ML20141G516

From kanterella
Jump to navigation Jump to search
Forwards Response to NRC Re Violations Noted in Insp Repts 50-010/97-06,50-237/97-06 & 50-249/97-06. Corrective Actions:Digital Voltmeter Was Removed from 24/48 Volt Dc Battery
ML20141G516
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/01/1997
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:97-0127, JSPLTR:97-127, NUDOCS 9707090145
Download: ML20141G516 (4)


Text

. _ .

Commonwealth Illison Company

  • Drewirn Generating Mation 7 6500 North Dresden Road Morri%, n. bO 450 Tei m sa> amo July 1,1997 JSPLTR: 97-0127 U. S. Nuclear Regulatog Commission ATTN: Document Control Desk Washington, D. C. 20555

Subject:

Dresden Nuclear Power Station Units 2 and 3 Reply to a Notice of Violation; Inspection Report 50-010; 237; 249/97006.

NRC Docket Numbers50-010. 50-237. and 50-249

Reference:

G. E. Grant letter to J. S. Perry, dated June 1,1997, transmitting NRC Inspection Report 50-010; 237; 249/97006 and Notice of Violation The purpose of this letter is to provide Comed's reply to the Notice of Violation transmitted in the referenced letter. Specifically, the violation involved the installation of a temporary alteration to the Unit 3 24/48 Vdc battery system without an approved procedure or engineering approved work request.

An investigation determined that the individuals involved in this event were not fully cognizant of the requirements of the Dresden Administrative Procedure (DAP) covering the installation of temporay alterations. Actions are being taken to ensure  ;

the personnel involved in this event along with other station personnel involved in the j installation of temporary alterations are aware of the requirements for instalhng ,

temporary alterations. l Accordingly, this letter contains the following new commitments:

  • Maintenance Department personnel will receive refresher training on the requirements of DAP 05-08, " Control of Temporary System Alterations."

e The Maintenance Departments will include training on DAP 05-08, " Control of Temporary System Alterations," in their continuing training programs.

The attachment to this letter provides Dresden's reply to the Notice of Violation along with corrective actions to preclude recurrence.

tI 9707090145 970701 g PDR ADOCK 05000010 /# '

G PDR llllll ll lllll l ll \

080050 A 1:nicom Company

USNRC Page 2 July 1,1997 i 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, I

f Ste hen Perry >

Site Vice President i Dresden Station i

Attachment  :

i cc: A. Bill Beach, Regional Administrator, Region III [

l W. J. Kropp, Branch Chief, Division of Reactor Projects, Region III j

, J. F. Stang, Project Manager, NRR (Unit 2/3)  !

l K. Riemer, Senior Resident Inspector, Dresden  !

Office of Nuclear Facility Safety - IDNS  ;

File: Numerical i l :- ,

r  :

l t l I l  !

1 i

1

)

- . .. . .- =_ .

l .

! ATTACHMENT i

RESPONSE TO NOTICE OF VIOLATION i NRC INSPECTION REPORT 50-010:237:249/97006-l l

VIOLATION: i l

Dresden Technical Specification 6.8.A required, in part, that written procedures shall be implemented covering the activities referenced in Appendix A of Regulatory Guide l (R.G.) 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2, l February 1978. Administrative procedures were referenced in R.G.1.33.

Dresden Administrative Procedure (DAP) 05-08, Revision 7, " Control of Temporary System Alterations," Section E.3.b.(1) allowed, in part, installation of test monitoring ;

and/or test equipment in accordance with an approved procedure or Engineering I 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 i

duration for break time andjob turn-over time)). Otherwise, additional controls for l temporary syste:n alterations were specified.

Contrary to the above, on March 16,1997, a digital voltmeter was installed on a l safety-related component (the 3 A 24/48 Vdc battery) without an approved procedure or engineering approved work request. The voltmeter was left installed and unattended, except for readings taken every two hours, until removal on March 28,1997. No additional temporaiy system alteration controls were l implemented.  !

REASON FOR VIOLATION:

I The individuals involved in this event were not fully cognizant of the requirements of Dresden Administrative Procedure (DAP) 05-08, " Control of Temporary System Alterations" The Maintenance Department installed the voltmeter and failed to recognize that DAP requirements were not being met. Training on this procedure is l not part of the department's annual training program.

l

O C'ORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The digital voltmeter was removed from the 24/48 Vdc battery. Additionally, it was verified that no other unauthorized temporary alterations were installed.

The individuals involved in this event were counseled on the importance of following DAP 05-08 requirements. They now understand the proper method for using temporary alterations.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:

The Electrical Maintenance Department was briefed on this event and DAP 05-08 requirements when temporarily connecting test equipment to plant systems and equipment.

Maintenance Department personnel will receive refresher training on the requirements of DAP 05-08, " Control of Temporag System Alterations." (NTS 2371009700603A)

The Maintenance Departments will include training on DAP 05-08, " Control of Temporary System Alterations," in their continuing training programs.

(NTS 2371009700603B).

DATE WHEN FULL COMPLIANCE WILL BE ACIIIEVED:

Full compliance was achieved on March 28,1997 when the unauthorized temporary alteration was removed.

l l

j l

\

l 1

l l