ML20204F472

Responds to NRC Re Violations Noted in IE Insp Repts 50-010/83-05,50-237/83-05 & 50-249/83-04.Corrective Actions:Amend 71 Reissued & Incorporated Into Tech Specs. Corporate QA Dept Will Audit Accounting & Followup Sys

ML20204F472
Person / Time
Site:	Dresden
Issue date:	03/30/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20204F470	List: IR 05000010/1983005 ML20204F472
References
6285N, NUDOCS 8305020106
Download: ML20204F472 (3)

Text

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" N )Commonwe:lth Edison One First Nabonal Plaza. Chicago Ilhnois O ' J Address Reply to: Post Ofhce Box 767 4j Chicago, Illinois 60690 March 30, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and

, Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 i

Subject:

Dresden Station Units 1, 2 and 3 Response to Items of Noncompliance in I.E. Inspection Report Nos.

50-010/83-05, 50-237/83-05, and 50-249/83-04 NRC Docket Nos. 50-10, 50-237 & 50-249 Reference (a): J. F. Streeter letter to Cordell Reed dated March 4, 1983.

Dear Mr. Keppler:

i Reference (a) transmitted the results of the routine inspection

, conducted by Messrs. T. M. Tongue, M. J. Jordan and S. Stasek during the period of January 4 through February 2, 1983, of Dresden Nuclear Power Station Units 1, 2, and 3. The Appendix to Reference (a) identified one item of non-compliance with NRC requirements. Our response to this item of non-compliance is provided in Attachment A of this letter.

If there are any questions regarding this matter, please contact this office, i

Very uly yours, m2 D. L. Farrar Director of Nuclear Licensing BR/lm cc: NRC Resident Inspector - Dresden Attachment e305020106 830425 51983 6285N khR

{DRADOCK05000 l

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COMMONWEALTH EDISON COMPANY ATTACHMENT A Response to Notice of Violation The item of non-compliance identified in Appendix A of the NRC letter, dated March 4, 1983 is responded to in the following paragraphs:

10 CFR 50, Part 50, Appendix B, Criterion VI states in part " Measures shall be established to control the issuance of documents... including changes thereto, which prescribe all activities aff'ecting quality." The licensee's Quality Assurance manual, under Quality Requirements 6.0 states "A document control system will be used to assure that documents such as specifications...are reviewed for adequacy and approved for release by authorized personnel... Such documents will be distributed to and used at the locations where the prescribed activity is performed. Changes to these documents will be handled similarly." This Quality Requirement also states in part " Periodic inspection and audits by Quality Assurance are as a final check to assure that the latest authorized documents are in use."

Contrary to the above, the Amendment No. 71 dated May 13, 1982, to the Technical Specifications (License No. OPR-19 or Docket No. 50-237) was not incorporated into controlled copies of Technical Specifications on the Dresden site. This was verified by review of at least five copies.

However, it was found that controlled copies of the Technical Specifica-tions at the Corporate office did incorporate the amendment. It was also found that there is not audit for verification that amendments are placed in the Technical Specifications to ensure they are current.

Discussion Dresden received notice from the Nuclear Regulatory Commission (NRC) on 6-14-82 of their approval of Amendment No. 71 to DPR-19. No action was, or is normally taken by Dresden at this time, as we await approval and notification from CECO's Nuclear Licensing Administrator (NLA).

The NLA stated that his of fice had distributed Amendment No. 71; however, there is no evidence of that document arriving on site in the manner that other changes are executed.

Corrective Action Taken and Results Achieved The NLA reissued Amendment No. 71 and it was received at Dresden on 2-07-83. Amendment No. 71 was discributed into Dresden Tech Specs on 2-09-83.

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. . . o Corrective Action Taken to Avoid Further Noncompliance

a. The NLA will follow-up on all Technical Specification changes issued if the transmittal sheets attached to such documents are not signed, and returned within 30 days to the NLA.

Corrective Action Taken to Avoid Further Noncompliance (Cont'd)

b. The corporate Quality Assurance Department will audit the accounting and follow-up system for Technical Specifications in their upcoming audit of the Nuclear Licensing Department.

c. The site Quality Assurance group audits for Tech Spec adherence periodically with the aim to review all sections of the Tech Spec within a three-year period. The site Quality Assurance group will include verification that the Tech Spec has all the proper amendments incorporated in future audits.

Date When Full Compliance Will Be-Achieved Follow-up program will be implemented by the Nuclear Licensing Department by May 15, 1983.

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