IR 05000010/1982004
| ML20053E320 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/12/1982 |
| From: | Jordan M, Tongue T, Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20053E300 | List: |
| References | |
| 50-010-82-04, 50-10-82-4, 50-237-82-06, 50-237-82-6, 50-249-82-06, 50-249-82-6, NUDOCS 8206070795 | |
| Download: ML20053E320 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-10/82-04(DPRP); 50-237/82-06(DPRP); 50-249/82-06(DPRP)
Docket Nos.50-010; 50-237; 50-249 Licenses No. DPR-02; DPR-19; DPR-25 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted:
January 30, 1982 through April 2, 1982
$b t
t Inspectors:
T. M. Tongue h-l>-$ A M.J.d, dan 55ln
Y~~ID-$k Jor hb $.t h
Approved By:
R. D. Walker b I)- D Inspection Summary Inspection on January 30 through April 2, 1982 (Reports No. 50-10/82-04(DPRP);
50-237/82-06(DPRP); 50-249/82-06(DPRP))
Areas Inspected: This was a routine unannounced resident inspection of licensee action on previous inspection findings, Operational Safety Verifi-cation, monthly maintenance observation, monthly surveillance observation, licensee event reports follow up, review of plant operations, refueling activities, surveillance-refueling, maintenance-refueling, inspection during long term shutdown, anonymous allegations, followup on regional requests, Three Mile Island Modification Tracking. The inspection involved a total of 399 inspector-hours onsite by two NRC inspectors including 105.5 inspector-hours onsite during off-shifts.
Results: Of the 13 areas inspected, there were no items of noncompliance identified in 11 areas; two items of noncompliance (failure to calibrate safety related instruments - Paragraph 5, and failure to meet a requirement of an NRC Order - Paragraph 14) were identified in two areas.
8206070795 920521 gDRADOCK 05000010 PDR
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DETAILS SECTION I
1.
Persons Contacted Commonwealth Edison Company i
- 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 T. Ciesla, Assistant Technical Staff Supervisor J. Wujciga, Unit 1 Operating Engineer.
J. Almer, Unit 2 Operating Engineer M. Wright, Unit 3 Operating Engineer I
- R. Meadows, Staff Engineer J. Doyle, QC Supervisor D. Sharper, Waste Systems Engineer
G. Myrick, Rad-Chem Supervisor D.Long, Lead Nuclear Engineer
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i B. Saunders, Station Security Administrator B. Zank, Training Supervisor
- E. Wilmer, QA Coordinator W. Sheldon, Station Construction Lead Engineer Contractor Personnel McCartin, McAuliffe A. Witvoet, Superintendent J. Ferriter, Assistant Superintendent The inspectors 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, and contract security personnel.
- Denotes those attending one or more exit interviews conducted on February 5, February 25, March 12, March 26, and April 2, 1982.
2.
Licensee Act_lon on Previous Inspection Items (Closed) Open Inspection Item 50-237/80-04-04 and 50-249/80-04-04:
Licensee Resolution to Water Seepage from the North Dike of the Dresden Cooling Lake.
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The licensee resolution of this matter was to install a collection sump, two automatic redundant submersible pumps, and about 1000 feet of drainage pipe along the too of the North Dike. Water is collected via the drainage pipe to the sump where it is pumped into the cooling lake. The inspector interviewed several licensee personnel on this
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matter and observed the facility in operation on several occasions.
The facility appears to be installed as stated in licensee and con-sultant correspondence and is adequate corrective action for the concerns of lucal residents who raised the issue. No further action is expected on this matter.
(0 pen) Noncompliance Item (249/80-29-03): The resident inspector reviewed the licensee's response to Operating Experience Assessment Report (OEAR) No. 81-7, Supplement 1.
This was the report that Dresden received from the independent engineering evaluation that was
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done on the pressurization on Unit 3 (Noncompliance Item 249/80-29-03).
The recommendations from this independent engineering evaluation was addressed in this response.
Station Nuclear Engineering Department (SNED) is continuing to evaluate instrumentation changes which may be required to provide a better indication of pressure and temperatures during shutdown conditions, also, they are evaluating methods of regulating flow through the shutdown cooling heat exchanger to regulate cool down. The resident inspector was particularly interested in the station action concerning establishing a minimum water level in the Reactor Vessel, which the engineering evaluation stated is needed to insure adequate flow through che core during shutdown condition with no recirculation pumps in operation. The date of the response to OEAR 81-7, Supplement 1, was November 10, 1981, which stated a procedure change would be issued addressing the water level. On April 2, 1982, this procedure change or a temporary change to the procedure had not been issued. The licensee stated that a procedure change was in routing and would be issued in the near future. This item will remain open.
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No additional items of noncompliance were identified.
3.
Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of January 30 through April 2, 1982. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of Unit 2 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 i
requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical
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security plan was being implemented in accordance with the station
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security plan.
The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the period of January 30 through April 2,1982, the inspector walked down the accessible portions of the Unit 2 Diesel Generator, SBLC, Isolation Condenser, 2A-LPCI, 2A CS, Unit 2/3 Diesel Generator, and SBGTS systems to verify operability. The inspector also witnessed portions of the
radioactive waste system controls associated with radwaste shipments and barreling, i
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.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 procedures.
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During this report period, the licensee reported several instances of i
finding pills of unknown substance, contractors attempting to enter the
site with alcholic beverages, marijuana, or while intoxicated. Each case was reported, appropriately, personnel were fired, and in one case an arrest was made by the Grundy County Sheriff. The licensee's cor-
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rective steps included instituting patdown searches of a portion of the contractor personnel.
In addition to the above stated corrective action the plant superintendent advised all personnel that the only pills or drugs allowed on site were those that could be identified by a prescription or as over the counter medicines and further stated that infractions could result in detention, interrogation, being watched
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j while on the job, discharge or arrests if necessary.
In each case
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identified, by the licensee, none of the restricted substances got
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inside the protected area of the site.
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No items of noncompliance were identified.
4.
Monthly Maintenance Observation
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Station maintenance activities of safety related systems and com-ponents listed below were observed / reviewed to ascertain that they
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were conducted in accordance with approved procedures, regulatory
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guides and industry codes or standards and in conformance with
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technical specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were 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
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control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; l
radiological controls were implemented; and, fire prevention controls I
were implemented.
Work requests were also reviewed to determine the status of outstanding l
jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performance.
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j The following maintenance activities were observed / reviewed:
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Unit 2
'B' SBGTS Suction Valve Refuel Floor A.R.M.
No items of noncompliance were identified.
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5.
Monthly Surveillance Observation The inspector observed technical specifications required surveillance testing on the Unit 2 SBLC Pumps, RFW Radiation Fluid Analyzer - cali-bration and cleaning 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 by appropriate management personnel.
The inspector also witnessed portions of the following test activi-ties: off gas functional test for Reactor Building Isolation and SBGTS initiation, containment spray permissive interlock, 'A' SBGTS ten hour run, LPRM calibration, IRM calibration, and IRM scram / rod block calibration.
While conducting routine surveillance observations on Unit 2, the resident inspector observed that the monthly surveillance to prove 39 GPM minimum flow of the Standby Liquid Control System (SBLC) was being conducted with a flow indicator which had not been calibrated.
The inspector then verified that the same flow indicator in Unit 3 was also not calibrated, and the instrument was not on the Master Instrument Mechanics list of instruments which required calibration.
The use of an uncalibrated instrument to prove safety and operability is in violation of 10 CFR 50, Appendix B, Criterion XII, which the licensee implemented under their Quality Assurance Program.
10 CFR 50, Appendix B, Criterion XII, requires licensees to assure gauges and instruments be properly calibrated at specific periods. The CECO QA Procedure, QP 12-52, requires lists and schedules for calibration of instruments used to show conformation with Technical Specification, Limiting Conditions for Operation. The QA Program, Section 12.7, further requires instrumentation for generating station equipment be periodically calibrated...to assure accuracy...
This is an item of noncompliance.
(50-237/82-06-01) (50-249/82-06-01)
One item of nomcompliance was identified.
6.
Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to deter-mine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specifications.
Unit 2 81-30 (Closed) HPCI Steam Line Possibly Filled with Water 81-33 (Closed) HPCI Auxiliary 011 Pump Failure
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81-61 (Closed) 2A CCSW Loop Inoperable Due to Broken Pipe Restraint 81-65 (Closed) MSIV Closure Time Out of Specification 81-69 (Closed) 2B Core Spray Subsystem Inoperable Due to Motor Operator Falling off Full Flow Test Valve 81-70 (Closed) 2A Core Spray Full Flow Test Valve Motor Operator Weld Broken 81-71 (Closed) Reactor Building Ventilation System Trip and SBGTS Automatic Start 81-72 (Closed) Train "B" SBGTS Trip After Automatic Start 81-73 (Closed)
Isolation Condenser Initiation Pressure Switch Valved Out 81-74 (Closed) ECCS Permissive Pressure Switch 263-52A Found Valved Out 81-75 (Closed) Failure to Satisfy Sampling Frequency Requirements During Reactor Startup 81-76 (Closed) SRM 23 Rod Block Greater than 10 E5 CPS 81-77 (Closed) ATVS Pressure Switches B and D Found Isolated 81-78 (Closed) Failure of 2B Electomatic Safety Relief Valve to Open 81-79 (Closed) HPCI Inoperable Due to Deluge Activation Regarding LER 50-237/81-61, final licensee corrective action will be in response to the findings identified in Inspection Report No. 50-237/81-30.
Regarding LER's 237/81-73; 237/81-74, and 237/81-77, the licensee was previously cited for this event 50-237/81-37-06.
Regarding LER 50-237/81-78, licensee personnel committed to review the wires in the junction boxes. This was previously reviewed and was iden-tified as open inspection item 50-237/81-37-07, 50-249/81-29-07.
Unit 3 81-25 (Closed) Failure of 3B Electromatic Relief Valve to Open 81-33 (Closed) Unit 2/3 and 3 Diesel Generators Declared Inoperable 81-35 (Closed) Reactor Building to Torus Vacuum Breaker 1601-20B Failed to Operate 81-37 (Closed) Unit 3 Diesel Generator Inoperable 81-38 (Closed) HPCI Inboard Steam Supply Line Isolation Valve MO-3-2301-4. Inoperable 81-39 (Closed) Spurious Activation of HPCI Fire Protection Deluge System 81-40 (0 pen)
Reactor Scram IRM HiHi Regarding LER's 249/81-33 and 249/81-37; the Diesel generator failures due to over heating were ultimately determined to have been caused by cooling water pump discharge check valve failures. This was the subject of a Special Inspection Reports No. 50-237/81-35 and 50-249/81-27 by Ragion III Engineering Specialists.
Regarding LER 249/81-40, at the request of the NRC, the licensee con-ducted a study of a history of control rod double notch withdrawals.
The conclusion of the study showed several recommendations as follows:
1.
DOS 300-6 be revised to include double notching.
2.
The SNCS and notch override switch be checked for proper operation each refueling outage.
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3.
The IICU control valves be checked for proper adjustment.
4.
The IICU scram valves be checked for internal Icakage.
5.
Continue the ongoing investigation to improve CRD system performance.
Since the licensee is presently resolving these recommendations, this LER will remain open.
No items of noncompliance were identified.
7.
Review of Plant Operations Training The inspector attended a class on Power Plex in the licensee's operator requalification lecture series and verified that lesson plan objectives were met and that training was in accordance with the approved operator requalification program schedule and objectives.
No items of noncompliance were identified.
8.
Refueling Activities The inspector verified that prior to the handling of fuel, all surveillance testing required by the technical specifications and licensee's procedures had been completed; verified that during the outage the periodic testing of refueling related equipment was per-formed as required by technical specifications; observed one shift of the fuel handling operations (insertion) and verified the activities were performed in accordance with the technical specifi-cations and approved procedures; verified that containment integrity was maintained as required by technical specifications; verified that good housekeeping was maintained on the refueling area; and, verified that staffing during refueling was in accordance with technical speci-fications and approved procedures.
While conducting control rod blade swaps in the Unit 3 reactor vessel, the licensee identified a control rod (H-13) with a missing lifting bail or handle.
Inspection by closed circuit TV of that control rod guide tube and associated surrounding guide tubes, revealed two pieces of the missing bail that were recovered, however, at least one piece remains missing after an extensive search.
In order to resolve this issue, the licensee's Station personnel and Nuclear Fuel Services group, along with G.E.,
conducting a missing parts analysis. The analysis concluded that part must have fallen into the lower head of the reactor vessel and it is extremely unlikely that it could have any adverse affect in that location. The inspector found the analysis acceptable.
No items of noncompliance were identified.
9.
Surveillance - Refueling The inspector observed the surveillance and testing listed below on Unit 3 to verify that the tests were covered by properly approved
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. procedures; that the procedures used were consistant with regulatory requirements, licensee commitments, and administrative controls; that i
minimum crew requirements were mat, test prerequisites were completed, special test equipment was calibrated and in service, and required data was recorded for final review and analysis; that the qualifica-
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tions of personnel conducting the test were adequate; and that the
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test results were adequate.
Off gas Function Test for Isolation and SBGTS initiation.
125 Volt Battery Discharge Test.
250 Volt Battery Discharge Test.
Containment Spray Permir,uive Interlock Surveillance.
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Core Spray Logic Testing.
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Main Turbine Vacuum Switch Calibration for Bypass and Stop Valve Closure.
MSIV Pilot, Safety Valve, and Safety / Relief Valve Temperature Recorder Calibration and Thermocouple Functional Test.
Fuel Channel Measuring.
No items of noncompliance were identified.
10.
Maintenance - Refueling i
The inspector verified maintenance procedures including administra-
tive 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 management.
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The inspector observed the maintenance activities listed below and verified work was accomplished in accordance with approved procedures and by qualified personnel.
Unit 3 Installation of New Reactor Mode Switch.
Functional Test of New Position Indication Switches for Torus Vacuum Breaks.
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LPCI Ileat Exchanger Repair.
Diesel Generator - five year Maintenance.
Fuel Channeling.
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Reactor Feed Water Sparger clad cutting, fitup, and installation.
Scram Discharge Volume fabrication and installation.
j No items of noncompliance were identified.
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11.
Inspection During Long Term Shutdown The inspector observed control room operations, reviewed applicable
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logs and conducted discussions with control room operators during the
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period of January 30 through April 2,1982. The inspectors verified surveillance tests required during the shutdown were accomplished, reviewed tagout records, and verified applicability of containment integrity. Tours of Units 1 and 3 accessible areas, including exterior areas were made to make independent assessments of equip-ment conditions, plant conditions, radiological controls, safety, and adherence to regulatory requirements and to verify that maintenance requests had been initiated for equipment in need of maintenance.
The inspector observed plant housekeeping / cleanliness conditions, including potential fire hazards, and verified implementation of radiation protection controls. The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan. The in-spector reviewed the licensee's jumper / bypass controls to verify there were no conflicts with technical specifications.
Unit 3 While making a plant tour on March 15, 1982, the resident inspector I
noted ground water leaking from a junction box into an ESS-1 cable tray in the circulating water pump building. The licensee took steps to stop the leakage. However, on April 2, 1982, following heavy rains, water was found leaking into the cable tray from other conduit penetrations. The station superintendent found and opened a drain in the tray that promoted drainage of the water from the cable tray. He also agreed to take steps to stop water from leaking into the cable tray.
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No items of noncompliance were identified.
12.
Anonymous Allegations The S.R.I. received two anonymous onsite telephone calls at 10:13 a.m.,
and again about 10:25 a.m., on February 17, 1982, from a person stating
"They're bootlegging ya," "you better check it out."
The caller further stated that it was on the 20" line in the CRD area in the Turbine build-ing.
He also named a person who turned out to be a contractor foreman.
The caller refused to give his name and would give no further informa-tion. The caller had a deep male voice with either a southern or black dialect. Follow up by the inspectors revealed that at about the same
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time, one of the contractors (McCartin - McAuliffe) had fired a pipe fitter for administrative or personnel reasons. The description of the caller's voice matched the description of the person fired. The inspectors found that this construction company was fabricating new CRD instrument volumes (20" diameter) for the Unit 3 scram discharge volume. The fabrication was being performed in the Turbine building.
The licensee had experienced a problem in getting an acceptable radio-graph of one of the welds and as an alternative elected to magnetic particle test each weld pass on the advice of a consultant.
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addition, the inspector reviewed this matter with Region III construc-tion QC specialists and found it to 1e acceptable. The caller later
contacted the R.I. on February 22, 1982, at about 4:00 p.m., and in a
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manner similar to the previous, alleged that hanger No. 17, Item 3, on the west side of Unit 2, had been eliminated. The caller continued to
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attempt to cover his identity however, the inspectors found that the individual describe i above, had been rehired onsite by a different contractor (Phillips, Getschow).
Further investigation with the assistance of CECO and McCartin-McAuliffe personnel revealed that hanger No. 17 on Unit 2 had no Item No. 3.
However, hanger No. 17 on the west side of Unit 3 did have several specific items and that the Item 3 had been climinated through a properly approved Field Design Request (FDR). This hanger was being installed as part of the licensee's response to IE Bulletin No. 79-14.
The caller has shown no interest in the inspector's findings and has made no further contact with the inspectors.
No items of noncompliance were identified.
13.
Followup on Regional Requests CRD Line Inspection On March 9, 1982, the Senior Resident Inspector from Quad-Cities inspected the insert and withdraw line connections of the Control Rod Drive Flange. This was a special inspection requested as a result of a discovery of a leak in this area at Quad Cities Station.
(LER 50-265/82-03/01T-0).
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The inspection was conducted to determine the possibility of generic l
degradation of these lines. The inspection at Quad-Cities revealed significant corrosion in the withdraw line. Other lines inspected indicated fragmented pitting indications with no degradation.
The inspection of Dresden revealed no pitting indications. Minor oxidation as also seen at Quad-Cities was noted.
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The inspector determined that no problem as identified at Quad-Cities cristed at Dresden. Details of the Quad-Cities inspection are reported in IE Reports No. 50-254/82-06 and No. 50-265/80-07.
Potential Failures in Certain G.E. Switchgear
The resident inspector forwarded a letter to the licensee dated December 30, 1981, from R. L. Baer, NRC, Chief Reactor Engineering Branch, DRRRI, IE.
The letter concerned the General Electric generic letter regarding vertical lift metal-clad switchgear equipment short
circuit bracing. The licensee reviewed the G.E. generic letter and found one of that type of switchgear in use at Dresden. The location
of the switchgear is on the Buses 21, 22, 31, and 32, and are used to feed the Reactor Feed Pumps (Non-Safety related equipment). According
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to the letter, the failure occurs if the switchgear is short circuited with 80,000 amperes, however, the equipment in use at Dresden is subject to only an estimated 33,000 amperes. According to the Station Superintendent, no further action will be taken by Dresden management on this item because of the low amperage the switch gear receives.
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Diesel Generator Governor Oil Level The resident inspector forwarded a letter to the licensee dated December 7, 1981, from J. L. Crews, NRC, Region V, Director, Division of Resident Reactor Projects and Engineering Inspection. The letter concerned potential generic problems related to an event at San Onofre
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Unit 1, where a diesel generator (DG) tripped on over speed from
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insufficient oil in the governor. Recommendations are to insure that the oil level is between the hi and low marks on the sight glass while the D/G is running rather than idle.
The licensee found that the uanufacturer of the D/G governors at Dresden also recommended checking the oil level while the D/G is running.
Since past practice had been to check the oil level with the engine idle, the licensee is issuing a temporary procedure change to the D/G operating surveillance implementing the manufacturers re-commendation. The temporary procedure change will be followed by a permanent procedure change.
This matter will remain open until that time. Open Inspection item.
(50-2S7/82-06-02) (50-249/82-06-02)
Contractor QC Inspectors with Questionable Certification On February 18, 1982, station licensee personnel informed the
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Resident Inspectors of finding a possible discrepancy with the certification of several contractor Quality Control inspectors working for CECO.
The individuals were contractor Quality Control inspectors working for Berkley in Michigan, through Trans Eastern, who was sub-contracted to General Electric for ISI inspections at the Dresden and LaSalle stations. The problem with the individuals'
certifications appeared to be related to who is authorized to sign
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the certifications. Licensee corrective action at Dresden was to
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identify all work that the QC inspectors had performed (five welds on the Reactor Water Cleanup system) and reinspect those areas with
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properly certified personnel.
In addition, CECO has requested proper i
documentation of the certifications of the QC inspectors.
l No items of noncompliance were identified.
MSIV, Local Leak Rate Testing Failures The SRI provided information at the request of Region III related to containment Local Leak Rate Testing (LLRT) of Main Steam Isolation Valves (MSIV's). The request was in response to an NRC-HQ, memo I
dated March 22, 1982, from R. L. Baer, Engineering and Technical Support Branch, DEQA, Id.
The memo requested a review to verify numerous BWR-MSIV, LLRT failures in the past three years. This included dates, LER numbers, numbers of MSIV failures, measured leak rates, causes, and test system capability in SCFH.
The follow up found several MSIV, LLRT failures that had not been identified in the memo.
In addition, the Assistant Superintendent for Maintenance recalled that Dresden had modified the operating
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pistons in 1974 to provide greater assurance that the MSIV's were seating properly. The modification consisted of backing the operat-ing piston off on it's piston rod about 1/4 to 1/2 turns. This information was forwarded to Region III on April 7,1982.
No items of noncompliance were identified.
Review of Documentation Related to IE Bulletin No. 80-17 Long Term Fix During this report pericd, the licensee removed the Unit 3 Scram Discharge Volume (SDV) drain lines to the instrument volumes (IV)
and installed separate IV's for each SDV bank (east and west) with larger drain lines for better hydraulic coupling between the SDV and IV.
The licensee submitted a request to NRR and received approval on a Technical Specification amendment on this modification as a long term fix in response to IE Bulletin No. 80-17.
In addition, the licensee submitted a letter dated March 24, 1982, requesting lifting of the NRC Confirmatory order of October 2, 1980, requiring SDV continuous level monitoring.
These documents and all related correspondence, were reviewed by the Senior Resident Inspector and found to be acceptable. This finding was passed on to the NRC Region III office for review and recommendation which will be sub-mitted to IE Headquarters for final resolution.
14.
Three Mile Island Modifications - Tracking Note:
NUREG-0737 is the latest summary of all requirements related to TMI and is the classification and basis for modifications and corrective actions.
By letter dated July 1, 1981, and other correspondence, CECO stated that all responses address Units 2 and 3 only. CECO also stated that since Unit 1 is undergoing an extended chemical cleaning, refueling and back fit outage, the issues of NUREG-0737 would be addressed prior to unit startup which is not scheduled until mid 1986.
The inspectors used the following criteria to review licensee actions on the Task Action Items in this inspection.
a.
Verify that the design changes were reviewed and approved in accordance with technical specifications and established QA/QC controls.
b.
Verify that the design changes were controlled by established procedures.
c.
Verify that test results were reviewed and evaluated by the licensee and that test results were within previously established acceptance criteria with retesting accomplished for those cases where test deviations were detected.
d.
Verify that operating procedure modifications were made and approved in accordance with technical specifications for such design changes / modifications.
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c.
Verify that as-built drawings were changed to reflect the modifications, f.
Verify that applicable licensee personnel have received training relating to the modification.
II.B.1.3 Reactor Coolant System Vents The licensee reported by letter dated July 1, 1981, that procedures specifically written to instruct reactor operators on using HPCI or ADS for venting purposes is not deemed necessary due to the inherent design of those systems.
These two systems are the major systems which in themselves provide adequatu venting.
N.R.R. is presently evaluating the licensee response and requested additional information from the licensee in a letter dated February 23, 1982.
II.F.1.4. Containment Pressure Monitor The licensee reported by letter dated January 8, 1982, that the equipment for containment pressure monitoring for Unit 2 completion was delayed for instrument calibration, and on Unit 3 completion was delayed until prior to startup from the Unit 3 refueling outage.
The completion date for unit 2 was January 15, 1982. Therefore, Unit 2 modification was inspected and Unit 3 will be inspected at a later date after the refueling outage.
The above Criteria a, b, c, and e, were inspected and found satisfactory. Criterion C was satisfactory after the pressure trans-mitters were again calibrated as a result of the resident inspector identifying to the licensee that the work package had only calibrated the pressure transmitters from 0 to 250 psi and not -5 to 250 psi as established by the guidance in NUREG-0737. The recalibration was reviewed by the inspector and found acceptable.
Criterion f above, was found acceptable after the inspector iden-tified on February 25, 1982, to the licensee that the training on the pressure indicators had not been accomplished and on February 26, 1982, the licensee forwarded a training department memorandum to all operating personnel on the use of the pressure indicators.
In addi-tion the licensee included training on this modification in the six week routine training program for operating personnel.
The licensee is also attempting to acquire a change to the Modifi-cation Approval Sheet in the QA manual which will notify the training department of the pending modification before the modification is complete rather than after completion. This will assist the training department in notifying the operating staff of modifications before they are installed and operating. The final resolution to the proposed change will be reviewed during a future inspection. This
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is Open Inspection Item.
(50-237/82-06-03) (50-249/82-06-03)
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II.F.1.5. Containment Water Level In a letter dated December 15, 19di, the licensee requested extension of his commitment date on this item from January 1, 1982, to February 1, 1982, because of a delay in the shipment of the indicators from the manufacturer. On February 1, 1982, the licensee reported via a letter, that the qualified level instruments were difficult to calibrate and only gross indication of IcVel change in the Torus could be seen on the indicators. The licensee is continuing to follow this item for correction.
In the December 15, 1981 letter, the licensee requested
the January 1, 1982 date for this item on Unit 3 be extended ur.til completion of the present refueling outage. Therefore, this item will be inspected after the present refueling outage.
Criteria a, b, d, e, and f, above, were inspected for Unit 2 and
found acceptable. Criterion c will be completed when the indicating
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problem is resolved.
II.F.1.6 Hydrogen Monitoring System The licensee reported by letter dated December 15, 1981, that inplant
testing of the G.E. hydrogen ronitors has proven them unreliable. A
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new hydrogen monitoring system is scheduled for installation in each unit during their respective next refueling outages.
N.R.R. is evaluating the licensee's response.
II.K.3.14 Isolation of Isolation Condensers on High Radiation
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The licensee reported in July 1, 1981, that a vent line high radia-tion trip will not be installed. This position was acceptable and
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the item is considered resolved by N.R.R. as stated in a letter to
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Mr. L. O. De1 George from T. A. Ippolito dated December 15, 1981.
II.K.3.24 Confirm Adequacy of Space Cooling for High-Pressure Coolant Injection and Reactor Core Isolation Cooling System The licensee forwarded their response in a December 15, 1980, letter to N.R.R.
The licensee stated no modification to room coolers is
required because the cooling water is provided from pumps powered by i-the emergency diesel generators. This item is under evaluation by
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N.R.R.
II.K.3.25 Effect of Loss of Alternating-Current Power on Pump Seals i
The licensee stated in two letters to N.R.R. dated July 1 and October 23, 1981, that no changes or modifications were required
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based upon the BWR Owners Group Evaluation of the effect of the
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i loss of AC power on the recirculation pump seals. Therefore, this item is presently under review by N.R.R. to determine acceptability
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of licensee's position.
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II.K.3.28 Verify Qualification of Accumulators on Automatic
D_epressurization_ System Valves The licensee forwarded the response to this item in a letter dated January 8, 1982 to NRR.
The licensee believes the existing ADS valves
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and accumulators at Dresden 2 and 3 are acceptable and no modifications are necessary. This item is pending NRR evaluation.
Temporary Instruction TI 2515/42 Revision 2, TMI Action Plan Inspection Requirements - Procedures and Staffing
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This TI provided a partial listing of inspection requirements for operating reactors from the TM1 Action Plan (Draft NUREG-0660, May 1980) and clarifi-cation of TMI Action Plan Requirements (NUREG-0737, November 1980). The TI addresses inspections of licensee actions regarding Administrative Controls / Procedures and staffing responses due in 1980. Those inspected
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are as listed below.
II.B.4 Training on Mitigating Core Damage The resident inspector reviewed the licensee's training on mitigating core damage. This task action item requires training for (1) Shift Technical Advisor and operating personnel from the plant manager through the operations chain, to the licensed operators, and (2) Managers and Technicians in the Instrumentation and Control (1&C), Health Physics, and Chenistry Departments
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shall receive training commensurate with their responsibilities. The training for the Shift Technical Advisors and operating personnel, was reviewed and found satisfactory and can be considered closed. However, the licensee did not have a training program for the managers and technicians in the Instru-mentation and Control, Health Physics, and Chemistry Departments. In spite
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of this programmatic deficiency, the inspector found that 50% of the manage-ment chemistry staff and 20% of the management health physics staff had been trained in methods to detect and mitigate core damage. Additionally, the non-management Rad-Chem Technicians had been trained on the High Range Sampling System Procedures, Emergency Plan Implementing Procedures, and Generating Station Emergency Response Plan (GSEP). The inspector informed the licensee that the remaining chemistry and health physics management personnel assigned GSEP responsibilities and the Rad-Chem Technicians assigned i
responsibilities under Figure 4.2-2 of the GSEP must receive this training to meet the requirements of Task Action Item II.B.4.
The licensee must.
develop a program to provide the commensurate training for these personnel.
The failure to have a program and complete training of these personnel is in violation of the Confirmatory Order issued July 10, 1981, by the NRC, which
required the training program be available for review by January 1, 1981, and be implemented by March 1, 1981. This is an item of noncompliance.
(50-237/82-06-04; 50-249/82-06-04)
15.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
throughout the month and at the conclusion of the inspection on April 2, 1982, and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings of the inspection.
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