ML18037A087: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(4 intermediate revisions by the same user not shown)
Line 3: Line 3:
| issue date = 02/19/1993
| issue date = 02/19/1993
| title = Responds to Notice of Violations Noted in Insp Repts 50-237/92-28 & 50-249/92-28.Corective Actions:Identified Ground Has Cleared W/O Any Action by Station Personnel & Operations Personnel Were Counseled on Procedure Adherence
| title = Responds to Notice of Violations Noted in Insp Repts 50-237/92-28 & 50-249/92-28.Corective Actions:Identified Ground Has Cleared W/O Any Action by Station Personnel & Operations Personnel Were Counseled on Procedure Adherence
| author name = FARRAR D
| author name = Farrar D
| author affiliation = COMMONWEALTH EDISON CO.
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name =  
| addressee name =  
Line 15: Line 15:
| page count = 14
| page count = 14
}}
}}
See also: [[followed by::IR 05000237/1992028]]


=Text=
=Text=
{{#Wiki_filter:'Commonwealth
{{#Wiki_filter:'
Edison 1400 Opus Place Downers Grove, Illinois 60515 February 19, 1993 V.S.Nuclear Regulatory
Commonwealth Edison 1400 Opus Place Downers Grove, Illinois 60515 February 19, 1993 V.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention; Document Control Desk
Commission
 
Washington, D.C.20555 Attention;
==Subject:==
Document Control Desk Subject: Reference:
==Reference:==
Dresden Nuclear Power Station Units 2 and 3 Response to Notice of Violation Inspection
Dresden Nuclear Power Station Units 2 and 3
Report 50-237/92028;
 
50-249/92028
===Response===
NRC Docket Numbers 50-237 and 50-249 T.O.Martin letter to L.O.Delseorge, dated January 20, 1993, transmitting
to Notice of Violation Inspection Report 50-237/92028; 50-249/92028 NRC Docket Numbers 50-237 and 50-249 T.O. Martin letter to L.O. Delseorge, dated January 20, 1993, transmitting inspection Report 50-237/92028; 50-249/92028 Enclosed is Commonwealth Edison Company's (CECo) response to the Notice of Violation {NOV)which was transmitted with the referenced letter. The NOV cited two Severity Level IVviolations requiring a written response.
inspection
The response to these violations is provided in the attachment, lf your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at {708) 663-7285.
Report 50-237/92028;
Sincerely, c3.W
50-249/92028
~
Enclosed is Commonwealth
D. Farrar Nuclear Regulatory Services Manager Attachment cc:
Edison Company's (CECo)response to the Notice of Violation{NOV)which was transmitted
A. B. Davis, Regional Administrator - Region III J.
with the referenced
Stand, Project Manager - NRR M. N. Leach, Senior Resident Inspector - Dresden 930324006i 9303i8 PDR ADQCK 05000237 8
letter.The NOV cited two Severity Level IV violations
PDR ZNLD/2112/13 F<B S g 199~
requiring a written response.The response to these violations
 
is provided in the attachment, lf your staff has any questions or comments concerning
ArrACHMENT RESPONSE TO NOTlCE OF VIOLATlON NRC INSPECTlON REPORT 50-237/92028, 50-249/92028
this letter, please refer them to Denise Saccomando, Compliance
Engineer at{708)663-7285.Sincerely, c3.W~D.Farrar Nuclear Regulatory
Services Manager Attachment
cc: A.B.Davis, Regional Administrator
-Region III J.Stand, Project Manager-NRR M.N.Leach, Senior Resident Inspector-Dresden 930324006i
9303i8 PDR ADQCK 05000237 8 PDR ZNLD/2112/13
F<B S g 199~  
ArrACHMENT
RESPONSE TO NOTlCE OF VIOLATlON NRC INSPECTlON
REPORT 50-237/92028, 50-249/92028
~gllj~2~72
~gllj~2~72
'I 249%2I!2JULll
'I 249%2I!2JULll 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by document instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
10 CFR 50, Appendix B, Criterion V, requires that activities
k Procedure DOP 6900-07, Revision 9, "125Vdc Ground Detections", required that the procedure be immediately performed at DC system grounds above 60Vdc, and a B1 Work Request be submitted once the ground was located.
affecting quality shall be prescribed
Furthermore, the procedure required, at grounds above 115Vdc, initiation of a 14
by document instructions, procedures, or drawings, of a type appropriate
'ay time clock (administrative Limiting Condition for Operation {LCO))to locate and remove the ground and preparation of a Justification for Continued Operation (JCO) if the ground could not be located or isolated within 14 days.
to the circumstances
Procedure DAP 07-05, Revision 9, "Operating Logs and Records", Paragraph B.5, required that when a LCO entry occurs, the event must be logged in the LCO Log.
and shall be accomplished
Contrary to the above:
in accordance
1.
with these instructions, procedures, or drawings.k Procedure DOP 6900-07, Revision 9,"125Vdc Ground Detections", required that the procedure be immediately
On Seotember 26, 1992, when a 125Vdc system ground was present in Unit 3, the Licensee failed to initiate actions to locate and remove the ground.
performed at DC system grounds above 60Vdc, and a B1 Work Request be submitted once the ground was located.Furthermore, the procedure required, at grounds above 115Vdc, initiation
In addition, the Licensee failed to initiate an administrative LCO and document the event in the LCO Log.
of a 14'ay time clock (administrative
2.
Limiting Condition for Operation{LCO))to locate and remove the ground and preparation
On November 3, 1992, when 125Vdc grounds were present in both Units 2 and 3, an administrative LCO was initiated and logged in the LCO Log for Unit 3 only. The Licensee could not provide evidence that actions were taken to identify and remove the grounds in either unit.
of a Justification
3.
for Continued Operation (JCO)if the ground could not be located or isolated within 14 days.Procedure DAP 07-05, Revision 9,"Operating
On November 12, 1992, when a 125Vdc ground was present in Unit 3, the licensee failed to initiate actions to locate and remove the ground.
Logs and Records", Paragraph B.5, required that when a LCO entry occurs, the event must be logged in the LCO Log.Contrary to the above: 1.On Seotember 26, 1992, when a 125Vdc system ground was present in Unit 3, the Licensee failed to initiate actions to locate and remove the ground.In addition, the Licensee failed to initiate an administrative
ZNLD/2112/14
LCO and document the event in the LCO Log.2.On November 3, 1992, when 125Vdc grounds were present in both Units 2 and 3, an administrative
 
LCO was initiated and logged in the LCO Log for Unit 3 only.The Licensee could not provide evidence that actions were taken to identify and remove the grounds in either unit.3.On November 12, 1992, when a 125Vdc ground was present in Unit 3, the licensee failed to initiate actions to locate and remove the ground.ZNLD/2112/14  
ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92028, 50-249/92028 NF T E VIO3A~QH; Dresden Station concurs with item 1 of the violation as written. Dresden Station procedures provide clear guidance on required actions upon identification of dc grounds.
It is clear that personnel failed to meet management's expectations.
ATI ACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION
Investigation of the events indicated that personnel failed to follow established station procedures.
REPORT 50-237/92028, 50-249/92028
With the issuance of the violation Dresden Station initiated an investigation which revealed that station did take appropriate actions on November 3 and November 12th In regard to the November 3, 1992, ground involving Unit 3 (example 2), action was taken to identify and remove the ground. The Unit 3 Log entry states that a ground check was performed at 1857 tlours for a -155V ground on the 125Ydc system.
NF T E VIO3A~QH;Dresden Station concurs with item 1 of the violation as written.Dresden Station procedures
The ground was identified on bus 3A-2 circuit number 16 and Work Request D-13836 was written for investigation and repair of the circuit. Electrical Maintenance identified and replaced a broken terminal block. Further testing revealed that the auxiliary transformer 31 fire protection circuit was grounded.
provide clear guidance on required actions upon identification
Work Request 15077 was written to implement repairs.
of dc grounds.It is clear that personnel failed to meet management's
In regard to the November 3, 1992, ground involving Unit 2 (example 2), action was taken to identify and remove the ground.
expectations.
Work Request D-13806 was written for investigation of the ground; however, the ground cleared before Electrical Maintenance personnel could begin work, The Unit 2 ground was not documented in the LCO Log since it never reached the required 115 volts, as specified in DOP 6900-06, 125Vdc Ground Detection".
Investigation
ln regard to the November 12, 1992, ground involvinq Unit 3 (example 3), action was taken to locate and remove the ground. The Unit Operator logged the -115Y ground, the ground checking, and the LCO in the Unit Log Book. The ground was located on bus 3A-2. No work request was written since Work Requests D-13836 and D-15077 were already open to investigate the ground on bus 3A-2. On November 16, 1992, Work Request D-14129 was written to document a -90V ground on the Unit 3 125Vdc system.
of the events indicated that personnel failed to follow established
Electrical Maintenance personnel investiaated and resolved the ground under work requests D-13836 and D-1 5077. The ground was monitored until January 2, 1993, and never returned.
station procedures.
D For examole 1, the identified ground has cleared without any action by station personnel.
With the issuance of the violation Dresden Station initiated an investigation
Operations personnel involved in the September 26, 1992, event were counseled by Operations's senior management with regards to the importance of procedure adherence.
which revealed that station did take appropriate
ZNLD/2112/15
actions on November 3 and November 12th In regard to the November 3, 1992, ground involving Unit 3 (example 2), action was taken to identify and remove the ground.The Unit 3 Log entry states that a ground check was performed at 1857 tlours for a-155V ground on the 125Ydc system.The ground was identified
 
on bus 3A-2 circuit number 16 and Work Request D-13836 was written for investigation
ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION REPORT 50-237/92028, 50-249/92028 E TIVE E
and repair of the circuit.Electrical
K T
Maintenance
D E
identified
VI The Operations Manager has discussed failure to followestablished procedures with the Shift Engineers.
and replaced a broken terminal block.Further testing revealed that the auxiliary transformer
Beginning on February 10, 1993, the Shift Engineers tailgated with their respective crews the importance of following procedures.
31 fire protection
They were reminded that adherence to procedures is a basic expectation and is required to ensure safe, reliable operations.
circuit was grounded.Work Request 15077 was written to implement repairs.In regard to the November 3, 1992, ground involving Unit 2 (example 2), action was taken to identify and remove the ground.Work Request D-13806 was written for investigation
DATE F
of the ground;however, the ground cleared before Electrical
LL MP AN E Full compliance was achieved when the individual was counseled.
Maintenance
ZNLD/2112/16
personnel could begin work, The Unit 2 ground was not documented
 
in the LCO Log since it never reached the required 115 volts, as specified in DOP 6900-06, 125Vdc Ground Detection".
ATlACHMENT RESPONSE TO NOTICE OF YIOLAllON NRC INSPECTION REPORT 50-237/92028, 50-249/92028 RE 10CFR50, Appendix B, Criterion XVI,requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment; and nonconformance are promptly identified and corrected.
ln regard to the November 12, 1992, ground involvinq Unit 3 (example 3), action was taken to locate and remove the ground.The Unit Operator logged the-115Y ground, the ground checking, and the LCO in the Unit Log Book.The ground was located on bus 3A-2.No work request was written since Work Requests D-13836 and D-15077 were already open to investigate
Contrary to the above, in February and April 1992, the licensee identified oversized fuses in various safety related circuits including the Emergency Diesel Generator exciters and Low Pressure Coolant circuitry. As of December,
the ground on bus 3A-2.On November 16, 1992, Work Request D-14129 was written to document a-90V ground on the Unit 3 125Vdc system.Electrical
: 1992, this condition adverse to quality had not been corrected.
Maintenance
F RT EVI The fuse verification program identified fuses that were inadequately sized.
personnel investiaated
These discrepancies were noted on Technical Problem Reports (TPRs) and forwarded to Corporate Engineering for resolution.
and resolved the ground under work requests D-13836 and D-1 5077.The ground was monitored until January 2, 1993, and never returned.D For examole 1, the identified
The Engineering evaluation of the fuse in the Unit 2 Low Pressure Coolant injection (LPCI) circuitry states that, "the currently installed 20A fuse, Bussmann Type MIN, in Panel 902-32, provides adequate protection for the circuit," and that the "existing installed 20A fuse protects the circuit." The evaluation also indicated that the fuse may not coordinate with the upstream 30A circuit breaker.
ground has cleared without any action by station personnel.
No safety significance or operability concerns were attributed to this potential lack of fuse coordination.
Operations
Engineering did, however, recommend replacement of the fuse. When the evaluation arrived at Dresden, the fuse coordinator prioritized replacement of the LPCI fuse commensurate with its lack of safety significance and operability concerns.
personnel involved in the September 26, 1992, event were counseled by Operations's
No specific due date was assigned for the fuse replacement.
senior management
Engineering's operability assessment of the fuses in the Unit 2 diesel generator excitation cabinets recommended no compensatory actions to ensure operability (i.e. the system is operable with the currently installed fuses).
with regards to the importance
Two 30A fuses and one 40A fuse were installed in the Unit 2 excitation cabinet, instead of the 25A fuses presented in the system drawing. The evaluation again included a recommendation to replace the subject fuses.
of procedure adherence.
It stated that during an abnormal fault condition, the fuses may not protect the primary windings of control transformers.
ZNLD/2112/15  
The recommendation was based on guidance from GE Bulletin GET-3039G, "How to Select an Apply Power Fuses, Types EJ-1 and EJ0-1." An Action Due Date forfuse replacement of February 28, 1993, was assigned by Engineering.
The reasoning behind the assigned due date was based upon the engineering judgment that any expected fault condition that a 26A fuse could protect against would also be protected by a 30A or 40A fuse.
ATI ACHMENT RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION
ZNLD/2112/17
REPORT 50-237/92028, 50-249/92028
 
E TIVE E K T D E VI The Operations
ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92028, 50-249/92028 Since identification of the diesel fuse discrepancy in April, 1992, Dresden Station has taken numerous actions to address Engineering's fuse replacement recommendation.
Manager has discussed failure to follow established
Most significant of these actions was a more detailed engineering calculation that supported continued operation with the currently installed diesel generator fuses.
procedures
This calculation states that "GE 25A, 30A, and 40A fuses, Type EJ0-1, willclear the fault before any damage is done to the primary windings of the transformer or the circuit." This evaluation confirmed Engineering's previous operability assessment and the engineering judgment of the fuse coord nator.
with the Shift Engineers.
Dresden Station believes that the LPCI fuses were not replaced prior to the inspection period because no safety or operability concern exists with the currently installed fuse.
Beginning on February 10, 1993, the Shift Engineers tailgated with their respective
For the diesel generator fuses, numerous actions were taken to replace and procure the fuses and fuse clips prior to the assigned Action Due Date of February 28, 1993.
crews the importance
Dresden does acknowledge, however, that Engineering's recommendations should have been dispositioned in a more timely manner.
of following procedures.
Dresden identified the need for additional administrative controls for fuses identified for replacement under the fuse upgrade program.
They were reminded that adherence to procedures
Examination of the current Dresden Administrative Procedure (DAP) 11-27, "Control and Maintenance of Fuses and the Fuse List," indicated that it did not provide direction for dispositioning of TPRs issued prior to October, 1992.
is a basic expectation
RR TIVE P
and is required to ensure safe, reliable operations.
T E
DATE F LL MP AN E Full compliance
D E
was achieved when the individual
V 0 The Unit 2 LPCl fuse was changed out on February 19, 1993. The Unit 3 LPCI system has also been inspecte8.
was counseled.
The Unit 3 LPGI fuse has the correct amperage, but is a MIN-type fuse rather than the recommended KTN-type fuse.
ZNLD/2112/16  
While no operability concerns have been raised, Dresden willstill replace the Unit 3 LPCI fuse the next time LPCI is out-of-service.
'
For good engineering practice, the one 40A diesel generator fuse on Unit 2 willbe replaced with a 30A fuse by April30, 1993. A Document Change Request was submitted on February 19, 1993 to update the amperage on all related drawings to 30 amps.
ATl ACHMENT RESPONSE TO NOTICE OF YIOLAllON NRC INSPECTION
To augment administrative controls until DAP 11-27 is revised, the Modification Implementation Supervisor has issued a memorandum to the fuse coordinator incorporating direction for fuse replacements identified in Technical Problem Reports issued prior to October, 1992.
REPORT 50-237/92028, 50-249/92028
ZNLD/2112/1 8
RE 10CFR50, Appendix B, Criterion XVI, requires that measures shall be established
 
to assure that conditions
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION REPORT 50-237/92028, 50-249/92028 RECTIYE TEP KE T
adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment;
V ID ER DAP 11-27, will be revised by March 31, 1993, to incorporate the interim directions described in the above memorandum.
and nonconformance
DTE F
are promptly identified
LL PLIN E Full compliance was achieved with the issuance a memorandum to the fuse coordinator incorporating direction for fuse replacements identified in Technical Problem Reports issued prior to October, 1992.
and corrected.
ZNLD/2112/3 9}}
Contrary to the above, in February and April 1992, the licensee identified
oversized fuses in various safety related circuits including the Emergency Diesel Generator exciters and Low Pressure Coolant circuitry.
As of December, 1992, this condition adverse to quality had not been corrected.
F RT EVI The fuse verification
program identified
fuses that were inadequately
sized.These discrepancies
were noted on Technical Problem Reports (TPRs)and forwarded to Corporate Engineering
for resolution.
The Engineering
evaluation
of the fuse in the Unit 2 Low Pressure Coolant injection (LPCI)circuitry states that,"the currently installed 20A fuse, Bussmann Type MIN, in Panel 902-32, provides adequate protection
for the circuit," and that the"existing installed 20A fuse protects the circuit." The evaluation
also indicated that the fuse may not coordinate
with the upstream 30A circuit breaker.No safety significance
or operability
concerns were attributed
to this potential lack of fuse coordination.
Engineering
did, however, recommend replacement
of the fuse.When the evaluation
arrived at Dresden, the fuse coordinator
prioritized
replacement
of the LPCI fuse commensurate
with its lack of safety significance
and operability
concerns.No specific due date was assigned for the fuse replacement.
Engineering's
operability
assessment
of the fuses in the Unit 2 diesel generator excitation
cabinets recommended
no compensatory
actions to ensure operability (i.e.the system is operable with the currently installed fuses).Two 30A fuses and one 40A fuse were installed in the Unit 2 excitation
cabinet, instead of the 25A fuses presented in the system drawing.The evaluation
again included a recommendation
to replace the subject fuses.It stated that during an abnormal fault condition, the fuses may not protect the primary windings of control transformers.
The recommendation
was based on guidance from GE Bulletin GET-3039G,"How to Select an Apply Power Fuses, Types EJ-1 and EJ0-1." An Action Due Date for fuse replacement
of February 28, 1993, was assigned by Engineering.
The reasoning behind the assigned due date was based upon the engineering
judgment that any expected fault condition that a 26A fuse could protect against would also be protected by a 30A or 40A fuse.ZNLD/2112/17  
'
ATI ACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION
REPORT 50-237/92028, 50-249/92028
Since identification
of the diesel fuse discrepancy
in April, 1992, Dresden Station has taken numerous actions to address Engineering's
fuse replacement
recommendation.
Most significant
of these actions was a more detailed engineering
calculation
that supported continued operation with the currently installed diesel generator fuses.This calculation
states that"GE 25A, 30A, and 40A fuses, Type EJ0-1, will clear the fault before any damage is done to the primary windings of the transformer
or the circuit." This evaluation
confirmed Engineering's
previous operability
assessment
and the engineering
judgment of the fuse coord nator.Dresden Station believes that the LPCI fuses were not replaced prior to the inspection
period because no safety or operability
concern exists with the currently installed fuse.For the diesel generator fuses, numerous actions were taken to replace and procure the fuses and fuse clips prior to the assigned Action Due Date of February 28, 1993.Dresden does acknowledge, however, that Engineering's
recommendations
should have been dispositioned
in a more timely manner.Dresden identified
the need for additional
administrative
controls for fuses identified
for replacement
under the fuse upgrade program.Examination
of the current Dresden Administrative
Procedure (DAP)11-27,"Control and Maintenance
of Fuses and the Fuse List," indicated that it did not provide direction for dispositioning
of TPRs issued prior to October, 1992.RR TIVE P T E D E V 0 The Unit 2 LPCl fuse was changed out on February 19, 1993.The Unit 3 LPCI system has also been inspecte8.
The Unit 3 LPGI fuse has the correct amperage, but is a MIN-type fuse rather than the recommended
KTN-type fuse.While no operability
concerns have been raised, Dresden will still replace the Unit 3 LPCI fuse the next time LPCI is out-of-service.
For good engineering
practice, the one 40A diesel generator fuse on Unit 2 will be replaced with a 30A fuse by April 30, 1993.A Document Change Request was submitted on February 19, 1993 to update the amperage on all related drawings to 30 amps.To augment administrative
controls until DAP 11-27 is revised, the Modification
Implementation
Supervisor
has issued a memorandum
to the fuse coordinator
incorporating
direction for fuse replacements
identified
in Technical Problem Reports issued prior to October, 1992.ZNLD/2112/1
8  
'
ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION
REPORT 50-237/92028, 50-249/92028
RECTIYE TEP KE T V ID ER DAP 11-27, will be revised by March 31, 1993, to incorporate
the interim directions
described in the above memorandum.
DTE F LL PLIN E Full compliance
was achieved with the issuance a memorandum
to the fuse coordinator
incorporating
direction for fuse replacements
identified
in Technical Problem Reports issued prior to October, 1992.ZNLD/2112/3
9
}}

Latest revision as of 01:28, 7 January 2025

Responds to Notice of Violations Noted in Insp Repts 50-237/92-28 & 50-249/92-28.Corective Actions:Identified Ground Has Cleared W/O Any Action by Station Personnel & Operations Personnel Were Counseled on Procedure Adherence
ML18037A087
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 02/19/1993
From: Farrar D
COMMONWEALTH EDISON CO.
To:
NRC
Shared Package
ML18037A086 List:
References
NUDOCS 9303240061
Download: ML18037A087 (14)
v • d • e


Text

'

Commonwealth Edison 1400 Opus Place Downers Grove, Illinois 60515 February 19, 1993 V.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention; Document Control Desk

Subject:

Reference:

Dresden Nuclear Power Station Units 2 and 3

Response

to Notice of Violation Inspection Report 50-237/92028; 50-249/92028 NRC Docket Numbers 50-237 and 50-249 T.O. Martin letter to L.O. Delseorge, dated January 20, 1993, transmitting inspection Report 50-237/92028; 50-249/92028 Enclosed is Commonwealth Edison Company's (CECo) response to the Notice of Violation {NOV)which was transmitted with the referenced letter. The NOV cited two Severity Level IVviolations requiring a written response.

The response to these violations is provided in the attachment, lf your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at {708) 663-7285.

Sincerely, c3.W

~

D. Farrar Nuclear Regulatory Services Manager Attachment cc:

A. B. Davis, Regional Administrator - Region III J.

Stand, Project Manager - NRR M. N. Leach, Senior Resident Inspector - Dresden 930324006i 9303i8 PDR ADQCK 05000237 8

PDR ZNLD/2112/13 F<B S g 199~

ArrACHMENT RESPONSE TO NOTlCE OF VIOLATlON NRC INSPECTlON REPORT 50-237/92028, 50-249/92028

~gllj~2~72

'I 249%2I!2JULll 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by document instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

k Procedure DOP 6900-07, Revision 9, "125Vdc Ground Detections", required that the procedure be immediately performed at DC system grounds above 60Vdc, and a B1 Work Request be submitted once the ground was located.

Furthermore, the procedure required, at grounds above 115Vdc, initiation of a 14

'ay time clock (administrative Limiting Condition for Operation {LCO))to locate and remove the ground and preparation of a Justification for Continued Operation (JCO) if the ground could not be located or isolated within 14 days.

Procedure DAP 07-05, Revision 9, "Operating Logs and Records", Paragraph B.5, required that when a LCO entry occurs, the event must be logged in the LCO Log.

Contrary to the above:

1.

On Seotember 26, 1992, when a 125Vdc system ground was present in Unit 3, the Licensee failed to initiate actions to locate and remove the ground.

In addition, the Licensee failed to initiate an administrative LCO and document the event in the LCO Log.

2.

On November 3, 1992, when 125Vdc grounds were present in both Units 2 and 3, an administrative LCO was initiated and logged in the LCO Log for Unit 3 only. The Licensee could not provide evidence that actions were taken to identify and remove the grounds in either unit.

3.

On November 12, 1992, when a 125Vdc ground was present in Unit 3, the licensee failed to initiate actions to locate and remove the ground.

ZNLD/2112/14

ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92028, 50-249/92028 NF T E VIO3A~QH; Dresden Station concurs with item 1 of the violation as written. Dresden Station procedures provide clear guidance on required actions upon identification of dc grounds.

It is clear that personnel failed to meet management's expectations.

Investigation of the events indicated that personnel failed to follow established station procedures.

With the issuance of the violation Dresden Station initiated an investigation which revealed that station did take appropriate actions on November 3 and November 12th In regard to the November 3, 1992, ground involving Unit 3 (example 2), action was taken to identify and remove the ground. The Unit 3 Log entry states that a ground check was performed at 1857 tlours for a -155V ground on the 125Ydc system.

The ground was identified on bus 3A-2 circuit number 16 and Work Request D-13836 was written for investigation and repair of the circuit. Electrical Maintenance identified and replaced a broken terminal block. Further testing revealed that the auxiliary transformer 31 fire protection circuit was grounded.

Work Request 15077 was written to implement repairs.

In regard to the November 3, 1992, ground involving Unit 2 (example 2), action was taken to identify and remove the ground.

Work Request D-13806 was written for investigation of the ground; however, the ground cleared before Electrical Maintenance personnel could begin work, The Unit 2 ground was not documented in the LCO Log since it never reached the required 115 volts, as specified in DOP 6900-06, 125Vdc Ground Detection".

ln regard to the November 12, 1992, ground involvinq Unit 3 (example 3), action was taken to locate and remove the ground. The Unit Operator logged the -115Y ground, the ground checking, and the LCO in the Unit Log Book. The ground was located on bus 3A-2. No work request was written since Work Requests D-13836 and D-15077 were already open to investigate the ground on bus 3A-2. On November 16, 1992, Work Request D-14129 was written to document a -90V ground on the Unit 3 125Vdc system.

Electrical Maintenance personnel investiaated and resolved the ground under work requests D-13836 and D-1 5077. The ground was monitored until January 2, 1993, and never returned.

D For examole 1, the identified ground has cleared without any action by station personnel.

Operations personnel involved in the September 26, 1992, event were counseled by Operations's senior management with regards to the importance of procedure adherence.

ZNLD/2112/15

ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION REPORT 50-237/92028, 50-249/92028 E TIVE E

K T

D E

VI The Operations Manager has discussed failure to followestablished procedures with the Shift Engineers.

Beginning on February 10, 1993, the Shift Engineers tailgated with their respective crews the importance of following procedures.

They were reminded that adherence to procedures is a basic expectation and is required to ensure safe, reliable operations.

DATE F

LL MP AN E Full compliance was achieved when the individual was counseled.

ZNLD/2112/16

ATlACHMENT RESPONSE TO NOTICE OF YIOLAllON NRC INSPECTION REPORT 50-237/92028, 50-249/92028 RE 10CFR50, Appendix B, Criterion XVI,requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment; and nonconformance are promptly identified and corrected.

Contrary to the above, in February and April 1992, the licensee identified oversized fuses in various safety related circuits including the Emergency Diesel Generator exciters and Low Pressure Coolant circuitry. As of December,

1992, this condition adverse to quality had not been corrected.

F RT EVI The fuse verification program identified fuses that were inadequately sized.

These discrepancies were noted on Technical Problem Reports (TPRs) and forwarded to Corporate Engineering for resolution.

The Engineering evaluation of the fuse in the Unit 2 Low Pressure Coolant injection (LPCI) circuitry states that, "the currently installed 20A fuse, Bussmann Type MIN, in Panel 902-32, provides adequate protection for the circuit," and that the "existing installed 20A fuse protects the circuit." The evaluation also indicated that the fuse may not coordinate with the upstream 30A circuit breaker.

No safety significance or operability concerns were attributed to this potential lack of fuse coordination.

Engineering did, however, recommend replacement of the fuse. When the evaluation arrived at Dresden, the fuse coordinator prioritized replacement of the LPCI fuse commensurate with its lack of safety significance and operability concerns.

No specific due date was assigned for the fuse replacement.

Engineering's operability assessment of the fuses in the Unit 2 diesel generator excitation cabinets recommended no compensatory actions to ensure operability (i.e. the system is operable with the currently installed fuses).

Two 30A fuses and one 40A fuse were installed in the Unit 2 excitation cabinet, instead of the 25A fuses presented in the system drawing. The evaluation again included a recommendation to replace the subject fuses.

It stated that during an abnormal fault condition, the fuses may not protect the primary windings of control transformers.

The recommendation was based on guidance from GE Bulletin GET-3039G, "How to Select an Apply Power Fuses, Types EJ-1 and EJ0-1." An Action Due Date forfuse replacement of February 28, 1993, was assigned by Engineering.

The reasoning behind the assigned due date was based upon the engineering judgment that any expected fault condition that a 26A fuse could protect against would also be protected by a 30A or 40A fuse.

ZNLD/2112/17

ATIACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-237/92028, 50-249/92028 Since identification of the diesel fuse discrepancy in April, 1992, Dresden Station has taken numerous actions to address Engineering's fuse replacement recommendation.

Most significant of these actions was a more detailed engineering calculation that supported continued operation with the currently installed diesel generator fuses.

This calculation states that "GE 25A, 30A, and 40A fuses, Type EJ0-1, willclear the fault before any damage is done to the primary windings of the transformer or the circuit." This evaluation confirmed Engineering's previous operability assessment and the engineering judgment of the fuse coord nator.

Dresden Station believes that the LPCI fuses were not replaced prior to the inspection period because no safety or operability concern exists with the currently installed fuse.

For the diesel generator fuses, numerous actions were taken to replace and procure the fuses and fuse clips prior to the assigned Action Due Date of February 28, 1993.

Dresden does acknowledge, however, that Engineering's recommendations should have been dispositioned in a more timely manner.

Dresden identified the need for additional administrative controls for fuses identified for replacement under the fuse upgrade program.

Examination of the current Dresden Administrative Procedure (DAP) 11-27, "Control and Maintenance of Fuses and the Fuse List," indicated that it did not provide direction for dispositioning of TPRs issued prior to October, 1992.

RR TIVE P

T E

D E

V 0 The Unit 2 LPCl fuse was changed out on February 19, 1993. The Unit 3 LPCI system has also been inspecte8.

The Unit 3 LPGI fuse has the correct amperage, but is a MIN-type fuse rather than the recommended KTN-type fuse.

While no operability concerns have been raised, Dresden willstill replace the Unit 3 LPCI fuse the next time LPCI is out-of-service.

For good engineering practice, the one 40A diesel generator fuse on Unit 2 willbe replaced with a 30A fuse by April30, 1993. A Document Change Request was submitted on February 19, 1993 to update the amperage on all related drawings to 30 amps.

To augment administrative controls until DAP 11-27 is revised, the Modification Implementation Supervisor has issued a memorandum to the fuse coordinator incorporating direction for fuse replacements identified in Technical Problem Reports issued prior to October, 1992.

ZNLD/2112/1 8

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRG INSPECTION REPORT 50-237/92028, 50-249/92028 RECTIYE TEP KE T

V ID ER DAP 11-27, will be revised by March 31, 1993, to incorporate the interim directions described in the above memorandum.

DTE F

LL PLIN E Full compliance was achieved with the issuance a memorandum to the fuse coordinator incorporating direction for fuse replacements identified in Technical Problem Reports issued prior to October, 1992.

ZNLD/2112/3 9

Retrieved from "https://kanterella.com/w/index.php?title=ML18037A087&oldid=5030662"