ML19340A876

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Responds to NRC Re Violations Noted in IE Insp Repts 50-010/78-10,50-237/78-09 & 50-249/78-09.Corrective Action:Shift Supervisor 780407 Meeting Stressed out-of-svc Procedure & Responsibility for Equipment Status
ML19340A876
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 05/03/1978
From: Reed C
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19340A875 List:
References
NUDOCS 8009040696
Download: ML19340A876 (4)


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@ One First National Pf728. Chicago Ithnois Commonwealth E " son Address Reply to: Post Othee Box 767 Chicago, litanois 60690 May 3, 1978 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Units 1, 2 and 3 Response to IE Inspection Report Nos. 50-10/78-10, 50-237/78-09 and 50-249/78-09 NRC Docket Nos. 50-10/237/249 Reference (a) :

G. Fiorelli letter to B. Lee, Jr. dated April 12, 1978

Dear Mr. Keppler:

The following is in response to an inspection conducted by Messrs. W. D.

Shafer and J. L.

Barker on March 2,3, 7, 8, 14-16, 22, 23, 27 and 28, 1978 of activities at Dresden Station.

Reference (a) indicated items that appeared to be in noncompliance with NRC requirements.

Our response is enclosed in the attach-ment to this letter.

Regarding the commitments relating to the modification program, approximately one dozen relatively old modifications were cancelled on March 31, 1978, after it was determined that all necessary records were on file for these modifications and no physical work had actually begun on them.

Another four modifica-tions, for which some records were missing, were cancelled by

/ eil 7, 1978 after determining that no physical work had been parformed.

Approximately twenty-five modifications, with few or no records available, remain to be reviewed to determine if any physical work has been initiated.

If any work has been performed, an additional review by the On-Site Review function will be made to determine that any necessary procedure or drawing changes are identified.

Although the schedule is tight, the station currently plans to complete this review by June 15, 1978.

$I3 800004,ofpf

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Commonwe:lth Edison NRC Dockot Nos 50-10 50-237 1

50-249 Mr. James G. Keppler: May 3, 1978 Please refer any additional questions you might have on this subject to this office.

4 Very truly yours, b

o Cordell Reed Assistant Vice-President i

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Commonwe:lth Edison NRC Dockst Noa. 50-10 50-237 ATTACHMENT 50-249

'N INFRACTION 10 CFR 50, Appendix B, Criterion 5 reauires that activities affecting euality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, os drawings.

The licensee's Quality Assurance Manual and Administrative Procedures (QP 14-51 and DAP 3-5) require out-of-service equipment to have affixed to it OOS cards.

DAP 7-2, " Conducting of Operating Shift Routine," recuires that at a minimum the items to be covered during a shift turnover include the status of the unit systems and problems encountered during the concluding shift and their solutions or the progress,made towards solving them.

Contrary to the above, the licensee failed to affix an out-of-service card to the gland seal leakoff drain pump for the Unit 2 HPCI system when that pump was taken out of service on March 22, 1978, and failed to turnover the status of the gland seal leakoff drain pump during the shift turnover between the midnight and day shifts.

DISCUSSION At 0850 on March 22, 1978 an NRC inspector observed the HPCI Gland Seal Condenser (GSLO) Drain Pump control switch on panel 902-3 in the pull-to-lock position.

This pump is not re-quired for HPCI system operation, however, and the HPCI system remained operable.

The inspector.cuestioned the NSO about the status of the pump.

The NSO was unaware that the pump switch was locked out, and he returned the cortrol switch to " auto".

A prompt investigation by the Shift Foreman, Ecuipment Attendant, and Ecuipment Operator revealed that the pump was inoperable but not out-of-service.

The pump was subsequently taken out-of-service.

Later.that day, the pump motor brushes were replaced and realigned, and the pump was returned to service.

During the investigation of this event, it could not be determined when the control switch was placed in pull-to-lock.

At 0425 on March 22, the HPCI system had been returned to service following repair of a steem chest flange leak.

The necessary system operating surveillances had been completed and witnessed by an Equipment Operator, who was in training to become an NSO, and a Shift Foreman.

As recuired by the curveillance checklist, the GSLO pump had been operated and the control switch position l

CommonweIlth Edison NRC Dockst Noa. 50-10 50-237 50-249 rw had been witnessed in "off" at the completion of the tests.

The NSO may have inadvertently placed the control switch in pull-to-lock, however, upon completion of the surveillances.

Because the pump indicating lights re.aain " green" (normal) in pull to lock, as well as in off, and because no off-normal alarm annunciation would have been received, all three personnel monitoring the test could have failed to notice the actual position of the switch.

When in the pull-to-lock position, the control switch for this pump is parallel with the control panel, and it is possible to fail to notice the switch position is abnormal.

CORRECTIVE ACTION AND CORRECTIVE ACTION TO PREVENT RECURRENCE A shift supervisor's meeting was held on April 7, 1978.

During this meeting, it was emphasized that the operating Department is responsible for the status of ecuipment at all times.

The shift supervisors were also instructed to follow the Out-of-Service Procedure vigorously and not to deviate from it.

Additional meetingc will be held by.iane 15, 1978 with shift supervisors and with the Nuclear Station Operators to further emphasize the need for strong control of plant equipment.

The available methods for controlling the statu= of equipmont will also be reviewed at the meetings.

DATE OF FULL COMPLIANCE The station will be in full compliance by June 15, 1978.

On this date, the shift supervisors and Nuclear Station Operators meetings will be completed.

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