IR 05000010/1977038
| ML19340A655 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/31/1978 |
| From: | Knop R, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A654 | List: |
| References | |
| 50-010-77-38, 50-10-77-38, 50-237-77-35, 50-249-77-33, NUDOCS 8009020597 | |
| Download: ML19340A655 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
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Report No. 50-010/77-38; 50-237/7'-35; 50-249/77-33 Docket No.50-010, 50-237; 50-24$
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 Inspection At: Dre: den Site, Morris, IL Inspection Conducted: December 1, 2, 7, 8, 14, 15, 20,
"2, 27, and 28, 1977; January 3, 4, 5, and 10, 1978 1-30-7[
Inspectors:
W. D. S af r te.D s
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R.~C. Knop 5l Approved By:
R.
Knop, ief
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Reactor Projects Section 1 Inpsection Summary Inspection on December 1, 2, 7, 8, 14, 15, 20, 22, 27, and 28, 1977; and January 3, 4, 5, and 10, 1978 (Report Nos. 50-010/77-38; 50-237/77-35; 50-249/77-33)
Areas Inspected: Routine, unannounced, inspection of licensee's control of safety trip signals for Units 1, 2, and 3: Tour of Unit I reactor protection system cabinets in the control room; review of onsite LER's for Units 1, 2, and 3; review of licensee's Quality Assurance program for Units 1, 2, and 3; review of plant operations for Units 1, 2, and 3; review of Unit I safety limits, limiting conditions safety settings, and limiting conditions for operation; and a plant tour for all units. The inspectcr also participate in a
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'D meeting weih site management, relating to the augmented inspection
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The inspection involved 92 inspector-hours onsite by two
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NRC inspectors.
Results: Of the seven areas inspected, no items of noncompliance or deviations were found in four areas; seven apparent items of noncom-pliance were found in three areas (violation - lockout of both diesel generators No. -3 and 2/3 on Unit 3 during operation - Paragraph
8; infraction - Unit 3, failure to perform visual lineup surveillance on Unit 3 diesel generator - Paragraph 8; infraction - Unit 2, f ailure to follow outage procedure program when taking breaker 2871 out-of-service - Paragraph 6; infraction - Unit 2, use of an inadequace undervoltage test procedure - Paragraph 6; infraction - Unit 2, failure to complete surveillance after performing safety related work - Paragraph 12; infraction - Unit 2, failure to maintain the
standby liquid control system operable - Paragraph 15; deficiency -
Unit 2, failure to follow procedures regarding flow bias testing -
Paragraph 14.
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DETAILS
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1.
Persons Contacted Exit Interview Conducted on December 2, 1977
- B.
Stephenson, Station Superintendent
- A.
Roberts, Assistant Superintendent i
- G. Abrell, Quality Assurance Corporate Office
- J. Eenigenburg, Maintenance Engineer
- G. Reardanz, Quality Assurance Site
- R.
Kyrouac, Quality Control Engineer The inspector also talked with and interviewed several other licensee employees.
- Denotes those attending this exit interview.
Exit Interview Conducted on December 8, 1977
- B. Stephenson, Station Superintendent
- A.
Roberts, Assistant Superintendent i
- G. Reardanza, Quality Assurance Supervisor
- R. Kyrouac, Quality Control Engineer The inspecea-also talked with and interviewed several other licensee t'
~oyees.
- Denotes those attending this exit interview.
Exit Interview Conducted on December 15, 1977
- B. Stephenson, Station Superintendent
- G. Reardanz, Quality Assurance Supervisor
- R. Kyrouac, Quality Control Engineer J
The inspector also talked with and interviewed several other licensee employees.
- Denotes those attending this exit interview.
Exit Interview Conducted on December 28, 1977
- A. Paberts, Assistant Superintendent
- B.
Shtiton, Administrative Assistant
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3. Zank, Dresden Training
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R. Coen, Quality Control
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Those Present from the NRC were
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R. Knop, Chief, Reactor Projects Section 1
W. Shafer, Principal Inspector
2.
Review of Management Controls Relating to Surveillance Testing (Units 1, 2, and 3)
A review of the licensee's management control relating to safe surveillance testing was accomplished to assure that safety signals are not negated during performance of surveillance test.
The findings are as follows:
7, The inspector determined by review of procedures that l
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the-licensee's procedure content specifically limits and j
restricts the individual performing the surveillance test such that only one safety instrument is isolated at a time.
No concerns were identified.
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The inspector determined that the licensee's training pro-
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gram relates primarily to craft training only. Formal Training
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j programs by themselves, for craft personnel do not include
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sufficient information to ensure an indepth understanding
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I of system functions. The licensee relys primarily on on-
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I the-job training to familiarize the craft personnel with system function, system interaction, and Technical Specifica-j.
tion requirements. One additional control used by the licensee is the requirement that all work must go through the shift engineer prior to implementation.
In reviewing management controls, the inspector determined c.
by review of the licensee's administrative procedures that requirements to review and approve tests and surveillance activities appears adequate. No concerns were identified.
3.
Tour of Unit 1 RPS Cabinets In The Control Room i
The inspector touted the back panels of the Unit I control room area and determined that all wires previously identified in a special Headquarters inspection on October 3 and 4, 1977, have been properly covered to reduce the potential for a hot short
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I in that area. The inspector noted that :the area was clean and free from any trash or miscellaneous debris. No further con-cerns were identified.
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Relating to the fire protection system power center in the in-
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take building for Unit 1 the inspector determined that restraints
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for seismic loads for the fire protection system power center have not been installed.
In discussions with licensee representatives the inspector was informed that this particular item.is a commitment made by the licensee's corporate office and will be accomplished prior to resumption of operations after January 1, 1978.
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4.
Review of Plant Operations (Units 1, 2, and 3) December 1 and 2, 1977 The inspector conducted a review of the control room log book, Shift Engineer's log book, and routine control logs for the period of November 25 through December 2, 1977. No concerns were identified.
Discussions with the licensee representatives relating to the various alarms that were lit at the time of the inspection indicates that the control room operator appeared knowlegeable about con-ditions of the plant. The inspector noted however, that those alarms identified as having multiple alarm functions, are not being cleared in order to prevent masking out of other alarms on the same indicator. Of primary concern are those alarms on the CRD temperature recorder, the main steam line leak detection record-er and the area radiation monitors.
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During a plant tour of the Unit 2/3 reactor building on December 1 and 2, 1977, the inspector noted that very little progress is being made to maintain the proper control over housekeeping and storage of material within the reactor building complex. This will be reviewed in a future inspection.
A review was conducted of the licensee's Units 2 and 3 deviation reports (Unit 2 DVR's 133-138; Unit 3 DVR's 79 and 80) for proper reporting requirements, management review, and prompt corrective action. No concerns were identified.
The inspector conducted a tour of the Unit 2 drywell to determine the adequacy of cleanliness in this area. During the tour the inspector determined that a thermocouple lead, on the "D" electromatic relief valve drain line was damaged as a result of someone step-ping on it.
A licensee representative stated that a work request
'will be submitted to repair the thermocouple lead. The inspector also noted that temporary test leads traversing the drywell area still exist in place as installed, long af ter the tests are over.
The plant superintendent stated that the continued existance of these test leads will be properly reviewed. No further concerns were identified.
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5.
Review of Plant Operations (Units 1, 2, and 3) December 7, 8,
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y s 14 and 15, 1977
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The inspector conducted a review of the control room log book, Shif t Engineer's log book, and routine patrol logs from the period of December 3-7, 1977. One concern relating to the removal of a breaker from the essential service redundant power supply was identified and is discussed in Paragraph 6 of this report.
The inspector conducted a plant tour on December 8 and 15, 1977, to determine the general condition of the plant. The inspector noted that plant housekeeping conditions and radiation controls have changed very litela since the last plant tour.
6.
Review of Missing Breaker No. 2871 In October,1977, Unit 2 breaker 2871 was removed from motor control center No. 28 and placed in motor control center No. 29-3.
A caution card was placed on the control switch for Breaker 2871 in the control room, identifying that the breaker-was removed. However, the breaker was taken out-of-service and required an out-of-service card in accordance with Dresden
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Administrative Procedure No. 3-5, equipment out-of-service procedure. Because no out-of-service sheet was. filled out the
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missing breaker was not tracked by the out-of-service tracking system. As a result of removing breaker 2871 from MCC No.
28, the redundant power supply for uninteruptable buses 28-7 and 29-7 was not available for use had the need arose. The failure to take breaker 2871 out-of-service in accordance with DAP No. 3-5, is an item of noncompliance and was discussed at the exit interview.
On December 4, 1977, the licensee, while conducting surveillance tests No. DOS 6600-5 and No. 6600-6, Bus Undervoltage, and ECCS Integrated Functional Test for Unit 2 Diesel Generator and Unit 2/3 Diesel Generator respectively, determined that breaker 2871 was not installed. A breaker (not the original breaker), was found near motor control center No. 28.
After assuring that this breaker was capable of performing the required service, the breaker was placed in motor control center No. 28 but only
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Further review by the inspector, of the above identified procedures, indicated that breaker 2871 was required to be racked in service and tagged with a caution card during the test, with subsequent-7-
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f removal of the tag after the test was completed. The data
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sheets used for this test indicated the caution card was not
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placed on the breaker. A note at the bottom of the data sheet indicated that no breaker existed for MCC 28-7.
Supervisory review of the data sheet did not intercept the act of not placing the caution card on the missing breaker. No other comment was made on the data sheet. The failure to identify this inadequacy is an example of inadequate supervisory review.
In reviewing the content of procedures DOS 6600-5 and 6, the inspector determined that the procedures in general were in-adequate for the following reasons:
In discussing the procedure with the licensee's shift a.
foreman, the foreman stated that only those portions of the procedure which were applicable were initiated be-cause to follow these procedures step-by-step, the breaker alignments for buses 23, 24, 23-1, 24-1, 28 and 29 would unnecessarily require lockout of redundant equipment simul-toaeously. This inedequacy contributed to the licensee's failure to follow the step by step procedure as required by the Technical Specification. The inspector queried the licensee representatives to find out why a knowingly inadequate procedure was being used. No comment or response was made
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by these people. In questioning management on this same subject during the exit interview, management also had no comment.
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In the step-by-step procedure portion of DOS 6600-5 (Section 13), the licensee ~is required to observe and record several equipment operations, including the LPCI and core spray motor operated valves lineup for injection. The power for the LPCI and core spray motor operated valves comes from motor control center No. 28-7 and No. 29-7.
The procedure does not specifically identify the requirement to observe the automatic transfer of power from bus 29 to bus 28 for the uninterruptable buses 28-7 and 29-7.
The equipment is designed such that in the event power to bus 23 is interrupted the redundant power supply from bus 28 will automatically supply power to buses 28-7 and 29-7 af ter a 15 second period without power. The licensee manually reclosed bus 29 to motor control center No. 29-7 in order to observe the proper LPCI valve lineup for injection because no power from bus 28 was available due to the breaker not being in service.
The procedure prerequisites, Item 3 of DOS 6600-5 stated:
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" Equipment lined up as listed in Appendix A, except as
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required by plant operation or mainteaance. Items not tested must be verified at another time to satisfactorily
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complete the bus undervoltage functional test. Equipment to be lined up to buses which will not be energized during test to allow normal plant operation." This prerequsite is not clear. No part of the procedure or data sheet is identifiable as Appendix A, and no exceptions to this lineup were identifiable.
The inspector discussed this procedural inadequacy during the exit interview and identified the using of an inadequate procedure as an item of noncompliance.
As a result of breexer 2871 not being in service during plant operations from December 6, 1977 to December 8,
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1977, the LPCI system would not have been available had a
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LOCA condition occurred simultaneous with a loss of power from motor control center No. 29.
The reactor was shutdown on December 8, 1977, and the condition was corrected.
On three (3) occasions the licensee had the opportunity to prevent this situation from occurring. These occasions (1) In October,1977 when breaker 2871 was improperly were:
removed; (2) during the equipment lineup and tagging as
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specified in the test procedure; and (3) when the licensee rediscovered breaker 2871 missing during the first test on December 4, 1977. This event clearly shows the consequence of the licensee's failure to use its quality assurance program. A previous inspection report identified four additional areas of noncompliance in the same general area of equipment outage control.
(IR 011/77-35-237/77-32; 249/77-30)
7.
Review of Plant Operations (Units 1, 2, and 3)
Throughout the month of December the inspector conducted a review of general plant operations, including examination of control room log books, shift engineer log books, equipment outage logs, special operating orders, and jumper and tagout logs including the period from September 1, 1977, to December 28, 1977. This review was conducted to confirm that facility operation is in conformance with the requirements established in the Technical Specifications, 10 CFR, and administrative procedures. The inspector also reviewed the licensee's deviation reports for this period. One area of concern relating to emergency power availability on Unit 3 was identified and is discussed in Paragraph 8.
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T T The inspector conducted a plant tour of all three units to
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determine that monitoring instrumentation is recording as
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required, radiation controls are properly established, house-keeping conditions are adequate, the existence of fluid leaks and pipe vibrations are minimal, pipe hanger and seismic restraint settings have proper oil levels, equipment caution or lockout tag information corresponds to that identified in the control room, and selected valve positions or equipment start position switches are correct. Discussions were conducted with the control room operators relating to the reasons for selected lighted annunciators. The inspector noted that control room manning at the time of the inspection was in conformance with the requirements of 10 CFR 50.54(k) and the facility's Technical Specifications.
During the tour the inspector noted that housekeeping conditions throughout the plant have improved in those areas identifiable in need of housekeeping attention. This was discussed at the exit interview.
8.
Loss of Unit 3 Emergency Power On December 28, 1977, while reviewing Units 2 and 3 control room panel lineup, the inspector discovered tLe Unit 3 diesel generator and Unit 2/3 diesel generator both disabled as a
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result of improper breaker lineup. Further investigation by the inspector indicated that at 0545 hours0.00631 days <br />0.151 hours <br />9.011243e-4 weeks <br />2.073725e-4 months <br /> the Unit 2/3 diesel generator was taken out-of-service for a monthly inspection.
At this time the operator on duty also inadvertently opened the Unit 3 automatic circuit breaker to bus 34-1 instead of opening the Unit 2/3 autonatic circuit breaker to bus 33-1.
These breakers are located on the Unit 3 panel in close proximity to each other. As a result of this personnel' error, both Unit 3 and Unit 2/3 diesel generators were out-of-service for a period of approximately three hours. This personnel error was identified as an item of noncompliance and was discussed at the exit interview.
In discussions with a licensee representative the inspector was informed that the licensee performs Dresden Technical Procedure (dip) No. 8 each normal working day when the unit is operating at greater than 1% rated power. This procedure requires that the lead engineer or his designee verify equipment status as identified in Table 1 of the procedure. Table 1, Item 6 requires checking the status of the diesel generator, the diesel generator bypass / normal switch position and the
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electrical bus feed to determine satisfactory position. In dis-
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cussions with the lead engineer responsible for this surveillance, he stated that between 7:00 to 7:30 a.m. he conducted his morning
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tour, looking at the Unit 2 and the Unit 3 panels. However, he stated he did not accomplish the surveillance as specified in Table 1, of DTP-8, because he felt that Table 1 of DTP-8 was only a guideline. As a result, the improper breaker alignment was not identified during the lead engineer's surveillance of the control room panels.
The failure to follow procedure DTP-8 was identified as an item of noncompliance and was discussed in the exit interview.
The inspector reviewed the Dresden Administrative Procedure (DAP) No. 3-5, Equipment out-of-service procedure and noted that Item 1.m.10 of the procedure requires independent verification that all outage tags have been properly placed. Additionally Step 1.r implies that the independent verification is required prior to beginning the work. A licensee representative stated that work was not started on the diesel generator until after 12:00 noon on the day the inspector identified the problem.
Licensee representatives stated that the independent verification was conducted prior to the start of work that same day.
In reviewing the out-of-service check sheet used to document
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compliance with procedure DAP 3-5, the inspector noted that no provisions existed to acknowledge accomplishment of the independent verification as identified in procedure DAP 3-5.
The problems identified with the method of independent verification is an unresolved item and will be revieaed in a future inspection. This matter was reviewed during a previous inspection and the licensee acknowledged that additional changes need to be made.
On December 29, 1977, the RIII office issued an immediate action letter regarding the disabling of the Unit 3 and Unit 2/3 diesel generators. The following actions were identified as being implemented:
A station operating order was issued on December 28, a.
1977, requiring a second individual to independently verify that equipment is taken in and out-of-service correctly. This order will only apply to safety-related equipment and will include valve and electrical operations.
This station operating order will serve as a temporary measure until Item 8.b has been concluded and the results of that Task Force implemented.
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An investigating Task Force, which has already been I\\
formed, will review this event and similar incidents and
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make recommendations to Company management to preclude
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similar problems. The Task Force is expected to have preliminary recommendations available for the scheduled January 10, 1978 meeting, between Commonwealth-Edison and NRC in the Region III office.
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9.
Review of Safety Limits, (SL), Limiting Safety System Settings (LSSS)
and Limiting Conditivas for Operations (LCO), Unit 1 A review of the Unit I routine operations (for January through December 1977), was made to determine that the licensee was complying with the Technical Specifications safety limits, limiting safety system settings, and limiting conditions for operations. The review included discussions with licensee personnel, direct observation of process instrumentation, review of instrument charts, startup reports and surveillance records.
No concerns were identified.
10.
Re"iew of Quality Assurance Program (Units 1, 2, and 3)
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The inspector conducted a review of the licensee's Quality
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Assurance progrm-and determined that the licensee's implementation
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and control of Quality Assurance Manual revisions was adequate.
The inspection revealed that procedures have been established and responsibilities assigned to personnel to assure that these controls are maintained.
A review of offsite audits and surveillance indicate a satisfactory level of implementation. No items of noncompliance or deviations were identified.
11.
Inoffice Review of Licensee Event Reports (Units 1 and 2)
The following licensee event reports were reviewed inoffice.
No concerns were identified.
Unit 1 LER No. 77-38, Channel 2 Excore Neutron Monitor Failed Downscale LER No. 77-40, Channel 1 Excore Neutron Monitor Failed
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LER No. 77-42, Scram Discharge Level Switch No. 264 Failed
- 1 LER No. 77-43, Reactor Pressure to Core Spray Header DP Switch
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LER No. 77-44, Emergency Condenser Condensate Outlet Valve No.
MO-101 Failed to Close Automatically Unit 2 I
LER No. 77-35, HPCI Valve 2301-8 Failed LER No. 77-39, Gasket Failure on Torus Drain Flange LER No. 77-43, Drywell High Pressure Switch Tripped LER No. 77-44, LPCI Logic DPIS 261-35B Failed LER No. 77-44, Drywell Snubber Failed LER No. 77-59, Failure to Perform HPCI Surveillance LER No. 77-60, Drywell CAM Isolation Valve Excessive Leakage
LER No. 77-61, Reactor Water Level Switch Setpoint Failed Specific comments regarding individual LER's are as follows:
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Regarding Unit 2, No. LER 77-35, the inspector identified in a previous inspection report (Inspection Report 237/77-24), the NRC's concerns with the repeated failure of the 2301-8 HPCI
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valve. The licensee's reponse to this inspection report (Letter Bolger, to Keppler, dated October 27, 1977), identifies the
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licensee's interim and long-term corrective action. Additionally, in a telephone conversation on November 2 and 3, 1977, the licensee committed to the following:
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As an interim measure during normal operations, the Unit 2 HPCI valve No. 2301-8 will remain open. Also, when this valve is used for any surveillance, the valve position will be visually verified at the completion of the surveil-lance. This commitment will remain in effect until the small motor modification is complete.
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To assure an acceptable X-area atmospheric condition, the Unit 2 X-area will be visually checked for steam leaks by the operator during daily rounds. This surveillance will continue until the new packing on valves 220-90 is verified to be adequate or until the 220-90 valves are replaced.
As a result of these commitments LER No. 77-35 is considered closed.
Regarding Unit 2, LER No. 77-46, the licensee determined by visual inspection, that two snubbers in the Unit 2 drywell had less s
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than the required amount of fluid. Both snubbers were bench
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tested. The bench test indicated that one of the two suspect
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snubbers was still operational. As a result of'a failure to one snubber, the licensee is required to reinspect these snubbers in a 12-month period.
As a result of the inspector's inoffice review, the inspector determined that one item of concern relating to Unit 2 had been properly identified and corrected by the licensee.
12.
Onsite Review of Licensee Event Reports (Units 1, 2, and 3)
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The following licensee event reports were reviewed for proper reporting requirements, corrective action, proper licensee review, and safety of operations.
Unit 1 LER No. 77-30, Failure of Channel 9 Reactor Period Monitor LER No. 77-31, Failure of Channel 3 Neutron Monitor LER No. 77-37, Reactor Pressure Switch Failed LER No. 77-39, Failure of Unit 1 B Core Stray Pump
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Unit 2
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LER No. 77-36, Failure of HPCI System LER No. 77-37, Failure of Recirculation Suction Valve 202-4B LER No. 77-41, APRM No. 5 Inoperative LER No. 77-42, Keeper Failure on Jetpump No. 4 LER No. 77-47, CRD Return Line Nozzle Crack LER No. 77-48, Cracked Weld in CRD Return Line to Reactor Vessel LER No. 77-49, Inadequate Welds on Torus Vent Header LER No. 77-51, Failure of Unit 2/3 Diesel Generator LER No. 77-54, CRD H5 Overtraveled LER No. 77-55, Unit 2/3 Diesel Generator Declared Operable Without Proper Testing LER No. 77-57, Potential Single Rod Withdrawal in Refuel Failure LER No. 77-66, Failure of Unit 2/3 Diesel Generator Cooling Water Pump Unit 3 LER No. 77-21, Pinhole Leak on Feedwater Line LER No. 77-37, APRM's 1 and 2 Failed t
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( 'g LER No. 77-38, Unit 3 Diesel Generator Cooling Water Pump
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Breaker Tripped
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LER No. 77-39, Reactor Level Switch Drift LER No. 77-40, MO-3-4102 Circuit Breaker Found in Of f Position LER No. 77-41, APRM's 4 and 6 inoperative LER No. 77-43, B Main Steam Line Radiation Monitor Failed High LER No. 77-44, Insufficient Diesel Generator Fuel for Unit 3 Diesel Generator LER No. 77-46, Improper Switching of LPRM's LER No. 77-47, Surveillance Interval Missed LER No. 77-48, Excessive Leakage in Drywell Floor Drains Comments on specific licensee event reports are as follows:
Regarding Unit 1, No. LER 77-39, the inspector informed the licensee that as Technical Specifications require only 2 core spray pumps be operable, the failure of the 3rd core spray pump was not a reportable event.
Regarding Unit 2, No. LER 77-41, the inspector determined that the licensee has set the LPRM fnput to a more conservative number. No further concerns were identified.
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Regarding Unit 2, LER No. 77-42, the inspector reviewed onsite television tapes of the restrainer clamp bolt keeper with a
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broken tack weld. The keeper was tack welded with 2 tack welds approximately 180 degress apart. No further concerns were identified.
Regarding Unit 2, LER No. 77-51, the licensee has committed to a weekly surveillance of all Unit 2/3 diesel generators. In addition, a failure analysis is being performed by the licensee.
Diesel generator failures, cause, and corrective action will be followed as an unresolved item.
Regarding Report Event No. 237/77-55, the licensee described how Unit 2/3 diesel generator was declared operable after com-pletion of two separate work items; (1) Work on the diesel turbo charger and (2) work on the auto start relay. An operability test consisting of manual starting was performed on the diesel, however, the auto start relay was not tested prior to returning the diesel generator to service. The cause code for this event was identified as personnel error. The corrective action was inadequate in that maintenance foreman was identified as being at fault while, in reviewing this event the inspector t
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determined that the shif t engineer had prime responsibility
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to review the work request for any work that was being performed on the diesel generator prior to returning the diesel to service.
In reviewing the problem further, the inspector determined that verbal communications were used to clear the outage tags relating to the auto start relay work, contrary to QP 3-51.
Further investigation by the inspector indicated that the work acccmplished on the auto start relay was accomplished in accordance with a modification package. The modification package included 39 other relays relating to Unit 2.
The licensee's program does not allow partial closure of a modifica-tion package and-return to service of specific affected equipment without signing the single work request in the mod package that identified all work relating to the mod package as complete and all tests accomplished.
To compensate for this the licensee identifies the work and test requirements for each piece of equipment on a " work traveler." The work traveler however, stays with the modification package and is not reviewed until the entire modification is completed. As a result, the specific test requirements relating to the Unit 2/3 diesel generator auto start relay, remained in the incomplete modification package.
This package was not completed until December 4,1977. The licensee's failure to follow DAP No. 15-1, requiring review of
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the work for completeness and final test completion prior to returning equipment to service is an ites of noncompliance and was discussed at the exit interview.
Regarding Unit 3, LER'u No. 77-37 and No. 77-41, the inspector determined that the licensee has set the APRM inoperable circuits in a conservative direction. The number of LPRM inputs is now set at 8 to 9 instead of 11 to 12 in order to indicate APRM f ailure or APRM problems well before the 50%
trip setpoint is exceeded. No further concerns were identified.
During the onsite review of the licensee event reports, the inspector determined that the licensee identified and corrected 4 items of concern. No further concerns were identified.
13.
NRC Management Meeting at the Dresden Nuclear Power Station A meeting was conducted on December 7,1977, with Station management, to discuss the significance of events occurring
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at the Commonwealth Edison Nuclear Generating Stations. The
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inspectors also discussed the augmented inspection program and outlined the areas of concern at the excessive number of problems recently identified with the equipment out-of-service program at the Dresden Nuclear Power Station.
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14.
Review of Unit 2 Flow Bias Calibration The inspector reviewed the recent Unit 2 APRM flow bias system calibration (DIS 700-1), to detarmine the cause of a licensee identified high setpoint on the APRM and RBM safety limit.
The review indicated that while the procedure could have been clearer, a licensee representative failed to adhere to the "as
left" flow converter setpoint acceptance criteria and as a result the safety limit setting was nonconservative by approximately 30.
The inspector determined that at no time did the licensee exceed
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the Technical Specification limit due to planned for conservative measures. The above described failure to adhere to procedure was identified as an item of noncompliance requiring no further response, based on a licensee commitment made during the exit interview conducted on December 28, 1977.
15.
Unit 2 Inadvertant Insolation of the Standbv Liquid Control System. (SLCS) Suction Line
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On January 6,1978, the licensee reported to the RIII office via telephone that on January 5,1978, during a plant tour, a group of students from the General Electric Simulator School found I
the suction valve (No.1101-4) from the SLCS tank unlocked and closed. The instructor from the school contacted the shift engineer and immediate corrective action was implemented.
On January 10, 1978, the inspector reviewed the above described finding, including the last Dresden Operating Surveillance (DOS)
No.1100-1 conducted on December 18, 1977. No adverse findings, redarding the surveillance tests were identified.
In discussions with a licensee r cresentative the inspector noted that the key (identified as an "O" key) used to remove the lock on the SLCS valves is loosely controlled in that the key is avail-able in the Shift Engineers office or off the shift engineer's personal key ring. A licensee representative stated that the only reason for locking the valves is to remind personnel of the need to pay special attention to the system valving requirements.
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From the inspector's review and the available records onsite, it
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appears that valve No. 1101-4 was unlocked and closed, sometime
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between December 22, 1977 when the valving was checked by the NRC inspector and January $, 1978, by a person or persons unknown.
The closure of valve No. 1101-4 resulted in isolation of the SLCS storage tank and defeating of the standby Liquid Control System.
This is contrary to Technical Specifications, Section 3.4.A and is an item of noncompliance.
16.
Exit Interviews a.
Exit Interview on December 2,1977 On December 2, 1977, the inspector met with licensee representatives denoted in Paragraph I at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection. The licensee represent-ative made the following remarks in response to one area of concern discussed by the inspector.
Stated that, as a result of the recent increase in diesel generator failure, the monthly surveillance operability of the Units 2, 2/3, and 3 diesels will be increased to a
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weekly surveillance until the diesel generator problems
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have been resolved.
b.
Exit Interview on December 8, 1977 During an exit interview on December 8, 1977, the inspector discussed the significance of the failure to identify the operating condition of breaker 2871 on motor control center No. 28.
The inspector stated that this problem area is an unresolved item and will be reviewed further.
c.
Exit Interview on December 15, 1977 The inspector met with licensee representatives (denoted in Paragraph 1), at the conclusion of the inspection on December 15, 1977. The inspector summarized the scope and findings of the inspection. The licensee representative made the following remarks in response to certain items discussed by the inspector:
Acknowledged the statement by the inspector with respect to items of noncompliance identified in Paragraph 6.
Stated that management has recognized certain inadequacies in equipment out-of-service progtsm, and stated that a revision is being written to rectify these problems.
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Made no comment relating to licensee personnel knowingly
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using insdequate procedures without attempting to correct
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them.
Stated tist a previous commitment (Inspection Report No.
010/77-33; No. 237/77-29; and No. 249/77-27) to implement a program by December 31, 1977, to properly identify and control recorder charts, will not be completed by the above specified date. However, interim measures for this control appear to be working. Final resolution of this problem will be accomplished as soom as practicable.
c.
Exit Interview on December 28, 1977 The inspector met with licensee representatives noted in
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Paragraph 1, at the conclusion of the inspection on December 28, 1977. The inspector summarized the scope and findings of the inspection. The licensee made the following remarks in response to certain items discussed
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by the inspector:
Acknowledged the statements by the inspector regarding the noncompliance identified in Paragraphs 8 and 14.
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Stated that a investigative task force has been appointed to review the recent noncompliance identified at the Dresden site.
Stated that as an interim measure, all safety related equipment taken out-of-service will be reviewed by in-dependent verification.
Stated that the APRM flow bias procedure identified in Paragraph 14 will be revised to increase clarification and that an independent review of the test will be accomplished by the nuclear engineer, including proper signoff.
I d.
Exit Interview on Januarv 5, 1978 The inspector met with licensee representatives noted in Paragraph 1, at the conclusions of the inspection on January 5, 1978. The inspector summarized the scope and i
findings of the inspection. The licensee made the fol-lowing remark to one item discussed by the inspector.
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Acknowledged the second noncompliance identified in
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Paragraph 8.
Stated that the intent of the procedure was
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to provide a guideline for the lead engineer and was not intended to be a requirement.
I e.
Exit Interview on January 10, 1978 The inspector met with licensee representatives noted in Paragraph 1, at the conclusions of the inspection on January 10, 1978. The inspector summarized the scope and findings of the inspection. The licensee had no comment.
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