ML20037B547
| ML20037B547 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/06/1974 |
| From: | Brian Lee COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20037B545 | List: |
| References | |
| NUDOCS 8010170710 | |
| Download: ML20037B547 (8) | |
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@ Addr:ss Rep %o: Post Othc2 Box 767 Commonwealth 55 son One First Natar);..,f_Ptaza. Chicago, inmois h"-
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Chicago, Illinois 60690 September 6, 1974 Mr. James G. Keppler
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Regional Director Directorate of Regulatory Operations - Region III U.S. Atomic Energy Commission 799 Roosevelt Road i
Glen Ellyn, Illinois 60137
Subject:
Dresden Station Units 1 and 3, AEC Inspection Report, AEC Dockets 50-10 and 50-249
Dear Mr. Keppler:
This letter responds to your letter dated August 6, 1974, concerning AEC Region III inspections conducted May 7-10, 16, 17, 28-31, and June 7, 1974.
Specific replies to the items listed in the " Enforcement Action" section of the " Summary of Findings" are provided in.
In addition to the specific corrective actions identified in Attachment 1, a general corrective action will be taken to improve the understanding and implementation of the Commonwealth Edison Quality Assurance Manual and philosophy.
A formal Quality Assurance training program has been initiated for Dresden Station management personnel, which includes Technical Staff personnel.
The majority of this training will be completed by November 1, 1974; however, due to the limited availability of instructors and students, it will not be possible to complete the entire program until January 1, 1975.
It is our belief that this training program will minimize violations of the type identified in your letter of the general type involving violation of 10CFR50, Appendix B.
As indicated in a letter to you dated August 28, 1974, con-cerning this inspection report, the information contained is not proprietary.
If you want to discuss this response further, contact me at your convenience.
Very truly-yours,
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Replies to Enforcement Actions A.l.a Unit 1 Batterv Bank'Discharce Test Procedural Violation In November,1973, w' hen the subject Unit 1 battery discharge test was conducted, it was not a requirement of the Operating License or applicable AEC regulations.
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amendment to the Operating License, which was not issued until July 29, 1974, included this as a surveillance testing require--
ment.
In anticipation of AEC approval and issuance of the pro-posed mnendment, a temporary procedure was developed and used for the first time during the fall, 1973 refueling outage.
Since, the Unit '1, Operating License now requires a battery discharge test every refueling outage, the Enforcement Action was investigated 'to determine the cause of the deviation from the pro-cedure and to preclude recurrence of the deviation during future, required tests.
The investigation determined the deviation resulted because the temporary procedure used for the test on November,1973, did not include a data sheet for recording tha dat,a required by each step of the procedure.
As a consequence, the data required by step 9 of the procedure was omitted from the test results.
Corrective stens taken and results
.The procedure has been revised to include the appropriate data sheet and was issued as a formally approved procedure on
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June 7, 1974. 'The next required test which will be.during the next refueling outage and subsequent tests will be conducted using this procedure.
Corrective stens which will be taken to avoid further violationc Specifically, the revised procedure discussed above should ensure proper battery discharge testing; and generally, the,~ controls over the use of procedures have been tightened.
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Date when full compliance will be nchieved Full compliance will be achieved during the next Unit 1
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refueling outage.
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A.l.b Local Leak Rate Testing Procedural Violation on Unit 3 Corrective stens taken and results The double valving of the air supply was tested and leak tightness verified prior to the date when containment integrity
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was required by Technical Specifications.
Corrective stens which will be taken to avoid further violations The personnel involved were instructed concerning the importance of observing approved procedures.
The Quality Assurance training program discussed in the cover letter will reduce further~
the possibility of recurrence.
Date when full comoliance wili be achieved Full compliance was achieved as described in " corrective steps taken and results".
A.2 Violation of Radiation Control Procedures Corrective steps taken and results The violation was discussed with the personnel. involved, and it was pointed out that the area could possibly have contained airborne radioactivity and protective equipment was required.
They agreed that protective equipment should have been worn.
Correc_tive stens which will be taken to avoid further violations A radiation protection retraining program has been initiated for all Dresden Station personne'l.
This retaining will reinforce the importance of following radiation control procedures.
Date when full compliance will be achieved Full compliance was achieved when the violation was discussed with the personnel involved.
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-A.3, Unit 1 Refuelino Ooerations Without Written Procedures Corrective steps 'taken and results At the completion of the operation, the "as left" condition of the reactor was evaluated and determined.to be satisfactory.
Corrective steps which will be taken to avoid further violations As indicated in the citation, removal of the orifice plate
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from Unit 1 core position 55-08 with a stainless steel J-hook was performed without an approved written procedure.
This work in the past has been considered to be within " craft capability" using standard tools provided for this service.
This occurrence, however, has pointed out the need for a more detailed evaluation of in vessel work and consideration of the forces involved in remote handling such that the tools are not stressed beyond their capability.
In the future, special work in the reactor requiring hand tools will be done using approved procedures.
As a minimum, these procedures will be required to address 1) the allowable equipment and method of assembly, 2) the permissible force or load which may be used, and 3) other factors which will' ensure the equipment being used will remain intact and not damage reactors internals.
Implementation of these procedures should provide reasonable assurance tha t potential for recurrence will be minimized.
Date when full comoliance will be achieved The requirement to use approved procedures for special
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work in the reactor will be implemented on and after October 1, 1974.
A.4 No Documentation of Like-for-Like Replacement of Uni.t 1 Core Spray Pumo Breaker Trio Unit-Corrective steps taken and results The currently installed breaker trip unit has been checked and it has been verified as the proper unit and documented.
Corrective steos which will be taken to avoid further violations Implementation of the recently revised corporate an'd Dresden Station procedures for controlling safety related maintenance will minimice further occurrences of this type.
The revised corporate
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' procedure, commonwealth Edison Company Quality Assurance Manual QP-3-52, was ef fective 6-24-74 and the Dresden Station procedure,
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QCP-3-52.1 was effective 6-18-74 Date when full comoliance will be achieved
!I Verification and documentation of "like-for-like" replacement has been completed.
A.5 Modification to Unit 1 Standby Liquid control System Without Encineerine Deoartment Aporoval Corrective steps taken and results The "as built" modification package will be submitted.
to the Mechanical and Structural Engineering Department for review, If the change is not approved "as built", any design changes or retesting required will be completed as soon as possible but no:.
later than January 1, 1975.
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Corrective steps taken to avoid further violations Adherence to estab1'shed quality procedure for modifica-i
~ tions Qill preclude this type of violation.
The quality assurance training program discussed in the cover letter will improve under-standing and adherence of the quality procedure.
Date when full compliance will be achieved Full compliance will be achieved by the date indicated in the " Corrective steps taken and results".
A.6 Failure to Use ANSI N45.4-1972 Data Reduction Methods During the Unit 3 Primarv Containment Leak Rate Test Discussion of violation On the~ basis of a letter from D. L.
Ziemann to J.
S. Abel, dated November 26, 1973, it was and is our understanding that the Unit 3 containment surveillance program specified in the Technical Specifications (including Change No. 14) is acceptable compared with l
the requirements of Appendix J of lOCF550.
With this understandinc, adherence with the Technical Specifications was considered the proper and only criteria for the primary containment integrated leak rate.
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The Technical Specifications include the requirement:
"The data reduction methods of ANSI N45.4-1972
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will be applied for the integrated leak. rate tests."
The September 26, 1973, letter referenced in your report committed to testing in,accordance with the Technical Specifications and ANSI N45.4-1972 data reduction methods.
As indicated above, this commitment was included as a Technical Specification require-ment by Change'No. 14 dated November 26, 1973.
From the preceding facts, we conclude that the only bases for evalsating the adequacy of Unit 3 containment leak rate test are the Technical Specifications.
Corrective steos taker. and results a.
Final calculations included in the leak rate test report were made in accordance with ANSI N45.4-1972 data reduction methods.
The calculated leak rate was within Technical Specification limits.
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The information and data available was evaluated and on the basis that it was sufficient to allow proper data reduction and leak rate calculations, no other action was taken.
These calculations were performed subseq2 ent to the c.
test and included in the leak rate test report.
Corrective 'steos uhich will be taken to avoid further violations a, b & c.
The integrated leak rate test procedure will be modified to include requirements which will ensure implementation of all aspects of ANSI N45.4-1972 data reduction methods as required by Technical Specifications.
Date when full comoliance will be achieved Compliance was achieved whnn the leak rate test report including ANSI N45.4-1972 data reduction was completed.
This report will be submitted to you by September 13, 1974 and a summary was included in the Dresden Sta tion Semi-Annual Report submitted to you August 21, 1974.
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i A.7 Failure to Perform "As Found" Local Leak Rate Tests Discussion of violation As discus:cd in item A.6,'it is our belief that the only bases for evaluating the adequacy of the Unit 3 primary contain-ment leak rate test are the Technical Specifications.
The Technical Specifications require the integrated leak rate test be performed prior t'o leak repairs or corrected for local "as found" leak rates when local repairs are made prior to the integrated test.
The five (5) double gasketed penetrations were opened to allow access to the containment and equipment during the outage.
The penetrations were reclosed before the integrated test, but not repaired.
Since-repairs were not performed this practice was considered to be in accordance with the Technical Specifications; however, we now recognize the intent of the Technical Specifications was broader.
We now consider the intent of the specifications to determine as nearly as possible the leak rate of the containment at the time the - unit is shut down and not just to prohibit repairs before the test.
The corrective actions are predicated on this understanding.
Corrective ~steos taken and results The leak rates from these double gasketed. seals have been tested several times in the past and' leak rates have been so low that they would be expected to have very little effect on the-integrated leak test results.
On the bases of this evaluation, which is included in the leak rate test report, it is concluded the integrated test did provide an adequate measure of the "as found" condition.
Corrective st'eps which will be taken to avoid further violations The containment leak rate test procedure will be revised by September 1, 1975 to require leak rate testing of double j
gasketed seals before they are opened during an outage in which an integrated leak rate test is scheduled.
Date when full comnliance will be achieved Full compliance has been achieved on the basis of the evaluations of the likely effect of the double gasketed seal leakage on the "as found " integrated leakage.
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l No Calibration' Records for Several Instruments Use 'During A.8 the L'-3 Intecrated Leak Rnte Test Discussicr cf violation Complete calibration records for instruments utilized for the test were not obtained due to an inadequate understanding of i
the requirements in the Quality Assurance Manual.
Corrective stens taken and results Since the test results are considered valid for the reason described above, changes to the leak rate test procedures is con-to assure instrument calibration records for future test sidered the proper corrective action.
These procedural changes will be completed before the next primary containment integrated leak rate test.
steos which will be taken to avoid further violations Corrective The-quality assurance training program discussed in the cover letter will minLmize further~ violation of Quality Assurance requirements.
Date when full comoliance will be achieved Described in corrective actions.
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