ML20027B040
| ML20027B040 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/27/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20027B033 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.4, TASK-TM 4888N, NUDOCS 8209160292 | |
| Download: ML20027B040 (7) | |
Text
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O Commonwerith Edison O / One First National Plata. Chicago, Ilknois O
Address Reply to: Post OfEe bob 67 Chicago. Illinois 60690 Augus t 27, 1982 Mr. Jame s G.
Kepple r, Regional Adminis trator 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 Supplemental Response to I.E.
Inspection Report Nos. 50-10/82-04, 50-237/82-06 and 50-249/82-06 NRC Docket Nos. 50-10/237/249 References (a):
Cordell Reed letter to J.
G. Keppler date d June 18, 1982 (b):
R. L. Spessard letter to Cordell Reed dated May 21, 1982 (c):
E.
D. Swartz letter to D. G.
Eisenhut dated April 15, 1982 (d):
E.
D. Swartz letter to D. G.
Eisenhut dated June 11, 1982
Dear Mr. Keppler:
Re ference (a) provided the Commonwealth Edison Company response to the Notice of Violation contained in Reference (b).
Th e enclosure to this letter is being provided as a supplement to that response.
This supplemental response has been prepared to address the comments and concerns raised by Region III and as discussed with Louis 0. DelGeorge on July 29, 1982.
8209160292 820907 I
PDR ADOCK 05000010 AUG 3 0 1932 1
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' Please address any further questions that you or your staf f may have concerning this matter to this office.
Very truly yours, M v[-
Louis 0.
De1Geo rg e Director o f Nuclear Licensing EDS/bg Enclosure cc:
RIII Inspector-Dresden SUBSCRIBED and SWORN to before me this J 9 d day M
W No tary Public 4888N
ENCLOSURE COMMONWEALTH EDISON COMPANY DRESDEN STATION UNITS 1, 2, and 3 Supplemental Response to IE Inspection Report Nos. 50-10/82-04, 50-237/82-06 and 50-249/82-06 No tice of Violation Items of Noncompliance 1.
10 CFR 50, Appendix B, Criterion XII, requires that measures be established to assure gages used in activities a f fecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
The licensee's Quality Assurance Procedure Q.P.
12-52, requires the Master Instrument Mechanic to prepare lists and calibration schedules for instrumentation used for conformation to a limiting condition for operations.
Also, the licensee's Quality Assurance Program, Section 12.7, requires that in the operation o f generating stations, the equipment will be periodically calibrated or adjusted to assure that accuracy is maintained within necessary limits in order to verify design measurements.
Contrary to the above, while observing the surveillance testing of the Standby Liquid Control (SBLC) System on Unit 2,
the resident inspector noticed that the flow indicator had not been calibrated.
The surveillance procedure (DOS 1100-1) uses a rotometer flow indicator to verify the monthly surveillance requirement of " pump minimum flow rate of 39 GPM shall be verified against a system head o f 1275 psig", in Paragraph 4.4. A.1 o f the Technical Specifications.
The flow indicator did not appear on the Master Instrument Mechanics prepared lists and scheduled calibration, nor was tnere any indication of when the last time the flow indicator had been calibrated.
Corrective Action Taken and Results Achieved The noncompliance was reviewed by both the Technical Staf f and Instrument Maintenance Departments.
Since the test flow indicating device is a rotometer, calibration can only be accomplished through indirect means.
The Technical Staf f has developed a procedure for calibration o f the SBLC test flow indicator.
Water will be pumped through the flow indicator into the SBLC test tank; and using a stopwatch and the volume o f the test tank, the flow through the flow indicator will be calculated.
The volume o f the test tank has been verified by use of the test tank construction drawing and actual field measurements.
. Date When Full Compliance Will Be Achieved The calibration of both the Unit 2 and Unit 3 SBLC test flow indicators was completed on August 27, 1982.
The respective l
l SBLC test flow indicators will be calibrated each unit refueling outage.
Discussion If the noncompliance described above results in the rotometer reading higher than the actual flow rate then the pump (s) might not be meeting the minimum flow requirements.
However, this is judged not to be a concern for the following reasons:
a)
The rotometer is composed of two basic parts:
a float and tapered cylinder.
If either or both components were to wear, the rotometer would indicate a flow rate lower than the actual rate.
This would be in the conservative direction, because the monthly flow test is verifying that the pumps are operating above a minimum flow rate.
b)
A review o f all of the 1982 SBLC system pump tests revealed that the lowest average flow rate of the SBLC system pumps 3
for both units was 44 gpm.
If the rotometer calibration was of f by 10% in the nonconservative direction, the minumum Tech Spec flow rate of 39 gpm would still be satisfied, c)
Once per operating cycle, one of the two SBLC systems is actuated using the normal actuation switch, and clean demineralized water is pumped into the reactor vessel.
During this test, pump minimum flow rate is verified and compared against a previous test at the same reactor vessel pressure.
A review of past refueling outage test data indicates that the minimum pump flow rates have not been compromised.
There is no requirement in the Technical Specifications to specifically calibrate the SBLC pump flow test indicator.
However, as stated above, the calibration was completed on l
Augus t 27, 1982.
The respective SBLC test flow indicators will I
be calibrated each refueling outage.
, The only ~ Technical Specification that could be affected by the noncompliance is the monthly SBLC pump operability requirement:
4.4.A.1 At least once per month - Demineralized water shall be recycled to the test tank.
Pump minimum' flow Rate of 39 gpm shall be verified against a system head o f 1275 psig.
However, as discussed above Dresden Station believes that it is in full compliance with the Technical Specification requirement.
To address Region III's concern regarding this matter, the station has reviewed all the operating surveillances regarding -
ECCS equipment, and has verified that instrumentation used to satisfy the operability requirements of this equipment as defined in the Tech. Specs. are calibrated routinely.
In addition, the station will complete a similar review of the operating surveillances regarding the remaining equipment covered by the Tech. Specs. by October 1, 1982.
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2.
10 CFR 50.54(h) states that the -licensee shall be subject to the provisions o f the rules, regulations, and orders o f the Commissior..
On July 10, 1981, the Commission issued an order confirming the licensee's comaitments on Post-TMI related issues.
Appendix A, of the subject order listed Item II.B.4, Training on Mitigating Core Damage with dates o f January 1, 1981, for having available for review a training program for mitigating core damage and a date of March 1, 1981, for implementing the training program.
Item II. B.4 o f NUREG-0737, required training on mitigating core damage for (1) Shif t Technical-Advisors and operating personnel from the plant manager through the operations chain to the licensed operators, and (2) Managers and Technicians in the Instrumentation and Control (I&C),
Health Physics, and Chemistry Departments shall receive training commensurate with their responsibilities.
Contrary to the above, while reviewing the licensee 's training for Item II.B.4, the resident inspector found that the licensee's training program on mitigating core damage did not include I&C, health physics and chemistry personnel.
In spite of this programmatic deficiency, the inspector observed that significant portions o f these personnel as discussed in paragraph 14 of this report had been trained on the procedures for mitigating core damage commensurate with their responsibilities.
Corrective Action Taken and Results Achieved The training of all Dresden Station licensed personnel was completed as of September 22, 1981, in accordance with NUREG 0737 requirements.
Af ter reviewing the information presented in General Electric Company 's " Degraded Core" training course and in the station procedure DG A-19, " Procedure to Assure Adequate Core Cooling,"
it was determined that no additional training above what was currently in place is required by the Instrument Maintenance Department personnel commensurate with their responsibilities.
Although some members o f the Health Physics and Chemistry Departments had received training commensurate with their responsibilities, additional training was initiated to assure that all members were adequately trained.
This training was completed as o f May 28, 1982.
Re ferences (c) and (d) documented the above to the NRC Staf f and l
Region III in response to Generic Letter No. 82-05.
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> Corrective Actions Taken To Avoid Further Noncompliance In an effort. to assure that all TMI Task Action Item require-ments and commitments are adequately reviewed, a Technical Staf f engineer has been specifically assigned the task of tracking all NUREG C/37 items.
His responsibilities include assuring that all TMI Task Action Items are adequately addressed, commitment dates are met, and documentation is availaole to verify full compliance.
He will be the Station contact for Region III inquiries concerning TMI Items and will either have or be able to obtain such information that exists regarding NUREG 0737 items.
All enrrespondence pertaining to NUREG 0737 items is sent directly to '.nis individual by the Nuclear Licensing Administrator, in addition to the normal distribution copies sent to Dresden Station.
The Nuclear Licensing Administrator also provides a "NUREG 0737 Open Item Monthly Status Report" in an ef fort to identify Dresden Station commitments to the remaining NUREG 0737 open items along with their associated NRC submittal and implemen-tation dates.
Additionally, all NUREG 0737 items will be re-reviewed by the Station to assure that all issues have been addressed.
In particular, the review of items indicated as complete in our correspondence referenced in Confirmatory Order No. 7590-1, and Generic Letters 82-05 and 82-10 will be completed by October 1, 1982.
Dresden Station believes that the above methods employed to l
review TMI Task Action Item requirements and commitments are adequate.
Da te when Full Compliance Will Be Achieved All training as required by NUREG 0737, Item II.B.4 has been completed and Dresden Station believes it is now in full compliance.