ML19340A746
| ML19340A746 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/13/1975 |
| From: | Bolger R COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19340A745 | List: |
| References | |
| NUDOCS 8009030774 | |
| Download: ML19340A746 (6) | |
Text
Comm:nwrith Edison ons First National Plaza. Chicigo. !!hrtoG Address Repiy to: Post Othc3 Box 767 Chicago, Ilhnois 60690 s
August 13, 1975 Mr. James G. Keppler, Regional Director Region III, Inspection and Enforcement 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Response to Noncompliance Items Contained in Dresden Station Inspection Report 50-10/75-11, 50-237/73-16, and 50-249/75-13, NRC Dockets 50-10, 50-237, and 50-249
Dear Mr. Keppler:
This response addresses the items of noncompliance specified in the above referenced inspection report, which was transmitted by your letter dated July 18, 1975.
Responses to those items are stated below.
As discussed with Mr. Fiorelli on August 8, 1975, these responses are being submitted 23 days after receipt of your letter on July 21, 1975.
A.
Infractions 1.
The loss of a roll of Nashua silver duct tape in the Unit 2 reactor vessel.
Corrective Action Taken The immediate corrective action was to complete installation of the dust seal around the work platform and hold discus-sions with the contractor doing the work, with emphasis on following procedures.
The roll of tape was dropped into the vessel just after the work platfom was installed and before installation of the dust seal.
Details of the efforts made to locate the tape and subsequent evaluation were reported in report 50-237/75-25, dated May 23, 1975.
Corrective Action To Prevent Recurrence The procedure usad for the Unit 3 sparger replacement work (which followed) were improved, with travelers containing hold points for installation of the dust seal and with the addition of taping it to the vessel walls to seal off any 800gggg
.u u e.
C mmonwealth Edison Company Mr. Jmues G. Keppler August 13, 1975 openings.
The tool and equipment vessel log was specified to be in use before the dust seal was installed and is to be used throughout the job to account for all tools and equipment.
Procedures called for equipment and tools to be tied off with lanyards when used in the vessel to prevent inadvertent dropping into the vessel.
The proce-dures also specified notifying the shift engineer imme-diately upon loss of an object in the vessel for prompt assessment and action.
The contractor responsible for the work was made aware that he had not followed Station Procedure.
Date of Full Comoliance Pull compliance was achieved with the modification of.the procedures on May 22, 1975.
2.
Movement of control rods while personnel were working on the service platform over the open vessel.
Corrective Action Taken When the operating engineer became aware of the occurrence on April 23, 1975, the immediate corrective action was to stop movement of the control rods.
Corrective Action to Prevent Recurrence The procedure for CRD Friction Testing was revise'd to include Ehe precaution to exclude personnel from within line of sight of the core.
The reactor service platform for Units 2 and 3 will be modified to initiate a rod block whenever it is installed.
This modification will allow removal of presently installed jumpers 1-72 and 2-72.
I Date of Full Comoliance The Procedure was revised on August 13, 1975, and the modification will be installed by the next refueling outage for-Units 2 and 3 presently scheduled for 1976.
l3.
Lack of review of response to recent enforcement actions by the onsite Review and Investigative function.
Corrective Action Taken The immediate corrective ac' tion taken was to review all
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Ccmmonwealth Edison Company Mr. James G. Keppler August 13, 1975 enforcement correspondence for 1975 and institute onsite
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reviews where necessary.
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Correction Action to Prevent Recurrence After the Administrative Assistant and the Technical Staff Supervisor reviewed the requirements, Procedure DAP 9-4 was revised to r equire Onsite Review of responses to enforcement action through the use of deviation reports.
Date of Pull Comoliance Procedure DAP 9-4 was revised on May 22, 1975.
Onsite reviews for all outstanding responses were completed by June 1, 1975.
4.
Replacement of 2A recirculation pump seal without use of an approved maintenance procedure.
Corrective Action Taken No immediate corrective action could be taken since the NRC inspector noted the deficiency subsequent to comple-tion of the workI.
Corrective Action to Prevent Recurrence The maintenance procedure used has been approved by Onsite Review.
Date of Full Comoliance Full compliance was achieved on July 14, 1975, when the Onsite Review approved the procedure.
B.
Deficiencies 1.
The three deficiencies noted all concerned the failure to report abnormal occurrences in the required time period.
a.
Failure to report the item discussed under Infraction No. 2 Corrective Action Taken T
The deviation report was instituted.
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I e
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Cemmenwealth Edison Company Mr. James G. Keppler Auguet 13, 1975 Corrective Action to Prevent Recurrence The incident was initially evaluaced as not requiring an abnormal occurrence report.
Upon.further conver-sations with the NRC, it was decided to report the incident as an abnormal occurrence, at which time the necessary reporting requirements were met.
Date of Full Comoliance Full compliance was achieved with the filing of the ten-day letter, May 27, 1975.
b.
Failure to report the failure of the Unit 2 diesel generator to start.
Corrective Action Taken Upon recognition of the event as an abnormal occur-rence, a deviation report was initiated.
Corrective Action to Prevent Recurrence The incident occurred during an unrelated outage on the diesel generator.
The incident has been reviewed with the operating engineers to stress the reporting requirements of unrelated failures during equipment outages.
Date of Full Ccmoliance Full compliance was achieved with the submittal of the ten-day letter, May 23, 1975.
c.
Reporting of Infraction No.1 Corrective Action Taken Upon discussion with the NRC inspector and his statement that it was a reportable event, a deviatinn report was instituted.
Corrective Action to Prevent Recurrence Again, the operating engineers are aware of the reporting requirements, once an incident is classified as an abnormal occurrence.
Date of Full Comoliance Full compliance was achieved with the issuance of the ten-day letter, May 23, 1975.
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Ccmmonwealth Edison Company Mr. James G. Keppler August 13, 1975 2.
Failure to report certain chenistry data in the Semi-Annual Report Corrective Action Taken The data for the second half of 1974 will be included in the first half, 1975, Semi-Annual Report.
Corrective Action to Prevent Recurrence The chemistry personnel have reviewed the appropriate sections of Regulatory Guide 1.16, Rev. 1.
The applicable blank data sheets will be added to the Semi-Annual Report data sheets for future use.
Date of Pull Comoliance Full compliance will be achieved by September 1, 1975, with the submission of the Semi-Annual Report for the first half of 1975.
Your letter transmitting the inspection report also expressed concern about Dresden's system for management control of NRC licensed activities and asked what actions have been taken or
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are being considered to improve the effectiveness of such control.
Listed below are several steps which are being considered or have been tiken to improve station control over URC licensed activities.
Dr'esden Station staffing is under constant review.
Manpower has been increased each year, frem 254 at the end of 1971 to 402 at the present, with over 40 added so far in 1975.
Dresden is several persons'short of"its goal of licensed people, although plans are to train about 16 people for licenses each year, which should meet the licensed personnel requirements by late 1976.
An engineering assistant was recently added to the shift engineers office to assist with some of the more routine shift engineer adninistrative duties.
Consideration is being given to adding a shift foreman on each shift to provide additional supervision for each unit and radwaste.
To develop a greater awareness of the significance of reactivity related evaluations, a special one day seminar on nuclear and thermal fuel considerations is being provided.
All licensed e
i Commonwealth Edison Company Mr. James G. Keppler August 13, 1975 shift personnel and the technical staff nuclear engineers are scheduled to attend.
This special training should be completed by September 1,.1975.
All new and revised procedures concerning control rod movements are now reviewed by one of the technical staff nuclear engineers.
By January 1976, all present procedures requiring control rod movement will have been reviewed by the nucicar engi-neers and revised as necessary.
The nuclear engineers are receiving training from the lead nuclear engineer to improve their skills and assure exchange of information in the group.
Earlier this year, four (4) quality control inspectors were added to the staff.
These persons have received and vill continue to receive appropriate training.
These inspectors are performing an important service which should reflect in improved operations.
Recently, the Training Department acquired an engineer who will be assigned the task of training the Station personnel in the use of the Quality Assurance Manual.
The Dresden Station Technical Staff has recently received training on the Unit 2 and 3 Technical Specifications, to be followed in September 1975 with an Equipment Description course.
This course will continue to be available to train new Technical Staff Engineers.
This training should substantially improve the Technical Staff's knowledge of the Station and will assist then in performing their duties.
An im,oortant force in Quality Assurance Training is the ASME "N" stamp program in progress at Dresden Station.
This program requires a number of changes to the Station procedures, but should result in a better trained operating management team.
Dresden is presently scheduled for its inspection by ASME in February 1976.
Previous commitments to the NRC required revision to all Station procedures, which are scheduled for completion by May 1976.
We are currently reviewing and reorganizing the Administrative Procedures.
Very.truly yours, R. L. Bolger Assistant Vice-President