IR 05000237/1985016
| ML17195A828 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/06/1985 |
| From: | Rescheske P, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195A826 | List: |
| References | |
| 50-237-85-16, NUDOCS 8506140515 | |
| Download: ML17195A828 (8) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION II I Report No. 50-237/85016(DRS)
Docket No. 50-237 Licensee:
Commonwealth Edison Company P.0. Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Unit 2 Inspection At:
Morris, IL Inspection Conducted:
April 11 through May 3, 1985 Approved Inspection Summary License No. DPR-19 Inspection on April 11 through May 3, 1985 (Report No. 50-237/85016(DRS))
Areas Inspected: Routine, unannounced safety inspection of surveillance of core power distribution limits; calibration of the *1ocal power range monitoring system; APRM (average power range mo~itor) calibration; core
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thermal power evaluation; determination of reactor shutdown margin; nuclear instrumentation response and reactivity checks; and control rod drive performance testing. The inspection involved a total of 81 inspector-hours onsite by one NRC inspecto Results:
Of the seven areas inspected, no items of noncompliance or deviations were identified in four areas; two items of noncompliance were identified in the remaining three areas (failure to follow procedures -
Paragraphs 3 and 8.d.; failure to follow Q.A. procedures - Paragraphs 7.a, 7.b, and 8.d).
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- DETAILS Persons Contacted
- D. J. Scott, Station Manager
- J.*o. Brunner, Assistant Superintendent - Technical Services
- M. C. Luoma, Station Quality Assurance Supervisor
- J. H. Paczolt Jr., Lead Nuclear Engineer J. Achterberg, Technical Staff Supervisor J. Almer, Unit 2 Operations Engineer E. Kotrich, Special Projects Engineer R. Stobert, Quality Assurance Engineer P. Roth, Nuclear Engineer
- T. M. Tongue, NRC Senior Resident Inspector
- C. D. Anderson, NRC Resident Inspector The inspector also interviewed other licensee employees including members of the quality assurance, technical, and operating staf *Denotes persons attending the exit meeting of May 3, 198.
Surveillance of Core Power Distribution Limits The inspector reviewed a number*of the licensee's surveillances of thermal limits and core power distribution limits. Procedure DTS 8235, 11Nuclear Engineer's Checklist," Revision 2, is used by the licensee to periodically check plant parameters and acquire data above 10% rated core thermal powe The inspector reviewed a sample df the checklists completed in April 1985 and verified that the data was properly recorded at the recommended frequency of about three times per wee The licensee performs and documents daily surveillances using Appendix A (of OAP 7-2), "Unit 2(3) Operator's Daily Surveillance Log, 11 Revision 16, which references a series of procedures (DOS 500) providing the methods to be used (usually above 25% rated power).
The inspector reviewed the following surveillances for April 15 through 28, 1985, and verified that the results and the frequency of the testing satisfied technical specifications, and that the data was properly recorded and reviewed:
DOS 500-6, Revision 7, "APRM Gain Adjustment, 11 provides a check on Average Power Range Monitor (APRM) reading DOS 500-12, Revision 3, "Unit 2(3) Operator's Surveillance of APRM Flow Biased Scram and Rod Block Settings (Mixed Core),
11 provides a check on APRM setting DOS 500-13, Revision 2, "Unit 2(3) Operator's Surveillance of ECCS Limitations on Power Distribution (Mixed Core),
11 provides a check on Local and Average Planar Linear Heat Generation Rates (LHGR and APLHGR).
DOS 500-14, Revision 2, "Unit 2(3) Operator's Surveillance of
- Thermal-Hydraulic Limitations on the Core Power Distribution (Mixed
- Core),
11* provides a check on Minimum Critical Power Ratio (MCPR).
_DOS.~00-17, Revision 0, 110perator 1s Daily Surveillance for Limiting Control Rod Pattern, 11 checks if a Limiting Control Rod Pattern
{LCRP) exist DOS 500-18, Revision 7, "Operator's Flow Control Line and Average Core Thermal Power Surveillance," checks if Core Thermal Power (CTP)
is<.2527 MWt (over one shift) and checks the Flow Control Line (FCI) against its limi The inspector observed that procedures DOS 500-6 and DOS 500-12, and
- Appendix A referenced Techn.ical Specification Sett.ions 3.1.B and 4.1. B concerning the reattorprotection syste Amendment 80 to the Technical Specifications, dated February 14, 1984, revised and renumbered Sections 3.1 and 4.1 such that part B no longer existed~ The inspector noted that the above mentioned procedures were revised in 1985, and that this Technical Specification change was not incorporated into the revisfon The licensee noted this concern and agreed to cotrect the error in the procedure No violations or deviations were identifie.
Calibration of the Local Power Range Monitoring System The inspecto~ reviewed the.licensee's procedures for the calibration of the Local Power Range Monitor (LPRM) system and noted that, although not specified in technical specifications, a calibration is required by the Fue 1 Warranty Contract once every 1000 effective full power hours of operatio Procedure DTS 8236, "Whole Core LPRM Calibration (Mixed Core)," Revision 1, is the checklist used *for the calibration and is performed in conjunction with DIP 100~16, LPRM Amplifier ~ain Calibrations, 11 Revision 0, which provides the instructions for prop*erly adjusting the LPRM amplifier gains. for a calibration performed on April 18~ 1985, the inspector verified that the methodology.was te~hni~ally adequate and that the checklist was properly initiale The i nspec.tor observed for LPRM adjustments performed on April 18 and
. May 1, 1985, that the LPRM Calibration Data computer printout (data sheets} had not been completed correctl Procedure DIP 100~16, Step F.8, requires that the past current level listed on the computer printout be ver~fied and recorded (checked off) on the printou Technical Specification 6.2.A states in part that written procedures shall be prepared, approved, and adhered to conc~rning normal startup, surveillance, and testing activities. Contrary to this, the license failed to check off the past current level column on the printout. This is considered an example of an item of nonco~pliance (237/85016~0la(DRS)).
The inspector also reviewed Procedure DTS 8233, "TIP System Calibration,"
Revision 3, and the completed checklist for the Traversing 1n-Core Probe (TIP) calibration performed on April 18, 198 The inspector noted that Steps F.7 and f.10 were not clearly stated and that the thecklist used to
- record the data was not properly formatte The licensee agreed to revise the procedure so that a TIP calibration can be more adequately performed and documente Step F.7 requires that a sample of both
1 and 1C 1 level calibrated LPRM readings be recorded and used in the calculation to determine the desired 100% deflection current for each TIP amplifie Contrary to this requirement and Technical Specification 6.2.A, the licensee recorded only one of the LPRM level readings and not both
1 and 1C 1 levels as specified in the procedur This is considered another example of an item of noncompliance (237/85016-0lb(DRS)).
No additional violations or deviations were identifie.
APRM (Average Power Range Monitor) Calibration The inspector reviewed Procedure DTS 8139, 11APRM Calibration," Revision 2, and verified that the results from a calibration performed on April 13, 1985, (at about 10% CTP) indicated that the APRM channels were adjusted to read equal to or greater than the actual percent of reactor rated powe The inspector observed that some of the required calibration data was recorded in the margins on the data sheet, apparently due to the inadequate format of the data sheet. The licensee noted the inspector's concern and agreed to revise the data sheet so that the data can be more clearly and properly documente Procedure DIS 700-17, 11APRM Gain Adjustment, 11 Revision 4, provides the instructions for adjusting the Average Power Range Monitor gain factor The inspector reviewed a sample of results from 10% to 95% CTP between April 13 and May 1, 1985, and verified that the Average Gain Adjustment Factors (AGAFs) were in the acceptable range of 0.980 to 1.01 The inspector also verified that all data was properly recorded, including the as-found and as-left AGAFs, and that the results were signed-off and reviewe No violations or deviations were 'identifie.
Core Thermal Power Evaluation The inspector reviewed Procedure DTS 8237, "Calculation of Core Thermal Power - Technical Staff Method, 11 Revision 4-, and related information such as computer printouts and daily surveillances of CT This procedure outlines four methods for performing a thermal heat balance and determining CT The inspector reviewed calculations performed on April 14, 17, and 23, 1985, and verified that the licensee's methodology and calculations were technically correc The inspector noted that the completed calculations were apparently not being properly reviewe Examples were found in which an incorrect and/or incomplete calculation was being signed-off as completed and reviewed; however, the inspector observed that all data necessary for the calculation was retrievable (e.g., a computer printout was attached to the calculation). The licensee noted this concern and assured the inspector that proper independent review would be implemente The inspector has no further concerns regarding this ite No violations or deviations were identifie..
- Determination of Reactor Shutdown Margih The inspector reviewed Procedure DTS 8134, "Units. 2/3 Shutdown Margin Demonstration," Revision 8, used by the licen~ee to satisfy Technical Specification 4.3.A.l surveillance requirement subsequent to the cycle 10 core loa The licensee used both the in-sequence critical method and the 2-rod diagonally.adjH~ent subcritical method to demonstrate t_R~t the minimum margin of 0. 25% -. + R could.be met (note that R = 0. 02% -, as provided by the fue 1 vend~r). The inspector verified that the *1ic~nsee 1 s methodo 1 ogy and calculations were technically correct and in accordance with techni ca 1 speci fi cations, and that the results indicated that an adequate shutdown margin could be maintained throughout the current operating cycl The inspector also verified that the data was properly recorded, including data supplied by the fuel vendor (Exxon), and that the resµlts and calculations were reviewed by the appropriate personne No violatians or deviations were identifi~.
Nuclear Instrumentation Response and Reactivity Checks The inspector reviewed the licensee's procedures and test results concerning Nuclear Instrumentation (NI) response and reactivity check The following observations were made during this review: Procedure DTS 8138, "IRM Performance," Revision 1, is used by the 11 censee during startup to verify that the Intermediate Range Monitors (IRMs) can detect neutron flux and to verify IRM overla The inspector reviewed the data obtained between
April 10 and 13, 1985, and observed that the format of the data sheet was apparently inadequate in that data and subsequent corrections to the data could not be clearly recorded in the spaces provided. The licensee agreed to revise the data sheet so that the data can be
.clearly and legibly recorde CFR 50, Appendix B, Criterion II, as implemented by the CECo Quality Assurance Manual, states in *part that the quality assurance program shall be documented by written p~ocedures and shall be carried.out in accordance with those
. procedure Quality Procedure Q. P. No. 17-51, "Quality Assurance Records for Operations - Control of Station Records, states that the acceptable method for making changes to records is to line-out the information, initial, date it, and then make the correctio This quality procedure specifically prohibits modifying documents with the use of white-out~ correction tape, scribbling out information, and marking over dat Contrary to this, the inspector identified a number of scribbled out and marked over data on the IRM performance data sheet This is considered an example of an.item of
- noncompliance (237/S5016-02a(DRS)). Procedure DTS 8135, "SRM Performance," Revision 2, is used by the licensee during startup to verify SRM operability and to verify overlap into the intermediate flux rang The inspector reviewed the data obtained on April 10, 1985, and contrary to the Q.P.
No. 17-51 requirement above, a number of examples were identified in
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- which data had been scribbled out and marked over (not legible).
This is considered another example of an item of noncompliance
. (237/85016-02b(ORS)).
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Procedure OTS 8154, 11Contro 1 Rod Following and LPRM Operability Verification, 11 Revision 2, is used by the licensee during startup to verify that the LPRM detectors are operable and to verify that each control rod blade is following its drive by observing the NI respons The inspector reviewed the results obtained during the Cycle 10 startup in April 1985, and verified that the licensee's methodology was adequate and that the data was properly recorded and reviewe Procedure OTS 8141, "U~2(3) Init1al Criticality Comparison, 11 Revision 3, is used by the licensee during startup to perform an eigenvalue comparison by comparing the calculated critieal control rod pattern to the actual critical con.trol rod patter The inspector reviewed the results from the April 10, 1985, calculation and verified that the methodology was adequate, that the licensee had accounted for period and moderator temperature coefficient corrections, and that the data was properly recorded, including data supplied by the f,H~l ve~do~. The inspestor noted ~hat.the resultant a~omaly of O.O_Ai k sat1sf1ed the Technical Specif1cat1on 3. limit of 1.0% I(* Procedure OTS 8137, 11Moderator Temperature Coefficient of Reactivity,"
Revision l; is used by the licensee during startup to describe a
method of acquiring data and evaluating temperature de~endence. The inspector revfewed data obtained on April 10, 1985, and verified that the procedure was performed and data recorded for at least three reference temperatures as specifie The.inspector observed that the procedure did not require signatures of the test personnel or review of the dat The lice.nsee noted this. concern and agre~d to revise the data sheet to include a signature block for the participants p*erforming the tes No addftional violations or devi~tions were identifie.
Control *Rod Drive Performance Testing The inspector reviewed the licensee's procedures and test results for startup testing of the control rod drive The following observations were made during this review:.Procedure OTS 300-*2, 11Contro 1 Rod Ori ve Scram Testing and Scram Valve Timing Test, 11 Revision 9, is used by theJicensee to satisfy Technical Specification 3.3.C, 4.3.C, and 3.5.K surveillance requirements and scram valve timing requirement The inspector witnessed portions of the test and reviewedthe results from the testing performed on April 15 and 16, 1985, and verified that the data was recorded correctly, that the checklists were properly reviewed and documented, and that all technical specification
requirements were me The inspector observed the "Limitations and Actions 11 section of the procedure did not include a reference to the Technical Specification 3.3.C requirement, which st~tes the limits on the average scram insertion times as a function of the percent that the rod is inserted. The licensee's administrative procedures discuss the content of a "Limitations and Actions" section and state, in part, that this section should include the limitations on the parameters being.controlled. Other licensee commitments require that written acceptance criteria be included in a procedur The licensee noted the inspector's concern and agreed to revise the "Limitations and Actions section to include a statement referencing the Technical *
Specification 3.3.C requiremen Procedure DTS 300-6, "Control Rod Drive Friction Testing,
Revision 5, is used by the licensee to provide the instructions to friction test the Control Rod Drives (CRDs).
The inspector reviewed the results from testing performed subsequent to Cycle 10 core load and verified that the data was properly recorded and that the sign-off checklists were complete The inspector noted that there*
was extensive use of pencil entries for recording and verifying dat Although this is considered a poor documentation practice, there is no written requirement prohibiting the use of pencil on quality record Procedure DTS 300-10, "Control Rod Drive Functional Scram Testing,
Revis.ion 1, is used by the licensee to functionally test the CRDs prior to reactor startup to verify their operability. The inspector reviewed the test and verified that the checklists were properly signed-off and reviewe Procedure DOS 300-4, 11Control Rod Drive Timing, 11 Revision 4, is used by the licensee to verify proper CRD withdraw and insertion time The inspector reviewed data from the testing performed on April 3 through April 8, 1985, to verify that the applicable checklists were completed correctly and that the results indicated that the test requirements were satisfied. Part C.4 of this procedure requires that the drive time shall be adjusted to 48 seconds +/-10.0% and then retime Drive timing is performed by the process computer which will print out the time accurate to the nearest 0.01 second (if the computer is not available, a stopwatch is used).
Technical Specification 6.2.A states in part that written procedures shall be prepared, approved, and adhered to concerning normal startup, surveillance, and testing activities. Contrary to this, on April 5, 1985, the licensee failed to adjust and retime the drive at location G-11 (26-43) which had a total insertion time of 43.15 second This is considered an example of an item of noncompliance (237/85016-0lc(DRS)).
In addition, the inspector noted that corrections to the records were not being properly mad CFR-50, Appendix B, Criterion II as implemented by the CECo Quality Assurance Manual, states in part that the quality assurance program shall be documented by written
- procedures and shall be carried out in accordance with those procedure Quality Procedure Q.P. No. 17-51, "Quality Assurance Records for Operations - Control of Station Records, 11 states that the acceptable method for making changes to records is to line-out the information, initial, date it, and then make the correctio This quality procedure specifically prohibits modifying documents with the use of white-out, correction tape, scribbling out information, and marking over data. Contrary to this, the inspector identified a number of scribbled out and marked over data. Further-more, for CRD D-4 (14-15), steps 160A and 1608, on April 6, 1985, correction tape was used to change the withdraw and insertion times, the drive water pressure, and the stall flow This is considered an example of an item of noncompliance (237/85016-02c(DRS)).
No additional violations or deviations were identifie.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) on May 3, 198 The inspector summarized the scope and findings of the inspectio The licensee acknowledged the statements made by the inspector with respect to the items of noncomplianc The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents/processes as proprietar *
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