ML20134G096
| ML20134G096 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/04/1997 |
| From: | Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20134G097 | List: |
| References | |
| NUDOCS 9702100270 | |
| Download: ML20134G096 (3) | |
See also: IR 05000010/1996014
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February 4, 1997
EA 96-532
Mr. J. S. Perry
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Site Vice President
Dresden Station
Commonwealth Edison Company
6500 North Dresden Road
Morris. IL 60450
SUBJECT:
NRC RESIDENT INSPECTION REPORT 50-010:237:249/96014(DRP) AND
Dear Mr. Perry:
This refers to the inspection conducted on October 21 through December 6,
1996, at the Dresden Nuclear facility.
The )urpose of the inspection was to
determine whether activities authorized by t1e license were conducted safely
and in accordance with NRC requirements.
During this period, routine resident
inspections were performed.
Based on the inspectors' findings, overall
performance at the Dresden facility was safe.
At the conclusion of the
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inspection the findings were discussed with those members of your staff
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identified in the enclosed report.
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Based on the results of this inspection, one apparent violation was identified
and is being considered for escalated enforcement action in accordance with
the " General Statement of Policy and Procedure for NRC Enforcement Actions"
(Enforcement Policy) NUREG-1600. The apparent violation involved the failure
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to perform post-modification testing of control room emergency ventilation
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system to ensure design recuirements were maintained.
This licensee
identified issue, describec in Section E2.1 of the enclosed report, is of
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concern because design modification testing controls were inadequate to ensure
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system operability was maintained.
In addition, your engineering backlog
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reviews conducted in the spring of 1996 failed to identify the potential for
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significant system degradation due to the open control room modification
packages. As a result, the control room was found not capable of maintaining
the required positive pressure or in-leakage limitations.
The as-found
degradation was significant in that the potential may have existed for control
room radiological doses to be in excess of regulatory limits following a
design basis accident.
The circumstances surrounding the apparent violation, the significance of the
issue, and corrective actions were discussed with members of your staff at the
exit meeting on December 19, 1996.
An open pre-decisional enforcement
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conference to discuss these apparent violations has been scheduled for
February 28. 1997, at 10:00 a.m. (CST) in the Region III Office in Lisle.
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The decision to hold a pre-decisional enforcement conference does
notmeanthattheNRChasdegrminedthataviolationhasoccurredorthat
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enforcement action will be taken. This conference is being held to obtain
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information such as a common understanding of the facts, root causes. missed
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opportunities to identify the apparent violation sooner, corrective actions,
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significance of the issues, and the need for lasting and effective corrective
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action to enable the NRC to make an informed enforcement decision.
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During the enforcement conference we expect you to address:
(1) the
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circumstances resulting in the apparent violation: (2) your methods to ensure
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post-modification testing is com)leted in a timely manner: (3) the corrective
steps that have been taken and t1e results achieved; (4) the corrective steps
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that will be taken to avoid further violations; and (5) the date when full
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compliance will be achieved. These discussions should not be limited solely
to the control room heating. ventilation, and air conditioning (HVAC) system.
In addition. this is an opportunity for you to point out any errors in our
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inspection reports and for you to provide any additional information
concerning your )erspectives on:
(1) the severity of the violations. (2) the
application of t1e factors that the NRC considers when it determines the
amount of a civil penalty that may be assessed in accordance with Section
VI.B.2 of the Enforcement Policy, and (3) any other application of the
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Enforcement Policy to this case, including the exercise of discretion in
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accordance with Section VII.
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In accordance with the Enforcement Policy, no Notices of Violation are
presently being issued for these ins)ection findings.
Please be advised that
the number and characterization of t1e apparent violation described in the
enclosed inspection report may change as a result of further NRC review.
You
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will be advised by separate correspondence of the results of our deliberations
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on this matter.
No response regarding the apparent violation is required at
this time,
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In addition to the concerns described above. an additional violation of NRC
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requirements was identified this period. The violation involves a failure to
ensure that vendor technical information is controlled in accordance with your
approved station procedures. This issue is of concern. because during
previous inspections. the vendor equipment technical information program
(VETIP) was a major topic, and the need for strong controls was clearly
necessary to reduce your existing backlog. The emergency diesel generator
(EDG) manual, which had information missing, was one of the manuals that had
been processed through VETIP and was believed to be complete and correct.
Our
inspection identified this was not the case.
The violation is cited in the enclosed Notice of Violation (Notice), and the
circumstances surrounding the violation is described in detail in the enclosed
report.
Please note that you are required to respond to this letter and
should follow the instructions specified in the enclosed Notice when preparing
your res]onse.
Your response should include a discussion of your efforts to
ensure tlat the VETIP procedures are being followed by your staff.
Additionally, describe your efforts to ensure that all previously revised and
approved manuals are complete and correct. The NRC will use your response, in
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J. S. Perry
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part, to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's Rules of Practice." a copy of
this letter and its enclosures will be placed in the NRC Public Document Room
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(PDR).
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Sincerely.
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/s/ J. A. Grobe for
James L. Caldwell. Director
Division of Reactor Projects
Docket Nos. 50-10: 50-237: 50-249
Enclosures:
1.
2.
Inspection Report 50-010:237:249/96014(DRP)
cc w/ encl:
T. J. Maiman. Senior Vice President Nuclear Operations Division
D. A. Sager. Vice President. Generation Support
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H. W. Keiser. Chief Nuclear Operating Officer
T. Nauman Station Manager Unit 1
M. Heffley, Station Manager Units 2 and 3
F. Spangenberg. Regulatocy Assurance Manager
I. Johnson. Acting Nuclear Regulatory Services Manager
Richard Hubbard
Nathan Schloss. Economist Office of the Attorney General
State Liaison Officer
Chairman. Illinois Commerce Commission
Document Control Desk-Licensing
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Distribution:
Docket File w/ encl
Project Manager. NRR w/ encl
PUBLIC IE-01 w/ encl
DRP w/ encl
OC/LFDCB w/ encl
RIII PRR w/ encl
SRI LaSalle. Dresden.
CAA1 w/ encl (E-Mail)
Quad Cities w/ encl
A. B. Beach, w/ enc 1
RAC1 (E-Mail)
H. B. Clayton, w/ encl
W. L. Axelson, w/ encl
R. Zimmerman. NRR w/ encl
J. Goldberg. OGC w/ encl
J. Lieberman. OE w/ encl
DOCUMENT NAME:
R:\\INSPRPTS\\PDWERS\\DRES\\DRE96024.DRP
receive a copy of this document, indicate in the box "C" = Copy without attach / encl
- E" - Copy with attach / enc 1
"N" =
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NAME
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DATE
1/J7/97
1/ L7/97
h4/97
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0FFICIAL RECORW COPY
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