ML20037B129
| ML20037B129 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/19/1976 |
| From: | Bolger R COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20037B128 | List: |
| References | |
| NUDOCS 8009040626 | |
| Download: ML20037B129 (7) | |
Text
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w/ Ch.caan, m.me, co< <;a January 19, 1976 Mr. Jamca G.
Keppler, Director Directorate of Incpection and Enforccment - Region III U.S. Nuclear Regulatory Co.:aiccion 799 Roosevelt Road Glen Ellyn, Illinoic 60137
Subject:
Dresden Str. tion Units 1, 2, and 3 Response to Ili: Inc;cc' ion Rcportc 50-3D/95-20 T,C-2 3 ?, i a -2 G, c c-'
5 0 - 2 <".- 9/ 7 6 - 2 3, UnC Dito. 50-10,
.'0-237, and 50-249
Dear Mr. Keppler:
This in in response to your letter dated Deccul.acr 24, 1975 which referred to an inspection conducted by I*cs:,.n.
Shafer and ' Johnson of your office on November 5-7 n;id 2S-26, 1975.
The subject report referenced items in apparent vio-lation of URC requircmonts.
Attachment A of this letter rcplies to the itens identified in the enforcement section of the inspcct. ion re--
port.
The report was reviewed for proprietary informatdon and none was found.
A minor delay in the response was discussed with Mr.
Fiorelli of your staff by telephone on January. 16, 1976.
Any questions concerning this reply chould be directed to this office.
Very truly yourc,
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R. L. Bolger Assintant vice President Attachment A
Commonwealth Edison NRC Dhts. 50-10 50-237 ATTActii:M!<T A 50-249 INFPACTION UO. 1 1
Purchase of safety related parts from an un~ approved vendor contrary to the requirements of Commonwealth Edinon Company Quality Assurancc Procedure 4-L1.
Discussion:
The tempernture switches ucre purchased in an effort to obtain a switch with loss setpoint drift.
Switches with improved perfornmnce charactern: tics worn nurcha,ad frc:a a vender not on 1.hc Commonwealth 1.:dison Ccupany Approved Didders List.
The pc.-formance of these switchen has been satisfa...>rv, nnd the incidence of set-point drift has been significant.lv reduced, Correctivo 1.ction:
A request vill bo initinted to place the vendor on the Approved Bidders List.
Corrective Action to Avoid Recurrence:
Section 4-51 paragraph A.10.c of the Quallty Assurance Manual designates th c staff nasistant for inventory control-nuclear as the individual responbible for ensuring that vendoru arc on Ao-proved Bidders List.
A review of procedurcs for this position in being conducted to determine what changes could be made to avoid rc:-
l currence.
Date of Full Compliance:
l Full compliance will be achieved when the temperaturc switch vendor has qualified to be placed.on the Approved Bidders l
List.
l INFRACTION NO. 2 Relcaco of safety related material for use without re-l colving a recorded discrepancy.
Discuusion:
The Discrepancy Record was issued for this material (valve),
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Coinmonwealth Edison because the quality documents roccived were not in accordance with the purchase requirements.
Corrective Action:
The roc,uired quality documentation Will be obtained and rocciving inspcction documentation will bc completed.
Corrective Action to Avoid Recurrence:
Since the dato of this infraction, storcroom personnel have been trained in the proper procedure for handling discrepan-cies resulting from nonconformance identified during receipt in-spections.
This training in conjunction with physical knproc monts in the storeroca to segregato nonconfonaing materials will avoid recurrence of this infraction.
Date of Full Complianco:
Full complianco vill be achieved when the required do-cuments are rcccived, reviewed,.and accepted.
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INFRACTIONS NO. 3 and UO. 4 No reply-rcquested.
INFRACTION NO. 5 Contrary to DAP 2-12, action was not-initiated to correct improper operation of the LPCI loop select logic.
Discussion:
As a result of a high dryucl1 pressure reactor scram and ECCS initiation on September 29, 1975.(Abnormal Occurrence Report No. 50-237/75-46), an investigation was immediately initiated to determine the cause of possible wrong loop selection and pump trip failure of the LPCI loop select logic system.
Confusion resulted when both loop colections appeared to bc wrong and the opposite loop pump did not trip as tha design calls for.
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Due to the complexitics of trraing out the LPCI loop select logic on the electrical drawings, the project took several days to complete.
An accurato evaluation needed to be made to detennine if a problem actually existed.
As a result of this investigation, the loop select and pump trip (d P) switches were investigated by the instrument me-chanics with the resulting reported failurcs (Rcport No. 50-237/
75-49).
The problem was identified promptly after occurrenca even though a deviation report was not written until tha actt'al malfunction was found.
An investigation was promptly initiated to dctormine if, in fact, a problem c::isted.
Corrective Action:
The switches repcrted as out of calibration or failed were rcolaced or recalibrated and logic system operation verified satisfactorily.
Corrective Action to Avoid Recurrence:
To prevent recurrence, the loop select logic switches wore replaced with new switcheu which have signal damping and which will reduce the amount of relay ' cycling.
The pumpe.P switches were replaced with new lower range bellows (0-60 psi to 0-6 psi) to allow switches to perform accurately in the 2 psid range which is required.
Date of Full Compliance:
Full compliance was achieved on November 5, 1975 when all the switch modifications were completed.
DEFICIENCY 1;0. 1 Lack of material control for the safety related systems.
No red two-part tagc on the IIPCI temperature cwitchen.
Discussion:
This' deficiency was identified because the red two-part tags woro not available in the completed modification packages.
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, Co.rrective Action:
The red two-part tag.hac been placed in the modification package after verification of proper rocciving acceptance of the material (temperature awitchec).
Corrective Action to Avoid nceurrence:
Sinco mid 1975, Quality Procedure training hac bcon con-ducted and the purpoce and proper use of the red two-part tag was included in this training.
Sinco June 1975, final document check-licto are being uced to provide a final check to encure that cafety related moffif feation and '.tork request packagcc contnin the required quality documents.
Date of Full Oc.'1pliance:
Full compliance was achieved with completion of the cor-rective action on January 10, 1976.
DEFICI2I:CY EO. 2 Discussion:
Unit 2 went critical for Cycle 4. operation on nny 10, 1975.
With the c::ception of the single recirculation pump c'.cta, the startup tects ucro ccmpleted by the first of Juno.
Duc to system load re-quirements and othc; cporating rectrictioac,, sin.jlc pump oparating data wac not obtained until September 13, 1975.
The staff uns not aware of the cpocific wording of the reporting requircuents of Regulatory Guido 1.16.
Thereforc, the startup test report was not prepared until the completion of the testing program.
Correctiva Action:
On December 5, 1975, the complete startup tect report was submitted.
Thic wac within 90 days of the lact tcat but not within 90 daya of return to power operating and commercial g:crvice.
Corrective Action to Avoid Recurrence:
The schedttle requirements for.submittin'g a startup tent report will bc ' included in the outage nurveillance file to remind cognizant raambers of the specific requiremento.
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'-S-Date of Full Complianec:
o'n December 5,1975, full compliance was achieved when the L
report was submitted.
DEFICIENCY NO. 3 Discussion:
On September 29, 1975, an uncontrolled nitrogon addition to the dryucil created a high drywell proscuro condition.
This condition cauced a reactor ceram, a drywell icolation, and started l,
al1~ low proscure coolant' injection system ptcaps, core cpray pumpc, and the higM proccurc'coolent injection cystem.
With,a drywell?icolation'in offect, it was not poscible to reduce the drpwell prosauro and c1 car the coro spray /lo proscure-s E
coolant injection systou indicating signal in a timely nnnner.
Under j '
these circumstances, an uncontrolled injection of these systems would have occurred a'c about 35d psi or about 4400F reactor water tempora-
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Ir. ordef to avoid scvoro consequences of the inevitable V
injection of the systems, operaticas personnel placed the pung control
< switches in pull-to-lock in order to stop the pumps.- Thi~c was donc
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in accordance with? Station procedures after determining that the reactor vossel unter' level was normal and the source of high drywell y
pressurovwas identified.
According to the datails of the report, this action has taken at 700 psi which corresponds to about 5000F j ~
reactor wanor, temperature.
The normal cool down rato is 1000F per hi g,I;[ jhour;for/this unit.'. Thore for*c,.the operator placdd the switches in
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pull-to-lock approximately 35 minutco before injection could be ex-
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In' view of the many manipulations required during.
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c the cuitchen in pull-to-lock was prucknt.
The fact that the operatorn were able to. control the scram redoycry Mnd naintain a reasonable cool down rato under the circum-
'stapMon#b[$o'theircredit.
i oy i-A review of the incident reveals no inctancca of violationc of'thc Technical Specifications; Dy'the details of,the inspection 4 report,fomeactionhadtobetakentopreventtheceverotrancient which would have reculted from the core spray and low proccure coolant 3 3
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Therefore, if one conciders placing the pump cwitchec in pull-to-loc]; making the cystem inoperable despite the fact that the pumps were i:nmediately availabic at the touch of the operator's hand, then by the termc of your report, Section 3.5.n.1 and 3.5.A.3 could not be fulfilled.
However, the Technical specificationc prc-vide guidance por Section 3.5.A.7 in the event the above specific _t-tions are not mot.
The reactor uns placed in a ;old shte down condi-tion within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by Section 3.5.A.7.
It is judged that operator responce to the ceram was r'ctsonable and proper and it did not constitute a violation of the Technical Specifications.
The operatora uced rcaconable judgement in acting in the interect of reactor c?fety.
It is esncntial they continue io do co and not abdicr_.tc th.i c recponcibility to preccure suitches and relayc.
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