IR 05000237/1988018

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Insp Repts 50-237/88-18 & 50-249/88-19 on 880714-0909. Violation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Operational Safety Verification, Followup on Events & Monthly Surveillance Observation
ML17201L544
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 09/23/1988
From: Ring M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17201L428 List:
References
50-237-88-18, 50-249-88-19, NUDOCS 8810050147
Download: ML17201L544 (11)


Text

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U. S. NUCLEAR REGULATORY COMMISSION REG ION "II I Report Nos. 50-237/88018(DRP); 50-249/88019(DRP)

Docket Nos. 50-237; 50-249 Licensee:

Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 License Nos~ DPR-19; DPR-25 Facility Name:

Dresden Nu.clear Power Station, Units 2 and 3 Inspection At:

Dresden* Site, Morris, IL Inspection Conducted:

J~ly 14 _through September 9, 1988 Inspectors:

s.* G. Du Pont P. D. Kaufman D. R.. Calhoun Approved By:

M. A. Ring, Chief~~~7-.

Reactor Projects S~tion 1B :..

Inspection Summary a/t~l10. *

~

.. IRS ection durin the eriod of Jul 14 throu h Se tember 9~ 198 Re ort No /88018 DRP ; 0-2 /88019 DRP Areas Inspected:

Routine unannounced resident safety inspection by the resident inspectors on licensee action on previous inspection findings, operational safety verification~ followup of events, monthly maintenance observation, monthly surveillance observation, licensee event reports followup, management meetings, and report revie Results: *Of the eight areas inspected, no violations or deviations were identifie One violation regarding failure to maintain secondary containment while in the run_ mode was i dent i fi ed in a previOus report (237 /88011; 249/88013),

however, the Notice of. Violation (NOV) was not 1ssued at that time due to

. * *

delibefations for potential escalated enforcemen Following an enfo~tement conference with the 1 i censee on August 19, 1988, th'i s issue.was determined by the NRC to be properly categorized as a Severity Level IV violation and the NOV is being issued with this report (see paragraph 2).

3810050147 PDR ADOCK

8EK>923 05000237 PDC*

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_DETAILS Persons Contacted Corrunonwealth Edison Company

  • E. Eenigenburg, Station Manager J. Wujciga, Production Superintendent

. *C. Schroeder, Services Superintendent

  • L. Gerner, Superintendent of Performance Improvement T. Ciesla, Assistant Superintendent -

Planni~g

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D. Van Pelt, Assistant Superintendent - Maintenance J. Brunner, Assistant Superintendent ~Technical Services J. Kotowski,.Assistant Superintendent -

Op~rations R. Christensen, Unit 1 Operating Engineer G~ Smith, Unit. 2 Operating Engin~er K. Peterman, Regulatory Assurance Supervisor W. Pietryga, Unit 3 Operating Engineer

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J. Achterberg, Te~hnical Staff Supervi~or R. Geier, Q.C. Supervisor

D*.*sharper, Wast~ Systems Engineer D. Adam, Radiation Chemistry Supervisor J. Mayer, Station Security Administrato D. Morey, Chemistry Supervisor D. Saccomando, Radiation Protection Supervisor

  • E. Netzel, Q.A. Superintendent
  • J. Williams, Regulatory Assurance
  • K. Yates, ONSG Supervisor
  • R. Janecek, Superintendent Participant - Offsite Review

.*L. Tapella, BWRE Fi~ld Engineer

  • T. Lewis, Regulatory Assurance_Staff The inspectors also talked with and interviewed several. other licensee

~mployees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, and contract security personne *Denotes those attendihg one or more exit interviews conducted on September 9, 1988, and i nforma llY at various times throughout the inspection perio *. Licensee Action on Previous Inspection, Findings (92701).

(Closed) Open Item~ (237/88017-07; 249/88018-07):. DET Item 2~2.1.5, NRR to evaluate Technical Specification Table 3.1.1 for adequacy of APRM/IRM

. companion requirements while in the RUN mode.* NRR has. reviewed the licensee's Technical Specification amendment to elimi~ate the average power range monitor scram requirement and has issued Amendment No. 100 to Provisional Operating License No. DPR-19 for Dresd~n Unit 2 and Amendment No. 96 to Facility Op.erating License No. DPR-25 for Dresden Unit 3 per*

'

NRC letter dated August 24, 1988 to Mr. H. Bliss, Nuclear Licensing Manager* Commonwealth Edi son Company..

(Closed) Open Items (237/85006-04 and 249/85005-04):

Core spray isolation valves 1402-24A and 24B need to be added to the Inservice Testing (I~T) Program for Stroke tim~ testin The inspector verified by reviewing. the 11 Inservice Testing Program for ASME Class 1, 2 and 3 Pumps and Valves, Revision 2~ submittal to NRC, that valves 1402-24A and 24B are scheduled for BT type testing (full stroke timing).

As such,

.these items are constder~d to be administratively closed~

(Closed) Unresolved Items (237/86004-03):. All main Control room panels not installed according to design draw-ings.. Licensee should supply an evaluation. of the new installation design for seismic qualification.. on*

June 3, 1986, the R_egion III Div.ision of Reactor Safety completed the review of CECo's submittal for the Dresden Station Control Room Panel The associated Sargent and Lundy report, "Design Assessment of.Dresden Units 2 and 3 Control Room Panel Mounting," dat~d April 28, 1986, was reviewed and verified to be adequate to meet the necessary code requirement The inspector also verified by visual inspection of the panel anchorage that modifications: associated with the design assessment were complete This concern is close *

(Closed) Open Items (237/87032-01 and 249/87031-01):

The.licensee conducted the first mandatory training session from August 10* to September 18, 198 The licensee has committed to incorporate this mandatory attendance training into the "Licensed Operator Requal ification >> *

Program," DPP-The inspector reviewed Revision 8 to DPP-5 and verified that the mandatory attendance training was incorporated. This item is

  • considered to be closed, however, additional open items {237/87038-02 and 249/87037-02) identify that all training cycles; beyond the two training sessions identified by items 237/87032-01 and 249/87031-01 are also to be
  • incorporated as mandatory training* sessions, and, as such, remain ope (Closed) Unresolved Item (249/86017-02):

The acceptance criteria used to*

upgrade a non-safety related motor for application as the Emergency Core*

Cooling System (ECCS) keep fill pump was not readily ~pparent in the work package 4786 The original motor specifications were compared to the replacement motor's specifications and an evaluatfon was complete The inspector reviewed the comparison and concluded that the evaluation was satisfactory.* This item is close (Closed) Open Items (237/88017-24; 249/88618-24):* DET Items 3.2,j~ * *

measurement and testing equipment (M&TE) should be verified to be controlled, including logged per DMP 100- The DMP 100~2 procedure has*

.been deleted and replaced by OAP 11-22, "Control of Measuring and Test. *

Equipment," which enhanced the method for controlling and recording data.

associated with measuring and testing equipment..In addition, training *

was conducted on the implementation of OAP 11-2..

(Closed) violation (237/88011-01; 249/88013-01):

Secondary containment degraded *by Removal of Main Steam Line Penetration Seals.* An asbestos contractor inadvertently removed the boot seals from the MSL penetration The cause was determined to be management deficiency due to the fact that contractor personnel received inadequate direction and sup~rvisio Corrective actions included replacement of the boot seals, performance of a followup Secondary Leak Rate Test (SLRT), and discussions with the personnel involved. This event was reviewed and documented in paragraph 4.d o( Inspection Report 237/88011; 249/8801 In addition, the licensee discussed and presented their corrective actions for this event in an enforcement conference at the NRC Region III Offices on Aug~st 19, 198 This event was described as a violation (237/88011-01; 249/88013-01) for permitting Unit 2 to operate at power without maintaining the integrity of secondary containment, which is a Violation of Technical Specification 3.7. However, a Notice of Violation was not. issued in report 237/88011; 249/88013 due to escalated enforcement deliberations. The NOV is b~ing issued w*ith this report.* Since the corrective actions listed below were*

already discussed during the Enforcement Conference and adequately ensur~

prevention of recurrence, no response to this violation is required:.

Short Term torrective Actions

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0

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Discussed e~ent in detail with Project and Construction Ser~ices (PACS) and contractor personnel involved on May 17, 198 Isolated X-Area from Rx. Buildin Secondary Containment Leak Rate Tes.t (SCLRT) successfully performed on May 19, 198 Included event in an awareness/expectation session pr,esented by

. Station Manager and PACS Superintendent to contractor personnel and supervision on June 6, 198 Discussed eve~t in Station Tai1gate S~ssion on June 16, 198 Installed new permanent seal Passed SCLRT on June 19~ 198 Discussed quality of information provided on work requests and during the review of work requests in a Station Tailgate oh June 23, 198 Long Term Corrective Actions

Development of improved control of:contractor work activitie PACS Initiative Elements include:

0

100% pre-job walkdown with checklist Station review of work packages prior to work startin Real time station/non-station (PACS) interaction at plannirig meetings~

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..

Station augmentation of waJkdowns and checklists, as appropriat Issue Sta ti on OAP 1-4, 11Stati on Contra.ctor Control 1.

Operational Safety Verification (71710 and 71707) The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the inspection perio The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component Tours of Units 2 and 3 react9r buildings and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid l~aks, and extessive

  • vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc~.

The inspectors denoted an improving trend with respect to the ~mount df oil ~nd ~ate~ leaks during this inspectio The inspectors observed plant housekeeping/cleanlines~ c6nditio~s an~

verified implementation of radiation protection controls. During trye_

inspection, the inspectors walked dowh the accessible*portions of the systems listed below to verify operability by comparing system lineup with plant drawings, as~built configuration or present valve lineup lists; observing equipment conditions that could degrade performance; and verified that in~trumentation was ~roperly valved, functioning, and calibrate **

The inspectors reviewed new procedures and changes to procedures that were implemented during the inspection period. The re~iew consisted. of a verification for accuracy, correctness, and compliance with regulatory requirement *

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 following systems were inspected:

Control Rod Drive System - Unit 2 and 3 Isolation Condenser System - Units 2 and 3 Low Pressure Coolant Injection - Unit 2 *

Core Spray ~ Unit *

No violations or deviations were identified in this are Followup of Events (92700)

During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50~72. The inspectors pursued the events onsite with licensee and/or

other NRC official In each case,.the inspectors verified that the

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notification was correct and timely, if appropriate, that the licensee was taking prompt and appropriate actions, that activities were conducted within regulatory requirements and that corrective actions would. prevent future recurrenc The specific events are as follo~s: On August 10, 1988, at 6:30 p.m.(CDT), while.Unit 2 was at 50%.

power, the suction valve (1601-55) to the nitrogen pumpback system failed the required Technical Specification timing requirement during a routine surveillanc The valve supplies nitrogen to the pumpback system from the normal nitrogen makeup and purge syste The pumpback system maintains the drywell to torus differential pressure and provides the operating motive force to the inboard MSIV In addition, the valve serves as a primary containment isolation valv The Technical Specifications require that th~

valve will go full closed during a primary containment isolation initiation within 15 second Since the valve failed th~ timing requirement, Technical S~ecifications require that the valve be placed in its initiation position or. be in cold shutdown within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The licensee inspected the valve's ai~ operated solenoid, manufactured by ASCo, for internal dust, oil and wate The-inspection did not reveal any significant impuritie.

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The valve was retested at about 1:00 a.m. on August 11, 1988, but still failed to pass the timing requirement.* The valve was plated in its initiation positi6n, closed, and, as such~ satisfied the Technical Specification*requirement for primary c_ontainmen isolation. With the valve in the closed position, shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> w~s no lcinge~ required.. However, Technical Specifi~ations also require that all valves associated with the normal nitrogen makeup and purge system be operable.* With the nitrogen suction va 1 ve to the pumpback system, part of the normal nitrogen system, declared to be inoperable and in the closed position, the unit *

entered a 7 day Limiting Condition for Operatio The emergency nitrogen makeup system was lined up to the pumpback system to ensure that the drywell to torus differential pressure was being maintai*ned within the Technical Specification limits and that nitrogen wa~ being provided for MSIV operatio To restore the normal nitrogen pumpback system the licensee replaced the diaphragm on ~alve 1601-55's solenoid.. The valve substjuently tested satisfactorily and the LCO was exited. *

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- On August 25, 1988, at 4:00 a.m. {CDT), with reactor power at 77%,

Unit 2 High Pressure Coolant Injection System (HPCI) was declared inope~able when the HPCI steam line flow transmitter failed to meet Technical Specification limits while perfonning an instrument calibration surveillanc The licensee replaced the HPCI flow transmitte The failed transmitter is being analyzed by th manofactur~r fat root caus *. On August 27, 1988, with Reactor Power at 57%, an Unusua 1 Event was declared on Unit 2 at 10:28 p.m. (CDT) due to a Target Rock Safety Relief Valve being declared inoperable after receiving a control room alarm which would not reset. The alarm circuitry was checked

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,*

to be satisfactory, so the licensee made a drywell entry to further investigate the proble The pressure switch was removed and replaced, however, the pressure switch which was removed. bench-tested satisfactorily. The safety relief valve performed as r~quired. The problem appears to have been too much tension o~ the electrical connection The Unusual Event was terminated at 6:32 a.m. on August 28, 198 On August 31, 1988~ while at 95l power (760MWe), Unit 3's 3A Recirculation Pump tripped at 6:10 p.m. (CDT) during a transfer o the Motor Generator Oil Coolers for cleaning 9f the oh-service.

coole The trip was caused by low oil pressure associated with the standby coole The low bil pressure and 3A Recirc Pump tri~

annunciators were reteived immediately after the tran~fer to the standby cool~r. The operator took manual control of feedwater and maint~ined vessel level l~ss than 43 inche The unit was stabilized at'6:15 p.rr:. and the feedwater was returned to automatic control with vessel level at 30 inches and reactor power at 360 MW The

  • operator insert~d the control rods to return reactor operations below the operating curve for single-loop operatio The apparent cause of the low oil pressure was due to the standby cooler not being fully vented and fi 11 ed prior to transfe The 3A Reci re Pump*

was returned to operation at 8:25 p.m. after the oil cool~r was

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comp 1 ete ly vented. and fi 11 e The 1 i censee determined the root

  • cause of -the failure to have the oil cooler vented and filled was

.a procedural deficienc The Senior Resident Inspector was in the control room during the event ~nd observed the operator actions throughout the tran~ient and recovery process...

No violations or deviations were identified in this are.

Monthly.Maintenance Observation (62703~ 71710)

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

codes or standards and in conformance with technical specification The following items were considered during this review:

the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the*

work; activities were accomplished using.approved procedures and were

  • inspected as applicable; functional testin~ 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 wereimplemented; and, fire prevention*controls were implemente 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 followin~ maintenance activities were observed/reviewed:

Unit 2 CRD Accumulators for C-8 J E-11 (Post-maintenance testing after replacing the accumulators)

No violations or deviations were identified in this area.. * Monthly Surveillance Observation {61726)

The inspectors observed surveillance testing required by technical specific~tions for the items listed below and verified that testing was performed in accordance with adequate procedures, that test

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instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed witti technical specifications and procedure requirements and were reviewed by personnel other than t.he *

individual ~irecting the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne *

The inspectors witnessed portions of the following test activities:

Unit 2 - Scram Tinie Testing No vi6lations* or deviations were identified in this are.

  • Licensee Event Reports Followup (93702)

Through direct observations, discussions with 1icensee personnel, and review of records, the following ~vent reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective ~ction to prevent recurrence had

. been accomplished in accordance with Technical. Specifications:

(Closed) LER 237 /88006-00:

Loss of PrimarY Containment Nitrogen Inertin*g Makeup System Due to Piping Damage Caused by Personnel Error *. Cause was determined to be personnel error due to inattention to detail. during rigging operations in which a sling and come-along assembly were inadvertently slung over a nitrogen.inerting makeup line. Corrective actions included repairing the damaged nitrogen inerting makeup system*

line, the issuance of a policy memorandum regarding proper riggin9 practices and making a revision to Dresden Maintenance Procedure (DMP)

5800-3, "Safe Rigging Practices," (237/200-88-05501).

Also, additional

  • training on rigging operations was scheduled for MMD personnel. This event which was reviewed and documented in Inspect.ion Report.237 /88006; 249/88007, resulted in a Notice of Violatio (Closed) LER 237/88011-00: Secondary Containment Degraded by Removal

. See paragraph B

...

(Closed) LER 237/88012-00: *Main Steam Isolation Valves Failure to tlose Due to High Stem Drag Forces Caused by Valve Packing.* The cause was

  • determined to be the replacement of the original packing material by a substitute packing material fabricated with a 287I material. Corrective actions included repacking all inboard MSIVs using a Chesterton grafoil type packing; adjusting the packi~g on two of the outboard MSIVs, and replacing the upper six rings of packing* on the remaining two outboard MSIV In addition, operator training in regards to the event was performed, control room annunciator procedures were revised and a leak inspection of all Unit 2 MSIVs was performed prior to power operatio The followup on this issue was documented in the Augmented Inspection Team (AIT) Inspection report N ~237/88013(DRP).

(Closed) LER 237/88013-00: Fuse in Analog Trip System Panel 2202"".73A Opened Du¢ JO.* Failed Standby Gas Treatment Master Trip.Unit... The cause was deterrnfoed to be High Current Drawn by the SBGT MTV 2/3-7541-46A card; however, the cause of the fault in the SBGT *MTV card could not be determined~ Corrective actions included removing the SBGT MTV card and feplacing fuse F-5 on Panel 2202-73A to restore power* to the other MTV (Closed) LER 237/88014-00:

Unit _2/3 Chimney Tritium Sampling

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Surveillance Interval Exceeded Due to Personnel Erro The cause ~as.

  • determined to b~ inattention to the* pending due dat~ of the surveillance by a Chemistry Department Management personne Correc_tive actions includ_ed ~ssigning an individual to be the Departmental Surveillance Co6rdiriator and. the personnel involved were counseled. *

. (Closed) LER 237/88016-00:. Emergency Core Cooling System (E'cCS) *

Initiation Indicating Switches Out 6f.Calibration Due to Instrument Drif The cause was attributed to instrument drift; however, the

  • .cause -of the instrument drift could riot be determine Corrective action included adjusting the level indicating switches to within ideal trip setpoint limits:

(Closed) LER 249/85018-02:

Re~ctor Scram on High Flux Resulting From Turbine Control Valve Closure Due to"Personnel Erro Cause wa determined to be inadvertent movement of a circuit car Corrective action included revising Unit 2/3 Scram Procedu~e DGP 2-3, to ensure tha the SDV vent and drain valves remain closed until all scram inlet and outlet valves are closed. Also, larger air regulators will *be installed*

on the Unit 2 and 3 SDV Air Header Systems in order to provide -improved air suppl (Closed) LER 249/88008-00:

Violation of Secondary Containment Integrity Due to Personnel Interlock Door Circuitry Failure. Cause was determ.ined to be a loose power supply fuse for the interlock door circuitr Corrective action included tightly inserting the fuse Jnd installing a*

restraining assembly over the fuses *. This event was pre!liously reviewed and documented in Paragraph 4.d. of Inspection Reports 237/88011; 249/8801 In addition, the licensee attended an enforcement conference on August 19, 1988, which included this even..

(Closed) LER 249/88011-00:

Group II Primary Containment Isolation Due to Pro.cedura 1 Inadequac Cause was determined to be the De-Energization of the Drywell High Radiation Monitors While Hanging an Out-Of-Service on the Atmosphe~ic Containment Atmosphere Dilution /Containment Air Monitoring/ACAD/CAM Syste Corrective actions included clearing the outage~ restoring power to the drywell High Radiation Monitors and attaching caution labels to the two Breakers which supply power to the

  • drywell High Radiation Monitor In addition, revisions to Dresden Administrative Procedure (OAP) 3-5, Out-of-Service and Personnel Protection Cards ~ere made to require the review of current electrical schematics and wiring diagrams to verify unusual out-of-service requests, as well as to emphasize the individual's responsibility for assuring out-of;..serv ice accura.cy from a personne 1 safety aspect and a system interaction per~pectiv~.

(Closed) LER 249/88013-00:

Loss of the 3A ~eactor Protection System Bus and Subsequent ESF Actuations Due to a Loose Wire *connectio The cause*

was determined to be a loose RPS MG setoverload relay connection on the Main Feed Breaker. Corrective actions included lugging ~11 the cable connections to the overload relay Breaker.maintenance procedures will be revised to ensure that all ove~load relay cable connections ar~ sblid; as well as utilizing a thermovision devic~ for detecting hot spots caused by poor connection *

(Closed) LER 249/88014-00: * Group.II and Group III Primary Containment Isolations Due to a Procedure Deficienc Cause was determined to be an erro~ in procedure DOS 6600-3 which d{d not m~ntion the Group II.and Group III isolations. Corrective actions intl'ude ~ procedure revisiori *

which will state that an isolatioh will-occur when performing the surveillance in accordance with the procedur (Closed) LER 249/88015-00:

Main Steam Isolation Valve (MSIV) Pneumatic Une Exceeded FSAR-Design Criteria Due to Design Deficie*ncy; Cause was determined to.be a design deficiency during the original construction of the MSIV-pneumatic accumulator supply syste Corrective action included modifying the" pneumatic supply.line to meet the FSAR design.criteria.

. (Closed) LER 249/88016-00: Anticipated Transient ~ithout Scr~m (ATWS)

System Actuation Due to Inadequate Operator Training. *Cause was determined to be an improper method of instrument isolation. Corrective action included tra'ining operating personnel on the correct manner to isolate various types of instruments based on their trip funct'io One violation was identified in this are.

Management Meetings (30702)

NRC Region III Management visited the Dres*den site on July 14 and August 25, 1988, to discuss recent licensee performance and INPO's 1988 Evaluation Summary with Commonwealth Edison Manag~men **

An Enforcement. Conference was held on August 19, 1988, in the NRC Region III Office to discuss the chronology of events regarding two events in *

.*which Secondary Containment was degrade *

9;

~epo~t Review During the inspection period, the inspectors reviewed the licensee's Monthly Operating Repo~t*for July and August, 198 The inspectors confirmed that the information provided met the requirements of Technical Specification 6.6.A.3 and Regulatory Guide 1.1 l Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

on September 9,. 1988, and informally throughout the inspection period, and summarized the scope and findings of the inspection activities. *

The inspectors 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 riot identify any such *

documents/processes as proprietary. The licensee acknowledged the findings of the inspectio