ML20129J256

Responds to NRC 850228 Ltr Re Violations Noted in Insp Repts 50-010/84-20,50-237/84-26 & 50-249/84-23.Corrective Actions: Action Item Records QP 16-51,QA Commitments & Open NRC Noncompliances Will Be Added to Commitment List

ML20129J256
Person / Time
Site:	Dresden
Issue date:	04/08/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9938N, NUDOCS 8506100044
Download: ML20129J256 (3)

Text

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$ o Commonwealth Edison one First National Plazn, Chicago, lihnois Address Reply to: Post Office Box 767 Chicago, lilinois 60690 April 8, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Units 1, 2 and 3 Response to Inspection Report Nos.

50-010/84-20, 50-237/84-26 & 50-249/84-23 NRC Docket Nos.50-010, 50-237 and 50-249 Reference (a): C. E. Norelius letter to Cordell Reed dated February 28, 1985.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs.

T. M. Tongue, S. Stasek and C. D. Anderson during the period of December 21, 1984 through February 15, 1985, of activities at Dresden Station.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.

If you have any further questions on this matter, please direct them to this office.

Very ruly yours, D. L. Farrar Director of Nuclear Licensing 1m cc: NRC Resident Inspector - Dresden Attachment 9938N 8506100044 850408 ADOCK 05000010

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ATTACHNENT A COMMONWEALTH EDISON CO WANY

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RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOWLIANCE The Commonwealth Edison Company Quality Assurance Manual Section 16 addresses corrective actions. Quality Procedure 16-51, Corrective Action for Operations - Corrective Action System, specifically addresses the mechanism available to CECO personnel to assure timely follow-up on important items such as audit deficiencies.

Contrary to the above, no formal mechanism was utilized to track the self-identified possible deficiency to ensure a timely review and resolution.

DISCUSSION In May 1983, CECO personnel identified a potential discrepancy involving the 10 CFR 50.59 evaluation format utilized in the CECO QA Manual. The potential discrepancy was eventually determined not to be a problem. Adequate procedural controls existed both at Station Nuclear Engineering Department and Dresden to identify potential Technical Specification changes required for plant modifications. Thus, no change was required to the CECO 10 CFR 50.59 review process.

An NRC Inspector in February 1985 inquired as to the resolution of this matter. Although no corrective action was required on CECO's part, a substantial period of time (21 months) has elapsed between identification of the potential discrepancy and the NRC follow-up with no CECO documented evaluation of the matter. This excess time to follow-up was considered a non-compliance to 10 CFR 50, Appendix B, Criterion XVI. During this time period several conversations were held between the station and SNED and site Quality Assurance listed this item as requiring follow-up but no written evaluation was produced.

CORRECTIVE ACTIONS TAKEN & RESLLTS ACHIEVED A review was performed by Dresden Station to determine if the event was an isolated one. No other similiar instances were identified and it is our belief that the corrective action noted below should preclude reocurrence.

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CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE Dresden will add to its existing commitnent list station generated

- Action Item Records (QP 16-51), QA commitments, open NRC non-compliances and open items requiring station followup. This list is presently being converted from a work processing based list to a computer based list to facilitate selective sorting on any of numerous topics or dates (e.g., NRC commitments, QA commitments, Action Item Records, due dates, etc.). By placing important commitments and followup required items on the computer, periodic updates and reviews for timely implementation should eliminate, the possibility of untimely responses. The present list is updated and distributed on a monthly basis.

DATE WHEN FULL COWLIANCE WILL BE ACHIEVED The commitment list is already in existence. Action Item Records (QP 16-51), Dresden QA commitments and Dresden NRC follow-up items (e.g.,

open non-compliances and open items) will be added to this list by June 1, 1985.

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9938N

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