ML20037B140
| ML20037B140 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/30/1977 |
| From: | Bolger R COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20037B139 | List: |
| References | |
| NUDOCS 8009040685 | |
| Download: ML20037B140 (5) | |
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3 Ona First National Ptart go. Ilknots v'
Address Reply to: Post vffice Box 767 Chicago, tihnois 60690 i
November 30, 1977 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. 50-10/77-33, 50-237/77-29, and 50-249/77-27 NRC Docket Nos. 50-10/237/249 Reference (a) :
G. Fiorelli letter to B. Lee, Jr.,
dated November 9, 1977.
Dear Mr. Keppler:
Attached to this letter is Commonwealth Edison's response to the two apparent items of noncompliance noted in Appendix A and the item of deviation noted in Appendix B transmitted by Reference (a).
Please direct any additional questions concerning this matter to this office.
Very truly yours,
.b.
W i
R. L. Bolger j
Assistant Vice President Attachment DEC i 1977 800904'O Q g
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Commonwealth Edison NRC Docket Nos. 50-10 50-237 Attachment 50-249
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Infraction 1:
Contrary to 10 CFR 50, Appendix B, Criterion V, and the licensee's Quality Assurance Program, the licensee, on two separate occasions, allowed safety-related modification work on Unit 2 to be completed prior to proper management reviews, as identified in QP 3-51 and DAP 15-1.
Corrective Action:
As stated in the inspection report, the DAP 15-1 reactor safety precaution form was reviewed for modification 12-2-75-110 However, this review was not done until after the modification was installed.
This review showed that no precautions were violated during the modification installation.
The noncompliance for modification 12-2-75-91 was identified and a discrepancy report was written.
The response to the report indicates the need for training.
Corrective Action to Avoid Recurrence:
A training session will be held to stress the importance of obtaining reviews as required by DAP 5-1, DAP 9-1, DAP 15-1, QP 5-51, and QP 3-51.
Also, the requirement for proper authorization as required by QP 3-51 will be emphasized.
This training session will be held for all persons involved with revica and authorization of modifications.
l Date of Full Compliance:
The training session will be completed by 3/1/78.
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1 Commonwealth Mison NRC Docket Nos. 50-10 50-237 50-249 g
Infraction 2:
Contrary to 10 CFR 50, Appendix B, Criterion V, and the licensee's Quality Assurance Program, the licensee failed to properly control Unit 2 modification package No. 2-76-55 in that the package is lost.
Quality Procedure No. 17-51 identifies modification packages as lifetime records.
Corrective Action:
The memo to file, which teports the modification as being lost, also contains a safety evaluation which reviews this modification.
This evaluation was made to ensure that no unreviewed safety questions were created by the lost modification.
Corrective Action to Avoid Recurrence:
A modification status form will be implemented in the next four months.
This form is designed to keep track of the location of modifications and indicate the person presently responsible for some action on the modification.
This form will serve a twofold purpose.
One is to prevent lost modifications and the other purpose will be to provido a log by which the progress of modifications can be reviewed.
Date of Full Comoliance:
The modification status form will be implemented by March 31, 1978.
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P Commonwealth Edison NRC Docket Nos. 50-10 50-237 50-249
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Deviation:
Contrary to the commitment made in the licensee's Quality Assurance Program, the licensee failed to comply with the requirements of ANSI N45.2.3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plants," in that an adequate program to control housekeeping and storage at the facility does not exist.
Discussion:
Historically, routine plant cleaning has been accomplished in accordance with Dresden Administration Procedure (DAP) 7-2.
This procedure specifies that cleaning assignments will be made by an Operating Engineer and verified complete by the Shift Engineer.
In addition, specific plant cleaning, such as that which is required following completion of a major task (pmmp overhaul, piping reroute, etc.), is normally considered a part of the task and is normally completed immediately following completion of t'e task.
n Corrective Action and Corrective Action to Prevent Recurrence:
In order to supplement facility control of housekeeping and storage areas, two new Administration Procedures have been written.
DAP 7-12, " Plant Cleanliness Inspection Program",
specifies the requirements and method of conducting plant clean-liness inspections.
This procedure identifies overali cleanliness
' program responsibility and provides plant inspection guidelines.
A periodic plant inspection will be made and any discrepancies identified will be directed to responsible department heads for correction in a timely manner.
DAP 7-13, " Control of In-Plant Permanent Storage",
provides guidelines for the control of in-plant storage.
This procedure describes the criteria for a permanent storage area and specifies a periodic review of permanent storage areas to reevaluate their continuance.
The responsibility for periodic review and maintenance of permanent storage areas is also specified in the procedure.
q Cvmmonwealth Edison NRC Ducket Nos. 50-10 50-237 50-249
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The station believes that these procedures should ensure
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compliance with the sections of ANSI N45.2.3-1973, " Housekeeping During the Construction Pahse of Nuclear Power Plants", which apply to an operating plant.
Date of Full Compliance:
DAP 7-12, " Plant Cleanliness Inspection Program", is scheduled for initiation by 12/5/77 and DAP 7-13, " Control of In-Plant Permanent Storage", will be initiated by 1/31/78, with the first periodic inspection.
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