ML20198C003
| ML20198C003 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/29/1997 |
| From: | Heffley J COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-010-95-05, 50-10-95-5, 50-237-94-02, 50-237-94-2, 50-237-95-05, 50-237-95-5, 50-249-94-02, 50-249-94-2, 50-249-95-05, 50-249-95-5, JMHLTR-#97-0131, JMHLTR-#97-131, NUDOCS 9801070148 | |
| Download: ML20198C003 (4) | |
Text
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i wm, n (mso TriHl49 U JVlo December 29,1997 JMilLTR #97 0131 U. S Nuclear Regulatory Commission Washington, DC 20555 Attn.: Document Control Desk
Subject:
Update et Dresden Station's Instrument Out of Tolerance Program.
NRC Docket Numbers 50 237 and 50 249 a
References:
(a)
Edward O. Greenman letter to M. Lyster dated March 11,1994
Subject:
Notice of Violation 50-237/249-94002-04, regarding Inadequate corrective actions associated with reactor ' vater level instrumentation.
(b)
D. Farrar letter to Director, Office of Enforcement, dated June 16, 1994,
Subject:
Commonwealth Edison Company's response to Notice of Violation 50 237/249-94002-04 (c)
Patrick L. Hiland letter to T. Joyce, dated May 22,1995.
Subject:
Inspection 50 010/237/249/95005 (d)
T. P. Joyce letter to US Nuclear Regulatory Commission, dated June 21,1995,
Subject:
Commonwealth Edison Company's resp (mse to NRC inspection 50-010/237/249/95005, which requested an update of corrective actions associated with violation 50 237/249/94002-04.
(e)
J.S. Perry letter to US Nuclear Regulatory Commission, dated December 31,1996, updating Dresden Station's corrective actions associated with violation 50-237/249 94002-04 and inspection 50-010/237/249/95005.
The purpose of this letter is to document status of the Instrument Out of Tolerance Program at Dresden Station and to provide an update to docketed responses to Vic!ation 50-237/249/94002-04 and Inspection Report 50-010/237/249/95005.
Reference (b) documented Commonwealth Edison Company's response to Reference (a) Notice of Violation regarding inadequate corrective actions associated with reactor water level instrumentation performance. The status of the corrective actions taken to date is summarized below:
t Revisal Technical issues Resolution Program to include formal and periodic prioritiration process. ( Completed)
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Replaced Yarway Level Switches. (Completed) 7
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9901070148 971229
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JMilLTR: #97 0131 Page 2 Develop and implement Integrated Reporting Process (IRP) database (CAPSYS) for trending equipment performance. (Completed) initiate Performance Improverrent Form (PIF) for each Instrument out of e
tolerance for entry into the IRP database. (Ongoing)
Revise Technical Specification Setpoints. (As required) e Develop guidance for a station performance trending program. (Completed) j Reference (d) documented Commonwealth Edison Company's acknowledgment of the weakness in programs and poorly implernented corrective actions as identified in Reference (c)
Inspection, it provided requested update, it further identified several new corrective actions to augment previously committed actions. The status of the corrective actions taken te < late is summarized below:
System Engineering Memo 25 was revised to incorporate specific expectations for instrument performance monitoring. (Completed)
Enhance IRP database (CAPSYS) to ensure more consisten'. data is recorded on PlFs for instrument out of tolerances. (Completed)
Counsel individual system engineers and system engineering supervisors to ensure e
expectations regarding instrument trending were understood.(Completed)
Periodic surveillance's by Dresden Station's Site Quality Verification Group (SQV) e of the instrument out of tolerance trending program to ensure expectations regarding instrument out of tolerance trending are met (Ongoing) Corrective actions are tracked via NTS tracking System.
Reference (e) provided Plant Engineering assessment of instrument Out of Tolerance Program for calendar year 1996, and noted the following cccomplishments:
Issue Dresden Approved Instrument Performance Monitoring Program (Completed)
Complete a System based Review of the Instrument Out of Tolerances prioritized e
consistent with the IPE model (Partial Completion April 30,1997 and August 29, 1997. Remaining Systems: Expected completion by June 1998)
It also identified problems encountered in implementing the program, e g inconsistent and incomplete data continued to be entered in PIFs, inconsistent trending approach was taken by individual system engineers and a large backlog of P!Fs existed that masked the real issues. As a result, the following corrective actions were proposed:
Computer Based Automated Calibration and Instrument Trending Program.
All Instrument Out of Tolerances PlFs to be reviewed by an Electrical /l&C
- Engineer, Identify adverse trends based on the review and implement appropriate corrective actions.
Review effectiveness of the program.
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JMHLTR: #97-013I Page 3 i
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Subsequent to Reference (e) submittal several improvements have been made to the PlF program, nls has resulted in our ability to obtain more consistent calibration data for i
documenting and trending purposes.
t PIPS are now being generated electroni, ally. This system requires more consistent and complete data entry on the form.
- Improvements have been made to the sorting and trending capabilities of the IRP data base (CAPSYS). This has improved our ability to trend performance data and identify adverse trends based on component characteristics, e.g. type, manufacturer, model, etc.
- Setpoint changes have been issued which has resulted in reducing the number of PIFs due to IOOT. (M percent reduction in the first 11 months of 1997 vs. the same period in 1996)
These improvements have improved our ability to identify adverse trends, issue setpoint changes and monitor the effectiveness of these changea.
The reduced number of PlFs will enanle us to concentrate on potential replacement candidate instruments that fall to meet revised setpoint tolerances. Therefore; we propose to continue to ase the IRP database (CAPSYS) and the PlF system for tracking instrument performance, documenting nonconforming conditions, and identifying adverse trends related to instrument performance. As a result of these improvements, the proposed Computer Based Automated Calibration and Incrument Trending Program identitled in Reference (e) is unwarranted and will not be implemented at this time. The program identified in Reference (e) may be i
considered for implementation in the furture as a production enhancement tool in summary, based on the improvements described above, Dresden Statim Plant Electrical /IAC Engineering plans to continue to utilize IRP database (CAPSYS) and the PIF aystem to identify trends related to plant instrumentation, in addition to normal monitoring, the following actions are in progress / planned:
Surveillance's continue to be performed by the Quality and Safety Assessment (QAS A) organization.
Complete remaining Systems based Review of the Instrument Out of Tolerances prioritized consistent with the IpE model. Expected completion date June 1998 Identify adverse trends based on the above review and implement appropriate corrective actions, Expected completion date July,1998.
Perform an effectiveness review of the instrument out of tolerance program following implementation, Expected completion date November,1998.
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Theso actions are expected to result in continued improvement in our ability to monitor plant l
Instrumentation and implement actions to ensure that performance remains within the current industry standards.
l If you have any questions concerning this issue please contact Mr. Frank Spangenberg, Dresden Station Regulator) Assurance Manager, at (815) 942 2920 ext. 3800.
Respectfully, J. M. Hot 11ey Dresden Station Manager cc:
A. Bill Beach, Regional Administrator - Rlli f
J. F. Stang, project Manager NRR Senior Resident inspec:or Dresden Office of Nuclear Facility Safety IDNS File / Numerical i
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