ML20198L627

Responds to NRC Re Violations Noted in Insp Repts 50-010/97-19,50-237/97-19 & 50-249/97-19.Corrective Actions: Investigation Revealed Low Speed Problem & EDG Was Successfully Tested & Declared Operable

ML20198L627
Person / Time
Site:	Dresden
Issue date:	01/09/1998
From:	Heffley J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-010-97-19, 50-10-97-19, 50-237-97-19, 50-249-97-19, JMHLTR:#98-0002, JMHLTR:#98-2, NUDOCS 9801160078
Download: ML20198L627 (17)

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' lei Hi% 942 29N January 9,1998 JMIILTR: #98-0002 U, S. Nuclear Regulatory Commission ATTl: 'locument Control Desk Washington, D. C 20555

Subject:

Dresden Nuclear Power Station Units 1,2 and 3 Reply to a Notice of Violation; Inspection Report 5010/237/249/97019.

NRC DockcWymbers50-010. 50-237. and 50-249

Reference:

G. E. Grant letter to J. S, Perry, dated December 4,1997, transmitting NRC Inspection Report 50-10/237/249/97019 and Notice of Violation The purpose of this letter is to provide Comed's reply to th( + :e of Violation transmitted by the above reference. Srecifically, the violations resulted from the failure to maintain effective operating procedures, and a failure to follow the equirements of administrative procedures. Three examples were identified for each violation, and each is addressed b the attachment.

The currem status of the Inspector Followup Item and an Unresolved item noted in rcfetenced NRC letter are included in this letter.

INSPEC1'OR FOLLOW UP ITEM (IFI) 50-237;249/97017-03(DRP) Review of seismic requirements of emergency lights.

The inspector noted deficiencies in the asseinbly of a number of emergency lights used to support the safe shutdown of the units. In response to the Performance improvement Form (PlF) initiated to document the problem, an Apparent Cause Evaluation (ACE) was conducted. Stmetural Desigr. Engineering evaluated the assembly deficiencies and concluded that neither the function of the lights nor the seismic interaction with any seismic category I equipment was affected by those deficiencies. The Electrical Malinenance Department (EMD) concluded in the ACE that improvemenc,in training and in the inspection procedures were needed. DES 4153-02 and DES 4153-03 were revised to show the proper assembly of vendor required hardware. TR 97-1805 was initiated to revise the lesson plan and train Et,d.D personnel on the upgraded procedures for assembling and mounting of emergency lights. In addition work requests were initiated to walk down the emergency lights to identify end correct deficiencies associated with assembly or mounting of the emergency lights.

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USNRC January 9,1998 JMHLTR: #98 ^002 Page 2 t

i UNRFF)LVFD ITEM (URI) 50 237;249/97019-04(DRP) Review of analysis of conc.ie expansion anchors seismic qualification.

j The report notes i at a safety factor of two (2) was used for high energy pipe whip b

1 restraints concrete expansion anchors (CEAs) while a safety factor of four (4) is used for CEAs in other pipe restraints. Dresden and Quad Cities Stations have investigated this issue and have concluded that a safety factor of two (2)is acceptable. A meeting will be i

arranged with NRC Region Ill Management to discuss the basis for this conclusion and resolve the issue.

1 The following attachments contain the following commitment:

DAP 03 05, Out o/ Service Process will be revised to clarify the specific time limits associated with 4KV breakers to be consistent with the limits found in the operat.tng i

procedures such as DOP 6500-04 Racking Out Sqfety Related 4KVBreakers.

(NTS 237100-97019 02801)

The Station's request for an extension of time for responding to the Notice of Violation was granted by NRC Manar.ement on December 11,1997 during a telephone conversation between Mr. Ken Riemer (NRC) and Frank Spangenberg (Comed - Dresden).

This response contains no proprietary or safeguards information. If there are any.

j questions concerning this letter, please refer them to Mr. Frank Spangenberg, Dresden Station Regulatory Assurance Manager, at (815) 942-2920 extension 3800.

Sincerely, i

)1NQif J. M. Hetty te Vice Pre ' dent Dresden Station Attachments A; Bill Beach, Regional Administrater, Region III cc:

M. Ring, Branch Chief, Division of Reactor Projects, Region 111 J. F. Stang, Project Mant.ger, NRR (Unit 2/3)

K. Riemer, Senior Resident Inspector, Dresden Office of Nuclear Facility Safety IDNS

. - - - - - - = -. _ -

e ATTACliMENT1 ER9NSE.TO NOTICE OF_YlOIATION NCR INSPECTION REPOKI 50-10/237/24M '019 97019-01A 1

DOIAILDE1 1

1. 10 CFR Part $0, Appendix B, Criterion V, requires, in part, that activities aff'ecting quality be presen, bod by procedures of a type appropriate to the circumstances i

A. Dresden Technical Specification 6.8. A requires that written procedures be established, l

Implemented, and maintened covering the applicable procedures recommeaded in i

Appendix A of Regulatory Guide (RO) 1.33, Revision 2, February 1978. Procedures for operation of emergerey diesel generators were recommended in RG 1.33.

Contrary to the above, as of August 28,1997, the licensee failed to maintain operating surveillance procedure DOS 6600-01 sufficiently to operate the emergency diesel ponerator (EDG) by not providin;; adequate procedural guidance re atding control room 4

mdication of EDG speed and by not providing adequate procedural uidance regarding the response to an automatic trip of the EDG. As a con uence of the equate operatmg procedure, the licensee was unable to operate the E for a routine surveillance test and the EDG was made inoperable for 2 days.

L REASON FOR VIOLATION:

On August 28,1997, an unqualified toggle switch was found installed on the Unit 2/3 Emergency Diesel Generator (El>G) feeder breaker which supplies Unit 3 ESF Bus 33-1.

4 The EDG was declared inoperable until the breaker could be replaced and successful complet;on of operability testing was perfonned. The appropriate Techdes! Specification actions were taken upon discovery of this condition.

j Following installation of a replacement breaker at Bus 33-1, the 2/3 EDG was started for an operability run. Dresden Operating Surveillance (DOS) 6600-01, Diesel Generator -

Surveillance Tests, required that a low idle start be performed. The procedure directs that a tachometer or alternate method be used to determine engine speed. However the '

tachometer was not working, and the EDG Testing Team decided to utilize the Control Room firoquency meter for EDG speed indication, which is permitted per procedural step I.9.s. The High Voltage Operator (HVO) locally adjusted the governor to the low speed

. stop, in accordance with the surveillance, in the Control Room, the Nuclear _ Station' i

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Operator (NSO) started the EDG by taking the 2/3 EDG " START /STOP/ AUTO" switch to START. The EDG was properly started and allowed to run at the low idle speed.

After waiting the required length of time (3 5 minutes), the llVO used the governor to locally raise EDG speed, i

While raising speed the liVO heard the room vent fan start and observed field flashing, which indicated to him the EDG was approximately 800 rpm. (Actually, these actions may take place anywhere between 600 and 800 RPM) Operator Training, as well as a note in DOS 6600-01 prior to step I.9.h, states this rpm interlock is for the vent fan to auto start The }{VO contacted the Control Room for speed indication. The NSO running the EDG observed the frequency meter on the 902 8 panel indicating approximately 60 IIz during the perfonnance of an EDG surveillance even though the EDG did not come up to speed.

and subsequently tripped on low water pressure. The EDG speed was below that necessary for the frequency meter to provide an accurate indication of actual speed. The trips of the EDG that occurred during the sequence of events were due to low EDG cooling water flow. Subsequent review of the event determined that the EDG cooling water pump operated as designed, but the EDG was not operating at 900 rpm (60 liz),

Wnen the EDG trips occurred, the EDG wu actually operating at approximately 670 rpm.

The Operating Team incorrectly believed that the EDG frequency meter would read downscale until speed of the EDG achieved the lowest possible frequency available or; the frequency meter. Ilowever, the frequency meter fails to an indicated nominal value of about 60 IIz until a minimum of 58 IIz is achieved (the minimum indicated value on the meter). At the time of the EDG trips, actual EDG speed and voltage were approximately 670 rpm and 3000 VAC (instead of 4160 VAC) respectively. The EDG failed to reach nominal operating speed which reduced internal cooling water pressure and caused a trip of the EDG upon completion of the 2 minute trip bypass timer cycle. The EDG and its associated trip function performed as designed.

CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED:

The EDG remained inoperable until the cause of the problems were identified and corrected. Investigation revealed the low speed problem and on August 30,1997 the EDG was successfully tested and declared operable.

CORRECTIVE STEPS TAKEN TO AVOID FURTIIER VIOLATIQEJ The Operations Staff has revised DOS 6600-01, Diesel Generator Surveillance Tests, to include information on the EDG frequency meter operatiun. Additionally other Page 2 of 3 JMiiLTR: #98-0002

I procedures related to the EDG were reviewed to verify they contained adequate Information. No additional deficiencies were identified. The event was discussed with all Operators as part of the continuing training program.

DATE WHEN FUtL COMPLIANCE WILL BE ACHIEVED:

Full rempliance was achieved on October 5,1997, when DOS 6600-01 was resised to include the necessary information.

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ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION NCR INSPECTION REPORT 50-191237n49/97019 97019-01B VIOLATION:

1, 10 CFR Part 50, Ap xndix B, Criterion V, requires, in part, that activities affecting quality be prucribed by procedures of a type appropriate to the circumstan:es.

B.

Dresden Technical Specification 6.8.A requires that written procedures be established, im >lemented, and maintained covering the applicable procedures re ommended,n Appendix A of RG 1.33. Revision 2, February 1978. Procedures for alarm conditions were recommended in RG 1.33, Revision 2, February 1978.

Contrary to the above, as of August 28,1997, the licensee failed to maintain an adequate alarm stocedure for the EDG. As a consequence of the inadequate procedure for alarm condit.ons the EDG was unexpectedly automatically started and returned to an operating state with lnadequate cooling, thereby causing the EDG to trip automatically.

REASON FOR VIOLATION:

On August 28,1997, an unqualified toggle switch was found installed on the Unit 2/3 Emergency Diesel Generator (EDG) feeder breaker which supplies Unit 3 ESF Bus 33 1.

The EDO was declared inoperable until the breaker could be replaced and successful j

completion of operability testing was performed. The appropriate Technical Specification actions were taken upon discovery of this condition.

Following installation of a replacement breaker at Bus 33 1, the 2/3 EDG was started for an operability run. Dresden Operating Surveillance (DOS) 6600-01, Diesel Generator Surveillance Tests, required that a low idle start be performed. The procedure directs that a tachometer ur alternate method be used to determine engine speed. Ilowever the tachometer was not work!ng, and the EDG Testing Team decided to utilize the Control Room frequency meter for EDG speed indication, which is permitted per procedural step 1.9.s. The Iligh Voltage Operator (llVO) locally adjusted the governor to the low speed stop, in accordance with the surveillance.. In the Control Room, the Nuclear Station Operator (NSO) started the EDG by taking the 2/3 EDO " START /STOP/ AUTO" switch to START. The EDG was properly started and allowed to run at the low idle speed.

AAer waiting the required length of time (3 5 minutes), the liVO used the governor to locally raise EDG speed.

Page 1 of 3 JMHLTR: #98-0002

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Wile raising speed the HVO heard the room vent fan start and obwved field flashing, which indicated to him the EDG was approximately 800 rpm. (Actually, these actions may take place anywkm; hetween 600 and 800 RPM) Operator Training, as well as a note in DOS 6600-01 prior to step 1.9.h, states this rpm interlock is for the vent fan to auto start. W HVO contacted the Control Room for speed indication. N NSO running the EDG observed the frequency meter on the 902 8 panel indicating i

approximately 60 Hz during the performance of an EDG surveillance even though the EDG did not come up to speed and subsequently tripped on low water pressure. The indication for EDO speed was a frequency meter in the cetrol room. W EDG speed was talow that necessary for the firoquency meter to prov.de an accurate indication of actual ypend. W trips of the EDO that occurred during the sequence of events were due to low EDO coo'ing water flow. Jubsequent review of the event determined that the EDG cooling water pump operatert as designed, but the EDG was not operating at 900 rpr (60 Hz). When the EDO trips occurred, the EDG was actually operating at approximately 670 rpm.

The Operating Team incorrectly believed that the EDG frequency meter would read downscale until speed of the EDG cchieved the lowest possible frequency available on the frequency meter. However, the firequency meter fails to an indicated nominal value of about 60 Hz until a minimum of 55 Hz is achieved (the minimum ind!cated value on the naer). At the time of the EDG t ips, actual EDG speed and voltage were approximately 670 rp and 3000 VAC (instead of 4160 VAC) respectively. The EDG failed to reach nominal operating speed which reduced internal cooling water pressure and caused a trip 1

of the EDG upon completion of the 2 minute trip bypass timer cycle. W EDG and its associated trip function performed as designed.

A common operator practice is to weet all alarms when conditions permit. The HVO reset the local annunciatus, and then proceeded to dcp.vss the 2/3 Diesel Engine Local Control Panel ALARM RESET push-button, located on the EDG control cabinet. The j

HVO believed that depressing this push button wou' i anly reset the low cooling water pressure trip indicator. However, this action also rewts the sealed in trip logic for the diesel. With W2/3 EDG " START /STOP/ AUTO" switch in the control room still in START, the diesel generator restarted as designed.

No clanges had been made to the diesel governor position following the original trip of the EDO. At 2027, the 2/3 EDG again tripped due to low cooling water preswre after opern'ing for approximately 2 minutes. The NSO in the Control Room placed the 2/3 EDG ' START /STOP/ AUTO" switch in the STOP position to prevent subsequent restarts which may result firom recovery activities of the 2/3 EDG.

Page 2 of 3 JMHLTR: #98-0002

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4 COkRECTIVE STEPS TAKEN AND RESULTS ACillEVED:

The EDG remained inoperable until the cause of the problems was identified and corrected. Investigation revealed that resetting the 2/3 Diesel Engine Local Control Panel ALARM RESET push-button also reset the low water pressure trip logic. On August 30, 1997, the EDG was successfully tested and declared operable.

CORRECTIVE STEPS TAKEN TO AVO!D FURTIIER VIOLATION:

' Caution" placards have been affixed to all the Diesel Engine Local Control Panel ALARM RESET push-button panels, stating the ebility to reset the trip logic of the EDG's. Operations revised the EDG trip procedure arid several annunciator prcudures related to EDG trips to place the EDO control switch to 'STOP' aller a tiip.

DATE WilEN FULL COMPLIANCE WILL BE ACIIIEVED:

Full compliance was achieved on October 5,1997, when the procedures were revised to include the necessary information.

Page 3 of 3 JMHLTR: #98-0002

i ATTACHMENT 3 RESPONSE TO NOTICE OF VIOLATION NCR INSPECTION REPORT 50-10/237/249/97019 97019-01C VIOLATION:

1. 10 CFR Part 50, Ap xndix B, Criterion V, requires, in part, that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances.

C. Dresden Technical Specification 6.8.A requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of RG 1.33, Revision 2, February 1978. Procedures for operation of fuel pool cooling were recommended by RG 1.33.

1 Contrary to the above, as of October 14,1997, the licensee failed to maintain the operating procedures sufficiently to perform a swap of fuel pool cooling trains. As a temperature m, fuel pool cooling was madvertently secured, and the consequence eressed from 90-F to 96-F until the error was detected and corrected.

REASQMJOR VIOLAT[QH:

On October 14,1997 at 0413 hours0.00478 days <br />0.115 hours <br />6.828704e-4 weeks <br />1.571465e-4 months <br />, the 3 A Fuel Pool Cooling (FPC) pump was started and the 3B FPC pump was 1,ccured to support upcoming Instrument Maintenance work. The pump swap was performed in accordance with DOP 1900-01 Rev. 07, Fuel Pool Cooling And Cleanup System Startup.

During the following shift an incressing trend in fuel pool water temperature was observed. Inspection of the FPC system revealed that Reactor Building Ctosed Cooling Water (RBCCW) was not valved into the 3 A FDC heat exchanger. RBCCW flow was subsequently established to the 3 A FPC heat.Lnanger and fuel pool temperature returned to a normal value.

RBCCW to 3A FPC liest Exchanger was not valved in during the pump swap. The RBCCW Inlet Valve,3-3709 A-500 and RBCCW Outlet Valve,3 3720-A-500 were found in an abnormal closed position. This is contrary to the lineup required by the system checklist DOP 3700-M2/E2. A review of RBCCW work history could not identify when this RBCCW line-up error occurred.

ProcedureInadequacy: DOP 1900-01, Revision 07 did not have adequate guidance to swap Fuel Pool Ceoling Pumps. The procedure mntains steps to verify proper RBCCW alignment for system startup and placing a second heat exchanger in service; however, the procedure review and revbion process failed to ideraify that the section for swapping pumps did not contain steps to verify proper RBCCW alignment.

I Page 1 of 2 JMHLTR: #98-0002 l

CORRECrlVE STEPS TAKEN AND REST!LTS ACillEVED:

1.

RBCCW inlet valve,3 3709 A-500 and outlet valve,3 3720.A 500 were opened and Fuel Pool temperature returned to nortnal.

2.

RBCCW valves were verified open to both Unit 2 Fuel Pool llent Exchangers to ensure they were available for service.

3.

A review of Out of Services, mair.tenance, engineering and operational activities was performed but the reason for the abnormal lineup could not be determined.

4.

A historical review of DOP 1900-01 revisions was conducted. Steps to verify proper RBCCW alignment for this evolution were not included in Rev 04 through Rev 07. The procedure revision and review process did not provide any reason why the verification of RBCCW alignment during pump swaps was not included.

CORRECTIVE STEPS TAKEN TO AVOID FtIRTilER VIOLATION:

DOP 1900-01 was reviewed to ensure proper cooling flow alignment for all system man 1pulations governed by that procedure.,.s a result of this review, Step G.6.a was added to verify RBCCW is properly aligned when swapping 1 PC Pumps.

DATE WilEN FilLL COMPLIANCE WILL IIE ACillEVED:

Full compliance was achieved on October 15,1997 when DOP 1900-01 Revision 08 was authorized for use.

Page 2 of 2 1MHLTR: #9862

A*ITACHMENT 4 RESPONSE TO NOTICE OF VIOLATION NCR INSFECTION REPORT 50 10/137/249/97019 97019-02A VIOLATION *

2. Drerden Station Technical Specification 6 8. A requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended m Appendix A of RG 1.33, Revision 2, February 1978. Appendix A of RG 1.33, Revision 2, February 1973, referenced admmistrative procedures.

A. The licensee used DAP 07-43, Revision 3, " Discrete Component Operation (DCO)," to provide guidance for the operation ofindividual components where other procedural guidance does not exist. The DAP addressed techriical specifications and safety evaluations and required approval by the unit supervisor or shift manager for all DCOs.

Contrary to the above, on September 11,1997, the operator failed to implement DAP 07-43 prior to closing the air start valve for the Unit 2/3 EDO. As a consequence, the 2/3 EDG was momentarily rendered inoperable.

REASONIORl'lOLAT10E:

On September 12,1997, at 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br />, Urdt 2/3 Emergency Diesel Generator (2/3 EDG) local annunciator panel failed the local lamp test performed each shift by the IIigh Voltage Operator (IIVO) during rounds. The IIVO contacted the Unit 2 control room and reported the "B" annunciator panel had alarm lights but no audible alarm and the "A" panel had no lights or audible alarm. The main control room confirmed a problem with the annunciator panel because the expected alarm on the 902-8 panel had not been received during the locai annunciator lamp test. The Unit 2 Nuclear Station Operator (U2 NSO) notified the Unit 2 Unit Supervisor (U2 US) of the equipment feiture.

The U2 US attempted to contact two Emergency Diesel Generator system engineers, but was unsuccessful. The US then contacted the Work Week Manager (WWM) and dit ected him to obtain engineering assistance for the annunciator problem.

While the WWM attempted to find engineering support, the U2 US decided to pursue two

_ parallel paths to determine the extent of the annunciator failure. One path was to direct an electrical engineer working with the Out-of-Service Writer's Group to review the electrical schematics and determine alternate methods of monitoring the components monitored by Page 1 of 3 JMHLTR: #984)002 l

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i ths "A" annunciator panel. The second path was to determine if the failure was in the test i

circuitry oc the annunciator circuitry. This information would be used to write the Action l

Request (AR) for troubleshooting.

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The U2 US and U2 NSO discussed different options to force an alarm into the local annunciator panel. It was stated by the U2 US that no action would be performed which would render the EDG inoperable. It was decided to send the llVO to the U2/3 EDG to determine if the limit switch on the air start isolation valve could be moved to generate a loc.=! alarm. The U2 US directed the U2 NSO to contact the IIVO to determine if the limit switch could be manually moved without affecting the valve. The U2 US len the horseshoe area of the Unit 2 control room to perform an IIcightened Level of Awareness (IILA) brief for the Unit 2 Station Black-Out (SBO) Diesel Generator surveillance.

AAer the llLA brief was complete, the U2 US returned to the horseshoc section of the control room and asked what the IIVO had found regarding the limit switch on the valve.

The U2 NSO stated the IIVO reported be would not be able to move the limit switch without moving the valve. The U2 NSO then informed the U2 US that he had directed the IIVO to momentarily close the 2/3 EDG air start isolation valve to generate an alarm.

Subsequent interviews with the U2 NSO revealed the following causal factor for the NSO's decision to momentarily close the air start valve. The U2 NSO believed an operator " dedicated" at a component would not ronder the component inop erable. This philo;ophy was reinforced wl.en DIS 5200-02, Unit 2/3 Fire Pump Day Tank Level Switches Calibration Check, was brought to the control room for authorization at 0806 hours0.00933 days <br />0.224 hours <br />0.00133 weeks <br />3.06683e-4 months <br /> - 21 minutes aAer the report of the failed 2/3 EDG annunciators. Per DlS 5200-02, Step E.3. states, " Dedicated IIVO required at 3-5299 212 (D3 Diesel Oil Day Tank Fill Line ISO Valve) when it is not locked open to maintain D3 Emergency Diesel Operability". In essence, this procedural step was a contributing factor in the NSO's decision to momentarily close the valve.

CORRECTIVE STEPS TAKEN AND RESULTS ACiliEVED:

Upon hearing the report the air start valve had been closed, the U2 US stated the 2/3 EDG s

was potentially inoperable during the time the valve was closed (approx. 2 seconds). The U2 US contacted the Shin Operations Supenisor (SOS) for clarification on operability.

Specifically, when can Operations take credit for a dedicated operator at a velve. The initial response from the SOS was the EDG was not inoperable, but would check some documents in his oflice and report back to the U2 US. As a contingency, tbc U2 US directed the U2 NSO to perform Appendix X to ensure Tech Spec compliance was met for an inoperable EDG.

Page 2 of 3 JMHLTR: #98-0002

A few moments later, the SOS reported back to the U2 US. The SOS stated the documentation in his oflice was based on design criteria for a component and the time it takes for an operator to perform an action to meet the design criteria. The design basis for the EDG is to start and be at rated speed and voltage in less than 13 seconds. Based on this desian criteria and the information provided by the SOS, the U2 US determined the 2/3 EDG was inoperable for the 2 seconds the valve had been closed. Since all compensatory actions for an inoperable EDG had been completed, no other action except gererating a PIF was required.

CORRECrlVE STEPS TAKEN TO AVOID FURTilER VIOLATION:

During subsequent discussions with the U2 NSO, the U2 NSO understood he had made an error in directing the llVO's actions without authorization from the Unit Supervisor or without proper documentation for component manipulation. The NSO stated he had made a momentary unintentionallapse and fuit, understands the need to have Unit Supervir,or authorization and proper documentation to manipulate in plant components.

Corrective actions for this event was counseling of the NSO and documentation of this event in his personal file in accordance with MARC principles. Both corrective actions have been completed.

Further action taken by the Operations department was to implement the Score Card Program. This goal of this program is;"to monitor and reinforce behaviors which promote event free operation relating to personnel safety and reactor safety." The program will be implemented through documented management oversight ofimportant shill activities and will include shill turnover and OOS activities.

DATE WilEN FUI L COMPLIANCE WII,L HE ACillEVED:

Full compliance vias achieved on September 12,1997, when the 2/3 EDG air start valve was re opened and the compensatory actions for entering an LCO for an inoperable EDG were completed.

Page 3 of 3 JMHLTR: #98-0002

4 ATTACHMENT 5 RESPONSE TO NOTICE OF VIOLATION NCR INSPECTION REPORT 50-10/237/249/97019 97019-02B VIOLATION:

2.

Dresden Station Technical Specification 6.8. A requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Ap xndix A of RG 1.33, Revision 2, February 1978. Appendix A of RO 1.33, Revision 2, February 1978, referenced administrative procedures.

B. The Action and Limitation section of Dresden Operating Procedure (DOP) 6500-04,

" Racking Out Safety-Related 4KV Breakers." states that breakers are not to be racked out in the test mode for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the plant is in hot or cold shutdown.

Contrary to the t.bo,e, on September 16,1997, the inspectors identified that the licensee had racked a safety related breaker in the test mode for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

REDON FOR VIOLATION:

The controls to prevent a breaker from being in the test position more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permitted a temporary liR during an Out of Service to last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less. The ShiR Manager was designated to control the time limit of the temporary liR within the Out of Service Procedure, however, this was not the correct level of responsibility. The responsibility to control the duration of a temporary lified Out of Service should have been given to the Out of Service Supervisor (OOSS) because he is aware of all of the Out of Service activities for each unit. He is responsible to ensure adherence to DAP 03-05 by all station employees.

There were no formal controls in the turnover process to ensure adherence to these procedures.

Page 1 of 2 JMHLTR: #98-0002 l

CORRECTIVE STEPS TAKEN AND RESULTS AClIIEVED:

9 A Problem Identification Form (PIF) was generated, documenting that the.% Shutdawn Cooling Pump breaker was in the test position and temporary lifted for gremer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The OOSS was instructed to return the bre.aker to the Out of Senice position, fully racked ou', and rehang the Out of Senice. On September 16,1997, a search of the ternporary lin file revealed two other Out of Services (OOS's) that were temporary lined for greater then 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without the shift manager's approval. These OOS's were corrected immediately to bring them into compliance with DAP 03-05, Out of Senice Process.

C_ORRECTIVE STEPS TAKEN TO AVOID FURTIIER VIOLATION:

The OOS supervisor position each shift inust sign that he has reviewed the status of temporary lifted (TL) OOS's. Another sheet for the OOS supervisor to sign signifying this review was placed in the binder that covers reviewing operator rounds (located in the WEC). This was an interim action until the stanha turnover checklists were implemented for the Out of Service Supervisor pc ition. These new checklists for the OOSS have ieeriincorporated into DAP 7-02 Londuct ofShift Operations. This procedure controls shift turnover and requires the use of shin turnover sheets or checklists.

DAP 03-05, Out of&n' ice Process will be revised to drify the specific time limi associated with 4KV breakers to be consistent with the limits found in the operating procedures such as DOP 6503-04 Racking Out Safety Related 4KVBreakers.

(NTS 237-100-97019-02B0l)

Further actiori taken by the Operations department was to implement the Score Card Program. This goal of this program is;"to monitor and reinforce behaviors which promote event-free operation relating to personael safety and reactor safety." The program wih be implemented t!ncugh documented management oversight ofimportant shift activities and willinclude shift turnover and OOS activities.

DATE WIIEN FULL COMPLIANCE WILL HE ACIIIEVED:

Ful' compliance will be achieved when DAP 03-05 revision is implemented on 3/15/98.

The standard turnovet checklists were implemented for the Oi t of Service Supenisor position in DAP 7-02 knuary 7,1998.

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ATTACHMENT 6 i BGtQH,SE TO NOTICE OF VIOLATION NCR INSPECTION REPORT 50 10/237/249/97019 97019-02C VIOLATION:

2.

Dresden Station Technical Specification 6.8.A requires that written procedures be a,stablished, implencated, and maintained ccvering the applicable procedures recommended in Appendix A c; RG 1.33, Revision 2, February 1978. Appendix A of RG 1.33, Revisior 2, February 1978, referenced administrative procedures.

C. Dresden Administrative Procedure (DAP-03-05, "Out-of-Service Procedures,"

states that when an out-of-service is temporarily liRed for test purposes, temporary liRs should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> un'.ess approved by the station manager or his designee.

Contrary to the above, on September 11,1997, the licensee temporarily liRed a 4KV '

breaker to the test mode from the out-of-service position to perform pressure switch logic testi:.g on the 3B shutdown cooling pump. On September 16,1997, the inspectors identified that the 4KV breaker was still temporarily liRed in the test position, without prior approval from the shiA manager, REASON FOR VIOLATION:

The controls to prevent a breaker frora being in the test position more than 24 houra permitted a temporary liR during an Out of Service to !ast 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 'ess. The Shia Manager was designated to control the time limit of the temporary liR within the Out of Service Procedure, however, this v as not the correct lesel of responsibility._ The responsibility to control the duration of a temporary liRed Out of Service should have. -

been given to the Out of Service Supervisor (OOSS) because he is aware of all of the Out of Service activities for each unit. He is responsible to ensure adherence to DAP 03-05 by _

all station employees.

There were no formal controls in the turnover process to eruure adherence to these procedures.-

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CORRECTIVE STEPS TAKEN AND RESULTS ACillEVED:

A Problem Identification Form (PIF) was generated, documenting that the 3B Shutdown Cooling Pump breaker was in the test position and temporary lined for greaW than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The OOSS was instmeted to return the breaker to the Out of Service position, fully racked out, and rehang the Out of Senice. On September 16,1997, a search of the temporary lift file revealed two other Out of Senices (OOS's) that were temporary lined for greater than 24 hourt without the shin manager's approval. These OOS's were corrected immediately to bring them into compliance with DAl 03-05, Out of Senice Process.

CORRECTIVE STEPS TAKEN TO AVOID FURTIIER VIOLATION.2 The OOS supervisor position each shin must sign that he has reviewed the statas of tempe;ary lined (TL) OOS's. Another sheet for the OOS supervisor to sign signifying this review was placed in the binder that covers reviewing operator rounds (located in the WEC). This was an interim action until the standard turnover checklists were Suplemented for the Out of Senice Supenisor position. These new checklists for the OOSS have been incorporated into DAP 7-02 Conduct ofShift Operations. This procedure controls shin tumover and requires the use of shiR turnover sheets or checklists.

DAP 03-05, Out ofService Process will be revised to clarify the specific time limits associated with 4KV breaken to be consistent with the limits found in the operatin3 procedures such as DOP 6500-04 Racking Out Safety Related 4KVBreakers.

(NTS 237-100-97019-02801)

Further action taken by the Operations department was to implement the Scoa Card Program. This goal of this program is;"To monitor and reinforce behaviors which promote event-free operation relating to persanel safety and reactor safety." The program will be implemented through documented management oversight ofimportant shiR activities and will include shiR turnover and OOS activities.

DATE silEN FULL COMPLIANCE WILL HE ACIIIEVED:

Full compliance will be achieved when DAP 03-05 revision is implemented > n 3/13/98.

The standard turnover checklists were implemented for the Out of Senice Supervisor position in DAP 7-02 January 7,1998.

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