ML20149E748
| ML20149E748 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/11/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry COMMONWEALTH EDISON CO. |
| References | |
| 50-010-97-11, 50-10-97-11, 50-237-97-11, 50-249-97-11, NUDOCS 9707210052 | |
| Download: ML20149E748 (2) | |
See also: IR 05000010/1997011
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July 11, 1997
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Mr. J. S. Perry
Site Vice President
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Dresden Nuclear Power Station
Commonwealth Edison Company
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6500 North Dresden Road
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Morris, IL 60450
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SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT
50-10/237/249/97011(DRS))
Dear Mr. Perry:
This will acknowledge receipt of your July 1,1997 letter in response to our June 6,
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1997 letter transmitting a Notice of Violation associated with the above mentioned
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inspection report. This report summarized the results of the maintenance rule inspection at-
your Dresden Plant. We have reviewed your corrective actions and have no further
questions at this time. These corrective actions will be examined during future
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inspections.
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Sincerely,
/s/ J. M. Jacobson (for)
John A. Grobe, Acting Director
Division of Reactor Safety
Docket No. 50-10
Docket No. 50-237
Docket No. 50-249
Enclosure:
Ltr 07/01/97, J. S. Perry,
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J. S. Perry-
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July 11, 1997
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cc w/o encl: T. J. Maiman, Senior Vice President,
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Nuclear Operations Division
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D. A. Sager, Vice President,
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Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
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T. Nauman, Station Manager, Unit 1
M. Heffley, Station Manager, Units 2 and 3
F. Spangenberg, Regulatory Assurance
Supervisor
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1. Johnson, Acting Nuclear
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Regulatory Services Manager
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Document Control Desk - Licensing
cc w/ encl:
Richard Hubbard
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Nathan Schloss, Economist,
Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
Distribution:
Docket File w/ encl
SRis, Dresden, LaSalle,
Rlli Enf. Coordinator w/ encl
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Quad Cities w/enci
R. A. Capra, NRR w/enci
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C. Pederson, Rlli w/enct
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DRP w/enci
LPM, NRR w/ encl
DRS w/enct
A. B. Beach, Rlli w/enci
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J. L. Caldwell, Rill w/enci
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Commonn e. tith i:dmin ('om[un)
I)resden Gener.uint: N uion
MOO North IJresden 1(o.id
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Tri s i v> a and
July 1,1997
JSPLTR: 97-0122
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555
Subject:
Dresden Nuclear Power Station Units 2 and 3 Reply to a Notice of Violation,
Inspection Report 50-010; 237; 249/97011.
NRC Docket Numbers50-010. 50-237. and 50-249
Reference:
J. A. Grobe letter to J. S. Perry, dated June 6,1997, transmitting NRC
Inspection Report 50-010; 237; 249/97011 and Notice of Violation
The purpose of this letter is to provide Comed's reply to the Notice of Violation
transmitted in the referenced letter. Specifically, the violation involved the failure to
include the reactor vessel level indication reference leg backfill function of the Control
Rod Drive Hydraulic system within the scope of the maintenance rule.
An investigation determined that the installation of the backfill modification occurred after
the initial scoping of the maintenance rule. A process was not in place at the time to
ensure evaluation of modifications for impact on the maintenance rule program.
'Dresden Station has reviewed the process used to capture structures, systems, and
components into the scope of the maintenance rule and is revising the process to ensure
compliance with the program.
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July 1,1997
Accordingly, this letter contains the following new commitments:
A comprehensive review of the UFSAR, Design Basis Documents (DBD) and Dresden
Emergency Operating Procedures (DEOP) is being undertaken to identify structures,
systems, and component (SSC) functions that may have been added or modified since
initial scoping was accomplished. (NTS 2371009701101 A)
Dresden Administrative Procedure (DAP) 21-06," Changes and Revisions to the
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Updated Final Safety Analysis Report" will be revised to add a requirement to the
technical review section for an evaluation of the impact of the change on the
maintenance rule program. (NTS 2371009701101B)
The attachment to this letter provides Dresden's reply to the Notice of Violation along
with corrective actions to preclude recurrence.
If there are any questions concerning this letter, please refer them to
Mr. Frank Spangenberg. Dresden Station Regulatory Assurance Manager, at
(815) 942-2920, extension 3800.
Sincerely,
<} Step
ien Perry %
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Site Vice President
Dresden Station
Attachment
cc:
A. Bill Beach, Regional Administrator, Region Ill
W. J. Kropp, Branch Chief, Division of Reactor Projects, Region III
J. F. Stang, Project Manager, NRR (Unit 2/3)
K. Riemer, Senior Resident Inspector, Dresden
Oflice of Nuclear Facility Safety - IDNS
File: Numerical
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ATTACIIMENT
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
50-237/97011, 50-249/97011
VIOLATION:
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10 CFR 50.65(b)(1) requires, in part, the holders of an operating license shall include
within the scope of the monitoring program specified in 10 CFR 50.65(a)(1), safety-
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related and nonsafety-related structures, systems, or components that are relied upon to
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remain functional during and following design basis events. Included are systems
necessary to ensure the integrity of the reactor coolant pressure boundary, the capability
to shut down the reactor and maintain it in a safe shutdown condition, and the capability
to prevent or mitigate the consequences of accidents that could result in potential offsite
exposure comparable to the 10 CFR Part 100 guidelines.
Contrary to the above, as of May 7,1997, for Units .. and 3, the facility failed to include
the reactor vessel level indication reference leg keep-fill function of the Control Rod Drive
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Hydraulics system within the scope of the maintenance rule.
REASON FOR VIOLATION:
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The Maintenance Rule Program initial Structure, System or Component (SSC) scoping
was accomplished in early 1995. The Control Rod Drive (CRD) Hydraulics system was
modified (M-2(3)-93-004)in May 1995 to include the Reactor Vessel Water Level
Indication System (RVWLIS) function. The Updated Final Safety Analysis Report
(UFSAR) was revised to add this function in December 1995.
The UFSAR is the principal document that was used to identify SSC functions.
Therefore, the initial SSC scoping did not identify the CRD RVWLIS backfill function,
because this function had not yet been documented in the UFS AR.
A process for capturing SSC function changes due to plant modifications was added to
Dresden Administrative Procedure (DAP) 21-03, " Processing Plant Design Changes" in
November 1996. A review of modifications made from the time ofinitial scoping to the
time of the change to DAP 21-03 was not made. There is no process for identifying new
SSC functions or changes to SSC functions as a result of UFSAR revisions. Therefore,
there was no process in place to identify new or changed SSC functions at the time
M-2(3)-93-004 was implemented.
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CORRECTIVE STEPS TAKEN AND RESULTS ACilIEVED:
Upon identification, a Problem Identification Form (PIF) was generated. documenting that
the RVWLIS backfill function of CRD had not been evaluated for scoping under the
maintenance rule. A maintenance tule expert panel was convened. The RVWLIS backfill -
function of CRD was evaluated as being within the scope of the maintenance rule.
CORRECTIVE STEPS TAKEN TO AVOID FURTIIER VIOLATION:
A comprehensive review of the UFSAR, Design Basis Documents (DBD) and Dresden
Emergency Operating Procedures (DEOP) is being undertaken to identify SSC functions
that may have been added or modified since initial scoping was accomplished. This review
will be completed by September 1,1997. (NTS 2371009701101 A)
DAP 21-03," Processing Plant Design Changes" was revised to provide a methed to
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identify the effect of plant modifications on maintenance rule scoping. This revision was
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completed after the completion of the RVWLIS modification.
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DAP 21-06, " Changes and Revisions to the Updated Final Safety Analysis Report" will be
revised to add a requirement to the technical review section for an evaluation of the
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impact of the change on the maintenance rule program. This revision will be completed by
August 1,1997. (NTS 2371009701101B)
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DATE WHEN FULL COMPLIANCE WILL BE ACIIIEVED:
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Full compliance will be achieved by September 1,1997, when a comprehensive review of
the UFS AR, Design Basis Documents, and Dresden Emergency Operating Procedures is
completed.
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