ML20202E616
| ML20202E616 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/26/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-010-97-20, 50-10-97-20, 50-237-97-20, 50-249-97-20, JSPLTR:-97-0199, JSPLTR:-97-199, NUDOCS 9712080092 | |
| Download: ML20202E616 (7) | |
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Drevien Generattin Natton 690 North Dtruk n Rual
%1onts, n Nil %0 Tri m s 9 u292o November 26,1997 JSP1,TR: 97-0199 U. S. Nuclear llegulatory Commission NITN: Document Control Dcsk Washington, D. C. 20$55
Subject:
Dresden Nuclear Power Station 1Jnits 2 and 3 lleply to a Notice of Violation; Inspection Iteport 50-10/237/249/97020.
NRC Docket Numbers50-010. 50 237. and 50 249
Reference:
John A. Grobe letter to J. S. Perry, dated October 30,1997, transmitting NRC Inspection Report 5010/237/249/97020 and Notiec of Violation The purpose of this letter is to provide Comed's reply to the Notice of Violation transmitted by the almve reference. Specincally, the violations resulted from the failure to follow station procedures during chemi try sampling activities and the failure to complete surveillances on the high radiation sampling system at the reydred intervals.
The response to the Notice of Violation is found in the enciesure to this letter.
The following commitments are contained in the enclosure to address the violations:
Action Requests (ARs) were written to padlock the panels and contial access to chemistry sampling equipment drain valves to ensure that only Chemistry persor.nel operate this equipment. This will be completed by December 31,1997.
All Chemistry Technicians will attend lluman Error Reduction Training by December 12,1997.
Chemistry will review their periodic work activities scheduled through the predefme program at intervals longer than weekly and identify those predefines needing immediate Central File storage. This will ensure proper retention of the supporting documentation in Central File and provide a signature requirement. (NTS# 237-200-97 04601 d ie 2/1/98)
Upon completion of the review of the Chemistry predennes, those items performed j
weekly or more oRen will be included into an Appendix procedur: or equivalent. The occuments for the weekly surveillances are retained as a package and sent to Ceotral File after management review. (NTS# 237 200-97-04602 due 3/1/98)
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November 26,1997 JSPLTR: 97-0199 i
USNRC Page 2 of 2 i
In addition, you requested that hir. Gary Shear of your staff be provided a written report of our findings related to the Unit I radiological intake incident on September 30,1997, including our dose assessment and root cause analysis. hir. Pete llolland of my staff contacted hir. Shear and arranged an infbrmal meeting to provide hir. Shear's staff with a copy of the report and a brief overview of the investigation. This meeting is tentatively scheduled Ibr November 26,1997.
This response contains no proprietary or safeguards information. If there are any questions concerning this letter, please refer them to hir. Frank Spangenberg, Dresden 1
Station Regulatory Assurance hianager, at (815) 942 2920 extension 3800.
4 4'
Sincerely, 1
, hN J) Stephen Perry 2
Site Vice President Dresden Station 1
1 Attachments i
)
cc:
A. Bill Beach, Regional Administrator, Region 111 i
bl. Ring, Acting Branch Chief, Division of Reactor Projects, Region 111 J. F. Stang, Project hianager, NRR (Unit 2/3)
K. Riemer, Senior Resident inspector, Dresden 1
Oflice of Nuclear Facility Safety - IDNS j
File: Numerical
NITACllMENT A lll! PLY TO A NOTICE OF VIOLATION Conunonwealth Edison Company Docket Nos. 50-237;50 249 Dresden Nuclear Power Strion, Units 2 and 3 License Nos. DPit i9; DPit-25 CllEMISTRY PROCEDURAL ADilERENCE DEFICll!NCIES NRC Notices of Violation 50-237/97020 01, 50-237/97020 01 VIOLATION Technical Specification 6.8.A requires, in part, that written procedures be established and implemented covering the activities recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,l'ebruary 1978. Appendix A of RG 1.33 recommends that procedures be implemented covering procedural adherence and radiochemical controls. The radiochemical control procedures should prescribe the nature and frequency of sampling and analyses.
Dresden Administrative Procedure DAP 0913. Revision 6, " Procedural Adherence," requires, in part, that procedures be adhered to during the course of activities and that each step of the procedure be perfonned exactly as written and in the sequence specified in the procedure.
Dresden Chemistry Procedure DCP 1019-01, Revision 10. " Sampling," requires, in part, that aDer an aqueous sample is obtained from the reactor building sample panel, the sample panel drain valve be closed to prevent drain back up and panel sink contamination.
Dresden Chemistry Procedure DCP 2218 01, Revision 4, " Reactor Building Vent," requires,in part, that if switching sample pumps after particulate and iodine filter changeout on the non-SPING system and prior to starting the pump motor of the pump to be placed in service, the sample pump valve lineup be performed in a specilled sequence.
Contrary to the above:
On or about September 18,1997, the reactor bailding sample panel drain valve was not a.
closed after a sample was collected. Specifically, on the aDernoon of September 18,1997, the inspectors observed the sample penel drain valve to be open prior to a chemistry technician demonstrating the process of collecting a reactor coolant sample from the panel.
Page1of3 Jsetxn 97-ot99 I
- b.,On September 16,1997, during the perfonnance of a Unit 3 reactor building vent particulate and iodine filter changeout, the sample pumps were switched and the sample pump valve lineup was not perfonned in the sequence specified in the procedure. Specifically, the inspectors observed a chemistry technician start the sample pump motor prior to closing the inlet valve of the previously operating sample pump and opening the inlet valve of the pump to be placed in service.
REASON FOR VIOLATION There are two separate reasons for the two cited examples oflack of procedural adherence. The exact cause of the first example could not be detennined, it could not be detennined if the drain valve was left open by a Chemistry Technician (CT) or if the valve was opened by someone other than Chemistry personnel. A contributing cause to this problem was the lack of positive control of the sampling equipment.
The other example ofinadequate procedural adherence was due a cumbersome procedure. In addition, the failure to use the Self Check process contributed to lack of procedural adherence.
CORRECTIVE STEPS TAKEN AND RESULTS ACillEVED Immediate corrective actions for the firrt example oflack of procedural adherence included walking down all station sample panels and approximately 75% of other sample points to verify proper plant configuration. No other valves were found out of normal position.
To correct the second example, DCP 2218 01, Reactor fluilding Vent, was revised. The procedure was cumbersome and difficult to follow as originally written. The procedure is now more streamlined and easier to use. This was completed October 23,1997.
CORRECTIVE STEPS TAKEN TO AVOlD FURTilER VIOLATION An Apparent Cause Evaluation (ACE) was perfonned due to other occurrences of sample panel drain valves (Turbine lluilding Sample Panels) being found open. During this ACE, evidence of non chemistry personnel using these drains was found (a total of 5 occurrences). To ensure that only Chemistry personnel operate this equipment, action requests (ARs) were written to padlock the panels and control access to these drain valves (AR# 970077642,970077645,970077654, 970077648). This will provide positive configuration control of these drain valves.
Page 2 0f 3 JSPLTR 97-0199
in addition to the specific corrective actions to the procedures or equipment, all cts are scheduled to attend lluman Error Reduction Training. Seven personnel have attended the training. The last six are scheduled to be done no later than 12/16/97. All cts have attended Self Check or STAR (Stop, Think, Act, Review) simulator training as part of Cycle 3 Chemistry Continuing training. The use of the techniques learned during these courses will assist in ensuring procedural adherence is the nonn in Chemistry.
DATE WilEN FULL COMPLI ANCE WILL llE AClllEVED For the first example, full compliance will be achieved by December 31,1997, when the padlock
- installation is coniplete. For the second example, full compliance was achieved on October 23,1997, when DCP 2218 01 revision 5 was issued.
Page 3 of 3 JSPLTR 97-0199
ATTACllMENT 11 REPLY TO A NOTICE OF VIOLATION Conunonwealth Edison Ccmpany Docket Nos. 50 237;50 249 Dresden Nuclear Power Station, Units 2 and 3 License Nos. DPit-19; DPit 25 llRSS ANNUAL COMPAltlSON DOCUMENTATION DEFICIENT NRC Notices of Violation 50-237/97020-02; 50 249/97020-02 VIOLATION Technical Specification 6.8.D.3 requires,in part, that a post accident sampling program be established, implemented and maintained. The program shall include procedures for sampling and analysis.
Dresden Sample lluilding Procedure DSilP 1000-37 Revision 2,"11RSS Operability Program,"
provides the steps necessary to perform and document the required operability surveillances of the liigh Radiation Sample System (llRSS). The procedure requires that yearly grab samples be collec'ed from the reactor water cleanup tilter inlet and reactor recirculation loop 11 at the llRSS and the reactor sample panels, and that isotopic analyses be performed and compared to ensure that acceptance criteria are met.
Contrary to the above, yearly surveillances on the liitSS were not all completed as required.
Specifically, in 1995 and 1996, Unit 2 reactor water grab samples were not collected, isotopically analyzed and compared from the cleanup filter inlet and reactor recirculation loop 11 at the llRSS and reactor sample panels.
REASON FOR VIGl.ATION The violation occurred due to the lack of management control of surveillance documentation.
A root cause investigation (RCI) was performed to identify the depth of the problem and identify corrective actions concerning the missing surveillance documentation. During the course of the RCI, documentation of the 1995 surveillance was located; however, only partial documentation was found for the 1996 surveillance. This surveillance is tracked via the station's predefine program. Discussions v.itu the personnel that signed off the predefine as being complete leads us to believe that the surveillance was completed, but no supporting documentation can be found.
The surveillance has been completed for 1997 on both Units.
Page 1 of 2 JSPLTR 97-0199
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During the RCl,it was determined that the primary cause of this event was a process weakness in implementing the pre defined program in the Chemistry 12epartment. All Chemistry predefines are set up such that no accompanying documentation is required when signing off the predefine.
Procedures do exist to document completion of these surveillances, but the paperwork is not required to be immediately sent to Central File fbr storage. These procedures are stored in Chemistry for oi jear, then sem to Central File. Also, no signature is required to document appropriate completion of the predefine.
CORRl!CTIVE STEPS TAKEN AND RESUI.TS AClllEVIID l
A detailed search of records was perfbrmed and the following were discovered:
A search of Chemistry Department records Ibund the completed llRSS surveillances for 1995 and one Unit Ibr 1996.
A search of the station's predefine system indicated completion Ibr 1995 and 1996 lbr both Unit 2 and Unit 3.
A search of Central File did not locate evidence of the missing 1996 paperwork.
CORRECTIVE STliPS TAKEN TO AVOID FURTilER VIOLATION To ensure that Chemistry predefines are effectively tracked and surveillance documentation is properly controlled, the ibliowing corrective actions are being taken:
Chemistry will review their peiiodie work activities scheduled through the predefine program at intervals longer than weekly and identify those predefines needing inunediate Central File storage. This will ensure proper retention of the supporting documentation in Central File and provide a signature requirement. (NTS# 237-200-97 04601 due 2/1/98)
Upon completion of the review of the Chemistry predefines, those items perfbrmed weekly or more often will be included into an Appendix procedure or equivalent. The documents lbr the weekly surveillances are retained as a package and sent to Central File aller management review. (NTS# 237 200-97-04602 due 3/1/98)
DATE WilEN FULL COMPLlANCE WILL DE AClllEVED Compliance with IIRSS requirements will be met by end of December 1997 with completion of the last annual requirement. The list predefine item will be complete February 1,1998. The appendix procedure will be complete March 1,1998.
Page 2 of 2 JSPl.TR 97-0199
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