IR 05000237/1985006
| ML17195A741 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/19/1985 |
| From: | Eng P, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195A736 | List: |
| References | |
| 50-237-85-06, 50-237-85-6, 50-249-85-05, 50-249-85-5, NUDOCS 8503260317 | |
| Download: ML17195A741 (7) | |
Text
U. S.* NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-237/85006(DRS); 50-249/85005(DRS)
Docket No. 50-237; 50-249 License N DPR~l9; DPR-25 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago IL 60690 Facility Name:
Dresden Nuclear Power Station, Units 2 & 3 Inspection At:
Morris, IL Inspection ~te~ebruary 13-26, 1985 Inspector:
P. L. Eng/
)!f)/#£ Approved By:j'~. ~eyi{, Acting Chief 1*operat1onal Programs Section Inspection Summary 3/g/~
Date Inspection on February 13-26, 1985 (Report No. 50-237/85006(DRS); 50-249/85005(DRS))
Areas Inspected:
Routine, unannounced inspection of previously identified in-spection findings; status of inservice testing program implementation; program compliance with the ASME Code; pump testing; valve testing; inservice test performance; and inservice testing records. The inspection involved a total of 58 inspector-hours onsite by one NRC inspector, including 6 inspector-hours onsite during offshifts. In addition, the inspection involved 9 inspector-hours in the Regional Offic Results: Of the seven areas inspected, no items of noncompliance or deviations were identified in four areas; three items of noncompliance were identified in the remaining three areas (failure to perform inservice testing in accordance with Code requirements - Paragraph 4; use of uncalibrated, uncontrolled equip-ment for surveillance testing - Paragraph 6; failure to evaluate inservice test data - Paragraph 7).
~gn3260317 950319 G
ADOCK 05000237 PDR
- DETAILS Persons Contacted
- J. Brunner, T~chnical Staff Supervisor T. Ciesla, Unit 3 Operations Engineer R. Coen, Unit 2 Lead Engineer L. Coyle, Technical Staff Engineer J. Gates, Shift Control Room Engineer E. Kotrich, Technical Staff Engineer
- B. McCabe, Technical Staff Engineer J. McDonnell, Nuclear Shift Operator R. Ragan, Assistant Superintendent for Operations D. Ringo, Surveillance Engineer
- R. Stobert, Quality Assurance Inspector
- J. Wujciga, Assistant Superintendent for Administrative and Technical Support Services
- Denotes those attending the exit interview on February 26, 198 Additional plant technical and administrative personnel were contacted by the inspector during the course of the inspectio.
Actions on Previous Inspection Findings (Closed) Noncompliance (237/81-31-01; 249/81-23-01): Failure to implement requirements of 10 CFR 50.55a(g) for inservice testing of Category A valves. This noncompliance was rescinded by letter dated April 1, 1982 from C. E. Norelius to C. Ree It should be noted, however, that an unresolved item regarding this issue for the second ten-year program is opened in paragraph 5.a.1 of this repor.
Second Ten-Year Inservice Testing Program for Pumps and Valves Implementation of the licensee's second ten-year inservice testing program as submitted to the Commission for approval, was reviewed for compliance with the requirements of Section XI of the American Society of Mechanical Engineers' Boiler and Pressure Vessel Code (ASME Code),
1977 Edition including addenda up through Summer 1979; Appendix B to 10 CFR 50; and 10 CFR 50.55a(g).
The inspector noted that the licensee has committed to addenda through Summer 197 Although use of addenda later than Summer 1978 is not explicitly allowed by 10 CFR 50.55a(b),
use of addenda through Summer 1979 is allowed as stated in Federal Register Notice 46 FR 20153, and is, therefore, acceptabl As yet, the licensee has not received approval of their second ten-year inservice testing program from the Office of Nuclear Reactor Regulation (NRR).
The program is currently undergoing a detailed review by the Mechanical Engineering Branch of NRR.
The licensee's second ten-year intervals for Units 2 and 3 began on January 7, 1980 and January 31, 1981, respectivel No items of noncompliance or deviations were identifie.
Inservice Testing Program Compliance with Code Requirements Pump testing was generally conducted in accordance with Code require-ment Test data for pump operability determination is reviewed and evaluated per licensee procedure DTP-12, "Technical Review of Inservice Pump Test Results," which addresses the timely evaluation of pump test data within the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> limit specified in the Cod The inspector reviewed the licensee's relief requests for the inservice testing of pumps and noted that the licensee is not measuring pump suction pressure with the pump idle as required by Table IWP-3100- No relief request associated with this requirement was submitted to the Commissio The inspector also reviewed the relief requests associated with inservice testing of valves. The inspector noted that the licensee had implemented a procedure, DOS 040-7, to verify that remote position indicators for inaccessible valves accurately reflected the true condition of the valve; however, the licensee did not have a procedure or other provision for verifying the accuracy of remote position indicators for accessible valve Subsection IWV-3300 of Section XI states that all valves with remote position indicators shall be verified at least once every two years to accurately indicate the true status of the valv The licensee had not requested relief from this requirement for accessible v~lve Failure to verify the accuracy of valve remote position indicators every two years and to measure pump suction pressure with the pump idle as required by IWV-3300 and IWP-3100-1 respectively, as required by the Code is considered to be an item of noncompliance (237/85006-0l(DRS);
249/85005-0l(DRS)).
No other items of noncompliance or deviations were identifie.
Inservice Testing of Valves The inspector reviewed the licensee's test practices and procedures for the inservice testing of valve Inspector concerns and findings are discussed belo Valve leak testing (1)
The licensee has submitted a relief request, VR-20, regarding the leak testing of containment isolation valves per the requirements of IWV-3420. The inspector noted that granting relief from the leak testing methods delineated in
IWV-3420 does not include relief from the trending and corrective action requirements of IWV-3426 and IWV-342 These requirements apply to all leak test data for valves in the inservice testing progra The licensee stated that they were unaware of the Commission position regarding leak test data evaluation and that they would submit a relief request specifically addressing the requirements of IWV-3426 and IWV-342 Review and approval of such a relief request and subsequent action by the licensee, if necessary, will be tracked as an unresolved item (237/85006-02(DRS); 249/85005-02(DRS)).
(2)
During the review of the valve testing requirements as delineated in the licensee program submittal, the inspector noted that the Core Spray testable check valves, 1402-9A and B, were categorized as A/ In addition, a relief re-quest associated with these valves defines the subject valves as category C. Classification of these valves is unclea The inspector also noted that these valves are similar to those discussed in Information Notice 84-74, 11 Isolation of Reactor Coolant System from Low-Pressure Systems Outside Containment.
The licensee agreed to pursue clarification of the function and appropriate categorization of these valves with NR Deter-mination of the proper category for these valves and subsequent appropriate actions by the licensee will be tracked as an unresolved item (237/85006-03(DRS); 249/85005-03(DRS)).
(3)
During the course of the inspection, the inspector noted that the Core Spray outboard isolation valves, 1402-24A and B, were leak tested per Appendix J, type C test method The licensee stated that these valves performed an isolation function in the event.of a Core Spray line brea The inspector inquired as to why these valves were not stroke time The licensee responded that they did not know, but would investigate possible reasons for the omission of stroke timing requirements for these valve Completion of the licensee 1 s investigation and modifications to the test requirements for these valves, if necessary, will be tracked as an open item (237/85006-04(DRS); 249/85005-04(DRS)). Valve Stroke Time Testing The inspector reviewed the maximum allowable stroke times for all valves in the inservice testing progra Generally, maximum times chosen were appropriate in that they were generally component oriented and independent of system response time The licensee stated that times were chosen to preclude valve stroke times from increasing without the initiation of corrective action prior to component failure, thereby increasing assurance of system
- *
availabilit During the course of the review, the inspector identified a relatively small number of valves which appeared to have excessively long maximum allowable stroke time These were:
202-4A and B, 202-5A and B, 202-7A and B, 202-9A and B, 1301-3, 1601-20A.and B, 1601-58, 1601-59, 2001-105 and 2001-10 The stroke times associated with these valves have been submitted to NRR for revie NRR is also preparing guidance regarding the acceptability of maximum allowable stroke times for use in inservice testing program The licensee stated that they would evaluate the stroke times for the above identified valves and change them as appropriat Completion of the licensee 1 s evaluation of the stroke times for the valves delineated above and modification of the associated maximum stroke times, if necessary, will be tracked as an open item (237/85006-0S(DRS); 249/85005-05(DRS)).
. Testing of Explosively Actuated Valves The inspector reviewed licensee procedures OTS-1100-2 a~d DOS-1100-3 which address the Section XI testing requirements for explosively actuated valve The procedure appeared to be adequate and tests were performed at a frequency commensurate with Code requirement No items of noncompliance or deviations were identified.
Performance of Inservice Testing The inspector witnessed the performance of licensee surveillance procedure DOS 2300-3, 11 HPCI System Pump Test.
During test performance, the inspector noted that the t~st procedure required use of 11 a strobotach to measure pump shaft speed, 11 and 11a hand held vibration instrument.
Upon inspection of the subject instruments, the inspector noted that there was no evidence that the strobotach had been calibrate Inquiries regarding the hand held vibration instrument revealed that the instrument was classified for 11General Use Only 11 and did not appear on the list of certified equipmen Vibration limits are one of the criteria used to determine the operability of pumps in the inservice testing progra The procedure did not require recording the equipment identification number for either instrumen The inspector also noted that the procedures which required valve stroke time testing did not require the use of calibrated stopwatches nor recording the identification number for the stopwatc Failure to establish measures to assure the use of controlled and calibrated measuring and test equipment for testing safety-related pumps and valves is considered to be an item of noncompliance (237/85006-06(DRS);
249/85005-06(DRS)).
The licensee stated that they were aware of the inspector's concerns and began implementation of procedure DAP 11-12, 11 Control and Calibration of Stopwatches, 11 during the course of the inspectio The licensee also stated that surveillance procedures using portable measuring and test equipment would be revised to require the notation of the equipment identification numbers by September 30, 198 The inspector agreed that these actions were adequate to preclude the future occurrence of the use of uncontrolled and uncalibrated equipment in inservice tests; consequently, no response to this item of noncom-pliance is require No other items of noncompliance or deviations were identifie.
Inservice Testing Records During the review of the licensee's inservice testing records, the inspector noted that quarterly and cold shutdown valve stroke test data for Unit 3 was not recorded for the entire year of 198 Conversations with the Surveillance Engineer indicated that the Unit 3 surveillance testing had been performed at the appropriate interval Members of the licensee's staff attempted to locate the completed test procedures and associated data but were unable to retrieve two or the five test data packages during the course of the inspectio The inspector reviewed the one quarterly valve stroke test data package which was located and discovered that a number of valves had been identified as experiencing a variety of problems during the test. The nature of the problems was not identified prior to the exit intervie Subsection IWV-3413 requires that for valves whose stroke times increase from the last test by given percentages, testing be conducted at an increased frequency unti I corrective action has been take Since the inservice test data had not been routed to the inservice test coordinator, the evaluation of the valve stroke times to insure compliance with the Code requirements could not and was not performed for the five tests which were conducted during 1984 for Unit Failure to establish methods insuring timely identification of conditions adverse to quality is considered to be an item of noncompliance (249/85005-07(DRS)).
No other items of noncompliance or deviations were identifie.
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 bot Open items disclosed during the inspection are discussed in Paragraphs 5.a.3 and.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviation Unresolved items disclosed during the inspection are discussed in Paragraphs 5.a.1 and 5..
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
on February 26, 1985, to discuss the scope and findings of the inspectio The licensee acknowledged the statements made by the inspector with respect to items discussed in the repor The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents/processes as proprietar