IR 05000010/1983008
| ML20024D111 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/06/1983 |
| From: | Reyes L, Stasek S, Tongue T, Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024D091 | List: |
| References | |
| 50-010-83-08, 50-10-83-8, 50-237-83-11, 50-249-83-09, 50-249-83-9, IEB-80-02, IEB-80-13, IEB-80-2, IEB-82-01, IEB-82-02, IEB-82-03, IEB-82-04, IEB-82-1, IEB-82-2, IEB-82-3, IEB-82-4, NUDOCS 8308030173 | |
| Download: ML20024D111 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-010/83-08(DPRP) 50-237/83-11(DPRP) 50-249/83-09(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: Dresden Site, Morris, IL Inspection Conducted: March 15 through May 20, 1983
$
$ AlL h
kg I
Inspectors:
T.
Tongue S S e
p) h N b
L. Reyes hb di 23db L
Approved By:
R. W 1 er, Chief ff M Projects Section 2B Inspection Summary Inspection during the period of March 15 through May 20, 1983 (Report
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Nos. 50-010/83-08(DPRP), 50-237/83-11(DPRP), 50-249/83-09(DPRP))
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-Areas Inspected: Routine unannounced inspection by resident inspectors of
previous inspection findings; headquarters / regional requests; operational l
safety; maintenance; surveillance; licensee event reports; I. E. Bulletins; startup testing-refueling; refueling activities; containment integrated leak l
l rate test including inspection of procedure review, instrumentation, witness of test, observation of valve lineups, blowdown and containment inspection, data evaluation, and supplemental test data evaluation; surveillance-refueling; maintenance-refueling inspection related to allegations and committee activi-ties; confirmatory action letter; inspection during long term shutdown; prep-l aration for strike; and independent inspection of hydrogen addition. The
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inspection involved a total of 401 inspector-hours onsite by three NRC in-spectors including 122 inspector-hours onsite during off-shift.
Results: Of the 16 areas inspected, no items of noncompliance or deviations were identified in 15 areas; one item of noncompliance was identified in the remaining area (failure to follow procedures - paragraph 13).
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DETAILS SECTION I
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1.
Persons Contacted Commonwealth Edison
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- D. Scott, Station Superintendent R. Ragan, Operations Assistant Superintendent
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- J. Wujciga, Assistant Superintendent for Administrative Services and Technical Support J. Eenigenburg, Maintenance Assistant Superintendent J. Brunner, Technical Staff Supervisor M. Wright, Unit 1 Operating Engineer J. Almer, Unit 2 Operating Engineer
T. Ciesla, Unit-3, Operating Engineer J. Kotowski, Technical Staff, Unit 2 Systems Group Leader J. Achterberg, Technical Staff, Unit 3 Systems Group Leader D. Sharper, Acting Waste Systems Engineer G. Myrick, Rad-Chem Supervisor B. Saunders, Station Security Administrator R. Meadows, Master Machanic
- R.
Stobert, Q. A. Inspector D. Ruppert, Q. A. Inspector a'
CECO Corporate Personnel G. Tanner, Q.A. Supervisor, Maintenance-G. Schulte, Corporate Maintenance Staff Engineer
~ J. Pizzica, Corporate Maintenance Staff Engineer Contractor
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B. Smith, Wyle Labs Field Representative NRC Persons Contacted C. Weil, Investigator L. Reyes, Chief, Region III, Division of Engineering Programs, Test Programs Section F. Maura, Inspector, Division of Engineering Test Program Section
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 of the exit interviews conducted
.on March 31, April 29, and May 17, 1983, and informally at various times throughout the inspection period.
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2.
Followup on Previous Inspection Findings (OPEN) Noncompliance 50-237/82-20-01(DPRP) and 50-249/82-2 1-01(DPRP)
Measures not Established to Control Nonconforming Parts in Order to Prevent Their Installation and Use.
The licensee has. replaced and tested the electromatic safety relief valve on Dresden. Unit 3 during the outage on October.29, 1982.
In addition, station procedures to evaluate ;and ' classify all spare parts -
used in safety-related components and administratively control a Spare Parts Classification Test was implemented on May 1, 1983. This was verified by the inspector; however, the effectiveness of the control should be observed for some time. During this inspection period, and prior to May 1,1983, an additional event occurred related to control of safety related parts (Drywell to Torus vacuum breaker shaft seals).
Refer to paragraph 7 of this report for further information.
(OPEN) Inspection Item, 50-237/83-07-06(DPRP),50-249/83-06(DPRP)
No Fuel Support Piece for CRD M-2 (46-07).
The licensee completed the supplemental deviation report and has committed to revise fueling procedures DFP 800-1 Master Refueling Procedure Units 2 and 3,_DFP 800-14 Replacement of a Fuel Support Piece, and DFP 800-16 Replacement of Operable Control Rods.
In addi-tion, a less cumbersome fuel support piece grapple with a more positive seating indication is being developed for EPRI and, if available, will be used during the upcoming Unit 3 refueling outage. This item will remain open until the followup action is in place.
(Closed) Open Item (249/82-08-01) Flowmeter Range for Superimposed Leak Rate Test did not meet ANSI N.45.4-1972 requirements. The licensee has obtained a flowmeter with a range of 21SCFM. This flowmeter was used during the 1983 Unit 2 CILRT.
(Closed) Noncompliance (249/82-08-03) Failure to perform the CILRT
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calculations for a short duration test. The licensee has issued Revision 6 to Procedure DTS 1600-7, " Unit 2/3 Integrated Primary Containment Leak Rate Test", which includes the calculations req" ired for a short duration test. A short duration test was successfully conducted in April 1983.
No items of noncompliance or deviations were identified in this area.
3.
Headquarters Request / Regional Requests-a.
An NRC headquarters request was relayed to the Senior Resident Inspector via Region III, expressing a followup on the missing fuel support piece that occurred on Dresden Unit 2 (reference inspection item 50-237/83-07-06(DPRP) and 50-249/83-06-06(DPRP).
The licensee provided a copy of the deviation and supplemental deviation reports that described the event, how it was found, immediate corrective actions taken and pending corrective actions.
This information was forwarded to NRC headquarters as requested.
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-b.
.A potential generic issue; Dresser Industries Main Steam Safety Valves Execaded Blowdown Limit of 5 Percent in Laboratory Testing was identified at Palo Verde Nuclear Generating Station..This applied to Dresser valve 3707 RA-RT 25, where blowdowns were 7 to 15 percent. This is apparently corrected by drilling a small hole in the outside edge of the disc holder. A review by the Dresden Station Superintendent revealed that the main steam safety valves on Dresden Units 2 and 3 are Dresser Industries, Consolidated Safety Valve, type 3777 QA-RT-21. The problem apparently is only applic-able to the type of' valve used at Palo Verde NGS.
c.
An allegation was received by Region III and relayed for_ followup by the Senior Resident Inspector, regarding improper installation a
of penetration seals by the Bisco Brand Industries Company. Speci-fically, the alleger stated that a " boot" used'in the penetration
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was being installed with a two_ inch overlap instead of a three inch overlap. The alleger also identified specific procedures as being deficient. Review by licensee personnel showed that_ penetration seals are not installed at Dresden by Bisco.
d.
Recent events at Kewaunee, Prairie Island, and Arkansas Nuclear One, identified _ capped containment pressure sensing lines. This alerted the Chief of the Region III Division of Resident and Projects Branch 2, to request all senior resident inspectors of Branch 2.to examine the containment pressure sensing lines for obstructions, caps, tape, or other objects and to review the Local Leak Rate Test (LLRT) procedures for adequate instructions for restoration of these lines subsequent to local leak rate testing.
During the recent refueling outage, the resident inspectors observed numerous LLRT's and verified that the procedures provided adequate restoration instructions and that they were being followed. During a Unit 2 drywell entry on April 20, 1983, the Senior Resident Inspector-located all four of the drywell penetrations (131A, B, C, D) for drywell pressure sensing. The penetrations numbered 131A and 131B were found with tape over the openings and penetrations 131C and 131D were found clear. Penetrations 131A, B, and C are of_the type where a reactor sensing line (1 inch in diameter) passes through the penetration which is 3 inches in diameter. The outer
.boundry is capped and welded between the inner and outer pipes.
The drywell pressure sensing line taps off the outer pipe, e.g.,
the pressure sensing penetration is the area between the two pipes.
This is the area:that was taped over. Further investigation by the SRI revealed that the tape appeared to be quite old in that it was extremely brittle. When touched, it broke with a snap and displayed no evidence of being flexible.
It was further n-ted that paint was on the tape from where the drywell interior was painted.
Interviews with licensee personnel indicated that there was origionally 3 coats of paint or preservative (primer and 2 types of white paint) applied to the drywell interior, of which the last coat of white paint appeared to be on the tape. They also pointed out several nearby areas where touch up painting had been done that had a different texture than the origional paint. Reviews-of records, surveillances,
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and instruments showed that the tape had no apparent affect on the sensing capability of the drywell instrumentation.
In addition, the inspectors observed the most recent Containment Integrated Leak Rate Test (CILRT) and the associated instruments and noted that their response was as expected. Licensee personnel removed the tape for samples in an attempt to identify when it was placed over the openings.
When this was brought to the attention of-the Superintendent, he in-structed station personnel to provide a means to verify that Unit 3 did not have the same problem. This was accomplished by attaching a pressure gauge to each of the Unit 3 drywell pressure sensing lines to verify that the one psi drywell pressure maintained during operation could be observed. Upon the first opportunity to enter the Unit 3 drywell, the associated penetrations will be checked for obstructions. Meanwhile, other drywell and Torus pressure sensing penetrations on Unit 2 were verified clear prior to closure for startup. Follow-up on this matter, Unit 3 penetrations, and the possible vintage of the tape, is an open inspectica item (50-237/83-11-01(DPRP) and 50-249/83-09-01(DPRP)).
No items of noncompliance or deviations were identified in this area.
4.
Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of March 15 through May 20, 1983. The inspectors verified the operability of selected emargency systems, reviewed tagout records and verified proper return to service of affected components. Tours of Unit 3 through-out the inspection period and Unit 2 from April 26 through May 20, 1983, 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 maintenance. The inspectors by obser-vation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the period of March 15 through May 20, 1983, the inspectors walked down the accessible portions of the:
UNIT 2 UNIT 3 UNIT 2/3 Diesel Generator Diesel Generator Diesel Generator Low Pressure Coolant LPCI (both loops)'
Standby Gas Treatment Injection (LPCI)
(SBGT)
(both loops)
Core Spray (both loops) Core Spray (both loops)
Isolation Condenser Isolation Condenser
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High Pressure Coolant Standby Liquid Control
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Injection (HPCI)
(SBLC)
SBLC Aux. Electrical Panels Aux. Electrical Panels systems to verify operability. The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.
During control room panel walkdowns, the Senior Resident Inspector noted considerable dirt and dust buildup on the control panels. This
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is of concern in that the dirt could eventually work it's way into the
control switches, especially the depression type, and result in switch or electrical control failure. This was brought to the attention of the Shift Engineer, who immediately had operators start cleaning the panels. This was brought to the attention of the Station Superintendent and other station management personnel who have responded with occas-(.
ional instructions in night orders to continue to clean these panels.
This will continue to be observed as part of the routine inspection program.
During' a question and answer period of a training session provided by the Senior Resident Inspector, several personnel expressed concern about the licensee's catage system. Outages or tag outs are placed in accordance with Dresden Administrative Procedure DAP 3-5 to provide a record of the equipment status existing before, during and after an outage so that abnormal system configurations can be evaluated. Pre-sently, the system allows for multiple outages to be hung for the same job, eg., each foreman, general foreman has a separate outage for his
. crew. This requires operating personnel to go through the process of hanging the extra outages'as'well as management verification of outages
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on safety related systems. This requires the operating personnel to
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l receive unnecessary radiation exposure ~to hang the additional-outages.
l-This outage system was established in about 1974 and came out of the j
old. fossil fuel plants and very high voltage system work for linemen.
L Maintenance personnel have an ongoing understanding that they normally p
do not work on a system'or component unless their foreman's outage is-hung on the equipment. This process has been agreed to as part of the negotiations between the corporate management and the union bargaining unit which requires union concurrence to change the system. The NRC has expressed concern previously that corporate union agreements could in-fringe on safety related matters.
(Reference Dresden SALP II and III
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reports).
In this case, a negotiated agreement may have resulted in
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a poor ALARA (As Low As Reasonably Achievable) practice for radiation
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protection of plant personnel. Modification of the procedure must be negotiated with the union rather than the normal procedure generation,
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ceview,- approval and implementation by station and/or corporate management.
l The Superintendent acknowledged the inspector's concern and' stated that efforts are being made to modify the tag out procedure.
It is felt that this concern could easily exist at other Commonwealth Edison Operating r
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nuclear stations in that the tag out process was developed inpart, through the corporate industrial relations department. This issue is considered
anLopen inspection item (50-10/83-08-02(DPRP), 50-237/83-11-02(DPRP),
50-249/83-09-02(DPRP)).
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I 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.
No items of noncompliance or deviations were identified in this area.
5.
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 u
codes or standards and in conformance with technical specifications.
The following items were considered during this review:
the limiting
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conditions for operation were met while components or systems were re-moved 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 qualified per-
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sonnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented.
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Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment main-tenance which may affect system performance.
The following maintenance activities were observed / reviewed:
Unit 2
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2B Feed Water Check Value Bonnet Seal Ring Unit 3 Control Rod Drive Hydraulic Unit K7 (38-27) Leakage Repair Channel A Main Steam Radiation Monitor No items of noncompliance or deviations were identified in this area.
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6.
Monthly Surveillance O'bservation The inspectors observed technical specifications required surveillance testing on the Unit 2 HPCI system, Unit 3 Diesel Generator, LPCI and Core Spray and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that
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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 activities:
Unit 3 Electrical Hydrautic Control (EHC) Low Oil Pressure Scran, Source Range Monitors (SRM) calibration and alarm set point.
No items of noncompliance or deviations were identified.
7.
Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine 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 (OPEN) 83-08 Indication Discovered During Inservice Inspection.
This matter was discussed in Inspection Report 50-237/83-05(DPRP).
During this inspection period, the inspectors accompanied licensee per-sonnel and the ASME authorized inspector during the Unit 2 hydrostatic test to observe the tests of the veld overlays for leakage as well as walking down the entire drywell to observe any leaks that may exist.
The weld overlays were found to be acceptable and approved by the Authorized Inspector.
In addition to the weld overlay work, the licensee has made several commitments to the NRC in order to operate with these indications. One of which is to pump the drywell floor and equipment drain sumps at four hour intervals. At a drywell floor drain leakage rate of 3 gpm or an increase of 1 gpm, an investigation will be conducted to identify the source of the leakage and a drywell entry to be made at 4 gpm.
In addition, the licensee has committed to notify the NRC when these levels are reached. This has happened on at least two occasions within two weeks and the SRI was placed on alert to monitor the activities. The problem was found to be some other source of leakage and was ultimately corrected by the licensee; however, this is expected to be a common occurrence in the coming months.
(OPEN) 83-27 Local Ieak Rate Test Failure Due to Foreign Substance on Valves This issue has created considerable regulatory attention from the NRC in the way it was identified and its indication of possible poor maintenance practices that could occur at Dresden.
It is discussed
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further in this report under Maintenance-Refueling: Allegation, Confirmatory Action Letters and Committee Activities (paragraph 13 and 14). This LER is to remain open until subsequent commitments are satis-factorily met.
(OPEN) 83-29 Excessive Leakage Found During Integrated Leak Rate Test The excessive leakage was found to be caused by leakage alcag.the shaft seals of the drywell to Torus vacuum breakers. Followup Local Leak Rate Tests (LLRTS) identified several of the shaft seals that would allow excessive leakage to occur after several hours at accident pressure.
Evaluation by the licensee found that replacement shaft seals, purchased from the original equipment manufacturer (OEM) had been changed by the manufacturer.
In fact, there were three variations of the seals supplied by the OEM under the same part number. The original _ seal, a four ring soft chevron type seal, was replaced for the OEM with a harder, three ring chevron seal. The licensee has implemented a program whereby some safety-related parts can be bought ~on general purchase provided proper review and certification is given prior to there use. This is similar to the event identified in Inspection Report 50-237/82-20-01(DPRP) and
.50-249/82-21-01(DPRP) where inferior valve guides were supplied and used in the safety-related electromatic relief valves at Quad Cities and Dresden stations that resulted in the issuance of a civil penalty.
In response to those items of noncompliance, the licensee has taken cor-rective action described in paragraph 2 of this report. The licensee is also implementing instruction procedures to maintenance personnel whereby if differences are noted in replacement parts when compared to original parts, they should bring it to the attention of supervisory personnel for evaluation.
It is felt that if those corrective procedures had been in place when the inferior shaft seals were installed, the problem would have been indentified. This LER has been deferred for further evaluation by an NRC Regional Engineering and QA inspector and therefore remains open.
UNIT 3 (OPEN) LER 83-16 Exceeding a Technical Specification Limiting Condition for Operation for an Inoperable Snubber.
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This issue may have significant enforcement consideration and is the subject of a special inspection report 50-249/83-12(DPRP).
8.
IE Bulletin Followup For the IE Bulletins listed below the inspector verified that the Bulletin was received by licensee management and reviewed for its applicability to the facility.
If the Bulletin was applicable the inspector verified that the written response was within the time period stated in the Bulletin, that the written response included the information required to be reported, that the written response included adequate corrective action commitments based on information presented in the Bulletin and the licensee's response, that the licensee management forwarded copies of the written response to
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the. appropriate onsite management representatives, that information dis-cussed in the licensee's written response was accurate, and that corrective action taken by the licensee was as described in the written response.
The status (open or closed) of I. E.Bulletins 80-13 and 82-04 refers to Dresden Units 1 and 3 only. The status of Unit l'will-be evaluated by
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a the licensee and inspected prior to the'pending startup planned for 1986.
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The status of all other I. E. Bulletins reviewed, refers to Dresden Units 1, 2, and 3 or as designated in the specific bulletin.
(OPEN)
I. E.Bulletin 80-13, Cracking in Core Spray Spargers (CLOSED)
I. E.Bulletin 80-02, Inadequate Quality Assurance for
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Nuclear Supplied Equipment
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(Closed)
I.E.Bulletin 82-01 Alteration of Radiographs of Welds in Piping Subassemblies
(Closed)
I.E.Bulletin 82-02 Degradation of Threaded Fasteners in
the Reactor Coolant Pressure Boundry of PWR Plants
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(Open)
I.E.Bulletin 82-03 Stress Corrosion Cracking in Thick Wall, Large Diameter, Stainless Steel, Recirc-ulation System Piping at BWR Plants (Closed)
I.E.Bulletin 82-04 Deficiencies in Primary Containment Electrical Penetration Assemblies Regarding I. E.Bulletin 60-13, the licensee has completed three in-spections of core spray spargers (Unit 2, 1981 and 1983, Unit 3, 1982).
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No evidence of cracking was found. By letter dated March 25, 1983, CECO requested a reduction in the frequency of inspections to once every 3 years in conjunction with the ISI program (ASME Section XI). The request has been forwarded to NRC office of NRR for review. This bulletin will'
remain open until that determination is made.
f Regarding I. E.Bulletin 82-03, the inspectors accompanied licensee-
quality control personnel and the Authorized Inspector (ASMI) while witnessing the primary hydrostatic test conducted on Unit 2, and observed repaired portions of the recirculation piping. The repairs were weld overlays on crack indications detected in welds located in the jet pump risers. All repaired welds showed no evidence of failure. The review of licensee action on this bulletin will remain open until final resolu-tion of licensee action is completed.
No items of noncompliance or deviations were identified.
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9.
-Startup Testing - Refueling The inspectors observed the tests listed below and verified that the refueling outage startup testing was conducted in accordance with
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technically adequate procedures and that the facility was being operated within license limits.
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' UNIT 2 Reactor Moderator Temperature Coefficient of Reactivity
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Automatic Blowdown at Low Pressure and Rated Pressure In response to identification of damaged main steam line snubbers in the Unit 2 drywell and in followup to a Confirmatory Action Letter (CAL),
dated April 13, 1983, the licensee provided instrumentation through Wyle Labs on the main steam lines. The purpose of the instrumentation is to
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monitor thermal growth and expansion plus movement due to transient and dynamic loadings. For the test of the automatic depressurization valves, during the reactor startup, the inspectors made several observations.
These were to verify that the test procedures were followed correctly and to observe the special instrumentation for expected response. No abnormal indications were observed and this issue remains unresolved between the licensee and Region III.
No items of noncompliance or deviations were identified.
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10.
Refueling Activities i
The inspectors verified that prior to the handling of fuel in the core, 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 performed as required by technical specifications; observed portions of 6 shifts of-the fuel handling operations (inspection and insertion) and verified the activities were performed in accordance with the technical specifications 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 specifications and approved procedures.
No items of noncompliance or deviations were identified.
11.
Containment Integrated Leak Rate Test a.
Procedure Review The inspector reviewed procedure DTS 1600-7 and verified that the procedure was technically adequate and consistent with regulatory
requirements.
b.
Instrumentation The inspector reviewed the calibration data associated with per-forming the CILRT. A multipoint calibration of all instrumentation
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was performed. Correction values were generated based on the difference between_ measurements of resistance from a NBS verified resistance box and actual resistance measured. All corrections were placed as an array or equation into the CILRT computer.
The following instrumentation was used in the CILRT:
Type Quantity Deco ID. Number RTDs
- 1-29, 30A, 30B, AmB.
Flowmeter
8211A0140A2 Pressure Gauge
P1, P2 Dewcells
- 1-10 c.
Witness of Test The inspectors witnessed portions of the CILRT on April 20, 21, and 22, 1983 and verified that:
l Appropriate revision of procedure was in use by test personnel,
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test prerequisites were met, and proper plant systems were in service.
d.
Direct Observation of Valve Lineups The inspectors verified by direct visual observations that valve lineups were completed in accordance with the test procedure.
e.
Blowdown and Containment Inspection The inspectors verified that blowdown was within Technical Specifi-cation radioactivity release limits. The inspectors also conducted an independent post CILRT containment inspection for equipment degradation after blowdown and did not identify any degradation.
f.
CILRT Data Evaluation The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> CILRT was started on April 20, 1983, at 8:30 p.m.
The inspectors reviewed the leak rate data to verify the licensee's calculations of the leak rate. The following summary list the licensee's calculations. (units are in weight percent per day):
Measure.'ent Licensee Leakage rate measured (Lam)
0.2383 during CILRT Lam at 95% confidence level 0.4871 Appendix J Acceptance Criterion at 95% confidence level
= 0.75 La = 0.75_(1.6) = 1.2.
As indicated above, the
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adjusted Lam at th'e 95% confidence level was less than the maximum allowable by 10 CFR Part 50, Appendix J.
g.
Supplemental Test Data Evaluation After the satisfactory completion of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> test on Unit 2, a known leakage of 1.735 weight percent / day was induced. The licensee's leak rate calculations are indicated in the following summary (units are in weight percent per day):
Measurement Licensee Measured leakage (Lc)
rate during supplemental test 1.8952 Le @ 95% confidence level 2.0155 Induced leakage rate (Lo) =
1.735 Appendix J. Acceptance Criterion: Lo+Lar-0.25La < Lc <
Lo+ Lam +0.25La.
As indicated above, the supplemental test results satisfied the requirements of 10 CFR Part 50, Appendix J.
No items of noncompliance or deviations were identified.
12.
Surveillance - Refueling The inspectors observed the Reactor Vessel Hydrostalic Test; Local Leak Rate Tests of Main Steam Isolation Valve (MSIV), 2A and B Feed Water Check Valves, and the Torus to Drywell Vacuum Braker Shaft Seals; Control Rod Timing; SRM Rod Block Calibration; and. Intermediate Range Monitor (IRM) Rod. Block and Scram Calibration on Unit 2 to verify that the tests were covered by properly approved procedures; that the pro-cedures 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 adequate.
No items of noncompliance or deviations were identified.
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13.
Maintenance - Refueling A.
The inspectors verified maintenance procedures for Unit 2 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
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-tions; provisions for aseuring LCO requirements were met during repair; provisions for-housekeeping during and following maintanence; and responsibilities f,or reporting defects to management.
The inspectors observed the maintenance activities listed below and verified work was accomplished in accordance with approved procedures and by: qualified personnel.
Reactor Head Replacment and Tensioning; Main Steam Isolation Valve (MSIVs) Maintenance, and Torus to Drywell Vacuum Booker Shaft Seals.
B.
Allegation On April 7, 1983, the Resident Inspector received an allegation via an anonymous telephone call. The caller stated that grease had been used during maintenance, on the internals of the Unit 2 Main Steam Isolation Valves (MSIVs). He wanted to know if this practice was proper in that.the application of grease to the valve disc'/ seat mating surfaces could aid the MSIVs in passing their Local Leak Rate Tests (LLRTs).
(These tests are required by 10 CFR 50 Appendix J and plant Technical Specifications to be performed each refueling outage.) Subsequent investigation by the licensee revealed that IB, 1C, and ID, MSIVs, and the 2A and 2B inboard feed water check valves which had had their disc / seat surfaces exposed due to maintenance activities during the refueling outage, did have grease applied to those surfaces. This was not in accordance with the vendor manual instructions referenced in the work request which stated that all' parts were to be cleaned prior to reassembly of the valve and included no provisions for lubricating the disc or valve seat surfaces. This is considered to be an item of. noncompliance (50-237/83-11-03(DPRP) and 50-249/83-09-03(DPRP)).
Because of the nature of the allegation, an NRC investigator from the Office of Investigations (OI) and the Region-III Section Chief, of the Test Program Section, Division of Engineering, were dis-patched to the site. Their purpose was to determine if any willful wrong doing was involved in the application of grease to seats so as to have an affect on the local leak rate test of the valves in question. The investigation revealed that the mechanics and one of their working foreman admitted to applying the grease-on their own initiative with no_ instructions from outside their work group. There
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l was no evidence that this was done in an effort to pass the LLRT, j
only as an aid in reassembly of the valve as grease was applied to numerous other surfaces for assembly. The investigation concluded that this did not involve a matter of wrongdoing (Q3-83-025).
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j Subsequent review of the work packages for those valves showed no
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evidence of QC or QA involvement in the work, e.g., no specific hold points for inspection nor documentation of the review per-formed. This was also a subject of a CAL for those valves. Based on interviews with station personnel, the reluctance to place QC or QA hold points on the work was done to prevent holding up
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the work and to avoid calling inspection personnel during off hours. This is a concern that should be addressed by the licensee and is considered an open inspection item (50-237/83-11-04(DPRP)
and 50-249/83-09-04(DPRP)).
C.
Committee Activities to Review Maintenance In a discussion between the NRC Region III Director of the Division of Projects and Resident Programs and the Commonwealth Edison Company Vice President and General Manager for Nuclear Stations, the question was raised regarding the quality of recent maintenance work at Dresden.
More specifically, "What-assurance is there to show that there were no other undesirable work practices taking place in safety related maintenance activities during the Unit 2 refueling outage?" as identified with the grease on the seals of the Main Steam Isolation Valves (MSIVs).
In response to this question,.the licensee formed an ad hoc committee to review the mainterance work performed during the outage. The committee was made up of 4 members of various backgrounds of which 3 members were from off-site. Their goal was to be able to answer the above question prior to the startup of Unit 2.
The committee selected a representative sample of work request packages (WRs) with selections from mechanical, electrical and instrument mechanic areas. The work requests were reviewed'to verify that the work was conducted with good work practices and consistant with management expectations. For those packages where questions were raised, follow-up personal interview of the personnel involved and/or an' actual observation of the equipment or work was perfo rmed. Following the review, the committee reported finding several good practices such as, "the employees are motivated to do quality work, work experiences gained by the electrical maintenance personnel during the Unit 3 refueling in 1982 were applied to Unit 2 in 1983, QC hold points are accomplished but not always documented, and the maintenance mechanics interviewed concluded that the quality of work was satisfactory." Two weaknesses were identified; first, the root cause of problems were not always documented in the work package so that it could be applied to future maintenance work, and second; the maintenance program could be enhanced by establishing more QC/QA hold points. The Senior Resident Inspector found the qualifications of the committee to be good. He also observed several of the committee reviews and found them to be excellant. The SRI also sat in on the committee closeout meeting with the Station Superintendent. The committee concluded that there was no evidence from their review of undesirable maintenance work practices at Dresden. The SRI agreed with this finding.
One apparent item of noncompliance was identified in this area.
14.
Confirmatory Action Letter As a result of the identification of grease (foreign substance) on the seats of the Main Steam Isolation Valves MSIV's) and the inboard reactor feed water check valves on Dresden Unit 2, the NRC issued a Confirmatory
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Action Letter (CAL) from Region III dated April 13, 1983. Each of the items listed and it's status follows:
A.
Dresden, Units 2 and 3 1.
Prior to Unit 2 startup, evaluate all Unit 2 containment isolation valves subjected to maintenance or repair work during the current outage to determine if there is a poss-ibility that foreign materials had been applied to the valve seating surface. For those valves where the seat was exposed during the maintenance or repair work, reinspect a sample of two valves out of seven that were reworked and one valve out of five that were replaced new.
These reinspections will be witnessed by the Resident Inspector.
Within two days of the date of this letter, evaluate all Unit 3 containment isolation valves subjected to maintenance or repair work after the shutdown for the last refueling oatage to determine if there is a possibility that foreign materials had been applied to the valve seating surface and report to Region III your plan for dispositioning those valves where the seat was exposed during the maintenance or repair work.
Regarding Unit 2, the resident inspectors witnessed the inspections of the internals of one Torus drain valve, one drywell equipment drain sump discharge valve and the Torus vent and purge valve.
In all 3 cases, the interiors of the valves were found to be free of foreign substances. The disassembly, inspections, and reassembly was performed with appropriate controls and documentation.
The dispositioning of the containment isolation valves on Unit 3, where internals were exposed during the last refueling outage, was completed as stated in the CAL. Maintenance was conducted on 4 valves where the valve internals were exposed or the valve was replaced. The work request packages were reviewed for adequacy and employees and foremen were interviewed to determine if foreign substances had been applied. The result of these dispositions were negative. The inspector also interviewed the personnel involved and found their responses favorable.
In the case of the A0 1601 21 and 23 valves for the containment vent and purge system; the licensee foremen volunteered information to the inspector that reinforced the licensee position. They revealed that it was common knowledge within their trade that grease on a butterfly type valve would have reduced the friction between the seat (neoprene) and the disc and its presence would have cause the disc to slide past the seat, e.g.,
the disc would not have seated. Thus, grease would have caused a failure of the local leak rate test. This item is considered closed (237/83-11-05(DPRP), 249/83-09-05(DPRP)).
2.
Develop, review, and approve a repair manual for MSIV's prior
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to the next refueling outage.
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The inspectors. verified that the licensee generated an interim MSIV repair manual for the work conducted on the Unit 2 valves.
This interim version was found to be acceptable. The permanent manual is still under development and is not'due for completion until October 1983 (Unit 3 refuel outage). This item remains open (50-237/83-11-06(DPRP),50-249/83-09-06(DPRP)).
3.
Develop and implement an interim. quality control inspection plan establishing appropriate hold points for valve disassembly and reassembly prior to any-further maintenance or repair work on Units 2 or-3 safety-related valves. Develop, review and approve a standard inspection plan for future use on activities involving safety-related valves prior to the next refueling outage.
The inspectors verified by review of work packages, that the interim QC inspection plan was in place for disassembly of safety related valves during the remainder of the. outage. The final standard re-view plan is presently under development and this item, therefore, remains open.
(50-237/83-11-07(DPRP),50-249/83-09-07(DPRP))
4.
Review, approve and implement existing maintenance and repair instructions and procedures for Unit 2 and 3 containment isola-tion valves to ensure proper precautions are in place to pre-vent the introduction of foreign materials onto valve seating surfaces prior to use of those instructions and procedures.
This matter is presently under review by the licensee and is con-sidered open.
(50-237/83-11-08(DPRP),50-249/83-09-08(DPRP))
5.
Develop a training module and train maintenance mechanics within 60 days of this letter on the correct use of lubricants and sealants.
This item is presently under development and is considered open.
(50-237/83-11-09(DPRP),50-249/83-09-09(DPRP)).
6.
Prior to further maintenance or repair work on safety-related valves, discuss this event with all mechanical maintenance personnel to ensure that foreign materials are not applied to valve seating surfaces.
The licensee has conducted shift " Tailgate" sessions for all mechanical maintenance personnel and given instructions related to ensuring foreign materials are not introduced into safety related valves and components. This item is considered closed.
(50-237/
83-11-10(DPRP),50-249/83-09-10(DPRP))
B.
La Salle, Unit 1 Quad-Cities, Units 1 and 2
. Zion, Units 1 and 2
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Within ten days of the date of.this letter notify Region III of the results of your review to determine if maintenance department-practices at the La Salle, Quad-Cities and Zion stations could have resulted in the introduction of foreign materials onto the seating surface of con-tainment isolation valves and actions planned at those facilities to preclude that possibility.
By letter dated April 22, 1983, D. L. Farrar, Director of Nuclear Licensing to J. G. Keppler, Regional Administrator, Directorate of Inspection-and Enforcement - Region III, the licensee provided the information requested.
Verification will be conducted by the resident inspectors at those stations.
This item is considered closed at Dresden (50-237/83-11-11(DPRP), 50-249/
83-09-11(DPRP)).
No items of noncompliance or deviations were identified.
15.
Inspection During Long Term Shutdown The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators on Unit I through-
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out the inspection period and on Unit 2 from March 15 through April 16, 1983. The inspectors verified surveillance tests required during the shutdown were accomplished, reviewed tagout records, and verified applic-ability of containment integrety. Tours of Units 1 and 2 accessible areas, including exterior areas were made to make independent assessments of equipment 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 protec-tion controls.
While accompanying licensee personnel during a walkdown of the Unit 2 suppression pool (Torus), the inspector noted numerous locations where welding had been conducted on interior components and no preservation (painting) had been done to the affected area. The unprotected areas were exclusively on internal components and were primarily Mark I Torus modifications on the downcomers and catwalk supports. The inspectors verified that all torus skin work had been properly preserved. The areas in question had immediately shown signs of rust and it is ack-nowledged that a corrosion allowance is designed into these components.
The concern.of the inspectors is a long term (e.g. 10 to 20 years)
corrosion / weakening of the components whereby they may fail under accident conditions. Even though it is looking far into the future, if licensee extensions are requested by the licensee at the end of the j
operating license, the ability to show acceptability of these components would be helpful in the renewal process. This was brought to the attention of the Station Superintendent who acknowledged the concern.
i This is considered an open inspection item (50-237/83-11-12(DPRP)
and 50-249/83-09-12(DPRP)).
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'An additional observation was made while walking down the Unit 2 torus for close out. There was considerable quantities of loose paint, rust, dirt, small pieces.of metal, etc., under the deck grating on the support'
beams of~the torus _ internal catwalk. Under accident conditions, vibration
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could cause this debris to fall into the suppression pool and possibly clog the suction screens to the ECCS suction header. The licensee
= arranged for contractor personnel to promptly clean the areas in question.
Other items found floating in tne suppression pool water were a stick and a roll of masking tape.
These were removed during the first inspec-tion. The final inspection revealed no further descrepencies for final torus closure and subsequent reactor startup.
No items of noncompliance or deviations were identified.
16. Preparation for Strike On March 29, 1983, informational pickets were established at the entrance to the site by local 73 of the General Services Employees Union. This union has a very small number of members in the contract security force at Dresden. The dispute was with Burns International Security (a CECO
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contractor) and not with the licensee. At most, there were 6 to 8 individuals on picket at one time and some were recognized as those that were terminated for failure to pass the firearm qualifications in 1981. There were also a few professional picketers identified. The inspector verified that the licensee was prepared for a disruption in security activities and that entrance and egress to the site was not affected. The pickets discontinued the demonstration about one week later.
No _ items of noncompliance or deviations were identified.
17.
Independent Inspection The licensee has commenced a full time program of hydrogen addition to the Unit-2 primary system as a means to inhibit corrosion. This was done as an experiment in 1982, reference NRC Inspection Report 50-010/
82-06(DPRP), 50-237/82-10(DPRP) and 50-249/82-11(DPRP). Although this is not a safety related activity, the inspector observed the actions for expected behavior of parameters, such as off-gas flow, temperatures, control, oxygen concentrations, etc., in the interest of the reduction in oxygen related stress corrosion and the present operation with the existence of crack indications in the recirculation piping.
It was noted that the hydrogen addition system was started without training in j
place for operators.
This was brought to the attention of one of the-station management personnel who promptly took steps to provide interim training for shift personnel and followup training to be provided during
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Meetings,--Training Other Relevant Activities A.
Performance Appraisal Team Inspection An NRC Performance Appraisal Team (PAT)' consisting of 6 members, started an inspection on May 9, 1983. The inspection is to be performed during the weeks of May 9, May 16, and May 31, 1983, and will consist of observations-and interviews at the Dresden-site and Commonwealth Edison Corporate Offices. The inspection is an evaluation of selected activities presently at Dresden and a comparison with " state-of-the-art" conditions. Any potential-enforcement finding will be turned over to_the resident inspectors for evaluation and follow-up.
E.
Systematic Appraisal of Licensee Performance The Systematic Appraisal of Licensee Performance (SALP III) report-for th~ period of January.1 through December 31, 1982, was released on April 22, 1983, for licensee comment.
The SALP meeting with the licensee was held on May 12, 1983, in the NRC, Region III office in Glen Ellyn, Illinois. The SALP report combined with the licensee's response and the NRC's final response will be released in the near future.
C.
During this inspection period, the Senior Resident Inspector pre-seated lectures to each of the station off-crews in training. The topic was the NRC hiitory, the enforcement program and the Systematic Appraisal of Licensee Performance (SALP) and ' concluded with a ques-tion and answer period. The response has been favorable as it provided an opportunity to improve communications between the NRC and the operating crews.
D.
The Resident Inspector attended a three day resident inspector seminar on April 20 through 22, 1983, at the NRC Region III office in Glen Ellyn, IL.
19.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or-licensee or both. Open items disclosed during the inspection are discussed in P,aragraphs 3, 4, 13, 14, and 15.
20.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) throughout the period and on May 17, 1983, summarized the scope and findings of the inspection activities. The licensee acknowledged the findings of the inspection.
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