ML20203J809

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-010/97-20, 50-237/97-20 & 50-249/97-20 on 971030

ML20203J809
Person / Time
Site:	Dresden
Issue date:	12/15/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jamila Perry COMMONWEALTH EDISON CO.
References
50-010-97-20, 50-10-97-20, 50-237-97-20, 50-249-97-20, NUDOCS 9712220103
Download: ML20203J809 (2)

See also: IR 05000010/1997020

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December 15, 1997

Mr. J_. S. Perry

Site Vice President

Dresden Nuclear Power Station 4

Commonwealth Edison Company J

6500 North Dresden Road i

Morris,IL 60450

SUBJECT: - NOTICE OF VIOLATION (NRC INSPECTION REPORTS 5010/97020(DRS);

50 237/97020(DRS); 50-249/97020(DRS)

Dear Mr. Perry:

This acknowledges receipt of your letter dated November 26,1997, in response to our letter

dated October 30,1997, transmitting a Notice of Violation associated with the failure to

adequately implement chemistry pror:edures and complete surevillances of the High Radiation

Sample System (HRSS) at your Dresden Nuclear Power. Station. In your letter, you indicated

that improvements would be made to better control access to chemistry sampling equipment,

that procedures were revised and that additional training would be provided to chemistry

technicians. Your letter also indicated that management oversight of the HRSS surveillance

documentation would be improved. We have reviewed your corrective actions and have no

further questions at this time. These corrective actions will be examlied during future

Inspections.

Sincerely,

John A. Grobe, Director

,

Division of Reactor Safety

Docket Nos. 50-10; 50-237; 50-249

Ucense Nos. DPR-02; DPR 19; DPR 25

E nclosure: Ltr dtd 11/26/97 J. S. Perry

'Dresdan to USNRC

DOCUMENT NAME: G:DRS\DRE121_7.DRS

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J. S. Perry 2 Decernber 15, 1997

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cc w/o encl: O. Kingsley, Nuclear Generation Group -

President & Chief Nuclear Officer  :'

M. Wallace, Senior Vice President.

Corporate Services

E. Kraft, Vice President, BWR Operations

Liaison Officer, NOC-BOD

D. A. Sager, Vice President,

Generatlun Support

D. Farrar, Nuclear Regulatory

Services Manager

1. Johnson, Licensing Operations Manager

Document Control Desk - Licensing

T Nauman, Station Manager, Unit 1

M. Heffley, Station Manager. Units 2 and 3 *

F. Spangenberg, Regulatory Assurance

Manager  ;

cc w/ encl: Richard Hubbard

Nathan Schloss, Economist,

Office of the Attorney General ,

State Liaison Officer

Chairman, Illinois Commerce Commission

D.istribution

Docket File w/enci Rlli PRR w/ encl Rill Enf. Coordinator w/ encl

PUBLIC IE-01 w/ encl SRI, Dresden w/ encl TSS w/ encl

LPM, NRR w/enci - - J. L. Caldwell, Rlli w/ encl R. A. Capra, NRR w/ enc!

DRP w/onel A. B. Beach, Rlli w/ encl DOCDESK w/ encl

DRS w/ encl CAA1 w/enci

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November 26,1997

JSPLTR: 97-0199

U. S. Nuclear Regulatory Commission

A1TN: Document Control Desk

Washington, D. C. 20555

Subject: Dresden Nuclear Power Station Units 2 and 3

Reply iw Notice of Violation; inspection Report 5010/237/249/97020.

NRC rocke, Numbers 50 010. 50 237. and 50 249

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Reference: John . .. Grobe I;tter to J. S. Perry, dated October 30,1997, transmitting

NRC Insne %n Report 50-10/237/249/97020 and Notice of Violation

The purpose of this letter is to provide Comed's reply to the Notice of Violation

transmitted by the above reference. Specifically, the violations resulted from the failure

to follow station procedures during chemistry sampling activities and the faihire to

complete surveillances on the high radiation s:impling system at the required intervals.

The response to the Notice of Violation is found in the enclosure 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 control access to

chemistry sampling equipment drain valves to ensure that only Chemistry personnel

operate this eqttipment. This will be completed by December 31,1997.

. All Chemistry Technicians will attend Human Error Reduction Training by

December 12,1997.

• Chemistry will review their periodic work activities scheduled through the predefine

program at intervals longer than weekly and identify those predefines needing

immediate Central File storage. This will ensure proper retention of the supporting

docum ntation 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 predermes, those items performed

weekly or more often will be included into an Appendix procedure or equivalent. The

documents for the weekly surveillances are retaicd as a package and sent to Central-

File after management review. (NTS# 237-200-97 04602 due 3/1/98)

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November 26,1997 JSPLTR: 97-0199  ;

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USNRC Page 2 of 2

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in addition, you requested that Mr. Gary Shear of your staff be provided a written report ,

ofour findings related to the Unit I radiological intake incident on September 30,1997, ,

including our dose assessment and root cause analysis. Mr. Pete llolland of my staff

contacted Mr. Shear and ananged an informal meeting to provide Mr. Shear's staff with a

copy of the report and a brief overview of the investigation. This meeting is tentatively

scheduled for November 26,1997.

This response contains no proprietary or safeguards infonnation. 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,

\ .'M ,

J, Stephen Perry

Site Vice President _

Dresden Station

Attachments

ec: A. Bill Beach, Regional Administrator, Region ill

M. Ring, Atting Branch Chief, Division of Reactor Projects, Region 111

J. F. Stang, Project Manager, NRR (Unit 2/3)

K. Riemer, Senior Resident inspector, Dresden

Office of Nuclear Facility Safety IDNS

File: Numerical

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NITACllMENT A l

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REPLY TO A NOTICE OF VIOLATION  !

Commonwealth Edison Company Docket Nos. 50 237;50-249

Dresden Nuclear Power Station, Units 2 and 3 License Nos. DPR 19; DPR 25

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CilEMISTRY PROCEDURAL ADilERENCE DEFICIENCIES

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

implemeated covering the activities recommended in Appendix A of Regulatory Guide (RG)

1.33, Revision 7. February 1978. Ap, :ndix 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 performed exactly as written and in the sequence specified in the procedure.

Dresden Chemistry Procedure DCp 1019 01, Revision 10 " Sampling," requires, in part, that

after 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," require;, in

part, that if switching samiyle pumps after particulate and iodine filter changeout on the non-

SPINO 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 specified sequence.

Contrary to the above:

a. On or about September 18,1997, the reactor building sample panel drain valve was not

closed after a sample was collected. Specifically, on the aftemoon of September 18,1997, the

inspectors observed the sample panel drain valve to be open prior to a chemistry technician

demonstrating the process ofcollecting a reactor coolant sample from the panel.

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b. On September 16,1997, during the performance of a Unit 3 reactor building vent particulate

and iodine litter changeout, the sample pumps were switched and the sample pump valve  ;

lineup was not performed in the sequence specined in the procedure. Specincally, the  !

inspectors observed a chemistry technician start the sample pump motor prior to closing the

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inlet valve of the previously operating sample pump and opening the inlet valve of the pump

to be placed in service.

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REASON FOR VIOLATION  :

There are two separate reasons for the two cited examples oflack of procedural adherence. The  ;

exact cause of the Erst example could not be determined, it could not be determined 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 adherenec was due a cumbersome procedure. In

addition, the failure to use the Self Check process contributed to lack of procedural adherence. 4

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CORRECTIVE STEPS TAKEN AND RESULTS ACillEVED

Immediate corrective actions for the first example oflack of procedural adherence included

walking down all station sanple 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 Building 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 war completed October 23,1997.

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CORRECTIVE STEPS TAKEN TO AVOID FURTilER VIOLATION

An Apparent Cause Evaluation (ACE) was performed due to other occurrences of sample panel

drain valves (Tmbine Building 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

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the panels and control access to these drain valves (AR# 970077642,970077645,970077654,

970077648). This will provide positive configuration control of these drain valves. >

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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 thrin 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 <

cnsuring procedural adherence is the norm in Chemistry.

DATE WilEN FULL COMPLIANCE WILL DE ACHIEVED

For the first example, full compliance will be achieved by December 31,1997, when the padlock

installation is complete. For the second examole, full compliance was achieved on

October 23,1997, when DCP 2218 01 revision 5 was issued.

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A'ITACilMENT 11 r

REPLY TO A NOTICE OF VIOLATION

Commonwealth Edison Company Docket Nos. 50 237;50 249

Dresden Nuclear Power Station, Units 2 and 3 License Nos. DPR 19; DPR 25 '

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llRSS ANNUAL COMPARISON DOCUMENTATION DEFICIENT

NRC Notices of Violation 50 237/97020-02; 50 249/97020 02

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VIOLATION

Technical Specification 6.8.D.3 requires, in part, that a post accident sampling program

be established, implemented and maintained. The program shal include procedures for

sampling and analysis.

Dresden Sample lluilding Procedure DSBP 1000 37, Revision 2,"IIRSS 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

collected from the reactor water cleanup filter inlet and reactor recirculation loop B 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 llRSS were not all completed as required.

Speci0cally, in 1995 and 1996, Unit 2 reactor water grab samples were not collected, isotopically

analyzed and compared from the cleanup litter inlet and reactor recirculation loop B at the HRSS

and reactor sample panels.

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REASON FOR VIOLATION

The violation occurred due to the lack of management control of surveillance documentation.

A root cause investigation (RCl) was performed to identify the depth of the problem and identify

corrective actions concerning the missing surveillance documentation. During the course of the

RCl, documentation of the 1995 surveillance was located; however, only panial documentation

was found for the 1996 surveillance. This surveillance is tracked via the station's predefine

program. Discussions with 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.

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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-denned program in the Chemistry Department. All Chemistry predeDnes

are set up such that no accompanying documentation is required when signing off the predefine.

Procedures do exist to document comple. ion of these surveillances, but the paperwork is not

required to be imm.diately sent to Central File for storage. Thew procedures are stored in

Clmmistry for one year, then sent to Central File. Also, no signature is required to document

appropriate completion of the predenne.

CORRECTIVE STEPS TAKEN AND RESULTS AClllEVED

A detailed search of records was performed and the following were discovered:

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A search of Chemistry Department records found the completed ilRSS surveillances for 1995

and one Unit for 1996.

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A search of the station's prede6ne system indicated completion for 1995 and 1996 for both

Unit 2 and Unit 3.

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A search of Central File did not locate evidence of the missing 1996 paperwork.

CORRECTIVE STEPS TAKEN TO AVOlD FURTilER VIOLATION

To ensure that Chemistry picdefines are effectively tracked and surveillance documentation is

properly controlled, the following corrective actions are being taken-

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Chemistry will review their periodic work activities scheduled through the predeDne program

at intervals longer than weekly and identify those predennes needing immediate Central File

storage. This will ensme 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 Chr mistry prede6nes, those items performed weekly or

more often will be included into an Appendix procedure or equivalent. The documents for

the weekly surveillances are retained as a package and sent to Central File after management

teview. (NTS# 237 200-97-04602 due 3/1/98)

DATE WilEN FULL COMPLIANCE WILL BE ACHIEVED

Colaplianer S llRSS requirements will be met by end of December 1997 with completion of

the last annu tluirement. The list predenne item will be complete February 1,1998. The

appendix procedure will be complete March 1,1998,

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JSPLTR 97-0199