ML20128B194
| ML20128B194 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/29/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302020422 | |
| Download: ML20128B194 (6) | |
Text
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- Ccmmonwsalth Edison
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Oi 1400 Opus Place U '
Downers Grove, lilinois 60515 January 29,1993 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk
Subject:
Dresden Nuclear Power Station Units 2 and 3 Response to Notice of Violation inspection Report 50-237/92032; 50-249/92032 tRO_DmketNumberL50-23 Land 50:249
Reference:
B. Clayton letter to L. O. DelGeorge dated December 31,1992, transmitting Inspection Report 50-237/92032; 50-249/92032 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter. The NOV cited two Severity Level IV violations requiring a written response. Our response to these violations is provided in the attachment.
If your staff has any questions or comments concerning this letter, please refor them to Denise Saccomando, Compliance Engineer at (708) 663-7285.
Sincerely, h
D. L. Farrar Nuclear Regulatory Services Manager Attachment cc:
A. B. Davis, Regional Administrator Region ill J. Stang, Project Manager, NRR M. N. Leach, Senior Resident inspector, Dresden 010079 9302020422 930129 PDR ADOCK 03000237 g
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' RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT-50-237/92032; 50-249/92032 VIOLATION:(237/92032-07) 10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be -
established to assure that conditions adverse to quallt, such as failures, malfunctions, deficiencies, deviations, defective mater,al and equipment, and nonconformances are promptly identified and corrected, in the case of significant conditions adverse to quality, the measure shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, corrective actions to conditions adverse to quality occurring on May 9,1992, and September 18,1992, failures to follow radiation.
protection (RP) procedures by mechanical maintenance personnel, falied to preclude repetition of the same failure to follow procedures on December 1, 1992. Specifically
- 1. On December 1,-1992, two mechanical maintenance personnel failed to -
perform a whole body survey after exiting a contaminated area and prior to-donning personal clothing as required by RP procedures.
- 2. On December 1,1992, a mechanical maintenance individual removed the rubber and inner cotton glov'es while working in a posted contaminated area; an action prohibited by RP procedures, REASON FOR VIOLATION:
CECO accepts the description of events stated in the Notice of Violation.
Radiation Work Permits utilized for completion of maintenance related activities prescribe appropriate protective measures and actions to be taken to ensure safety with regard to radiation protection issues. Dresden Administrative Procedure (DAP) 12-13, " Personal External Contamination Surveys," describes.
acceptable frisking methods. Step-off pads used at the entrance / exit points -
further reinforce survey requirements upon egress from contamination controlled areas. Clearly, the der -
1 actions taken by maintenance personnel failed to follow prescribed pract.
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ATTACHMENT
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' RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92032; 50-24tF92032
_(continued)
The oersonnel involved in the previous events received Individual counseling -
Addllionally, a tall control practices. gate was held discussing adherenc,e to established radiologica These corrective actions failed to prevent the recurrence of thei event. Dresden recognized the need to examine 3ast corrective actions to ensure-that future actions will be effective, Mechanical N alntenance in conjunction with~
Radidion Protection conducted a review of the data available on the events. 4 1
Past corrective actions for radiation protection program offenders have been -
summarized into the following categories:
1.
One on one counseling of the individu6s by radiation protection personnel
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stressing the importance of following radiation procedures.-
2.
One-on one counseling as in #1 above between the employee and their first line supervisor. These were informal and involved no formal warnings or discipline.
3.
General discussion of these types of events were held in departmental tallgates. These were done with all department personnel, but were fairly-
-informal and they were formatted using only one event as a basis, not all of the events as a group or a potential trend.-
While the implementation of the above actions addressed the specific incident, they have been ineffective in preventing recurrence because they only addressed -
a portion of the causal factors. A recent review of the data available for the incidents has pointed to three~ main causal factors.-
1.
Some workers may have believed that non-adherence to radiation protection prote iures/ programs was normal and was acceptable when performing work at the station.
2.
Actions in response to non-adherence to radiation protection prouvdures/ programs have not always been consistently implemented.
3.
Maintenance workers were not being briefed / coached on a frequent or widespread enough basis regarding radiological protection issues. In some instances, informal one-onione coaching was narrowly focused and did not raise the level of awam.1ess across the entire maintenance organization.
Department wide tall acceptable radiation gates were not frequent enough to effectively reinforce -
protection issues. Good radiation protection practices.
were not proactively reinforced.
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KITACHMENT
.v RESPONSETO NOTICE OF VIOLATION NRC INSPECTION REPORT
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50-237/92032;50-249/92032 (continued)
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The individuals involved in the events were counseled by their immediate supervisor who stressed the importance of following safe radiation protection practices.
Mechanical Maintenance in conjunction with Radiation Protection conducted a review of past events to determine why prior corrective actions did not prevent recurrence.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
A letter will be issued to maintenance and contract personnel by Febiuary 12, 1993, expressing management ex 3ectations for strict adherence to radiation protection procedures / programs.
ndividuals not following the requirements of these procedures / programs will be held accountable for their actions. Training of aersonnel on this policy will be completed by February 26,1993. This policy will 3e effective on February 26,1993.
To ensure maintenance personnel receive ongoing reinforcement of adherence to radiation protection procedures / programs, Dresden Station Maintenance Memorandum 300.12, " Maintenance Supervisor and Crew Pre-and Post-Job Checklists," will be revised to include radiation protection /ALARA items for the pre-job discussion.- This department standard will contain administrative mechanisms to document that each person has been briefed arlor to start of his job assignment. The revised memorandum will be issued by r bruary 5,1993, e
and training on this memorandum will be completed by February 26,1993.
Maintenance department heads will assess consistency of the memorandum implementation. This assessment will consist of supervisory and non-supervisory interviews, review of the pre job sign-off checklists, or use of other means to verify that the radiation protection standards are being consistently reinforced on every job with all participants. An Inillal assessment will be completed in each maintenance group by April 16,1993. If the results warrant a subsequent assessment, it will be completed by June 1,1993.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by February 26,1993, with the implementation of the new maintenance policy.
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ATTACHMENT L
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92032;50-249/92032 (continued)
VIOLATION:(249/92032-06) 1 10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be RI established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and
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nonconformances are promptly identified and corrected in the case of significant conditions adverse to c uality, the measure shall assure that the cause of the condition is determlnec and corrective action taken to preclude repetition.
Contrary to the above on November 30,1992, a condition adverse to quality was not identified and corrected. Specifically, operators continued to stroke valve 3-1601-55 after it failed to meet its five second stroke tirne. When the valve, after being restroked twice, met the stroke time acceptance criteria, the surveillance was declared successful and no measures were taken to correct the malfunction.
REASON FOR VIOLATION:
On November 30,1992, containment isolation valve 3-160155 was being stroke timed, along with other valves, per Dresden Operating Surveillance (DOS) 1600-01,"Ouarterly in Service Test (IST) Valve Stroking? The valve failed the 5 second surveillance acceptance criteria (Technical Specification acceptance criteria is 15 seconds) by 0.2 seconds (not 0.02 seconds as stated in the inspection report). The valve was declared inoperable and logged in the degraded equipment log. The IST coordinator was noilfled of the event; however, no other action was taken to determine the operability of the valve. The surveillance was ccmpleted without any other valves exceeding the acceptance criteria.
Operations personnel believed the valve may be operable. They decided to retest the valve because the valve timed within the perceived reaction time reoulred to operate the calibrated stopwatch used per the surveillance.
Additionally, they reasoned that retesting the valve would prove its operability, because it is a standard pract. ice to test valves (per DOS 1600-1) after valve maintenance.
Operations proceeded to retest the valve. The valve was successfully timed and declared operable and removed from the degraded equipment log. A unit outage work request and a Problem identification Form were initiated for the valve.
The Assistant Superintendent of Operations ordered that the valve be placed on a weekly timing schedule rather than the normal quarterly schedule. Technical Staff personnel evaluated and trended the timing of the valve to determine caerability. The valve has successfully passed the timing requirements since the b ovember 30,1992, event. In addition, the valve has recently been repaired and successfully tested.
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92032; 50-249/92032 (continued)
CORRECTIVE STEPSTAKEN AND RESULTS ACHIEVED:
Personnel involved in this event were counseled with regards to the appropriate actions they should have taken in response to the valve timing exceeding the surveillance acceptance criteria.
A temporary procedure change was issued for the procedures controlling c uarterly valve test timing (DOS 1600-03,04 and 05). This revision included c irections requiring the inspection of valves that f all the timing requirements and the writing of work requests if the valves require repair before the valves can be declared operable.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLAT10N:
This event will be tailgated, by February 28,1993, to operations personnel emphasizing the requirement to inspect or repair a valve before returning it to service.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved with the issuance of the temporary procedure changes.
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