IR 05000010/1977033
| ML20037B144 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/09/1977 |
| From: | Knop R, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20037B139 | List: |
| References | |
| 50-010-77-33, 50-10-77-33, 50-237-77-29, 50-249-77-27, NUDOCS 8009040691 | |
| Download: ML20037B144 (8) | |
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{{#Wiki_filter:, . . , ~ . ( ~ U.S. NUCLEAR REF-ULATORY COMMISSION .. OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-010/77-33; 50-237/77-29; 50-249/77-27 Docket No. 50-10; 50-237; 50-249 License No. DPR-2; DPR-19; DPR-25 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3 i Inspection at: Dresden Site, Morris, IL
Inspection Conducted: October 18, 20, 21, and 26-28, 1977 k)DS ' J 7 //'"3~[[ . . Inspectors: W. D. Sha r DN(?fNs< _ Approved by: R.C. Knop, Chief // 7 7) < Reactor Projects Section 1 F f Inspection Summary Inspection on Octooer 18,_20, 21, 26-28, 1977 (Report No. 50-010/77-33; 50-237/77-29; 50-249/77-27) Areas Inspected: Routine, unannounced inspection of Units 2 and 3 Design i Changes; records, cleanliness; review of licensee action on previous inspection findings; review of unresolved items; and participation la a fire protection review, conducted by Headquarters. All areas of review . apply to all 3 units unless otherwise specified. The inspection involved j 48 inspector-hours onsite by one NRC inspector.
Results: Of the six areas inspected, no items of noncompliance or devi- ! ations were found in three areas; three apparent items of noncompliance and one deviation. were found in three areas (infraction - management failure to review design changes prior to implementation of work - paragraph 4; infraction - failure to control design change records - paragraph 4; deviation - inadequate control of ho'isekeeping and storage of material - paragraph 6; deficiency - inadequate control of records - paragraph 5).
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' . . ' DETAILS - 1.
Persons Contacted < ! Fire Protection _ Review Exit
- B.
Stephenson, Station Superintendent
- E. Budzichowski, Unit 1 Operating Engineer
- M. Dillon, Engineering Assistant
- B. Weibler. Quality Assurance
- J. Reopelle, Consultant /NRC
- C. Heit, NRC Exit Conducted on October 28, 1977
- B. Stephenson, Station Superintendent f
- A. Roberts, Assistant Superintendent
- C.
Sargent, Tech Staff Supervisor
- 1. Scott, Lead Operating Engineer
- R. Zentner, Station Construction
- C, Lawton, Office Supervisor
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- G. Reardanz, Quality Assurance
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- R. Kyrouac, Quality Control Engineer
- J.
Brunner, Tech Staff The inspector also talked with and interviewed several other
licensee employees.
- Denotes those attending the exit interviews.
Licensee Action on Previous Inspection Findings
j (Closed) Noncompliance (237/77-15; 249/77-15): Failure to ade-quately correct Unit 2 and 3 flow bias scram setpoints. The inspector determined that interim measures to control the Unit 2 and 3 flow bias setpoint have been implemented.
In addition, a
new procedure was written to adjust the flow bias converters to the most current correlation after startup from a refueling outage.
Implementation of the new procedure will be followed in routine surveillance inspections.
(Closed) Noncompliance (237/77-15; 249/77-15): Failure to com-ply with Technical Specification surveillance intervals. The inspector determined that computer sof tware program revisions j have been made and are presently in use to more adequately control surveillauce intervals.
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. - . (Closed) Noncompliance (249/77-10): Failure to follow proe+- - dures. The inspector noted that all reactor scrams are identified in deviation reports. The inspector also noted that valves required by procedure to be locked are maintained in a locked con-dition.
(Closed) Noncompliance (249/77-10): Inadequate surveillance test of the Unit 3 emergency bus undervoltage relays. The inspec-tot determined that a permanent procedure has been initiated to control the surveillance of Units 2 and 3 undervoltage relays.
Review of the Unit 2 surveillance indicates adequacy.
(Closed) Noncompliance (237/77-06; 249/77-06): Failure to cali-brate undervoltage emergency bus relays. The inspector determined that surveillance of Units 2 and 3 undervoltage emergency bus relays has been accomplished. In addition, the Units refueling surveillance schedule has been changed to require this surveillance every refueling outage.
(Closed) Noncompliance (010/76-27; 237/76-28; 249/76-30): Lack of a program to calibrate instruments which verify that safety related systems conform within Technical Specification requirements.
The inspector determined that a surveillance list for Dresden . Units 2 and 3 have been completed and is now being implemented.
The inspector also noted that a program for Dresden Unit 1 surveil-Iance has been started and will be implemented by December 31, 1977.
The Unit 1 program will be reviewed at a later inspection.
3.
Review of Unresolved and Open Items In a previous inspection (010/76-18), the licensee committed to submit a Unit 1 Technical Specification change request, relating to the setpoint used for pressure switches which verify reactor pressure greater than core spray header pressure for injection valve actuation. The inspector reviewed the proposed Technical Specifi- , cation change without comment.
As a result of the issuance of IE Circular No. 76-04, the licensee committed to replace the neutron monitoring and flow bypass switches during the present refuel outage. The inspector observed, during a tour of the control room that the above identified switches have been replaced on Unit 2.
Unit 3 switch replacement is acheduled for the February, 1978 outage.
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. . ~ (' In a response 1/ to IE Bulletin No. 76-02, the licensee committed . to replacement of HFA and MGA D.C. relays in uncontrolled environ-ments for the Dresden plant. The inspector determined, by review of modification pactsgf No. 1-76-20 and No. 2-76-66, that this commitment has been accomplished on Units 1 and 2.
Unit 3 relays are scheduled for replacement during the February, 1978 outage.
In a previous inspection (010/76-27; 237/76-28; 249/76-30), the inspector noted that the storage of tools, materials and equipment within the facility do not appear to be as well controlled as specified in ANSI N45.2.3-1973. The inspector reviewed this open item during an audit of the licensee's cleanliness program. Comments on th. licensee's storage program may be found in paragraph 6 of this report.
4.
Review of Units 2 and 3 Design Changes and Modifications The inspector reviewed the following modifications to verify that design changes were made in accordance with 10 CFR 50.59, modifi-cations were reviewed and approved in accordance with the licensee's l Technical Specifications, modifications were conducted in accord-ance with formal procedures as applicable, acceptance tests were - completed as required, operating procedures were reviewed and approved - in accordance with the Technical Specifications, as built drawings , ' were changed to reflect the modifications, and that records of l modifications are maintained as described in 10 CFR 50.59(t).
l l Modification No. 2-75-110, modify modules for IRM's per GE sill No. 47.
Modification No. 2-75-91, replace reactor high pressure scram switch isolation valves with needle valves.
Modification No. 2-76-68, install heavier duty diesel genera-tor surge suppressors.
l Modification No. 2-76-55, reinstall old style diesel generator l cooling water pump.
Modification No. 2-76-16, modify the inter torus columns to give increased conservatism in a designed safety margin.
Modification No. 2-76-81, replace the 250 VDC charger control power pack.
The following concerns were identified.
l/ Letter, Bolger to Keppler, dated 9/10/76.
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. . t Regarding modifications No. 2-75-110 and 2-75-91, the inspector determined that in both cases, the work was completed prior to proper management review. In modification 2-75-110, the work was identified as being completed on September 24, 1976. However, the Dresden administrative procedure DAP 15-1 requires the licensee to review the work and approve installation prior to commencement of the work. This form was filled out and dated October 13, 1976. In modification 2-75-91, the inspector noted that the onsite review and authorization to install were signed off on March 19, 1977, while the actual work had been accomplished on March 18, 1977. These examples indicate that the licensee's quality procedure. QP-No. 3-51, is not being followed.
It is recognized that the Quality Control Department identified the lack of management review conducted on modification 2-75-91, however, the response to the quality control discrepancy report identifies a single individual at fault for the lack of proper review. This statement is incorrect, primarily because it is incumbent upon any individual handling the modification package, to assure that all proper reviews have been accomplished. This item of noncompliance was discussed at the exit interview.
Regarding modification 2-76-55, the inspector determined that the . modification psckage had been lost and was closed out by a memo - to file on October 7, 1977, from B. B. Stephenson. No information on why or how the package was lost and no corrective action to prevent recurrence was initiated. The licensee's quality proce-dure QP No. 17-51 identifies modification records as lifetime records. The inspector noted that there appears to be several modifications that are not accounted for in the licensee's records.
The lack of control of lifetime quality assurance records was discussed at the exit interview.
5.
Records Review (Units 1, 2 and 3) The inspector reviewed the licensee's program for the control, storage, retention and retrieval of records and documents. The review also included verification that as-built drawings, includ-ing vendor drawings are being properly maintained. The following concerns were identified.
In revieving the licensee's program for the retention and retrieval of records the inspector noted what appears to be the existence of inadequate control of the reactor control room roll chart records.
Roll charts for the IRM and APRM recorders, the reactor level and
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. -. - -... - -- . . . \\ fee 3 water control recorders and the air ejector offgas recorders l were identified as missing and not available for review at the ' records control office. The problem appears to be two-fold: a.
The roll charts removed from the recorders from the control room are not in all instances being properly identified by
! the control room operator. It was also noted that in many l cases the wrong roll chart was being used on the recorder.
b.
When these documents are sent to the records control office, they are stored in separate bins without identification of what was received or for that matter, what was supposed to be received. Furthermora, the distribution and retrieval of these records by licensee personnel is inadequately con-
trolled in that, records of distribution are vague and ' incomplete.
l The lack of control of records in this particular area was dis-cussed at the exit interview.
i i In reviewing the licensee's program to control as-built drawings and to control drawing changes necessitated by design changes, ' l the inspector noted that while vendor drawings are presently i being updated as design changes are made, no affort was made by l the licensee to determine if all vendor drawings have been brought up-to-date as a result of previous design changes. The licensee ' stated that a review program would be initiated to resolve this problem area. No further concerns were identified.
6.
Cleanliness (Units 1, 2 and 3) A review was conducted to determine the existence of administra-l tive controls on plant cleanliness and storage. The review l indicated that the administrative controls relating to plant cleaning are inadequate. The inspector also determined that administrative controls for proper storage in the plant area do not exist.
Regarding plant cleaning, the licensee's administrative proce-l dure DAP No. 7-2 states " plant cleaning will normally be conducted in accordance with assignments provided by the operating engineer.
Special assignments will be marked on the sheets. Shift engineer will initial the sheet to indicate cleaning has been completed satisfactorily or will so note that indicated plant conditions preclude cleanup."
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_ i - On several tours of the plant during this inspection, the inspec- ' tor found cigarette butts, food wrapping, candy bar wrappers, used ~ rad protection clothing including face masks, and general dirt and garbage strewn throughout the plant. Similar messy and unnecessary conditions have been pointed out to the licensee , throughout the year, however, the licensee has failed to respond to the inspector's comment.
, During the plant tour the inspector noted that velding machines being used by station constructicn personnel did not have weld permits as required by the licensee's quality assurance program.
The inspector did not determine if these welding machines were being used on safety related systems. The licensee's program for control of station construction personnel and their adherence to their quality assurance program is an unresolved item and will be reviewed at a future inspection.
Regarding storage of equipment and material in the reactor build-ing and turbine building the inspector noted no administrative control of storage of equipment and material. This concern was previously identified (inspection report No. 010/76-27; 237/76-28; 249/76-30) during an inspection conducted in December 1976. At that time the inspector requested the licensee to review their present program and to determine the need for better control. This _ concern has remained unresolved since then.
Since that time the licensee has written two procedures relating to equipment storage, however, these procedures have not yet been reviewed by management nor approved for use.
In the licensee's Quality Assurance Program, the licensee committed to comply to NRC document " Guidance on Quality Assurance Require-ments During the Operations Phase of Nuclear Power Plants," dated October 26, 1973. This document requires the implementation of Regulatory Guide 1.39, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants," which in turn commits the licensee to ANSI Standard N45.2.3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plants." ANSI N45.2.3-1973 requires the licensee to develop a program to control housekeeping, including storage on the facility site.
Regarding the previcusly identified concerns with regard to house-keeping and storage, the inspector informed the licensee of the failure to meet this commitment. This deviation was discussed at the exit interview.
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Fire Protection Review Team . The inspector participated in a fire protection review conducted onsite on October 18, 20, and 21, 1977. The results of this fire protection review will be documented in a separace' report from the NRC Headquarters office.
8.
Exit Interview The fire inspection team met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on October 21, 1977. The inspection team summarized the scope and findings of the review.
, The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on October 28, 1977.
, The inspector summarized the scope and findings of the inspection.
, The licensee representatives made the following remarks in re- ! sponse to certain of the items discussed by the inspector: Acknowledged the statements by the inspector with respect to the items of noncompliance identifiable in Paragraphs 4 and 5 and - the deviation identified in Paragraph 6.
- Stated that a program to properly identify and control recorder charts will be implemented by December 31. 1977. The licensee will obtain stamps for each chart to be used every 24 hours to properly identify the recorder chart. Also the use of transmittal sheets will be implemented for transfering used recorder charts and records to the central file.
Stated that an immediate plant cleanup would be conducted.
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