IR 05000010/1976014

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IE Insp Repts 50-010/76-14,50-237/76-17 & 50-249/76-15 on 760630-0702 & 0707-08.Noncompliance Noted:Failure to Test Vault Flood Protection Valves for Operability Following Installation
ML19340A759
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/28/1976
From: Johnson P, Knop R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19340A751 List:
References
50-010-76-14, 50-10-76-14, 50-237-76-17, 50-249-76-15, NUDOCS 8009030785
Download: ML19340A759 (14)


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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

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Report of Operations Inspection

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IE Inspection Report No. 050-010/76-14

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IE Inspection Report No. 050-237/76-17

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IE Inspection Report No. 050-249/76-15 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Dresden Nuclear Power Station License No. DPR-2 Units 1, 2 and 3 License No. DPR-19

Morris, Illinois License No. DPR-25 Category:

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Type of Licensee:

BWR (GE) 200 & 810 MWe

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Type of Inspection:

Routine, Unannounced Dates of Inspection:

June 30-July 2.and July 7-8, 1976

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Principal Inspector:

. H.

hnson d

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v Accompanying Inspector:

R. C. Knop

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(July 7-8,19 6 only)

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Other Accompanying Personnal: None R'eviewed By:

R.

. kn hie 8 Ih

Reactor Projects

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Section No. 1

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YO SUMMARY OF FINDINGQ (

Inspection Summary

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Inspection on June 30-July 2 and July 7-8 (Unit 1, 76-14; Unit 2, 76-17; Unit 3, 76-15): Review of plant operations, reportable occurrences, and selected followup items. Two items of noncompliance were identified for Units 2 and 3, relating to reporting requirements and preoperational testing of plant modifications.

Enforcement Items The following items of noncompliance were identified during the inspection:

A.

InJ actions Contrary to the licensee's Quality Procedure 3-51 and Criteria III and XI of 10 CFR 50, Appendix B, Units 2 and 3 CCSW vault flood protection valves were not tested for operability following installa-tion.

(Paragraph 4.e, Report Details)

B.

Deficiencies Contrary to Section 6.6.B of the Dresden 2 and 3 Technical Speci-

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fications, the following reports were not submitted to the NRC:

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(1) a prompt telegram or telecopy report concerning failure of the Unit 2 HPCI steam supply valve to open on March 13, 1976, and (2)

a 30-day written report conr.erning excessive closing time of a Unit 3 main steam isolatio. valve observed on May 3, 1976.

(Para-graphs 4.b and 4.j, Reporc Dntails)

Licensee Action on Previously Identified Enforcement Items Not reviewed.

Other Significant Items A.

Systems and Components

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No difficulties have been er.perienced in maintaining the 1.0 psi dif ferential pressure between the drywell and torus in Units 2 and 3.

(Paragraph 5, Report Details)

2.

Unresolved Item - The adequacy of documentation related to Unit 2 and 3 flood protection modifications will be reviewed at a later date.

(Paragraph 4.h, Report Details)

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B.

Facility Items

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None.

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C.

Managerial Items None.

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D.

Noncompliance Identified and Corrected by Licensee 1.

Contrary to paragraphs 3.5.A.4 and 4.5.A.4 of the Dresden 2 Technical Specifications, the 2A low pressure coolant injection pump was out of service for scheduled maintenance while refueling activities were in progress, with no sur-veillance performed on redundant components.

(Paragraph 4.d, Report Details)

2.

Contrary to paragraph 4.6.C.2 of the Technical Specifications, which requires coolant water sampics to be taken at 4-hour intervals (+ 25%), a lapse of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 55 minutes was observed between successive samples during a Unit 2 startup on June 28, 1976.

(Paragraph 3.b, Report Details)

E.

Deviations Contrary to a commitment established in the Licensee Event

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Report for Reportable Occurrence 249/76-05, Unit 3 isolation condenser initiation relay 595-117C was not examined and I

repaired during the next Unic 3 outage.

(Paragraph 4.1, Report Details)

F.

Status of Previously Unresolved Items 1.

The licensee has instituted controls to maintain a status of effective operating orders.

(Paragraph 6.c, Report Details)

2.

Lnproved definition of the Quality Assurance Engineer's responsibilities has been provided.

(Paragraph 6.d, Report Details)

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Management Interview The inspectors conducted a management interview with Messrs. Stephenson (Station Superintendent), Abel (Administrative Assistant), and other members of the station staff at the conclusion of the inspection on July 8.

The following matters were discussed:

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A.

The inspector stated that the inspection had included a review of reportable occurrences which occurred during the previous three-month period, with the following comments:

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1.

The omission of preoperational tests on the Unit 2 and 3 CCSW vault flood protection valves was identified as an item of noncompliance.

In response, the licensee established a commitment to perform an onsite review by August 1, 1976, of all plant modifications installed to prevent flooding of safety related components, to verify that such modifications have been properly installed, tested, and documented. The inspec-tor stated that in view of the commitment and actions taken to make the flood protection valves operable, a formal response to the noncompliance item would not be required. The inspector also stated that the adequacy of documentation related to the flood protection modifications would be considered an unresolved item, and would be evaluated for adequacy after completion of the onsite review.

(Paragraphs 4.e and 4.h, Report Details)

2.

The inspector described the noncompliance item associated with Technical Specifications reporting requirements, and stated that in v'iew of corrective actions taken and identified by the licensee,

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a formal response would not be requested.

(Paragraphs 4.b and 4.j, Report Details)

3.

A deviation identified during the inspection was discussed.

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(Paragraph 4.1, Report Details)

4.

Two noncompliance items identified and corrected by the licensee were discussed.

(Paragraphs 3.b and 4.d, Report Details)

5.

The inspector noted that the lack of lubrication eppeared to have been a factor in excessive packing leakage on two Unit 2 torus-drywell vacuum breakers. The licensee responded that additional personnel had been assigned to assist with the plant lubrication program.

(Paragraph 4.f, Report Details)

6.

The inspector stated that the checksheet used to document satis-factory performance of the Unit 2 and 3 CCSW vault flood protection valves presented a possible pitfall in documentation

of testing in that it did not specifically call for verification

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that the valves close when required. The licensee acknowledged the inspector's comment.

B.

Operation of Units 2 and 3 with a 1.0 psi differential pressure between the drywell and the torus was discussed. The inspector stated that, consistent with commitments to the Office of Nuclear

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Reactor Regulation, the related operating procedures should include:

(1) requirements for establishing the 1.0 psi dif ferential pressure

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I consistent with the Technical Specifications requirements for drywell

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s inerting, and (2) a statement that drywell and torus pressures may be equalized for a period not to exceed two hours for the performance of vacuum breaker tests.

(Paragraph 5, Report Details)

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The inspectors summarized other areas reviewed during the inspection.

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REPORT DETAILS

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1.

Persons Contacted B. Stephenson, Station Superintendent

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J. Abel, Administrative Assistant D. Adam, Radiation / Chemistry Supervisor J. Bauer, Shift Engineer E. Budrichowski, Unit 1 Operating Engineer R. Coen, Engineering Assistant G. Frankovitch, Master Electrician G. Gallo, Maintenance Foreman S. Harris, Engineering Assistant R. Herbert, Technical Staff Engineer W. Hildy, Instrumet.t Engineer S. Jerz, Engineering Assistant J. Kolanowski, Unit 2 Leading Engineer T. Lang, Technical Staff Engineer R. Mirochna, Technical Staff Engineer R. Nimmer, Surveillance Coordinator J. Phalan, Engineering Assistant R. Ragan, Unit 3 Operating Engineer G. Reimers, Technical Staf f Engineer

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G. Romba, Technical Staff Engineer N. Scott, Unit 2 Operating Engineer

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C. Schiavi, Modifications Coordinator E. Seckinger, Technical Staff Engineer T. Watts, Technical Staff Supervisor R. Weidner, Procedures Coordinator F. Willaford, Quality Assurance Engineer 2.

General All Dresden units were in operation at the time of this inspection, with a net power output from the station of approximately 1500 MWe.

3.

Review of Plant Operation

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'a.

Shift Logs and Operating Records. The inspector reviaved shift

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logs and operating records to verify the following:

(1) Control room log sheet entries are fille ' out and initialed.

(2) Auxiliary logs are filled out and initialei.

(3) Shift Engineer's and control room unit logs provide sufficient detail.

(4) Log book reviews are con' ducted.

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(5) Operating orders do not conflict with Technical Specifi-cations requirements.

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-(6) Bypass logs are being maintained in accordance with

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Technical Specifications requirements.

No discrepancies were found in log maintenance and review proce-dures.

b.

Problem Identification Reports. Deviation Reports for the past quarter were reviewed to verify that there were no violations

of Technical Specifications reporting requirements.

During the review the inspector noted that the licensee had identified a failure to take water samples every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

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-during a Unit 2 startup on June 28, 1976. The licensee identi-fled an interval of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 55 minutes between samples.

l Technical Specification 4.6.C.2 requires wat >r samples to be taken evety 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and analyzed for conductLrity and chloride content. The licensee had initiated correctivs action to prevent recurrence. The inspector stated he had no further questions on this matter.

c.

Plant Tour. The inspector toured various areas in all three

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units of the plant including control room, reactor building, turbine building and waste management area. The tour verified

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that:

(1)

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Housekeeping was generally acceptable except for excessive RWP clothing and plastic bags in Unit 1.

j (2) Radiation controls were properly established.

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Selected instruments were monitoring within Technical

Specifications tolerances.

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(4) No unusual fluid leaks or piping vibration existed.

(5) Pipe hanger / seismic restraint oil levels were satisfactory.

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(6) Selected valves were properly positioned.

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(7) Selected equipment tags were properly authorized and logged.

l (8) The control room operators were aware of the reasons for lighted annunciators and had taken action as required by

alarm procedures.

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(9) Control room manning was in conformance with the Technical

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Specifications and 10 CFR 50.54(k).

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4.

Review of Reportable Occurrences A review of reporting requirements, corrective act' ion, licensee review and evaluation, and compliance with regulatory requirements was conducted for the following reportable occurrencer:

Licensee Event Title Event Date Report Jate Unit 1 76-05 - Temporary Reduction of 3/9/76 3/30/76 Offsite Power 76-07 - Leakage of Sphere ventilation 5/7/76 6/6/76 Isolation Valve Unit 2 76-09 - Failure of HPCI Steam 3/13/76 3/24/76

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Supply Valve to Open

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76-10 - Excessive Leakage of 3/15/76 4/14/76 Cantair.aent Isolation Valve 1601-23 76-11 - Excessive Leakage of 3/15/76 4/12/76 Containment Isolation Valve 1601-56 76-12 - Inoperable LPCI Pump Breaker 3/22/76 4/6/76 76-13 - Inoperable CCSW Vault Flood 3/24/76 4/6/76 Prctection Valve 76-14 - Excessive Leakage of Torus-3/23/76 4/19/76 Drywell Vacuum Breskers

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76-17 - E?:cessive Leakage of SBLC 3/24/76 4/23/76 &

Check Valve 1101-16 6/25/76 76-18 - Excessive Leakage of Feed-3/25/76 4/23/76 &

vater Check Valves 583 and 62B 6/29/76 76-19 - Broken Tack Welds on 3/27/76 4/26/76 Jet Pump Retainer Gates

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76-20 - Excescive Leakage of HPCI 3/29/76 4/27/76 Exhaust Check Valve 2301-45-8-r

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Licensee Event _ Title Event Date Report Date

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(T-76-23 - Leakage of CCSW Vault 4/9/76 5/7/76

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Penetrations

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76-24 - SBLC Relief Valve Setpoint 4/12/76 5/12/76

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Drift I

l 76-26 - Isolation Condenser Condensate 4/14/76 5/14/76

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j High Flow Switch Setpoint Drift 76-27 - SBLC Relief Valve Setpoint 4/13/76 5/13/76

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Drift i

76-37 - 600 psig Scram Bypass Pressure 5/27/76 6/23/76 &

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Switch Setpoint Drift 7/6/76 Unit 3 t

i 76-05 - Isolation Condenser Reset 3/11/76 3/24/76

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Malfunction

76-06 - Inoperable CCSW Vault Flood 3/24/76 4/6/76 Protection Valve

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76-08 - Leakage of CCSW Vault 4/30/76 5/28/76

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Penetrations i

76-09 - Overload Trip of Core 5/10/.76 5/24/76

Spray Injection Valve 76-12 - Excessive MSIV Closing Tina 5/3/76 Pending i

The inspector's review included discussion of each event with licensee represencatives as required, in-plant observations, and examination of

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the report referenced above and documents related to the particular i

areas reviewed. The following comments resulted from the review:

a.

Unit 1, Event 76-07: This event was initially considered report-able by the licensee based on an incorrect calculation of the

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measured leak rate. As stated in the licensee's report, recalcu-

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1ation of the leak rate using the correct gas constant gave an acceptable leak rate.

Licensee representatives stated that leak rate measurement and calculation procedures were being revised to prevent recurrence.

b.

Unit 2, Event 76-09: Licensee representatives stated that inspection of the valve's feeder breaker as discussed in the

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licensee's report had shown no further cause of failure, and that a follevup report would not be submitted. The inspector (

noted cha prompt telephone report of the occurrence had been r

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made by L licensee, although the prompt telegraph or telecopy i

notification -aquired by paragraph 6.6.B of the Technical Specifications had not been provided. This was identified as i

noncor~'iance with NRC requirements and was discussed further du" i ne management interview.

c.

Unit 2, Event 76-10: Licensee representatives stated that no

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new leakage paths had been discovered during followup maintenance l

on this valve and that a supplemental report would not be sub-mitted. Test records shcued a final leak test result of 6.2 scfh.

d.

Unit 2, Event 76-12: This report related to refueling opera-tion s being conducted while one Li'CI pump was removed from service for scheduled breaker maintenance. One pump may be rer.oved from service for maintenance under such conditions

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provided redundant components are tested daily, which was not done in this case. The licensee identified this as an item of

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noncompliance and had initiated procedural changes to prevent recurrence, e.

Unit 2, Event 76-13 and Unit 3, Event 76-06: These events

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referred to the inoperability of a valve installed in each unit to prevent flooding of the CCSW pump vault in the event of flood-

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ing in the condansate pump room. Each valve is installed in a line which provides normal drainage of leak off from the CCSW pumps to the condensate pums room, and was installed as one of several

^difications design _ to prevent flooding of critical components due to failure of non-safety related equipment.

Discussions with station personnel indicated that the valves had not been tested for operability after installation, and had subsequently failed to operate during a scheduled surveillance test.

Investigation by the licensee after the problem was-identified showed that:

(1) the electrical circuitry which initiates closure of the valve had not been properly connected, (2) the control room annunciator which indicates high water level in the condensate pump room had not been connected, and (3) the

valves had been mechanically blocked in the open position.

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Records of tests conducted after the control c'rcuitry was pro-i perly installed showed the flood protection valve in each unit to be operable. Licensee representatives made a commitment to perform an onsite review of all plant changes associated with

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the flood protection modifications to verify that the design changes had been properly made and tested and that adequate (

records had been maintained. The licensee was informed that

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the failure to test the flood protection valves after installa-tion represented noncompliance with NRC requirements.

f.

Unit 2, Event 76-14: This event concerned excessive leakage through the shaft packine on two torus-drywell vacuum breakers, apparently as a result or t dequate lubrication. The licensee's report stated t hat lubricatio, of the packing had returned

leakage to withit. visowed limits. A licensee representative stated during the inspection that additional personnel had been assigned to the lubrication program and that this should prevent recurrence.

g.

Unit 2, Event 76-19: Licensee representatives stated that definition of long-term corrective actions related to the broken tack welds was awaiting a report from General Electric concerning analysis of the broken welds on jet pump No. 5.

The licensee's report stated that an updated report would be submitted when this evaluation had been completed. An action item record (AIR) was noted to have been issued to follow com-pletion of this commitment.

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Unit 2, Event 76-23 and Unit 3, Event 76-08: These events involved excessive leakage of penetrations through the concrete

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vault installed around two CCSW pumps in each unit as part of the flood protection modifications discussed in subparagraph 4.e above.

It could not be determined from available records whether post-installation testing of the penetrations had been performed prior to the tests discussed in the licensee reports, or whether these tests may actually have represented the initial post-installation tests. As discussed in subparagraph 4.e above, the licensee established a commitment to conduct a review of docu-mentation related to the flood protection modifications. Tne i

inspector stated that the adequacy of documentation related to the modifications vas considered an unresolved item and would be reviewed further fouowing completion of the licensee's review.

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Unit 3, Event 76-05: This event concerned an isolation condenser initiation relay which reset independently of the manual reset switch. The licensee's report stated that the relay would be examined and repaired during the next unit outage. Licensee representarites stated that this had not been accomplished, although operating records showed that a 5-day outage had been taken in early May, 1976. An AIR was noted to have been written i

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for inspection of the relay, although it was not initiated

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until June, after the outage had aircady occurred. The inspec-

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tor stated that failure to examine the relay during the May

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outage represented a deviation from the commitment established in the Licensee Event Report.

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Unit 3, Event 76-12: The Deviation Report related to this event was found by the licensee's clerical personnel while reviewing records for documentation of the telecopy report required for Unit 2, Event 76-09.

The deviation report had been reviewed by the Operating Engineer and Station Superinten-dent after corrective actions were taken. Surveillance records showed the closing time to have been corrected. The event had not'baen reported to the NRC, however, due to improper handling of the deviation report within the station.

Licensee representa-tives stated that the handling of deviation reports would be reviewed with clerical personnel, and the handling of deviation reports and related records would be covered by an audit in the

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near future. The inspector noted that failure to report the l

excessive clcsing time represented noncompliance with NRC require-I ments, although a formal response would not be requested in view of the correc-ive actions identified by the licensee.

The inspection also included a review of those aspects of the licensee's

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organization which provide for routine review and evaluation of non-

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routine events. No comments resulted from this review.

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5.

Drywell-Torus Differential Pressure (Units 2 and 3)

Recent correspondence 1/ between the licensee and the Office of Nuclear Reactor Regulation established a commitment by the licensee to operate Units 2 and 3 with 1.0 psi differential pressure esta-blished between the drywell and the torus to increase available margins of safety for the torus structural support system. Review of recorda covering a 20-day period for each unit established that the 1.0 psi differential pressure was being maintained. Discussions with licensee representatives established that no difficulty has beer. encountered in maintaining the differential pressure except for temporary reductions in a few isolated cases and the requirement to

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1ctter from *4e licensee to NRRgyres for vacuum breaker testing.

described a system which has been installed in Units 2 and 3 for continued maintenance of the differen-tial pressure. Licensee representatives stated that the systems had not been placed into routine operation pending resolution of out-standing items from operational testing. Two comments resulted from the inspector's review of revi' ed procedures and further pending revisions which govern operar.on with the 1.0 psi differential pressure:

(1) the requirement in current procedures that the 1.0 psi differential 1/_ Letter, Abrell to Ruscha, dated 3/2'/76.

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2/ Letter,'Abrell to Rusche, dated 3/12/76.

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r pressure be established in a time frame consistent with requiremedes for containment inerting should be retained in the pending revisions,

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and_(2) procedures should reflect the understanding with NRR that a (T relaxation of the differential pressare for not more than two hours

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is permitted for vacuum breaker testing.

6.

Miscellaneous Items

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a.

Operability of Scal-In Circuits. A previous inspection report /

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noted that the licensee was to revica procedures to verify that seal-in circuits in safety related valve controllers are ade-quately tested when valve operability is being demonstrated.

j Review during the current inspection established that surveil-i lance procedures for safety-related systems had been revised to call for releasing the switch while testing applicable valves to verify that the seal-in circuit functions properly.

Item resolved.

b.

Diesel Generator Shutdown Procedure (Units 2 and 3).

Abnormal Occurrence 237/75-04 involved overspeed trip of the Unit 2/3

diesel generator following auto start because of tmproper

governor speed droop settings. As a result of this occurrence,

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the licensee revised the periodic diesel generator surveillance test procedure to provide for readjustment of the speed droop to 61 Hz at no load prior to engine shutdown. During a subsequent

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inspection, the inspector noted that a similar revision had not beenmadetotheprocedureusedtotestauto-initiationo{fthe

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diesel generator during the refueling outage. The report-of this inspection documented a commitment by the licensee to revise the auto-initiation tect prior to the 1975 refueling outage. Review during the current inspection showed that proce-dures DOS 6600-5, DOS 6600-6, and DOS 6600-7, which are used i-for the refueling outage auto-initiation test, still had not been revised to provide for proper speed droop settings when returning the diesel to a standby condition. The inspector identified this item as a failure of the licensee to meet a com-mitment agreed upon in the above noted procedure. Although not considered a part cf the commitment, the inspector observed that procedures DOP 6600-3 and DOP 6600-6 also require revision to be consistent with the proper shutdown sequence.

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Listing of Ef fective Operating Orders.5/ The difficulty in

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determining which operating orders were still ef fective was noted to have been resolved. The inspector determined that the licensee

has instituted controls to show the status of each outstanding

operating order.

Item resolved.

3/ IE Inspection Reports No. 050-237/74-10 and No. 050-249/74-12.

4/ IE Inspection Reports No. 050-237/75-07 and No. 050-249/75-07, i

Mcnagement Interview, paragraph C.

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5/ IE Inspection Report No. 050-010/75-05.

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Effectiveness of Quality Assurance Engineer.6/

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Documentation

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requirements for the Quality Assurance Engineer's surveillance (~'

activities were noted to have been established. A review of QAE files indicated that documented surveillance has been

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accomplished, that deficiencies have been documented, and that there is documenta: ion of followup on corrective actions.

Item resolved.

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6,/ RO Inspection Reports No. 050-010/74-08, No. 050-237/74-05, and

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No. 050-249/74-08.

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