ML20203J809
| 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
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Commonwealth Edison Company
6500 North Dresden Road
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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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cc w/o encl:
O. Kingsley, Nuclear Generation Group
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President & Chief Nuclear Officer
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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
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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
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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
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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
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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
Page 2 of 2
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in addition, you requested that Mr. Gary Shear of your staff be provided a written report
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ofour findings related to the Unit I radiological intake incident on September 30,1997,
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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
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J, Stephen Perry
Site Vice President
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Dresden Station
Attachments
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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
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REPLY TO A NOTICE OF VIOLATION
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Commonwealth Edison Company
Docket Nos. 50 237;50-249
Dresden Nuclear Power Station, Units 2 and 3
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CilEMISTRY PROCEDURAL ADilERENCE DEFICIENCIES
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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
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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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JSPl.TR 97 0199
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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
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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
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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
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control of the sampling equipment.
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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.
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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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JSPLTR 97 0199
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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
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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
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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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- JSPl.TR 97 0199
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A'ITACilMENT 11
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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
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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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JS"LTR 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-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:
A search of Chemistry Department records found the completed ilRSS surveillances for 1995
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and one Unit for 1996.
A search of the station's prede6ne system indicated completion for 1995 and 1996 for both
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Unit 2 and Unit 3.
A search of Central File did not locate evidence of the missing 1996 paperwork.
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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-
Chemistry will review their periodic work activities scheduled through the predeDne program
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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
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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,
Page 2 of 2
JSPLTR 97-0199