ML18037A087

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
Issue date:	02/19/1993
From:	FARRAR D COMMONWEALTH EDISON CO.
To:	NRC
Shared Package
ML18037A086	List: ML18037A087
References
NUDOCS 9303240061
Download: ML18037A087 (14)

See also: IR 05000237/1992028

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 IV violations

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

ATI ACHMENT 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

ATI ACHMENT 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 follow established

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

'

ATl ACHMENT 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 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