IR 05000010/1981006

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IE Insp Repts 50-010/81-06,50-237/81-13 & 50-249/81-08 on 810404-0508.Noncompliance Noted:Failure to Follow Chemistry Procedure & Improper Valve Lineup
ML17252A732
Person / Time
Site: Dresden  
Issue date: 06/18/1981
From: Jordan M, Reimann F, Tongue T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17252A730 List:
References
50-010-81-06, 50-10-81-6, 50-237-81-13, 50-249-81-08, 50-249-81-8, NUDOCS 8107140764
Download: ML17252A732 (10)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Reports No. 50-010/81-06; 50-237/81-13; 50-249/81-08 Docket Nos.50-010; 50-237; 50-249 Licenses No. DPR-02; DPR-19; DPR-25 Licensee: *Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 Facility Name:

Dresden Nuclear Power Station, Units 1, 2, and 3 Inspection At:

Dresden Site, Morris, IL Inspection Co~duc ed:

April 4 through May

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Inspectors:

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Approved By: *F. W. Reimann, Acting Chief Reactor Projects Section lC Inspection Sununary 8, 1981

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Inspection on April 4 through May 8, 1981 (Report No. 50-010/81-06; 50-237/81-13; 50-249/81-08)

Areas Inspected:

Routine unannounced resident inspection of operational safety verification, monthly maintenance obstruction, monthly surveillance observation, licensee event reports followup, previously identified open inspection items, plant trips, surveillance - refueling, maintenance,- refu'eling, and inspection during long term shudow This inspection involved 244 inspector-hours onsite by two NRC inspectors including 63 inspector-hours onsite during off-shift Results:

Of the nine areas inspected, two items of noncompliance were identified in two areas (Section 2, failure to follow procedure and Section 9, improper valve lineup) and no items of noncompliance were identified in seven areas, 8107140764 810701 PDR ADOCK 05000010 G

PDR

e-DETAILS Persons Contacted

  • D. Scott, Station Superintendent
  • R. Ragan, Operations Assistant Superintendent J. Eenigenburg, Maintenance Assistant Superintendent
  • D. Farrar, Administrative Services and Support Assistant Superintendent J. Brunner, Technical Staff Supervisor C. Sargent, Unit 1 Operating Engineer J. Wujciga, Unit 2 Operating Engineer M. Wright, Unit 3 Operating Engineer E. Budzichowski, Unit Support Operating Engineer D. Adam, Waste Systems Engineer G. Myrick, Rad-Chem Supervisor B. Saunders, Station Security Administrator
  • E. Wilmer, QA Coordinator The inspector also talked with and interviewed several other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, contract security personnel, and contractor construction personne *Denotes those attending one or more exit interviews conducted on April 10, 17, 24, May 1 and 8, 198.

Operational Safety Verifica'tion The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of April 4 through May 8, 198 The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component Tours of Unit 3 reactor buildings and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc While walking down the Unit 3 ECCS System panels in the control room on April 17, 1981, the SRI noted that the Torus Hi level alarm was alarming, indicating excessive water in the toru Upon questioning the alarm con-dition the NSO stated that someone was probably sampling the torus, but had not informed the control roo Later review showed this was tru Interviews with several NSO's, Shift Engineers, revealed that this situa~

tion occurs frequently when sampling-the torus, Isolation Condenser, Offgas System and Drywel Procedures DCP 1600-9 and 10, for sampling torus water on Units 2 and 3 respectively, direct the person drawing the sample to notify the control

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room prior to drawing a torus sample, and upon completion of the samplin Through interviews with licensee employees, it was found that the control room operator is frequently not informed when sampling is complete Review of the procedures also revealed that the Unit 2 torus shoud be sampled via the torus drain line and Unit 3 torus should be sampled via a connection from the discharge of the ECCS fill system pum If sampling is done*per procedure the Hi level alarm should not actuate in the control room, which further indicates that the sample drawn on April 17 was taken from an instrument line and not as directed in the procedur RCT personnel also informed the inspector that control room operators often do not inform their relief personnel that such sampling operations are in progres Since sampling the above mentioned systems is a change in the valve configuration on ECCS systems and primary* con-tainment boundry it is extremely important that proper procedures be followed and effective cominunications be maintaine This occurance is in noncompliance with Technical Specification 6.2.A.7 and the Dresden Chemistry Procedure (50*249/81-08-01)

The inspector also noted that different sample points are used on each of the two identical units to draw torus sample This item will be followed up in a future inspectio (50-249/81-08-02)

The inspector by observation and direct inter~iew verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping/cleanliness conditions and verified implementation of radiation protection control During the period of April 3 through May 8, 1981, the inspector walked down the accessible portions of the Unit 2 Standby Liquid Control, LPCI and Core

. Spray systems to verify operabilit The inspector also witnessed por-tions of the radioactive waste system controls associated with radwaste shipments and barrelin These reviews and.observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure One item of noncompliance was identifie.

Monthly Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review:

the limiting conditions for operation were met while components or systems were

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  • removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by quali-fied personnel; parts and materials used were properly certified; radio-logical controls were implemented; and, fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activity was observed/reviewed:

Unit 2/3 Diesel Generator Following completion of maintenance on the Unit 2/3 Diesel Generator, the inspector verified that this system had been returned to service properl No items of noncompliance were identifie.

Monthly Surveillance Observation The inspector observed technical specifications required surveillance testing on the Unit 3 HPCI Quarterly Flow Test, HPCI Monthly Test, and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the.testing were properly reviewed and resolved b' appropriate.management personne The inspector also witnessed portions of the following test activities:

Unit 3 HPCI Valve Operability Test

!RM Calibration LPRM Calibration Turbine First Stage Pressure Scram Bypass Main Steam Line Low Pressure Isolation Unit 2/3 Diesel Generator No items of noncompliance were identifie.

Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine

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that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification Unit 2 80-30 80-31 80-32 80-33 80-34 80-35 80-.36 80-37 80-38 80-39 80-40 80-41 81-02 81-08 Unit 3 80-34 80-35 80-36 80-37 2A - LPCI Pump Seal Leak (closed)

U-1 Diesel Fire Pump was unavailable greater then seven days per T. S. Limit (closed)

Fire Pump Diesel Enginer - Day Tank - oil samples not taken

. on 30 day interval (closed)

2B LPCI heat exchanger was taken out of service to investi-gate possible tube leaks and cleaning (closed)

Fire system annual flush record missing for 1979 (closed)

Control Room and Computer Room Smoke Detectors out of service (closed)

Cardox Heat Detectors Surveillance not perf ommed at proper time interval (closed)

Control Rod G-8 Overtravel Uncoupled (cl~sed)

Controlled Rod C-11 Overtravel,uncoupled (closed)

HPCI MO 2-2301-4 (Inboard Steam Valve} Failure (closed)

Control Rod G-8 Overtravel - Uncoupled (closed)

Reactor Building and Refuel Floor Area Radiation Monitor set.point draft (closed)

LPCI Valve MO 2-l501-20B Failed to Operate (closed)

MSIV 2-203-2B Failure to Pass LLRT (closed)

"B" Recirc Pump,Runback (closed)

2/3 B SBGTS Failure to Start (closed)

RBM No. 7 Flow Control Trip - reference card failure (closed)

Reactor Vessel Low Water Level Scram and Isolation set point drift (closed)

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80-38 80-39 80-40 80-41 81-02 81-06 81-10 81-11 Leak in Reactor Water Clean-Up Heat Exchanger Equalizing Line (closed)

Isolation Condenser Inboard Valve 3 - 1301-1 failed to close during Valve Operability Test (closed)

Failure of HPCI 3-2301-4 Valve to Open (closed)

Isolation Condenser Vent Valve 3-1302-20 found shut (closed)

Reactor Water Level Switch LIS 3-263-58A set point drift (closed)

SBLC Tank Low Temperature (closed)

HPCI Steam Piping did not meet SSE operability criteria (closed)

MSIV 3-203-lC Fast Closure (closed)

LER's 50-237/80-33 and 50-237/80-41 were previously reviewed by a Region III Radiation Specialist and were addressed in IE Inspection Report 50-237/81-0 LER's 50-237/80-31; 50-237/80-32; 50-237/80-34 and 50-237/80-35 were reviewed* by a Region III inspector and will be addressed in IE Inspection Report 50-237/81-0 No items of noncompliance were identifie.

Previously Identified Open Inspection Items Open inspection items 50-249/81-03-01 and 50-249/81-03-02 were replaced by Licensee Event Report Nos. 50-249/81-06/036-0 and 50-249/81-11/036-0 respectivel These open items and LER's were reviewed by the SRI as stated in the previous report section and are considered close.

Plant Trips Following the plant trips on Unit 3 on April 17, 1981 the inspector ascertained the.status of the reactor and safety systems by observation of control room indicators and discussions with licensee personnel con-cerning plant parameters, emergency system status and reactor coolant chemistr The inspector verified the establishment of proper communica-tions and reviewed the corrective actions taken by the licensee; All systems responded as expected, and the plant was returned to operation on April 17, 198 No items of noncompliance were identifie. Surveillance - Refueling The inspector observed the LPRM Amplifier calibration surveillance, HPCI Automatic Isolation, HPCI Automatic Initiation, and Pressure Suppression Pool Vent Valve Operability testing on Unit 2 to verify that the tests were covered by properly approved procedures; that the procedures used were consistant with regulatory requirements, licensee commitments, and administrative controls; that minimum crew requirements were met, test prerequisites were completed, special test equipment was calibrated and in service, and required data was recorded for final review and analysis; that the qualifications of personnel conducting the test were adequate; and that the test results were adequat No items of noncompliance were identifie Maintenance - Refueling The inspector verified maintenance procedures include administrative approvals for removing and return of systems to service; hold points for inspection/audit and signoff by QA or other licensee personnel; provisions for operational testing following maintenance; provisions for special authorization and fire watch responsibilities for activities involving welding, open flame, and other ignition sources; reviews of

. material certifications; provisions for assuring LCO requirements were met during repair; provisions for housekeeping during and following maintanence; and responsibilities for reporting defects to managemen The inspector observed the maintenance activities listed below and verified work was accomplished in accordance with approved procedures and by qualified personne Unit 2 LPRM String Removal and Installation LPRM Cable Connection Verification LPCI Heat Exchanger Retubing Refueling the Reactor Core Height Test Reactor Vessel Head Steel Tensioning Changing Directional Control Valves on CRDHU's Reactor Cavity Wall Washing On April 15, 1981, the Resident-Inspector observed. an electrical main-~

tenance mechanic preparing to replace solenoid valves on two Control*

Rod Drive Hydraulic Units (CRDHU) on Unit The Equipment Outage check-list (Outage Numbers II 896 and 897) and outage tags were hung in accord-ance with Dresden Administrative Procedure The mechanic loosened the bolts securing the solenoid valve on one CRDHU and water began leaking around the sea An attempt to remove the solenoid valve from the second CRDHU gave the same result An equipment operator then directed

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the electrical mechanic to open the drain valves on the accumulator When the drain valves were opened (the position required by the outage checklist) the accumulators drained properl Following proper draining of the accumulators the solenoid valves were replaced as intende Failure to open the drain valves causing this eve~t is in noncompliance with Criterion XIV to 10 CFR 50, Appendix B, which states "Measures shall be established to indicate by the use of markings such as stamps, tage, labels, routing cards, or other suitable means, the status of....

tests performed.... measures shall also be established for indicating the operating status of structures, systems, and components of the nuclear powerplant.... ".' Also, Dresden Administrative Procedure (DAP) 3-5, which states "This procedure will provide a record of the equipment status before, during, and after an outage so that abnormal system configuration can be evaluated".

This is also in noncompliance with Quality Procedures 3-52 of the CECo Quality Assurance Manual which implements the require-ments of Criteria XIV of 10 CFR 50 and requires the Shift Engineer take appropriate action and remove equipment from service, and when satis-factory, clear the outag This problem is similar to the Notice of Violation reported in Section 2 of Inspection Report No. 50-249/81-02, dated March 23, 1981 which address a situation in which a valve was opened without placing it on the equipment outage checklist or placing an outage tag on the valv In the above case, the valves were on the equipment outage checklist and the outage tags were on the valves, but the valves were not in their.proper positio Although the impact of this event was of minor significanc*e, failure to implement outage control procedures is a matter of safety concer Recog-nizing that the opening the accumulator drain, valve may not drain th piping above the solenoid valve, and that breaking the solenoid valve off it's seat may be required to drain the piping upstream of isolation valve (305-105), neither the elctrical maintenance mechanic, nor his foreman, was aware that water should be expecte Upon finding *the drain valves closed, the entire outage became suspect and the operator then checked all the other valves in the outages to ensure proper position (50-237/81-13-01)

No additional items of noncompliance were identifie.

Inspection Duri,ng Long.Term. Shutdown~

The inspector observed control room operations, reviewed app1icable logs and conducted discussions with control room operators during the period of April 4 through May 8, 198 The inspector. verified surveillance tests required during the shutdown were accomplished, reviewed tagout records, and verified applicability of contairunent integret Tours of Unit 1 and 2 accessible areas, including exterior areas were made to make independent

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assessments of equipment conditions, plant conditions, radiological con-trols, safety, and adherence to regulatory requirements and to verify that maintenance requests had been initiated for equipment in need of mainten-anc The inspector observed plant housekeeping/cleanliness conditions, iilcluding potential fire hazards, and verified implementation of radiation protection control The inspectors by observation and direct interview verified that the physical security plan was being implemented in accord-ance with the station security pla The inspector reviewed the licensee's jumper/bypass controls to verify there were no conflicts with technical specification During a review of Unit 1 Control Room Log, the SRI noted variances of 5° to 7°F in recorded reactor vessel flange temperature entries from shift to shift. Further review showed that some NSO's read the scale on the temperature recorder pointer while others read the point on the recorder chart. It was further found that there was some confusion as to which point to read, eg., Point Number 1, 7, or A check of the temperatures at these three points showed a variance of as much as 61°F with.each othe Although none of the readings were below the Technical Specifica-tion limit for the flange temperature, it is noteworthy that the recorded data varies to this extent depending on where the readings are take This was brought to the attention of the Operating Engineer and the Shift Engin~er, and instructions were made available to all NSO's that point No. 1 on the temperature recorder chart is the true and legal record of vessel flange temperatur Subsequent review showed that the instruction is being followe During a routine *tour of the Unit 2 Drywell on April 29, 1981, the SRI noted considerable quantities of dirt, trash, air hoses, cables, et In addition, some lights were out and several deck grates had been removed for maintenance work, which created difficulty in moving about the Drywel The SRI also noted at that time that several crews o licensee personnel were busy correcting the problem During a sub-sequent tour on May 7, 1981, for outage close out with the Station Superintendent and several other management personnel, the problems had been adquately correcte During the inspection period, a licensee contractor employee working for Phillips-Getshaw, Inc., alleged that the licensee had not performed an adequate evaluation of radiation levels in the Unit 2 Drywell where he had been workin The result was a discrepency between his film badge reading (low) versus his pocket dosimeters and time keeping records (high).

This matter was. reviewed by the SRI with a Region III Radiation Specialist and Licensee Health Physicist The licensee conducted studies that showed the individuals exposure had not exceeded any regulatory requirement The licensee Health Physicists were unable to complete the study because of the-uncooperative attitude of the individua The individual refused to provide information requested by the licensee and the SRI, requested his final paycheck from a Phillips-Getshaw supervisor, and abruptly walked out of the meeting stating that the requested information would be available thru his lawye *

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The licensee choose to assign*the exposure values determined by the pocket dosimeters and time keeping because these exposure values are more conservative than the film badge exposure result This matter is consid_ered closed unless reopened for reasons stated abov While walking through the U-2 Reactor Building on April 30, 1981, the Senior Resident Inspector was observing activities at the drywell access change area Upon looking into the change area outside the personnel access the inspector noted about 10 persons in various stages of resting or lounging of which 4 - 5 were fully reclined on the floor in the area between the shoe cover removal and protective clothing step off pad Some of the personnel observed were dressed in SWP clothing while others were in street clothin All of the personnel observed were constructor employees which was confirmed by a contractor super-visor from Phillips~Getschaw Compan The SRI verified radiation backgrounds in the area with the NRC survey meter and found them to be from 0.1 to 0.2 millirem/hou The area was used as a rest and staging area for the contractor employees while waiting to work in the drywell where the floor may have been contaminate Later interviews with various licensee employees showed that the area has been used in the same manner for the entire outage, and further more, that SWP clothing had been spread out to create a soft rest area on the floo Further review of surveys in that area during the outage showed low levels of contamination and, according to licensee Health Physicists, all persons involved in work with that group showed no detectable internal contamination by whole body count In subsequent discussions with licensee contractor supervisors and licensee station management personnel, the SRI explained that personnel in these areas should be resting in a ~itting position or on a table or bench to prevent possible uptake of contamination from the potentially contaminated floo In an exit interview, this matter was discussed \\

with licensee management personnel and they agreed it was a poor radia-tion protection practice. It was later noted that all of the contractor personnel had been removed. from that are No ite.ms of noncompliance were identifie.

Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection on May 8, 1981, and summarized the scope and findings of the inspection activitie The licensee acknowledged the findings of the inspectio