ML20212F749
| ML20212F749 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212F732 | List: |
| References | |
| 50-237-97-20, 50-249-97-20, NUDOCS 9711050078 | |
| Download: ML20212F749 (3) | |
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t NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50 237; 50 249 Dresden Station, Units 2 and 3 License Nos. DPR 19; DPR 25 As a result of an inspection conducted between September 1$ and October 2,1997, violations i
of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedere for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
1.
Technical Specification 6.8.A requireo, in part, that written procedures be established and implemented covering the activities recommended in Appendix A of Regulatorv Guide (RG) 1.32, Revision 2, February 197a. 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 Administrativo 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 writtr'1 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 d.ain valve be closed to prevent ornin 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 particulato and lodine 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 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 afternoon of September 18,1997, the inspectors observed the sample panel drain valve to be open prior to a chemistry technician derronstrating the process of collecting a reactor coolant sample from the panel, b.
On September 16,1997, during the performance of a Unit 3 reactor building vent particulate and lodine filter changeout, the sample pumps were switched and the sample pump valve lineup was not performed 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.
This is a Severity Level IV violation (Supplement IV).
ADOC 10 G
I 2.
Technical Specification 6.8,D.3 requires, in part, that a post accident sampling program bo established, implemented and maintained. The program shallinclude procedures for sampling and analysis.
Dresden Sample Building Procedure DSBP 1000 37, Revision 2,'HRSS Operability Program," provides the steps necessary to perform and document the required operability surveillances of the High Radiation Sample System (HRSS). The procedure requires that yearly grab samples be collected from the reactor water cleanup filter inlet and reactor recirculation loop B at the HRSS and the reactor sample panels, and that isotopic analyses be performed and compared to ensure that acceptanco criteria are met.
Contrary to the above, yearly surveillt.hces on the HRSS were not all completed as required. Specifically, in 1995 and 1990, Unit 2 reactor water grab samples were not collected, isotopically analyzed and compared from the cleanup filter inlet and reactor recirculation loop B at the HRSS and reactor sample panels.
This is a Severity Level 'V violation (supplement IV)
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required 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, U.S. Nuclear Regulatory Commission, Region ill,801 Warrenville Road, Lisle, Illinois 60532, and a copy to the NRC Resident inspector at the incility which is the subject of this Notice, within 30 days of the date of the latter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each i
violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the 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 conospondence adequately addresses the required response, if an edequate reply is not received within the time specified in this Notice, an order or a demand for information may be l
issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper thould not be taken. Where good cause is shown, consideration will be Diven to extending the response time.
Because your response will be placed in the NRC Public Document room (PDR), to the extent possible, it should not includo ar,y personal privacy, proprietary, or safeguards informaton so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identibes the informa?. ion that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mni specifically identify the portions of your response that you seek to have withheld and provide in l.
detail the bases for your claim of withholding (e.g. explain why the disclosure or information will l
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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 described in 10 CFR 73.21.
Dated at Lisle, Illinois this 30th day of October 1997 l
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