ML19347C636
| ML19347C636 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/25/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19347C635 | List: |
| References | |
| NUDOCS 8012310630 | |
| Download: ML19347C636 (4) | |
Text
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1 gY one Usr Namaj Plata Cheage l'I ncis Address Reply to Post Of t:ce Box 767 Chicago. I!hno's 60690 November 25, 1960 Mr. James G.
Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Suoject:
Dresden Station Units 1, 2,
ano 3 Response to IE Inspection Repoit Nos. 50-10/80-19, 50-237/80-21, and 50-249/80-25 NRC OccKet Nos. 50-10/237/249 Reference (a):
R.
F. Heisnman letter to C. Reed dated November 4, 1980.
Dear Mr. Keppler:
Reference (a) transmitted the results of an inspection concocted by Messrs.
T.
M.
Tongue and M.
J. Jordan on September 7 to October 3, 1980, of activities at Dresden Nuclear Power Station.
Appendix A to Reference (a) identified one item of noncompliance with NRC requirements.
Our response to this item of noncompliance is provided in Attachment A.
The item of noncompliance enclosed with Reference (a) is a recurrent item.
Our review of the earlier citation concluded tnat the Drescen Administrative Procedure DAP 7-12, which provided directions for plant cleanliness, was too general.
As a result, a Acministrative Procedure DAP 3-11 was prepared which new specifically identifies responsibilities for plant cleanliness anc items to be examined during plant tours.
The new procedure was approved for station use at the beginning of August, 1980.
We Delieve that the new procedure provides proper direction for the plant cleanliness program, end that the recent citation principally reflects a continuing nsad to indoctrinate personnel to the new requirements.
To accomplish this, the material presented in the radiation protection class and the annual requalification class is being revised to provide greater emphasis on plant cleanliness as good radiation protection and f'.re protection practice.
Also, by December 1, 1980, sealor station management personnel will have held
" tailgate" sessions with all foremen in the Station Construction Department and the Dresden Operating and Maintenance Departments to emphasize the foremen's responsibilities in the cleanliness program.
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_2 We believe that these steps, supplemented by a period of increased frequency of inspe _ ion, will reinforce our current emphasis toward plant cleanliness an1 will provide the necessary improvement.
Very truly yours, A
1 Director of Nuclear Licensing Attachment cc:
RIII Resident Inspector - Dresden 8457A
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NRC Docket Nos.
50-10, 50-237, 50-249 ATTACHMENT A COMF.ONWEALTH EDISON ATTACHMENT RESPONSE TO NOTICE OF VIOLATION The item of noncompliance identified in Appendix A of the NRC letter dated November 4, 1980 is responded to in the following paragraphs.
1.
10 CFR 50, Appendix 3, Criterion II requires activities affecting quality be accomplished under suitably controlled conditions, including adequate cleanness.
The licensee's Quality Assurance Program, Section 2.2 requires that the 1* censee adhere to all
=andatory requirements of ANSI N13.7.
ANSI N18.7-1976, Section 5.2.10 requires quality housekeeping practices encompassing all activities related to control of fire prevention and protection, including disposal of combustible material and debris.
Contrary to the above, during routine plant tours on September 19, 26, and October 3,1980, the inspectors identified several areas of accumulated combustible material and debris which were not being controlled and which represented a potential fire hazard.
Examples included:
Septa =ber 19, 1980, Unit 1 Turbine building track way and turbine floor - presence of paper, wood, plastic and slings on the floor and Unit 2 Reactor Building, R.W.C.U.
Demineralizer Recirculation Pump Room - presence of mop heads, rags, paper on the floor and generally dirty on September 26, 1980, Unit 3 Reactor Building, ground floor west - presence of excessive SWP shoe covers, wipes, scraps of paper, plastic and generally dirry; and on October 3, 1980, Unit 2 LPCI rooms -
presence of. used SWP clothing, plastic bags, wipes, and a bag of trash and Unit 2 Torus basement - presence of hoses, wires, cables, wood, paper, plastic, debris and rubble in large quantities showing evidence of having been there for a long time.
Corrective Action Taken and Results Achieved In each of the instances cited above, the areas were promptly cleaned and unnecessary combustible material was renoved.
Corrective Action Taken to Avoid Further Non-Comeliance To indoctrinate personnel to the requirements of the Plant cleanliness program specified in DAP 3-11, the initial rad-1ation protection program and the annual taqualification classes are being revised to provide greater emphasis on maintaining clean-liness in the station. _Also, to emphasize to the foremen in the S tation Construction, Maintenance, and Operating Departments their responsibilities in the cleanliness program, senior station nanagers will review the cleanliness program with them_before December 1, 1980.
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To ensure the necessary improvements are occurring, the periodic surveillances throughout the plant which are called for in DAP 3-11 will be conducted on at least a weekly basis until February 16,1981.
Any discrepancies found during these surveillances will be promptly corrected.
Datt When Full Compliance Will be Achieved The tailgate sessions with the foremen will be held before December 1, 1980.
The emphasis on plant cleanliness in the ini-tial and retraining radiation protection classes will be in place by November 24, 1980.