ML20216E518
| ML20216E518 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/05/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-010-97-06, 50-10-97-6, 50-237-97-06, 50-237-97-6, 50-249-97-06, 50-249-97-6, JSPLTR:-97-0154, JSPLTR:-97-154, NUDOCS 9709100219 | |
| Download: ML20216E518 (4) | |
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Conimonnahh bleon Onnpany o-Drosten Generating Station
. Okm Mnh Drewlen Road Morrn,11. 60 60 Teisis m u no JSPLTR: 97-0154 September 5,1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
Subject:
Dresden Nuclear Power Station Units 2 and 3 Reply to Request for Additional Information Relating to Notice of Violation Response:
Inspection Report 50-010; 237; 249/97006 NRC Docket Numbers50-010. 50-237. and 50 249
Reference:
(1) J. S, Perry letter to USNRC dated July 1,1997 transmitting response to Notice of Violation for inspection Repon 50-010; 237; 249/97006 l
(2) G. Grant letter to J. S. Perry dated July 31,1997 requesting additional information for Notice of Violation Response for Inspection Repon l
50-010;237;249/97006 i
The purpose of this letter is to provide Comed's reply to the request for additional information associated with the Notice of Violation response transmitted in the reference (1) Additional information was requested on the extent of our investigation concerning administrative controls of our Temporary Alteration Program and the scope of our verification that no other temporary alterations were installed. The attachment contains the requested information.
Subsequent to the submittal of our response in Reference (1), Dresden's Site Quality and Safety Assessment Department (Q&SA) conducted an assessment of the Temporary Alteration Process. The assessment was conducted during the period of July 15-17,1997.
The purpose of the assessment was to evaluate the accuracy of the Performance Indicator for Temporary Alterations. Dresden has developed Performance Indicators as a tool to assist the station in tracking performance improvement. The number of temporary alterations instelled in the plant is one of those performance indicators. The assessment j g;f was to determine if the indicator accurately reflected the number of temporary alterations jp found in the plant. The results of this assessment have been incorporated into our response.
If 9709100219 970905 PDR ADOCK 05000010 0
PDR k,
A tinicom Gunpany
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7 JSPLTR: 97-0154 Page 2 -
September 5,1997 Additionally, a Nuclear Station Work Procedure (NSWP A-21)" Temporary Modifications,"is being developed to enhance the Temporary Alteration Program.
This letter contains no new commitments, 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, J. Stephen Perry Site Vice President Dresden Station Attachment cc:
A. Bill Beach, Regional Administrator, Region 111 W. J. Kropp, Branch Chief, Division of Reactor Projects, Region 111 J. F, Stang, Project Manager, NRR (Unit 2/3) a K. Riemer, Senior Resident Inspector, Dresden Office of Nuclear Facility Safety - IDNS File: Numerical I
I ATTACllM ENT Question: Did your investigation review the administrative controls for temporary alterations delineated in DAP 05-08 to ensure that they were adequate and did not contribute to the voltmeter being le0 unattended on the 24/48 battery?
Response: Dresden Administrative Procedure (DAP 05 08)" Control of Temporary System Alterations," was reviewed during the investigation and found to be adequate. The requirements are clearly delineated in DAP 05-08. Speci6cally, it states that test equipment may be install d during troubleshooting activities e
without classifying it as a temporary alteration provided several actions are implemented as stated below:
"The following arc examples of Temporary Alterations that are excluded i
from this procedure, if documented and controlled by other procedures l
or engineering approved work packages:
l l
- a. The lifling of a wire, removal of a circuit board, installing of test 1
monitoring and/or test equipment to perform troubleshooting or testing in accordance with an approved procedure or j
Engineering approved work package, provided the troubleshooting or test is performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, test monitoring and/or test equipment must be attended (except short duration for break time and job turn-over time), the system is returned to normal upon completion, the test is controlled by a procedure or work package, and the Operating Shill has been notined that the alteration has been performed."
Dresden clearly failed to follow this procedure during the troubleshooting of the 24/48 Vdc battery by not performing the troubleshooting within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and by not attending the installed temporary alteration as required.
Subsequent to the submittal of our response in Reference (1), Dresden's Site Quality and Safety Assessment Department (Q&SA) conducted an assessment of the Temporary Alteration Process. This assessment did identify denciencies in DAP 05-08 and that DAP 05-08 was in need of revision. A Corrective Action Record (CAR 12-97-063) was issued which documents the Q&SA fmdings. In summary, the CAR identi6ed inconsistencies between DAP 05-08 and the Corporate Desk Top Instruction. Exemptions are allowed by DAP 05-08 which are not allowed by the Desk Top instruction and there is no provisions to track Temp. Alts. long term which are installed within out-of-service boundaries. Additionally, DAP 05-08 Temp. Alt. Logs were identined as being of poor quality and is a configuration control Page1of2 J
challenge to the operators. The Station has taken interim measures to correct the Q&SA fmdings. Implementation of the NSWP-A-21 will address the long term Ox.
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DAP 05-08 is in the process of being replaced by a Nuclear Station Work l
Procedure. This procedure NSWP-A 21 " Temporary Modificuions" is l
currently scheduled to be deployed in October 1997.
Question: What was the scope of your verification that no other unauthorized temporary alterations were installed (limit to 24/48 Vdc battery, electrical discipline, plant wide, etc.)?
j Response: The primary scope ofour veri 6 cation was the 24/48 Vdc battery. No additional unauthorized temporary alterations were identified on the 24/48 Vdc battery. Additionally, the Electrical Superintendent performed a limited plant tour looking for unauthorized temporary alterations. No additional unauthorized temporary modi 6 cations were identined during this tour.
The Q&SA assessment focused on whether the number of temporary alterations listed in a performance indicator re6ect the actual number of temporary alterations being tracked by the statior. This assessment was primarily an assessment of documentation accuracy. During this assessment no current examples were identined of temporary alterations not being included in the performance indicator.
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