ML20203C938
| ML20203C938 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203C930 | List: |
| References | |
| 50-010-97-19, 50-10-97-19, 50-237-97-19, 50-249-97-19, NUDOCS 9712160050 | |
| Download: ML20203C938 (3) | |
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NOTICE OF Viol.ATION Commonwealth Edison Company-Docket Nos.50-010; 50 237;50 249 -
Dresden Nuclear Power Station, Units 2 and 3 1.loonse Nos. DPR 02; DPR 19; DPR-25 During an NRC Inspection conducted from August 28 to October 16,1997, two violations of NRC requirements were identified. In sooordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
l 1.
10 CFR Part 50, Appendix B, Critorion V, requires, in part, that activities affecting c:uality be prescribed by procedures of a type appropriate to the circumsta90es, i
A.
Dresden Technical Specification 6.8.A requires that written procedures be i
established, implemented, and maintained covering the applicable procedures recommersdod in Appendix A of RacdTi Guide (RG) 1,33 Revision 2 February 1978. Procedures for operation of emergency 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 generator (EDG) by not providing adequate procedural guidance regarding control room indication of EDG speed and by not providing adequate procedural guidance regarding the response to an automatic trip of the l
EDG. As a consequence of the inadequate op eating procedure, the licensee was unable to operate the EDG for a routine surveillance test and the EDG was I
l made inoperabia for 2 days.
B.
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 alarm conditions were mcommended in RG 1.33, Revision 2, February 1978.
l Contrary to the above, as of August 28,1997, the licensee failed to maintain an adequate alarm procedure for the EDG, As a consequence of the inadequate procedure for alarm e,onditions, the EDG was unexpectedly automatically started and retumed to an operating state with inadequate cooling, thereby causing the l-l EDG to trip automatically, l
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.
f 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 consequence, fuel pool cooling was inadvertently secured, and the fuel pool temperature increased from 90*F to 96'F until the error was detected and corrected.
. This is a Severity Level IV violation (Supplement I).
9712160050 971204 gDR ADOCK 05000010 PDR
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Notice of Violation 42-4 2.
Dresden Station Technical Specification 6.8.A requires that wrttien procedures be established, implemented, and maintained oovering the applicable procedures recommended in Appendix A of RG 1.33, Revision 2, February 1978. Appendix A of RG 1.33, Revision 2, February 1978, referonood administrative procedures; A.
The licensee used DAP 07-43, Revision 3, "Disorote Component Operation (DCO)," to provide guidance for the operation of indivHual components where r
4 Other procedural guidance does not exist. The DAP addressed technical specifications and safety evaluations and required approval by the unit supervisor -
or shift manager for all DCOs.
Contrary to the soove, on September 11,1997, the operetor failed to implement DAP 07-43 prior to closing the air start valve for the Unit 2/3 EDG, As a consequence, the 2/3 EDG was momentar9y rendered inoperable.
B.
The Action and Limitation section of Dresden Operating Procedure (DOP) 6500 04, " Racking out safety-Related 4kV Breakars," 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, j
t Contrary to the above, 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 />.
l C.
Dresden Administrative Procedure (DAP) 03-05, "Out-of-Service Procedures,"
states that when an out-of-service is temporar9y lifted for test purposes, temporary lifts should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless approved by the station manager or his designee.
Centrary to the above, on September 11,1997, the licensee temporarily lifted a L
4kV breaker to the test mode from the out-of-service position to perform pressure switch logic testing on the 3B shutdown cooling pump. On September 16,1997, the inspectors identified that the 4kV breaker was still temporarily lifted in the test position, without prior approval from the shift manager.
This is a Severity Level IV violation (Supplement 1).
f Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required i
- to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN.:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator,
' Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letur transmitting this Notice of Violation (Nctice). This reply should be clearty marked as a " Reply to a Notice of Violation" and should include for each v o a on: (1) the reason for the violation, or, if contested, the basis for disputing the i l ti violation, (2) the corrective steps that have been taken and the results achieved, (3) the i -
corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an l
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-3 adequate reply is not received witnin the time specified in this Nohoe, an order or a Demand for Information smv be issued 'As to why the license should not be modified, suspended, or revoked, or why such other action r,s may be proper should not be taken. Where good cause is shown, consideration will be givrsn to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, N should not include any personal privacy, proprietary, or safeguards information so that N can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, tim please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your responso that deletes such information, if you request withholding of such material, you mWEi specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
- create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information), if safeguards information is necessary to provide an acceptable response, please provide the level of protection desenbod in 10 CFR 73.21.
Dated at Lisle, IL this 4th day of December,1997 i
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