ML20077N259

Responds to NRC Re Violations Noted in IE Insp Rept 50-249/83-12.Corrective Actions:Action Plan Implemented to Modify Certified Pipe Clamp & Reconnect Snubber to ECCS Suction Header

ML20077N259
Person / Time
Site:	Dresden
Issue date:	09/02/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20077N256	List: ML20077N259
References
7240N, NUDOCS 8309130007
Download: ML20077N259 (5)

Text

.

~

• [

r N Commonwealth Edison

/ one First NItional Ptrza. Chicago. Ilknois

. ( jNChicago, Illinois 60690O "J Addrsss R; ply to: Post Offica Bo:: 757 September 2, 1983 Mr. C. E. Norelius, Director Division of Projects and Resident Programs - Region.III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Response to Inspection Report No. 50-249/83-12 NRC Docket No. 50-249 Reference (a): C. E. Norelius letter to Cordell Reed dated August 3, 1983 (NL-83-Oll3).

Dear Mr. Norelius:

This letter is in response to the inspection conducted by Mr. T.

M. Tongue during the period May 4 through June 24, 1983 of activities at Dresden Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to .the Notice of Violation is provided in the enclosure.

In the cover letter to this noncompliance you raised a concern about coordination between construction and operations personnel to assure that modifications which affect safety systems are adequately controlled and requested we respond to this concern. CECO believes the corrective actions delineated in the Attachment to this letter satisfies this concern.

l To the best of my knowledge and belief the statements contained l herein and in the attachment are true and correct. In some respects these statements are not based upon my personal knowledge but upon infor-mation furnished by other Commonwealth Edison employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

If you have any further questions on this matter, please direct

, thra to this office.

Very uly you ,

r

~

8309130007 830908 PDR ADOCK 05000249 D. L. Farrar O PDR Director of Nuclear Licensing BR/1m Attachment q%b cc: NRC Resident Inspector - Dresden gg$

7240N , _

. -. - - . ~ . .~ - - . . - . . - .~

I *

. .. 6 COMMONWEALTH-EDISON COMPANY ATTACHMENT'A RESPONSE TO NOTICE OF~ VIOLATION Regulatory requirements involved in this modification include the

.following: ,

A. 10 CFR-50.59(a)(1) states inipart, "The holder of a license i authorizing operation of a... utilization' facility may (i) make changes in the facility >as1 described in the safety analysis report...without prior Commission approval,'unless the proposed change... involves a change in the Technical Specifications

incorporated in the license or an unreviewed safety question.

- 10 CFR 50.59(b) states in part, "The licensee shall maintain-records

, of changes in the facility... -These records shall include a written safety evaluationLwhich.provides the bases for the' determination that

- the change...does not involve an unreviewed safety questions."

t .B. Technical Specification 3.6.I.1 requires that Hydraulic Snubber No, c 16 shall be operable during all. modes of operation except cold shutdown and refuel. Technical Specifications 3.6.I.2 and 3.6.I.3 require that the reactor shall be in the cold shutdown or refuel conditions 1within 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> after Hydraulic Snubber no. 16 is made inoperable unless'the snubber is sooner made operable.

! 'C. . 10 CFR 50, Appendix B, Criterion XIV, " Inspection, Test and Operating Status", requires that measures shall be~ established for indicating.

~

the operating status of. structures, systems'and components.

Criterion'XIV is f.mplemented by Topical Report CE-1-A, " Commonwealth i Edison Company Quality Assurance Program for' Nuclear Stations",

Section 14, which requires that measures beLestablished under the control. of the Shift Engineer for indicating tha operating status of

. equipment during plant operations. Section 14 is implemented by Quality Procedure 14-51, which requires'in Section B that authorization to remove-equipment from service can only be made by the-Shift Engineer.

Contrary to1the above requirements:

A. The-licensee removed Hydraulic Snubber No. 16 from the Emergency Core Cooling. System suction header on~ February 4 or 5, 1983, without prior Commission approval while the modification required a change in Technical? Specification Table 3.6.1.a; B. .The licensee replaced Hydraulic Snubber No. 16 on the Emergency Core Cooling System suction header with a mechanical snubber on May 5, 1983Ewithout prior' Commission approval while that modification required:a change in Technical Specification Tables 3.6.1.a and 3.6.1;b;.

.a

, ,.cc - ,..a-., ,,--.---.,n.--~.-_..-. . - , . . . - . , - = . , - _ - - - _ , - - . . - ,

r, .

i J.

. . t

c.  :.

2-C. IThe licensee-replaced Mechanical Snubber'No. 23 on'the Reactor Water i Cleanup-System piping with a hydraulic snubber sometime during the

~

refuelingnoutage that occurred between January 2 and May 4, 1982,-

withoutLprior-Commission approval while the modification-required a

. change.in-Technical Specification Tables 13.6.1.a and 3.6.1.b; i

D._ The licensee didinot maintain records that included a written safety evaluation which provided the bases for the. determination'that.

removal"of-a single hydraulic snubber from the -Emergency Core Cooling

' System su " ion. header did not involve an unreviewed safety question; i

~E.. Hydraulic Snubber No. 16'was detached (rendered inoperable) from the Emergency? Core Cooling System suction header on February 4'or: 5, 1983,cand was replaced with a mechanical snubber on May 5, 1983.

During the period that'the' snubber was inoperable (approximately 89 days) the reactor was in the run mode and action was not taker, to

- satisfy the requirements of Technical Specification 3.6.I.2 and 3.6.'I.3.

F '. -Hydraulic Snubber No. 16 was taken out of service on February 4 or 5,

- 1983, without' authorization'from the Shift Engineer.

DISCUSSION As'partlof.the BWR Mark.I Containment Modification Program and-to meet: certain I.E. Bulletin No. 79-14 requirements, the twelve -(12)  ;

original ECCS suction header hydraulic type snubbers are to be replaced

with twelve (12) mechanical' type snubbers. On May 4, 1983 at 1:00 p.m.

safety ~;related Snubber No.16 (one of twelve) located on the Dresden Unit 3itorus ECCS suction ring header was found to be physically disconnected.

Reconstruction of the event indicated that the site contractor personnel had removed the original snubber in February 1983 and were in the process of installing.the~ replacement snubber when they-discovered the pipe clamp

-(24-inchisize)...did not fit the associated piping header. The installation i

remained incomplete while the compatible pipe clamps were ordered. At this time:the Modification Group Cognizant Engineer was aware of the need c for the-license amendment-permitting the snubber removal but was unaware that-the. contractor.had started work under the approved modification

l package._ In' addition,'the work was left incomplete, because neither the site l contractor nor Station Construction Department personnel knew the n  ; Technical.~ Specification requirements governing snubbers on this system.

L -It must be recognized that snubbers are passive components and was not

removed from service utilizing conventional station out-of-service L techniques.

As a result, Dresden Unit 3 -was operated outside of the

. described snubber Technical Specification LCO for approximately 89 days, but within the bounds of an analysis-that had been accepted by the NRC for. previous ~ modification activities.

t '-~-N--*- + - Y ar +,w- e~-s w -r--w e- v m ~ --+eeev,s w o w newe,'-s a e -. woc -eme en wrm , v~r-ww~ wer s--o-w-w--~-,v-v-e~m,-vr- e--,---mev--. m v , w w ,e m , ws

^ * '

3-s flus for' Snubber No. 23, during the previous Unit' 3 refueling outage L(January 12, 1983 through May 4, 1983), the safety related mechanical snubber ~ located on the Reactor Water Cleanup (RWCU) System inside the drywell was replaced with an equivalent hydraulic snubber.- - Snubber No.

123iwas' changed out per a safety related modification. In addition, a 10 2

CFR 50.59. review was completed by SNED in which a Technical Specification i

.(T.S.)Lchange was identified. This T.S. change was not submitted to the NRC untilfJune 13, 1983 because it had no impact on plant _ operations. A 1 snubber was in place at position No. 23 to accomplish the required safety function. -The T.S. change merely reflected the type of' snubber located at-position No. 23 and is used specifically for determining surveillance >

testing requirements. . It was recognized that a snubber surveillance would ,

not-be required during the current Unit 3 operating cycle; therefore, the snubber type change was' included in a subsequent T.S. revision.

CORRECTIVE ACTIONS-TAKEN AND RESULTS ACHIEVED

. Following the discovery of the removed Snubber (No. 16),-it was immediately' declared inoperable and plans for a unit shutdown to comply.with! Technical-Specification'(T.S.) Limiting Condition for >

Operation'(LCO)tSection 3.0 were~ initiated. In addition, an action plan was implemented to modify a certified pipe clamp and reconnect the snubber to the ECCS suction header. That work was completed at

. 10:17 0.m. on'May~5, 1983. Prior'to declaring the snubber (No. 16)

- operable _an on-site review was completed to assure the new installa-tion was equivalent to the original design installation. Upon completion the snubber was declared operable and the appropriate

corporate and NRC notifications were made. The Unit 3 Operating 1 -

Engineer remained on-site until the event was terminated.'

Additional corrective. actions were to walk down the remainder of L the safety related snubbers to verify'their condition, stop any further: snubber' work until the license amendment can be acquired and ,

review all ongoing contractor work for Technical Specification j  : related activities. No abnormalities were noted and this is considered-to be an isolated' event.

33 CORRECTIVE' ACTION TO-BE-TAKEN TO AVOID FURTHER NONCOMPLIANCE

- Corrective act' ion to prevent recurrence includes: -

l L a) _ Meetings with the Station Construction Department (SCD) Site l . Superintendents at operating Nuclear Generating Stations and the l - SCD. Construction Manager to assure their awareness of the p event. The need of site SCD personnel to be aware of contractor work assignments was also emphasized.

b) This event was reviewed with all contractor General Foreman on-site by the SCD Site Superintendent.

l "m+e- w g -g - y w w q-+vew ----r-y-g g-- e

._ _~ , . - - . ~ -. . .. .- .

4- ..

n<

t 1

c) .Dresden Administrative. Procedure (DAP) 5-1, " Plant Modification Program", has been changed. The change requires all Maintenance /

Modification. Procedures (MMP) to be reviewed by the responsible or cognizant engineer. If:the_ work is reliability or safety related and includes any temporary or permanent' equipment removal which does not require an outage, the MMP must be routed trs the Shift Engineer's Office and DAP 15-1, " Attachment B" prect.ution and Tech Spec _ compliance checklist completed prior to the start oftwork.

ld) The Station Nuclear Engineering Department ~(SNED) has issued a memo to departmental personnel emphasizing the impact of work scope changes with respect to station, Technical Specifications.

DATE WHEN FULL COMPLIANCE WILL-BE-ACHIEVED o The corrective-actions described in the previous section have been completed and implemented as of June 24, 1983.

4 7240N t (

d i

- _ _.._, ,. ._ . . . . , , , . . , . . . , . . _ , , . , , _ . . . . _ , , , , _ _ _ . _ _ , _ _ . , _ _ _ . _ . - . . . , . _ _ _ _ . . , _ . . , _ . . . _ . . . . _ _ _ , , . . _ . _ _