IR 05000010/1978008
| ML19340A888 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/08/1978 |
| From: | Knop R, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A886 | List: |
| References | |
| 50-010-78-08, 50-10-78-8, 50-237-78-08, 50-237-78-8, 50-249-78-07, NUDOCS 8009040708 | |
| Download: ML19340A888 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
i Report No. 50-16/78-08; 50-237/78-07; 50-249/78-07 Docket No. 50-10, 50-237, 50-249 License No. DPR-2, DPR-19, DPR-25 Licensee: Cormonwealth Edison Company Post Office Box 767 Chicago, IL 60690
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Facility Name: Dresden Nuclear Power Station, Units 1, 2 and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted: February 2, 3, 7, 8, 14, 15 and 22-24, 1978 iRC* &
3"8-7 Inspector:
W. t. Shafer
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Approved by:
R. C. Kno, Ch Reactor Projects Section 1 Inspection Summary Inspection on February 2, 3, 7, 8, 14, 15 and 22-24, 1978 (Report No.
J 50-10/78-08; 50-237/78-07; 50-249/78-07)
Areas Inspected: Routine, unannounced inspection of previous inspec-tion findings, review of outstanding items, closecut of immediate action letter, review of the plant operations, review of work request program, training records, rad protection training, calibration of Unit 1 instru-mentation, review of Unit 1 procedures, and a plant tour. The inspection involved 86 inspector-hours on site by one NRC inspector.
Results: Of the ten areas inspected, no items of noncompliance or devi-ations were identified in eight areas. One apparent noncompliance (deficiency - failure to conduct an orderly shutdown as a result of Unit-2 high primary coolant conductivity); and one apparent nenecmpliance (deficiency - failure to maintain records of all completed safety-related work, Units 1, 2 and 3) were identified.
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DETAILS
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persons Contacted a.
Exit Interview Conducted on February 2, 1978
- B. Stephenson, Station Superintendent
- A. Roberts, Assistant Station Superintendent
- B.
Shelton, Administrative Assistant
- D. Farrar, Technical Staff Supervisor
- R. Ragan, Lead Operating Engineer
- J. Eenigenburg, Maintenance Supervisor
- C. Lawton, Office Supervisor
- G. Reardanz, Quality Assurance Operations
- R. Kyrouac, Quality Control Supervisor
- R. Falbo, Assistant Office Supervisor The inspector also contacted several other licensee employees including staff engineers, shift engineers, shift foremen, and Nuclear Station Operators.
- Denotes those present at the exit interview.
b.
Exit Interview Conducted on February 8, 1978
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- B. Stephenson, Station Superintendent
- A. Roberts, Assistant Station Superintendent
- B.
Shelton, Administrative Assistant
- R. Ragan, Lead Operating Engineer
- D. Farrar Technical Staff Supervisor
- G. Reardanz, Quality Assurance Operations
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- Denotes those present at the exit interview.
c.
Exit Interview Conducted on February 15, 1978
- A. Roberts, Assistant Station Superintendent
- R. Ragan, Lead Operating Engineer
- D. Farrar, Technical Staff Supervisor
- R. Kyrouac, Quality Control Supervisor
- R. Falbo, Assistant Office Supervisor
- Denotes those present at the exit interview.
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Exit Interview Conducted on February 24, 1978
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- B. Stephenson, Station Superintendent
- B.
Shelton, Assistant to the Station Superintendent
- R. Ragan, Lead Operating Engineer
- 0. Doubb, Quality Assurance
- C. Young, Corporate Of fice
- R. Kyrouac, Quality Control Supervisor
- Denotes those present at the exit-interview.
2.
Licensee Action on Previous Inspection Findings (Units 1, 2 and 3)
(Closed) - Noncompliance (249/77-15):
Failure to report exceeding limiting conditions for operation.
Since the occurrence of this
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noncompliance the inspector has noted that no repetitive failures have occurred.
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(Closed) - Noncompliance (249/77-21): Failure to follow quality procedures regarding use of nonsafety related components in a safety-relsted system. The inspector reviewed the licensee's warehouse procedure (DWP-10) without comment.
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(Closed) - Noncompliance (010/77-23; 237/77-21):
Failure to
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conduct adequate testing of components of safety-related components
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after completion of maintenance work. The inspector reviewed numerous licensee work requests and determined that equipment requiring tests af ter maintenance is being completed.
(Closed) - Noncompliance (237/77-24; 249/77-24): Failure to maintain secondary containment integrity. The inspector noted that when secondary containment doors are found inoperable a guard is dispatched to the doors to control egress and access.
(Closed) - Noncompliance (010/77-27; 249/77-24): Failure to conduct surveillance within the required frequency.
The inspector noted that the licensee has improved their computer printout on all surveillance and that the licensee represen-tative is tracking required surveillance as committed to by the licensee in their response to this noncompliance.
(Closed) - Deviation (010/77-22; 237/77-29; 249/77-27); Failure to m2intain adequate housekeeping. The inspector noted that the licensee has implemented procedures regarding housekeeping
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f and implant storage. Housekeeping at the site has improved con-
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siderably, however, continued NRC surveillance will be conducted
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periodically.
3.
Resolution of Outstanding Items (Units 1, 2 and 3),
In a previous inspection report (249/77-09), the inspector iden-tified several concerns relating to high energy pipe line protection.
The following is the licensee's response to these concerns.
Regarding impingement protection for essential service cable and ESS-2, the licensee stated that restraints for cable pan ESS-2 will be installed at location HPCI L-4 during the Unit 3 refueling l
outage scheduled for March, 1978.
Regarding the 1/2 inch wedge anchor bolt missing for a wall-mounted angle iron, the licensee has reviewed the need for this bolt and has issued an engineering change notice to delete the 1/2 inch bolt requirement.
Regarding the feedpump suction valve gland leakoff dripping on the floor mounted attachments for PWFW-2 and 3, the licensee
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installed a split shield to protect against corrosion. However, upon investigation the inspector noted that leaking sti'll drips
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down to the split shield and then onto the floor mounted attach-ments.
In further discussions with the licensee representative,
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the inspector found that a work request (No. 924) has been issued to resolve this problem.
In a letter (Turbak to Davis, dated May 10, 1977), the licensee committed to perform a detailed inspection on four control rod drive units which experienced uncoupling. The inspector reviewed l
the licensee's data sheets and determined that full compliance to the commitment was achieved.
In a previous inspection (010/77-33; 237/77-29; 249/77-27), the licensee stated that a review program would be initiated to determine whether all vendor drawings have been updated as a result of previous design change modifications. The inspector reviewed the licensee's program and determined that the vendor drawings have been audited and updating is in progress. The licensee utilizes indexing card systems to track vendor drawings.
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In a letter (Keppler to Lee, dated November 9, 1977), the RIII
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office documented the following commitments made by the licensee:
a.
As an interim measure, during normal operation, 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 surveillance.
This commitment will rer,ain in effect until a small motor modification is complete.
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b.
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 valve 2-220-90 is verified to be adequate or until the 2-220-90 valves are replaced.
The inspector noted that the additional surveillance is being conducted as committed to.
4.
Review of Licensee's Response to Immediate Action Letter (IAL)
dated December 29, 1977 An immediate action letter was issued to the licensee by the RIII
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office regarding the rendering of Units 3 and 2/3 diesel generators
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inoperative on December 28, 1977. The followings actions were identified:
a.
A station operating order was issued on December 28, 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
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ine :de valve and electrical operations.
This station operating order will serve as a temporary measure until item 2 has been concluded and the results of that task force implemented.
b.
An investigating task force, which has already been formed, will review this event and similar incidents and make
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recommendations to company management to preclude similar problems. A task force is expected to have preliminary recommendations available for the scheduled January 10, 1978 meeting between Commonwealth Edison and the NRC in the RIII
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office.
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The inspector reviewed the licensee's out-of-service program
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and determined that independent verification is being con-
ducted. No concerns were identified.
Regarding item 2 of the IAL, the inspector noted that an investi-gating task force is conducting extensive reviews at the Dresden site. No concerns were identified. Further review regarding the task force recommendations will be conducted during routine inspections.
5.
Review of Plant Operations (Units 1, 2 and 3)
Throughout.the month of February, 1978, the inspector conducted a review of control room log books for all three units including the shift engineer log books, deviation reports, routine patrol
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logs, out-of-service equipment outage log, and jumper and bypass log for the same period. The following concern was identified:
On February 12, 1978, the Unit 2 control room log book indicated that resin intrusion had occurred at 0425 a.m.
The log book at this time also indicated that a primary water conductivity sample was taken and the conductivity
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was determined to be 9.2 micromoes per em (umholem).
Technical Specifications Section 3.6.C.4 requires that the primary water conductivity not exceed 5 micromoes
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per cm with steaming rates greater than or equal to 100,000 pounds per hour. At the time of this occurrence, the steaming rate for Unit 2 was well above 100,000 pounds per hour. The inspector noted that the resin intrusion caused a decrease in power, however, the Unit 2 log book indicated that power was being held at steady state with no indication that an orderly shutdown had been initiated as required by Technical Specification Section 3.6.C.5.
The log book indicates that the primary water conductivity was in excess of the Technical Specification limiting con-dition for a period of approximately two hours.
During the
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exit interview the inspector informed the licensee that failure to comply with Technical Specifications Section 3.6.C.5 is an item of noncompliance, requiring no further response.
6.
plant Tour The inspector conducted a plant tour of the Unit 2 and 3 reactor building. During the plant tour the inspector noted that several
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7m work projects were in progress at the time.
In discussions with
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work personnel, and with the shift engineers office, the inspector
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determined that management had adequate knowledge of the ongoing work through the licensee's work permit program. In reviewing the work permit program the inspector noted that the work permit program appears to become progressively cumbersome, particularly when work projects continue for periods of weeks and months.
During the exit interivew the inspector cautioned the licensee that the daily work permit program appears to require considerably more paper work than necessary.
It was suggested to the licensee that a simpler method of tracking working personnel in the plant be found.
During the tour the inspector visually observed several maintenance projects that were progressing at the time.
No significant con-
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cerns were identified.
During the tour of the Unit 2 and 3 reactor building the inspector determined that the licensee has made considerable improvement in their housekeeping and storage. However, the inspector also noted that it appeared the work is still incomplete in that material that once was previously strewn throughout the building is now packed in various containers and still remains in the general area of the pickup. The inspector discussed the licensee's requirements regarding the total cleanup and suggested that material no longer
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necessary be removed from the reactor building.
The licensee's housekeeping and storage conditions will remain open and shall be reviewed in future inspections.
7.
Special Review of Licensee's Work Request program (Units 1, 2 and 3)
The inspector conducted a review of the licensee's work request program to determine if work performed on the units primary con-tainment isolation valves was being followed up by a time test in order to assure proper valve operation within the required time. A total of 12 work requests were issued relating to the primary containment valves since November of 1977. Of these 12 work requests, the inspector noted that 2 work requests relating to Unit 2 primary containment isolation valves, did not specify the required time testing. Further review by the inspector regarding these 2 work requests, indicated that the Unit 2 quarterly time testing of the valves were conducted immediately prior to reactor startup and that the 2 work requests in question had been completed prior to the quarterly test. As a result of
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performing the quarterly tests, the timing requirements for these
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2 valves were satisfactorily tested. No further concerns in this
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area were identified.
Further review of the licensee's work request program was conducted to determine if work performed on safety-related systems was being documented and retained as required in Technical Specifications Section 6.5.A.2.
During this inspection the inspector noted that the shift engineer has primary responsibility for assigning work request numbers. However, the shift engineer's log does not
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identify work requests that are safety-related. The Dresden facility processes approximately 11-12,000 work requests in one year and the safety-related work requests, which amount to approximately 1,000 per year, are interspersed throughout the shift engineer's work request log book. Further review indicates that the quality control department maintains an ur. official record of safety-related work requests. Through random sampling methods, the inspector identified 131 safety-related work requests in the QC unofficial log. Of the 131 work requests identified, the quality control unofficial log indicated that 59 of these work requests were still open (ie work in progress or package being processed). The 131 work requests identified in the QC log were cross checked against the official shift engineers log. According to the shift engineer's log, only 30 of the 131 work requests were still open.
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Of the 30 work requests identified as open by the official log, the inspector was able to determine that 27 of these work requests were under the control of various departments within the Dresden facility. Of the three remaining work requests, WR's No. 3789 and No. 1397 were identified by the maintenance department as having been accomplished, however no records were available. The final work request No. 2769, relating to installation of fire stops.
ould not be found.
Of the 131 work requests tracked, the licensee's official log indicated that 101 of these work requests were closed and were either in the record retention and retrieval office or in some-one's personal possession. By discussion with licensee represen-tatives and department heads, the inspector determined that the following 8 work requests packages were not being maintained as lifetime records:
Nos. 1064, 8505, 776, 3255, 9768, 11196, 395, and 9622. The inspector noted that with the 8 missing work requests, and the
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3 missing work requests identified as still open, it appears that
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approximately 10% of the sample taken is not being properly
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controlled.
The licensee does not maintain an official record of safety-related work requests which clearly identify and control the work requests to assure they are maintained as required.
Each department within the facility appears to have their own tracking system, however, once the work requests leave a specific department, methods of control do not appear to be adequate.
Upon receipt of a closed work request, in the record reten-tion area, the licensee documents the receipt of the work request, however, no tracking system is available for the
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licensee to review to assure that all safety-related work requests that were issued, were received and properly stored.
The inspector noted that once a work request is issued to various departments, the work request can be held for periods of up to several years as a result of priority or procurement problems.
It appears that it is up to the specific depart-ment involved to assure that the work identified on that work request is ultimately done. It also appears that in some
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cases these work requests disappear, requiring the licensee
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to rely on memory alone as to whether the work was ever accomplished. The inspector noted that some work requests still in department hands were identified as urgent, however, the work had still not been accomplished.
It is also questionable as to whether the management review of the specific work request was still adequate several years after the work request was initiated.
During.ne exit interview, the inspector informed the licensee that the failure to maintain lifetime records on all safety-related work requests is an item of noncompliance.
It was recommended to the licensee that a thorough review of the method for controlling work requests be conducted.
On February 24, 1978, the inspector was informed by the licensee that all the above mentioned work requests with the exception of numbers 11196, 3789, 1397, 2769, and number 395 have been located and are no longer considered missing. The licensee also informed the inspector that the following corrective actions will be imple-mented in order to upgrade control of the work request program.
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m The licensee stated that effective April 1, 1978, the quality
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control department will maintain an official record of all
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safety-related work requests. Furthermore, the licensee will cancel all safety-related work requests that were issued prior to the year 1976. The licensee will require anyone holding a 1976 or earlier work request, to resubmit this work request for an update and review to determine the need to accomplish the work. Also in the future all work requests will remain valid for a period of two calendar years.
This update will be completed by June 1, 1978.
As a result of the licensee's above described commit'ments the inspector informed the licensee at the exit interview that no further response would be necessary for this item of noncompliance.
The licensee's compliance to these commitments will be followed up in a future inspection.
8.
Review of Training Records (HO Request)
The inspector reviewed the training records of a Dresden licensed operator to determine if the licensee had performed reactivity changes in accordance with the Code of Federal Regulations.
The inspector reviewed the licensee's training records (DPP 505) and
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determined that the required reactivity changes and participation
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in reactor startups had been accomplished as required. No concerns were identified.
9.
Rad protection Training
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The inspector attended a tape presentation of the licensee's rad protection requalification program. The program presentation included a description of the plant layout, a basic explanation of a power reactor, plant safety, emergency procedure, and review of the basic radiation protection. No concerns were identified.
10.
Review of Unit 1 Procedures The inspector reviewed the licensee's program for control of procedures and determined that proper reviews and approvals were accomplished in accordance with the Technical Specifications. The inspector also determined that the technical content of the licensee's procedures appeared adequate and overall procedure content was con-sistent with the Technical Specification requirements. No concerns were identified.
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Calibration of Unit 1 Instrumentation
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The inspector, reviewed the licensee's program for the Unit 1
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calibration to determine whether the calibration of components and I
equipment associated with safety-related components should be safety-related systems and/or functions not identified in the Technical Specifications as requiring calibration at a specific frequency are calibrated. The review consisted of verifying
' he f requency of calibration, acceptance values, detailed step-
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i vise instructions, and review of procedures used to calibrate the components. The technical content, component trip points
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and' calibration instruments appeared adequate. The inspector also witnessed calibration in progesss at the time of this
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inspection.
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The inspector noted that while the licensee has identified all
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yet been calibrated nor have procedures been written for them.
The inspector informed the licensee that the program will be reviewed upon completion and remains an unresolved item until i
that time. No items of noncompliance or deviations were iden-i tified.
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12. General
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During the inspection the licensee requested an extension to their commitment relating to the diesel generator failure analysis. The licensee stated that the report would be sent to the RIII office by March.3, 1978.
As a result of high temperature on the pilot valve for one main
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steam isolation valve on Unit 1-2, the licensee has scheduled a maintenance outage for Febtuary 25 and 26, 1978.
Further discussions with the licensee on February 27, 1978, indicate that the problem has been resolved and normal operations has
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resumed.
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Exit Interviews 4-j-
Exit Interview for February 3. 1978
The inspector met with licensee representatives noted in l
paragraph 1.a at the conclusion of the inspection on February 3, 1978. The inspector summarized the scope and findings of the inspection. The licensee had no comment.
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Exit Intarview (February'8, 1978)
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The inspector met with licensee representatives noted in paragraph 1.b at the conclusion of the inspection on February 8, 1978. The inspector summarized the scope and findings of the' inspection.
The licensee made the following comment to one area of concern identified by the inspector.
Stated that an investigation would begin to determine the adequacy of controlling work requests (Paragraph 7).
Acknowledged the inspectors comment that reviews be con-ducted.
Exit Interview (February 15, 1978)
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The inspector met with licensee representatives noted in paragraph 1 at the conclusion of the inspection on February 15, 1978. The inspector summarized the scope and findings of the inspection.
The licensee made the following comment.
Stated that the Technical Specification requiring an orderly shutdown whenever the primary water exceeds 5
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micromoes per em was discussed by the Acting Plant
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the high conductivity was attributed to the resin intrusion problem and the fact that the conductivity was improving, the decision to continue reactor oper-ations was made (Paragraph 5). The inspector stated that the licensee's Technical Specifications do not allow for this type of analysis or determination.
The inspector discussed with licensee representatives the need for resolution of the cable separation problem on Units 2 and 3 as identified in a letter to the licensee from NRR. The i
licensee representative stated that a final resolution of this i.
problem cannot be accomplished until procurement of the acceptable cable (July 1, 1978) and a new battery charger (Septerber 1, 1978).
The inspector informed the licensee that this information would be forwarded to HQ for determination of acceptability.
Exit Interview (February 24, 1978)
The inspector met with licensee representatives noted in paragraph 1 at the conclusion of the inspection on February 24, 1978. The
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inspector summarized the scope and findings of the inspection. The
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licensee made the following comments:
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Acknowledged the item of noncompliance identified in paragraph 7 and stated the necessary corrective action will be implemented as identified in that paragr2ph.
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