ML18037A084
| ML18037A084 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/19/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302250251 | |
| Download: ML18037A084 (16) | |
See also: IR 05000237/1992028
Text
.ACCELERATED
DOCUMENT DISTRIBUTION
SYSTEM REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)CESSION NBR:9302250251
DOC.DATE: 93/02/19 NOTARIZED:
NO DOCKET¹CIL:50-237
Dresden Nuclear Power Station, Unit 2, Commonwealth
E 05000237 50-24/Dresden.Nuclear Power Station, Unit 3, Commonwealth
E 05000249 AUTH.NAME AUTHOR AFFILIATION
FARRAR,DE Commonwealth
Edison Co.RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC ltr re violations
noted in insp rept 50-237/92-28
6 50-249/92-28.Corrective
actions:Unit
2 LPCI fuse changed out on 930219.W/930219
ltr.'I DISTRIBUTION
CODE: IE01D COPIES RECEIVED:LTR
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES:License
Exp date in accordance
with 10CFR2,2.109(12/22/72).
05000237 RECIPIENT ID CODE/NAME PD3-2 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUiD
NRR/DOEA/OEAB
NRR/DRIL/RPEB10
NRR/PMAS/ILPB
2 NUDOCS-ABSTRACT
OGC/HDS2 RGN3 FILE 01 EXTERNAL: EG&G/BRYCEgJ.H.
I NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME STANGiJ AEOD AEOD/DSP/TPAB
DEDRO NRR/DLPQ/LHFBPT
NRR/DREP/PEPB9H
NRR/PMAS/ILPB
1 NRR/PMAS/ILRB12
OE D:E~LE 02 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25
e Commonwealth
Edison 1400 Opus Place Downers Grove, illinois 60515 February 19, 1993 U.S.Nuclear Regulatory
Commission
Washington, D.C.20555 Attention:
Document Control Desk Subject: 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 Reference:
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.
If your staff has any questions or comments concerning
this letter, please refer them to Denise Saccomando, Compliance
Engineer at (708)663-7285.Sincerely, cZ~A~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 9302250251
930219 PDR ADOCK 05000237 Q PDR ZNLD/2112/13
ATI ACHMENT RESPONSE TO NOTICE OF VlOLATION NRC INSPECTlON
REPORT 50-237/92028, 50-249/92028
.Vi l n: 2 79202 1.2 2 2 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.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 day 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 September 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
.REA ON F VI LATION: 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 hours0.0215 days <br />0.516 hours <br />0.00307 weeks <br />7.065885e-4 months <br /> for a-155V ground on the 125Vdc 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.ln 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".
In 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-115V 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 investigated
and resolved the ground under work requests D-13836 and D-15077.The ground was monitored until January 2, 1993, and never returned.RREC N AND I VED For example 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
ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION
REPORT 50-237/92028, 50-249/92028
.QQQQE VE TE D RTHE V N 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 LIAN E Full compliance
was achieved when the individual
was counseled.
ZNLO/2112/16
ATI ACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECT(ON
REPORT 50-237/92028, 50-249/92028, TION: 24 2 2 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.
REAS NF RTHEVI TI N 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-30396,"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 25A fuse could protect against would also be protected by a 30A or 40A fuse.ZNLD/2112/17
ATTACHMENT
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 windtngs of the transformer
or the circuit." This evaluation
confirmed Engineering's
previous operability
assessment
and the engineering
judgment of the fuse coordinator.
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.C RRE TIVE TEP T E LT D The Unit 2 LPCI fuse was changed out on February 19, 1993.The Unit 3 LPCI system has also been inspected.
The Unit 3 LPCI 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
Sup'ervisor
has issued a memorandum
to the fuse coordinator
incorporating
direction for fuse replacements
identified
in Technical Problem Reports issued prior to October, 1992.ZNLD/2112/18
ATl ACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION
REPORT 50-237/92028, 50-249/92028
.RRECTIVE TEP EN T AV ID ER VI LATION: DAP 11-27, will be revised by March 31, 1993, to incorporate
the interim directions
described in the above memorandum.
DATE OF FULL MP 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/2112/19