IR 05000010/1982013

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IE Insp Repts 50-010/82-13,50-237/82-17 & 50-249/82-18 on 820708-0809.Noncompliance Noted:Failure to Issue & Perform Air Pressure Test Procedure
ML20027C440
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 09/28/1982
From: Jordan M, Tongue T, Walker R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20027C429 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-010-82-13, 50-10-82-13, 50-237-82-17, 50-249-82-18, NUDOCS 8210150538
Download: ML20027C440 (8)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-010/82-13(DPRP); 50-237/82-17(DPRP); 50-249/82-18(DPRP)

Docket Nos.50-010; 50-237; 50-249 License Nos. DPR-02; DPR-19; DPR-25 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station - Units 1, 2, and 3 Inspection At: Morris, IL Inspection Conducted: July 8 through August 9, 1982 T. M. Tonguc [A.W/a[ th 7-M.9 2. '

Inspectors:

M. J. Jordan 9-29-9':2 f.f.

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R D.

alker, Chief 9-2C-g A Approved By:

Reactor Projects Section 2A Inspection Summary Inspection on July 8 through August 9, 1982 (Report Nos. 50-010/82-13(DPRP);

50-237/82-17(DPRP); 50-249/82-18(DPRP))

Areas Inspected:

Routine resident inspection in the areas of Followup on l

Regional Requests; Operational Safety Verification; Monthly Maintenance i

Observation; Monthly Surveillance Observation; Inspection During Long Term Shutdown; Three Mile Island Modification-Tracking; Systematic Evaluation Program; Contractor Fire Protection / Prevention Program Implementation and Contractor Employee Concerns. The inspection involved a total of 102 in-spector-hours onsite by two NRC inspectors including 38 inspector-hours onsite during offshifts.

Results: Of the nine areas inspected, no items of noncompliance were identified in eight areas; one item of noncompliance was identified in one area (Procedure not issued - Paragraph 7).

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DETAILS 1.

Persons Contacted Licensee Personnel

  • D.

Scott, Station Superintendent

  • R. Ragan, Operations Assistant Superintendent J. Eenigenburg, Maintenance Assistant Superintendent D. Farrar, Administrative Service and Support Assistant Superintendent
  • J. Brunner, Technical Staff Supervisor J. Wujciga, Unit 1 Operating Engineer J. Almer, Unit 2 Operating Engineer M. Wright, Unit 3 Operating Engineer
  • J.

Doyle, Q. C. Supervisor

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D. Sharper, Waste Systems Engineer G. Myrick, Rad-Chem Supervisor B. Saunders, Station Security Administrator B. Zank, Training Supervisor

  • E. Wilmer, Q. A. Coordinator
  • T.

Celsla, Assistant Technical Staff Supervisor

  • J.

Sheldon, Station Construction Lead Engineer F. Baker, Station Construction, Field Engineer Contractors McCarten and McAuliffe A. Witvoet, Jr., Site Superintendent and Project Manager J. Ferriter, Field Superintendent NRC Headquarters Personnel I

P. O'Connor, Licensing Project Manager, Operating Reactors Branch 5 l

W. Russell, Systematic Evaluation Program Branch D. Persinko, Systematic Evaluation Program Branch

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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 July 15 and August 9, 1982.

2.

Regional Requests The Senior Resident Inspector and Resident Inspector attended a meeting in Region III on July 13, 1982, to prepare a Confirmatory Action Letter (CAL) regarding the remaining work and schedules to complete IE Bulletin 79-14.

The meeting was attended by members of the regional staff and members of NRR. On July 14, 1982, a meeting was held with the licensee and the CAL was agreed to by the licensee.

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No items of noncompliance or deviations 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 July 8 through August 9, 1982. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of Units 2 and 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

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requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical security plan was being impicmented in accordance with the station security plan.

The inspector observed plant housekeeping /cicanliness conditions and verified implementation of radiation protection controls. During the period of July 8 and August 9,1982, the inspector walked down the accessible portions of the Unit 2:

Isolation Condenser, Standby Liquid Control, Low Pressure Coolant Injection (LPCI), Core Spray (CS) and Diesel Generator, and Unit 3:

Isolation Condensor, Standby Liquid Control, High Pressure Coolant Injection, LPCI, and CS systems to verify operability. The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.

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.

The Resident Inspector observed the licensee's action during the week of July 19, 1982, on Unit 2 for returning the 2B Recirculation Pump to service following its manual trip from a loss of 125 volt DC power to the turbine building reserve bus. The inspector observed licensee i

activities of restart attempts, drywell entry, power transients, etc.,

l and verified that appropriate procedures and Technical Specifications

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were followed.

The Resident Inspector reviewed the drawings and logic testing pro-cedure that the licensee performs on the LPCI systems. The review was of the electrical diagrams for the interlocks that prevent the operator from manually throttling LPCI flow during the first five minutes of the LPCI automatic initiation. This review was initiated as a result of these time delays being found improperly wired at the Millstone Nuclear Power Station. The Dresden Station has the time delay circuit installed correctly and is tested by the logic testing procedure, which is performed af ter each refueling.

No items of noncompliance or deviations were identified.

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4.

Monthly Maintenance Observation Station maintenance activities of safety related systems and com-ponents 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 specifications.

The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed frem service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicabic; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were impicmented.

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 performance.

The following maintenance activities were observed / reviewed:

Unit 2: Repair on the HPCI Motor Gear Unit and Diesel Generator Maintenance Unit 3:

Isolation Condensor Level Instrument Maintenance Following completion of maintenance on the Unit 3 Isolation Condensor Level Instrument, the inspector verified that the system had been returned to service properly.

No items of noncompliance or deviations were identified.

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Monthly Surveillance Observation The inspector observed the following technical specifications required

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surveillance testing: Unit 2, EHC Low 011 Pressure Scram Functional l

Test and SRM Rod Block Calibration Unit 3, Scram Discharge Instrumenta-tion Volume Calibration and Functional Test, SRM Rod Block Calibration,

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and IRM Rod Block / Scram Calibration. The inspector verified that testing j

was performed in accordance with adequate procedures, that test instru-mentation 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 i

the individual directing the test, and that any deficiencies identified i

during the testing were properly reviewed and resolved by appropriate

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management personnel.

No items of noncompliance or deviations were identified.

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6.

Inspection During Long Term Shutdown The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of July 8 through August 9, 1982. The inspector verified surveillance tests required during the shutdown were accomplished, reviewed tagout records, and verified applicability of containment integrity. Tours of Unit 1 accessible areas, including exterior areas were made to make independent assessments of equipment con-ditions, 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 verified the implementation of radioactive waste system controls. The inspector witnessed portions of the radioactive waste systems controls associated with radwaste shipments and barreling.

No items of noncompliance or deviations were identified.

7.

Three Mile Island Modifications 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

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controls.

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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.

e.

Verify that as-built drawings were changed to reflect the modi-fications.

f.

Verify that applicable licensee personnel have received train-ing relating to the modification.

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Task Action Item II.F.1.5 Containment Water Level Monitor The resident inspector reviewed the modification against the above criteria for Unit 3 and found items a, e, and f to be acceptable.

The resident inspector tvund discrepancies in items b, c, and d as listed below.

The work package required the Torus level indicator to be installed in two parts. The first installation procedure (called a traveler)

was to install two sets of two manually operated valves on the bottom of the Torus and air test these valves to 1.2 to 1.5 times the design pressure. This test was accomplished in accordance with a detailed procedure included in the work package in early 1980. The valves were then closed to isolate the Torus from the reactor building while the remainder of the Torus level instrumentation was completed.

The second Traveler was to install the remainder of the instrunentation, hydrostatically test at 1.2 to 1.5 x 62.5 psi, and PT the welds. The hydro test and PT tests for the second traveler were signed by the operator and dated April 28, 1982. The Q.C. inspector signed the same tests and dated them April 12, 1980, whereas the hold points were not established in the procedure by the Q.C. inspector until July 24, 1980. Because the signature of the completion of the hydro was prior to the issuance of the traveler, the resident inspector requested the documentation of the hydro for the second portion of the system which was not in the work package. The licensee was unable to produce the hydrostatic testing documentation. The licensee stated that the signatures were based on the test that was done in early 1980. Thus, the new portion of the Torus level indicator that was installed in early 1982 was not hydrostatically tested as required by the Traveler

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yet was signed as being complete, and the " work request" was signed

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that all work was accomplished.

This is in violation of 10 CFR 50, Appendix B, Criteria as follows.

Criterion XI requires a test program be established to demonstrate that systems and components perform satisfactory and the testing be done in accordance with written procedures. Criterion XIV requires that a means be established to indicate the status of tests performed

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upon individual items and identify items which have satisfactorily

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passed required inspection and tests to preclude inadvertant bypass-ing of inspections and tests. The work package covering this work activity violated the above referenced 10 CFR 50, Appendix B, Criteria, in that the licensee failed to:

l (a) issue test procedure to demonstrate the newly installed system would perform satisfactorily.

l (b) identify tha individual items to indicate the portion of the system which had been tested versus those items which had not l

been tested.

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This is an item of noncompliance (50-249/82-18-01(DPRP)).

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The licensee completed a 10 CFR 50.59 review as required, and it is part of the work package. The resident inspector requested the li-censee's analysis for line breaks from the Torus which the licensee indicated was in the FSAR. The licensee to date has been unable to provide the analysis. The licensee said that this analysis or an engineering evaluation which he used to complete the 50.59 review will be provided later.

The final problem identified by the resident inspector in this review is that clarifications for NUREG-0737 Task Action Item II.F.1 Attachment 5, states "The accuracy requirements of the water monitors shall be provided and justified to be adequate for their intended function."

The resident inspector requested that the licensee provide the above information. The licensee stated he would acquire it.

This is similar to a problem which was identified in Inspection Report No. 50-10/82-04, 50-237/82-06, and 50-249/82-06 where a portion of a task action item was missed or not addressed.

This task action item will remain open until the above problems are resolved.

Task Action Item II.F.1.4 Containment Pressure Monitor The resident inspector reviewed this item for Unit 3 against the above criteria and found it to be acceptable for these criteria. The in-spector then reviewed the Task Action Item Clarifications in NUREG-0737 and found that clarification (5), states "The accuracy and response time specifications of the pressure monitor shall be provided and justified to be adequate for their intended function". The resident inspector requested the licensee provide the above information. The licensee stated he did not have this information, but would acquire it (Same as II.F.1.5 in this report). This task action item will remain open until the above documentation is provided.

One item of noncompliance was identified.

8.

Systematic Evaluation Program The Resident Inspector participated in a site review of the Systematic Evaluation Program (SEP) on differences from current licensing criteria.

The site review was conducted with three NRC representatives from Washington, D.C., (Messrs. P. O' Conner, W. Russell and D. Persinko)

and several members of the licensee's staff. The review was conducted to discuss the licensee's proposed actions on these differences.

Results of this visit will be documented in a site visit report which will be issued by members of SEP at a later date.

No items of noncompliance or deviations were identified.

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Fire Protection / Prevention Program Implementation The inspector observed 14 persons participating in fire fighting training. This training was used to qualify individuals for the fire brigade.

No items of noncompliance or deviations were identified.

10.

Contractor Employee Concerns A contractor employee expressed a concern to the resident inspectors-that the licensee " black listed" him from their plants (i.e., barred from working). During the outage on Unit 2 in early 1981 he received an intake of radioactive material which was well within regulatory limits but which was detectable in his lungs.

(Reference Inspection Reports No. 50-10/81-05; 50-237/81-11; 50-249/81-07, section 10 and No. 50-237/81-33; 50-249/81-23, section 11.) He stated that as a result of his concerns nter the exposure he had increased his drinking.

He further stated that since termination of his services at the licen-see's site in March of 1982 he has stopped drinking, but has not been able to find employment. He stated he had received his termination report of radiation exposure, but he could not recall if it included his internal contamination. He stated he would get back to the SRI if it did not or if he needed further information.

The SRI followed up on the employee's concerns and found by conversa-tion with the licensee's security personnel that this individual was not on a " black list" barring him from the sites. A discussion with the contractor supervisor who employed the individual revealed that his productivity had declined during his employment, but the quality of his work was of no problem. Also, there was no evidence he had arrived for work drunk. This matter is considered closed.

No items of noncompliance or deviations were identified.

11.

INPO Evaluation During this inspection period, a 14 member INPO Team was on site to conduct the second INPO evaluation of the Dresden Station. The evaluation was conducted from July 12 throught July 22, 1982. The licensee will provide a copy of the report to the NRC.

12.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) throughout the month and at the conclusion of the inspection on August 9, 1982, and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings of the inspection.

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