ML20064M270
| ML20064M270 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/14/1983 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064M228 | List: |
| References | |
| 5798N, NUDOCS 8302150516 | |
| Download: ML20064M270 (3) | |
Text
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Commonwealth Edison
) one First National Plaza. Chicago, Illinois g
( C "J Address Reply to: Post Office Box 767 Chicago, Illinois 60690 N
e j
January 14, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and 1
Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Response to Item of Non-Compliance in I.E.
Inspection Report No. 50-249/82-28 Dated December 17, 1982.
NRC Docket No. 50-249 Reference (a):
W.
S. Little letter to Cordell Reed Dated December 17, 1982.
Dear Mr. Keppler:
Reference (a) transmitted the results of the routine inspection conducted by Mr. D. L. Robinson on November 9, 10, and 12, 1982, of activities at Dresden Nuclear Power Station, Unit 3.
The Appendix to Reference (a) identified one item of non-compliance with NRC requirements.
Our response to this item of non-compliance is responded to in Attachment A to this letter.
Please address any questions you may have concerning this matter to this office.
Very truly yours,
~:<
h L. O. DelGeorge Director of Nuclear Licensing 1m Attachment cc:
Region III Inspector - Dresden
'79 "
JAN 181983 8302150516 830208 PDR ADOCK 05000249 0
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NRC Docket No. 50-249 Commonwealth Edison Company Attachment A Response to Notice of Violation The item of non-compliance identified in Appendix A of the NRC letter, dated December 17, 1982 is responded to in the following paragraphs:
10 CFR 50, Appendix B, Criterion VI states in part that measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings,.
including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the pre-scribed activity is performed.
Contrary to the above:
Measures had not been established to assure that changes to procedures were reviewed for adequacy and approved for release i
by authorized personnel. Specifically, Revision 3 of DTS 8237,
" Calculation of Core Thermal Power - Technical Staff Method",
was reviewed by the Dresden On-Site Review Committee and-approved for release, distribution, and use without review and approval of the computer program involved.
1.
Corrective Action Taken and Results Achieved l
The procedure in question permits.the Technical Staff Engineer to independently calculate the core. thermal power. The routine method for determining the core thermal power and the APRM gain adjustment factors in compliance with the Technical Specificati.ns is performed by the Reactor Operators with Dresden Operating Surveillance (DOS) 500-6, "APRM Gain Adjustment". Both procedures, DTS 8237 and DOS 500-6, indicate that the primary means for calculating the core thermal power is with the pro-cess computer. When the process computer is not'available, a hand heat balance calculation may 'ce performed using a Monroe desk top calculator and manually input sensor readings. The inspector noted that the Technical Staff Procedure provided for an alternate backup method. This procedure referenced the use of the new PRIME computer program entitled SUBCTP2 which was undergoing operational testing. The review package for this program was completed on November 16, 1982. To permit the use of this backup in a timely manner, the procedure revision and operational testing using DTS 8080 were initiated concurrently. Unexpected problems were encountered during the program testing which delayed its approval for use.
Meanwhile, the procedure revision progressed as normal and eventually was on-site reviewed. Although technically the procedure was approved before the computer program was reviewed and approved using procedure DTS 8080, we believe that this was not a critical problem for a number of reasons.-
First, an attempt is always made to train the appropriate personnel on the use of a new system prior to its implementation. Included in this training is a review of the pertinent procedure. Therefore, a copy of the final procedure is very useful. Second, this program is an alternate backup to the normal method (process computer) for determining core ther-mal power. As such, use of this option has-been shown to occur less than once per year. Finally, the application of a hand heat balance calcula-tion requires the inclusion of a conservatism factor as stated by this procedure. The user is referenced to the reviewed documentation package for SUBCTP2. Since this package was not complete as discussed above, the user would be unable to complete the calculation.
2.
Corrective Action Taken to Avoid Further Non-Compliance f
We believe that additional corrective measures are not required i
based on the above information and.the fact that personnel who reviewed the procedure understood that a safeguard existed.co prevent the use of SUBCTP2 even though it was mentioned in procedure DTS 8237 because of our requirement to use DTS 8080 to approve new computer programs or revisions to existing programs.
3.
The Date When Full Compliance will be Achieved As discussed above, we believe the intent of the requirements has been met and that compliance was already achieved.
1 i