of Unit 3 "A" and "B" recircu-lation bypass piping.
The test was witnessed by Authorized In-spectors from the Hartford Insurance Co. and the Lumberman's Mutual Cacualty Company.
Except for minor valve and control rod drive flange leaks, integrity of the replaced piping, reactor veccol flange, and other portions of the reactor coolant system were verified satis-factory.
A second hydrostatic test, performed on September 4, 1975, at 1000 psig, verified repairs to the flange leaks.
During the followup review of the completed work package for the bypass line repair, the operating procedure for the 1120 1 10 psig test was inadvertently misplaced and subsequently lost.
The loss was determined during revicw by the NRC inspectors.
The test procedure was part of the documentation associated with the recirculation by-pass line repair to be maintained for the life of the plant as re-quired by section 6.5 of the Technical Specifications.
Correctivo Action:
Documentation required to comply 'with the Technical Specifi-cations now concist of documents signed by the Authorized Incpectors verifying satisfactory completion of the hydroctatic test and reactor proccure recorder traces recorded during the tout.
Theco documents will be maintained in permanent Station recordc.
.i'. l Attachment A Page 9 Corrective Action to Avoid Recurrence:
Ncwly rcvised document control procedures c econtly issued will prevent a recurrence of this nature.
The procedures spccify documents required in work packages of this type and specify de-tailed routing for specific material control.
Date of Full Compliancc:
Date of full compliance with Section 6.5 of the Technical Specifications was completed with inclusion in permanent plant records of documentation from the Authorized Inspector verifying satisfactory completion of the hydrostatic test.
Deficiency B.3 Reactor level switch not being checked at cardinal points as re-quired by the surveillance procedure.
Discussion:
Calibration of the reactor level yarway switches at cardinal points is not possible bccause the scale has been removed as an in-terim measure to prevent switch failure as a result of postulated post L.O.C.A. doncitions.
The check of cardinal points of the yar-way' indicator in no way affects calibration of the trip point.
At the present time, Station Nuclear Engineering Department is procuring level instruments which will satisfy the postulated post L.O.C.A.
environmental requirements.
Corrective Action and Corrective Action to Avoid Recurrence:
The surveillance procedure will be changed to remove the re-quirement to calibrato the level sensors at cardinal points.
Date of Full Complianec:
Our review indicates that full compliance with the Technical Specification requirements was achieved without the check of cardinal points.
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