IR 05000237/1988022

Safety Insp Repts 50-237/88-22 & 50-249/88-23 on 880910-1122.No Violations Noted.Major Areas Inspected:Tmi Action Plan Requirements,Operational Safety Verification, Followup of Events & Monthly Maint Observation

ML17201M245
Person / Time
Site:	Dresden
Issue date:	11/25/1988
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17201M244	List: IR 05000237/1988022 ML17201M242
References
50-237-88-22, 50-249-88-23, NUDOCS 8812010175
Download: ML17201M245 (20)

Text

U. S. NUCLEAR REGULATORY COMMISSION REGION I II Report Nos. 50~237/88022(DRP); 50-249/88023(DRP)

Docket Nos. 50-237; 50-249 License Nos. DPR-19; OPR-25 Licensee: * Conmonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 Facility Name:

Dresden Nuclear Power Station, Units 2 and 3 In~pection At:

Dresden Site, Mbrris, IL Inspection Condu~ted:

S~ptember 10 thru November 22, 1988 Inspectors:

s. G. Du Pont P. D. Kaufman D. R. Calhoun D. E. Jones J. D. Smith M. J. Kopp

. R. M. Lerch

1. /'.~**!ht-Approved By

M. A. Ring, Chief Reactor Projects Section 1B Inspection Summary

,,, ;2..r:-, B'

Date *

Ins ection durin the eriod of Se tember 10 throu h Nov.ember 22, 1988 e ort OS. 50-237/88022 D p ; 50-249/88023 DRP reas nspecte :

out1ne unannounce safety inspection by the resident inspectors on previously identified inspection items, TMI action plan requirements, operational safety verification, followup of events, monthly maintenance observation and program implementation, monthly surveillance observation, information of high temperature inside containment/drywell in PWR and BWR plants, management meetings, management changes and report revie Additionally, this inspection report addresses the initial findings of the Unit 2 drywe.11 elevated temperatures reported to the NRC on November 4, 198 Results:

Of the 10 areas inspected, no violations or deviations were identifie *

Review of TI 2515/98, "Information of High Temperature Inside Containment/Drywell in PWR and BWR Plants" indicated that the licensee monitors drywell temperatures with a single point source near a major heat source (recirculation pump motors) and does not monitor drywell average temperature representing the drywell as a whol ~~A201017s 00112s Q

.ADOCK 05000237 PNU

0

0 Several TMI Action Items (2.E.4.1.2, 2.K.3.28 and 2.D.3.1) were satisfactorily resolve *

General plant 6perati~n continues to be conducted in a professional.

and s-afe manner with the facility achieving* 397 days (on November 22, 1988) without any scrams from power on either unit.* According to General Electric this is the best record of any dual unit BWR (previous record of 310

days) in the worl The maintenance program implemeritation review indicated that many of the improvement programs are not completely implemented, however, performance indicators revealed significant improvement-of system reliability as demonstrated by only one HPCI failure in 1988 versus six in 1987, only three compone~t failure related LERs versus 23 in 1987, no equipment related scrams and a significantly reduced forced outage rat On November 4,.1988, the licensee discovered insulation damage to power and control cables to the Isolation Condenser (1301-04) and High Pressure Coolant Injection (2301-04) systems' steam supply isolation valves on the upper elevation of Unit 2's drywell during the initial drywell entry. inspectio Both of these are safety-related environmentally qualified motor-operated valve The licensee's initial root cause determination indicated that the cause was due to an incorrect ventilation lineup within the drywel *

DETAILS Persons Contacted Commonwealth Edison Company 0 *E. Eenigenburg, Station Manager 0 L. Gerner, Production Superintendent 0 *C. Schroeder, Services Superintendent 0 *C. Allen, Performance Improvement Supervisor

• T. Ciesla, Assistant Superintendent - Planning

• D. Van Pelt, Assistant Superintendent - Maintenance J. Brunner, Assistant Superintendeht - Technical Services J. Kotowski, Assistant 5uperintendent - Operations R. Christensen, Senior Operating Engineer G. Smith, Unit 2 Operating Engi~eer 0 *K. Peterman, Regulatory Assurance Supervisor W. Pietryga, Unit 3 Operating Engineer J. Achterberg, Technical Staff Supervisor R. Geier, Q.C. Supervisor D. Sharper, Waste Systems Engineer D. Adam, Assistant to the Assistant Superintendent - Technical Services J. Mayer, Station Security Administrator D. Morey, Chemistry "Services Supervisor D. Saccomando, Health Physics Services Supervisor

• E. Netzel, Q.A. Superintendent 0 E. Zebus, BWR Engineering 0 M. Pape, Quality Assurance 0 D. Silady, Licensing Administrator 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 personne *Denotes those attending one or more exit interviews conducted informally

.. at varfous times throughout the inspection period or the formal exit on November 4, 198 *

0 Denotes those attending ~he exit on November 22, 198.

Previously Identified Inspection Items (92701 and 92702)

(Closed) Violations (237/88006-01 and 249/88007-01):

Dresden Maintenance Procedure DMP 5800-3 (Revision 3), "Safe Rigging Practices", was inadequate because it did not specify the apparatus to which a chain fall can be attached or suspended when lifting loads. This resulted in a broken nitrogen makeup supply line to both Units 2 and 3 on April 29, 198 The procedure, DMP 5800-3, was revised to include correct rigging practices and a pre-lift verification to ensure that lifts are made from correct supports. Additionally, maintenance and contractor staffs ieceived initial training with additional continuing maintenance training starting in the first cycle of 1989. These actions appear to be adequate and these items are considered to be close *

(Closed) Violation (237/88006-02): _The operator inadv~rtently missed a

• step in the High Press~fe Coolant Injection (HPCI) monthly surveillance procedur The surveillance (DOS 2300-6) has an In-Service Test (IST)

required parameter of 50_QO ga 11 ons per minute ( gpin) and, s i nee the I ST value was. not reviewed uritil after the surveillance was completed, the omitted ~tep of the procedure was not discovered until the post test revie The licensee has corrected this deficiency by revising DOS 2300-6 to require review of IST limitations during surveillance testin These actions are considered to be adequate and, as such, this item is considered to be close (Closed) Unresolved Iteins (237 /88017-18 and 249/88018-18):

Diagnostic -

Evaluation Team Item 2.2.2.3, maintenance procedures DMP 040.:9, 040-11, 040-17 arid 040-18 are inadequate, in that, cautions and instructions for the removal and installation of motor operated valve motors and pinion gears were not contained in the procedures. Additiorially, DC power motors were not included in the procedure *

-

The inspector reviewed procedure DMP 040-9, 11Limitorque Valve Operator Maintenance," Revision 2 (dated December 1987).

The revision contained instructions and cautions for the installatiori and removal of the motor pinion gea In a_ddition, the procedure contained a clear drawing of the pinion gear assembly as a guide for the maintenance personnel using the procedur The procedure also contains instructions for the inspection-of DC motor Procedures DMP 040-9, DMP 040-11, DMP 040-17 and DMP 040-18 are scheduled by the lice.nsee to be cancelled and replaced with new procedures DEP 040-9, DEP 040-11, DEP 040-17 and DEP 040-1 The inspector reviewed the draft DEPs (the procedures are currently in the onsite review and approval process) and verified that the corrections made to DMP*040-9 (Re~ 2) were incorporated in the new procedures. _This item is considered to be close (Closed) Violation (237/87005-01):

On November 29, 1986, Unit 2 exceeded the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Limiting Condition of Operation (LCO) for Technical Specifications 3.7.A.5.b and 3.7.A.7.a(l) by de-inerting the containment while operating. This resulted in an imposition of a civil penalty on February 11, 198 On January 11, 1988, a meeting was held between CECo, the Office of Nuclear Reactor Regulation (NRR) and other*NRC offices to, discuss revising the Technical Specifications by clearly stating the requirements for the containment oxygen concentration, inerting and the drywell torus differential pressure LCD. and surveillance requirement This meeting occurred because a contributor to the root cause of the event on November 29, 1986, was the conflicting and unclear req~irements of the _Technical Specifications. A proposed amendment to the Facility-Operating Licenses, DPR-19 and 25 resulted on March 18, 198 Although the review of the proposed amendment has not been completed by NRR, this violation is considered to be closed because of additional corrective actions taken by the licensee, such as increased training of supervisors on the specifications and a demonstration of compliance to the specifi-cation LCO during several de-inerting evolution *

(Closed) Open.Item (249/87028-02):

During the August 7, 1987, feedwater *

ttansient on Unit 3, the inspector identified that the vendor manual for the Feed Regulating Valve (FRV) was n6t updated to reflect the actual configuratio The inspector verified that the licensee *has updated the vendor manual to indicate the correct installed model of FRV and that the manual was revised after the recent modification of the FRV in March

• 1988. This item is considered to be close No Violations 6r deviations were identifie.

TMI Action Plan Requirements (NUREGs 0737 and 0696) (92701 and 92702)

The inspector reviewed the following items for completion of installation, implementation, testing and documentation:

(Closed)

Item 2.E.4.1.2, Installation of Dedicated Hydrogen Penetration Th~ i~spector reviewed the letter from T. lpp~lito,

. Chief, Operating Reactors Branch #2, Di~ision of Licensing, Office of Nuclear Reactor Regulation (NRR) to Connnonwealth Edison Company (CECo)

dated December 8, 1981, stating that items 2.E.4.1.1 and 2.E.4.1~2 were considered resolved for Dresden Station Units 2 ~nd 3 and Quad Cities Units 1 and 2. This item is considered to be close (Closed)

Item 2.K.3.28, Qualification of the Automatic Depressurization System (ADS) Accumulator The inspector reviewed the NRR acceptance

.

letter from J. A. Zwolinski, NRR to CECo dated June 16, 1986, and verified that item 2~K.3.28 requirements were satisfied, resolved and accepted by*

NR This item is ~onsidered close *

(Closed)

Item 2.D.3.1, installation of direct indication of relief and safety valve positio NUREG-0737 states that relief and safety valves shall be provided with a positive identifi~ation in the control room derived from a reliable valve position detection device or a reliable indication of flow in the discharge pipe. *The inspector reviewed modifications Ml2-2(3)-79-41 and verified by document.revie~ and visual inspection that all primary coolant (steam) relief and safety valves have acoustic monitoring installed with the ability to provide positive indications of valve position in the control roo The review also. noted that NUREG-0737 indicates that this item was resolved for all operating facilities prior to January 1, 1981; therefore, this item is considered to be closed for Units 2 and No violations or deviations were identifie. * Operational Safety Verification (71710 and 71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during this period~

The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return tb service of affected component Tours of Units 2 and 3 reactor buildings and turbine buildings were conducted to observe plant equipment conditions, including 5 *

potential fire hazards, fluid leaks, and excessive vibrations ~nd to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspectors, by observation 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 inspection, the inspectors walked-down the accessible portions of the battery, emergency diesel generator and HPCI systems to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup li~ts; observing equipment conditions that could degrade perfonnance; and verified that instrumentation was properly valved, functioning, and calibrate The inspectors reviewed new procedures and changes to procedures that were implemented during the inspection perio The review consisted of a verification for accuracy, correctness, and compliance with regulatory requirement The inspectors also witnessed portions of the radioactive waste.system cont~ols associatep with radwaste shipments and bar,relin These reviews.and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and adm1nistrative procedure In addition, the licensee implemented on October 28, 1988, a corporate operating order (16-88) addressing newly calculated restrictions to preclude neutron flux instabilities while operating. The inspectors interviewed 12 licensee operators and verified that-they were aware of the requirements contained in the operating orde The inspectors also verified that the licensee's operators and supervisors were aware and understood the recent neutron flux instability event that occurred on October 30, 1988, at the Vennont Yankee facilit The licensee demonstrated very good management involvement by acquiring timely and detailed infonnation of the Vennont Yankee facility's core and of the even The licensee provided this information to their operating and nuclear engineering staffs, as well as the NRC Region III staff for evaluatio No viol~tions or deviations were identifie Followup of Events (92700)

Du~ing the inspection period, the licensee experienced se~eral events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.7 The inspectors pursued the events onsite with licensee and/or other NRC official In each case, the inspectors verified that the notification was correct and timely, that the licensee was taking prompt

.

.

and appropriate *actions, that activities were conducted within regufatory requirements and that corrective actions would prevent.future recurrenc The specific events are as follows: On October 3, 1988, with Unit 2.decr~asing power per the load dispatcher the 2A feedwater Regulating Valve (FRV) had to be isolated from the control room because the valve ~ould not go fully close The FRV was stuck open at 30% ~pen. A similar event of this nature occurred on April 7, 1988, and was documented in Region III Inspection Report 50-237/88006. Disassembly of the 2A FR revealed that 2 pieces of metal about 3/16 inch thick, were found lodged between the plug and seat. The licensee believes the pieces to be a seat as~embly hold down clamp from one of the three Reactor *

Feedwater Pump Isolation Check Valve The 2A FRV was reassembled, without examining the seal weld.between the stem and plu The licensee plans to disassemble all. three of Unit 2's Reactor Feedwater pump discharge check valves during this Unit 2 refueling outage, Which started on October 29~ 198 The licensee also

intends to implement some added improvements reconunended by.

engineering to the seat assembly holddown lock plates. These actions appear to be ad~quate since this i~ the only FRV of a design that would be susceptible to this problem (Unit 3A FRV has a protective internal design that screens debris). On October 29, 1988, the licensee conunenced a shutdown of Unit 2 and de-inerted the drywell for a scheduled 15 week refueling :outage.

Scheduled major activities include: Torus re-coat, mechanical stress improvement program, inservice inspection, recirculation piping decon, Unit 2 diesel generator turbo m6dification, cleanin~

of Low Pressure Coolant Injection (LPCI) Heat Exchangers, LPCI and Core Spray (CS) maintenance, draining and decon of the reactor vessel_cavity, cleaning of control rod drive blade guide tubes, replacement of the Local Power Range Monitor (LPRM) and Source Range Monitor (SRM) dry tubes, and repair and rebuild of 40 control rod drives. A dual unit outage is scheduled to start on November 27, 198 During the dual unit outage, the service water systems of both units will have significant maintenance pe~formed and a temporary piping system installed for shutdown cooling *. In addition, 42 modifications will be performed, including control room human factors modification On October 30, 1988, with the reactor shutdown for a scheduled refueling outage and the reactor water temperature less than 212 degrees F, a Group V Isolation Signal occurre The signal resulted in the automatic closure of the isolation condenser valves; 1301-4, 1301-17 and 1301-2 The other isolation condenser valves a~sociated with a Group V isolation were already in the closed position for an out-of-service. The licensee's investigati~n of the spurious isolation event did not determine the caus *

• On October 29, 1988, while Unit 2 was shutting down at 53% feactor power for a scheduled refuelirig outage, the HPCI system was.

voluntarily taken out of service in ordei to perform a HPCI turbi~e overspeed test. The test was successfully completed on October 30, 1988, and HPCI remained out of service for the refueling outag No violations or deviations were identified* in this are.. Monthl Maintenance Observation and Pro ~am Im lementation 62703, 71710, 62700 an 62 02 Station maintenance.activities of Unit 2's CS and HPCI systems 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 techn~cal 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 ins~ected as applicable; functional testing and/or ~alibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by

~ualified personnel; pafts and materials used were properly certified; r~diological ~ontrols were implemented; 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 performanc The inspectors reviewed documentation and observed maintenance activities during this inspection perio In addition, the inspectors reviewed the various aspects of the maintenance program, such as, the maintenance Improvement Plan (MIP)~ Motor Operated Valve (MOV) Maintenance, maintenance trending, maintenance procedures, Vendor Technical Manual Upgrade (VETIP), problem analysis, Quality Assurance {QA) Audits and associated Licensee Ev*ent Reports (LERs).

• In general, many of these programs are currently implemented and

• resulting in noticeable improvements of actual corrective and preventive maintenance practices. Examples of these include the recent (October 20, 1988) achievement of one year without any reactor scrams on both units, reduction of LERs associated with component or equipment failures from 23 i~ 1987 to only 3 at the conclusion of this inspection period and the increase of reliability of the High Pressure Coolant Injection (HPCI) *

Syste HPCI had experienced six failures in 1987, with only one to date. The only HPCI failure in 1988 was due to an unpreventible failure -

of an electronic circuit card while all six failures in 1987 were preventabl These examples are indicative of good management and QA involvemen Howe~er, many of the programs are not fully implemented resulting in certain programs being affected by the lack of implementa-tion of other program An example of this is the trend and analysis program Since the walkdown and identification efforts for the

• equipment.listing are not complete and beClUSe the Masier Equipment List i~ incomplete, it is difficult to perform accurate problem analysis and trending by components of the same model or type.

. The review of maintenance implementation was conducted in the following.

areas:

(1) MDV maintenance, (2) maintenance. trendin~, (3) completed Work Requests (WR) packages, (4) maintenance procedures, {5) Vender Technical Man~al control, (6) problem analysis, (7) general maintenance. program improvements, (8) Deviation Reports (DVRs) and LERs, (9) QA audits and surveillances, and (10) observation of maintenance activities. The conclusions of this review are as follows:

. a..

MOV Maintenance Program The.inspector reviewed the MOV Maintenance Program to determine the completeness and effectiveness of the l~censee's activities with safety-*related and balance-of-plant (BOP) MOV This area was*

identified by the NRC in 1987 as needing increased management and*

QA involvement to correct deficiencies such as, not. including all safety-related MOVs in their preventive maintenance progra The inspector found that about 70% of the safety-related valves of the

. licensee's commitment for MDV overhaul have been completed. This is ahead of the schedule and assures 100% completion with the MDV overhaul activities by the end of May 198 The licensee has accomplished this by establishing defined overhaul maintenance teams and ~roviding detailed training on MDV overhauling practice In -

addition, the licensee has completed overhauling 50 BOP MOV The commitment established starting of the BOP overhauling effort after the completion of all safety-related MOV Currently, the development of specific maintenance procedures for each type of MDV is in progress and reflects the concerns documented by the NRC Diagnostic Evaluation Team (DET) and Region III inspections/reports 237/87033 and 249/87032).

In addition, the licensee is installing the Liberty Testing System to allow for MDV testing without the disassembly or intrusion as

is required by the MOVATs testing syste The overhaul practices had previously been found by the NRC (reports 237/87033 and 249/87032) to be good, with the exception that these efforts were restricted to only safety-related environmentally qualified MOVs and, as such, the expansion of the program to all safety-related MOVs will resolve several DET identified concern Since the implementation of this program ~s incomplete, resolution of these concerns will be conducted during a scheduled NRC maintenance evaluation inspection during the first quarter of 198 Maintenance Trend1ng The inspector reviewed 40 of the licensee's Maximum Occurrence Reports (MORs) to determine if the MOR system could identify equip-ment failures in other systems of similar or identical components 9 ** *

or design to provide trending of component types or model This was a concern identified by both the DET and a special maintenance evaluation conducted by Region III in 1987.. The inspector found that progress had been made, but that the concern still exists. *

The licensee's Total Job Management (TJM) equipment history system still has iniomplete reco~ds of equipment model numbers and~

identification -0f manufacturer The TJM files are ~urrently being updated by adding identification, model and manufacture numbers through a 100% system walkdown effort. Since the walkdown effort is incomplete, the updating of the TJM is also incomplet Currently the licensee does have a method to cros~-check for similar equipment failure until the TJM is fully implemente However, this method is cumbersome in that it requires two different computer searches and some m~nual cross-checkin *

In addition, one portion of the DET concer*n has been. resolve The DET found that work analyst did not have adequate access to the TJ To correct this, the licensee has pr_ovi ded termi na 1 s to the work analyst for accessing the TJM equipment histor Work Requests The inspector reviewed 25 co~pleted WRs for completeness, technical content and clear work instructions: Several minor deficiencies

• were foun These.included 2 of the 25 post maintenance test checklists were not completed with all signatures and 2 packages did not contain as-found conditions of equipmen These deficiencies were previously identified by the NRC and the licensee is in the progress of implementing* their improvement efforts. The WR packages did, however, provid~ sufficient detail directions to ensure adequate performance of the requested maintenanc Maintenance Procedures The inspector revi~wed 30 procedures and the Maintenance Procedure *

Upgrade Progra The upgrade program committed to impr0ving 440 identified procedures in response to NRC concern The program includes answering that adequate technical instructions, cautions and equipment specific precautions exist and that human engineering is incorporated, such as installation and disassembly instructions contain checklists and detailed drawing The inspettor found that 350 procedures had been revised and an additional 90 new procedures had been implemente During the review of the revised procedures, the inspector found that the procedures did provide adequate technical guidance, however, the procedures were not consistent in styl Many of the procedures did not contain all of the human engineering factors, such as work step sign-offs or the detailed drawings were included in the back of the procedur Other procedures were found to contain the drawings and work step sign-offs within the procedure at the appropriate step The inspector determined that the cause for 10 these variatiohs were due to the implementation of the Writers Guide after the majority of the procedures had been revise The Writers Guide was implemented to ensure that all maintenance procedures are revised or written in th~ same *style. Since many procedures were written or revised without ~eeting the guid~lines contained within the Writers Guide; the license has cormnitted to ensure that whenever any of these prbcedures are requested to be revised, on a routine or needed.basis, that they ate flagged to ensure that all guidelines of the Writers Guide are incorporated with the next revision. This i considered to be an open item (237/88022-01 and 249/88023-01) until*

the licensee implements an administratt~e control to ensure that the Writers Guides' guidelines are incorporated in all maintenance procedure *

Vendor Technical Manuals

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.

The inspector reviewed the licens~e's _vendor manual control progr~m contained in the CECo Vendor Equipment Technical Informati.on Program (VETIP).

However, the VETIP is not fully implemente The VETI will also contain a corporate directive to contact all vendors to supply updated and validated technical manuals.. Currently the VETIP is scheduled to include 12 of the 15. systems contained. within the Maintenance.ImprovementPlan (MIP) and is scheduled to be completed by December 198 This effort, similar to the TJM *equipment history upgrade effort, is also dependent upon the completion of the system

• walkdown to identify all installed equipment manufacturers and model type *

The concern with control and use of vendor manuals were previously identified by NRC DET, resident inspectors and special. Region III maintenance evaluation inspection The licensee is in the process of updating vendor manuals on an as-found basis, however, additional management involvement is needed to ensute timely i~plementation of the VETI.

f~

Problem Analysis The inspector found that additional management involvement was demonstrated in this are The licensee made major revisions to the program in May 1988 to ensure that adequate classification of root cause failutes and corrective actions were being mad A d~tailed work sheet was implemented to aid in classification of root cause. *

Additionally, a pilot root cause analysis training was conducted~

The training is scheduled to be implemented for all foreman (maintenance), system engineers (technical staff) and work analyst (both maintenance and technical staffs). Initially, the program has demonstrated good results in improving root cause failure classification, however, the effectiveness of the.program was not evaluated since the implementation is incomplet Master Equipment Listing (MEL)

The NRC previously identified concerns with the MEL since the listing was not complet The licensee is ctirrently updating the

• MEL by conducting 100% walkdowns of all systems to identify as-buil and *tnstalled equipment identification, manufacturers and model type The inspector found that, because of the integration of the MEL in the TJM equipment history, VETIP and the problem analysis programs, thi~ effort ~equire~ additional management involvement to ensure completio Post Maintenance Testing The inspector reviewed th~ administrative controls of post maintenance testing to determine adequacy of testing. The licensee has implemented a testing matrix for generi~ MOV In addition, similar matrixes are being developed for all generic p.umps, valves*

and other equipment type The license.e is planning to implement 12 test matrixes during 1988 with an additional 8 in 198 These generic test matrixes will be used to also develop specific equipment test matrixes for non-generic equipment to be used by the

• work analys Predictive Maintenance The inspector found that the licensee has expanded the predictive maintenance program to include vibration monitoring* of over 100 BOP equipment and oil analysis for expanded trending of equ1pment performance. Additionally, the licensee has scheduled implementa-tion of an oil ferrography analysis syste~ for improved oil analysis and thermography to identify equipment hot spots durcing operation.*

The licensee appears to, have made a strong corrunitment to use *

predictive maintenance with equipment trendin Deviation (DVRs} and Licensee Event (LERs) Reports The inspector's revie~ of DVRs indicated a significant decrease in outstanding DVRs from 198 Additionally, the license~ has.improved timely processing of DVR The review of LERs indicated a significant feduction of component fai-lures (3 in 1988 and 23 in 1987):

One LER was due to a failure of a DC motor brush holder, one due to an electrical circuit card failure and another because of a loose connector in a breaker rela All of these were determined to have been unpredictable and isolated event Quality Assurance Audit and Surveillances The inspector reviewed the 1988 mafntenance audits performed by QA~ These audits covered activities performed by the Mechanical, Electrical and Instrument Departments. Audit 12-88-111 was performed by an offsite team to assess the implementation of the station improvement plan (DSIP).

The audit reviewed 22 of the goals contained in the DSIP and found their progress to be acceptable but had not been implemented for a period to make conclusions of the

effectiveness of the program The inspector's review of these programs is in agreement with QA's conclusio The inspector also reviewed 7 indepth surveillances conducted by QA on specific portions of the overall maintenance progra The inspector fourid these surveillances to be detailed and that *

management was responsive to findings by providing prompt corrective actions including to findings related to proc~dure adherenc The Quality Assurance Department compiles quarterly trend analysis reports of audit finding The inspector reviewed the trend reports for 1987 and 1988 to determine the effectiveness of QA and managements' corrective action The 1987 report identified negative trends in procedure adhe~ence and inadequate corrective actions to equipment failures. The 1988 second quarter report (QAL 12-88-182) indicated significant improvement in procedure adherence and corrective attion The 1988 failure to adhere to proced~re decreased to only J3% 6f the 1987 frequencies and inadequate corrective actions decreased to only 20% of the 1987 finding In general, good trends in the quality of maintenance,have been demonstrated by the observed procedure adherence during maintenance activities, decrease in equipment failures and no reactor scrams during 1988, QA and.management involvement and overall progress in the maintenance improvement program However, several of the programs are dependent upon completion of the 100% system walkdown This activity needs additional management involvement to ensure timely ~ompletion of maintenance improvemen No violations or deviations were identified in this are.

Monthly Surveillance Observation (61726)

The inspectors observed surveillance testing required by technical specifications for the items listed below and verified that testing was performed in accordance with adequate procedures, that test instrumenta-tion was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing 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 3 High Pressure Coolant Injection System Flow Core Spray System Flow Low Pressure Coolant Injection System Flo *

Closed Cooling Service Water System Pump and Valve*

No violatioris or de~iations were identified in this are.

Licensee Event. Reports Followup (93702) *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 aGcordance with Technical Specification (Closed) LER 249/88004-lL:

Type B and. C Local Leak Rate Test (LLRT)

Limit Exceeded Due to Leakage Through Primary Containment Isolation Valv This supplemental report was issued to provide the Type B and C (LLRT) results for the last Unit 3 refueling outage and corrective

.

actions taken regarding the Atmosphere Containment and Dilution (ACAD)

Purge Check Valve 3-2599-23 The cause of leakage was determined to be an ac~umulation of foreign material on the valve seating surface *The corrective actions taken included cleaning and lapping the valv The ~alve was retested and t~e new measured Leak Rate wa~ calculated to be 2.352 SCF The preceding LER was reviewed against the criteria of 10 CFR 2, Appendix C, and the incidents described meet all of the following requirement Therefore, no Notice of Violation is being issued for this ite The event was identified.by the licensee, The event was an incident that, according to the current enfqrcement policy, met the criteria for Severity levels IV or V violations, The event was appropriately reported, The event was or will be corrected (including*

measures t~ prevent recurrence within a reason~ble amount of time), and

• The event was not a violation that could have been prevented by the licensee's corrective actions for a previous violatio No violations or deviations were identified in this are in PWR and BW In order to comply with Regulatory Guide 1.97, which requires that the drywell atmosphere thermocouples be environmentally qualified {EQ), th licensee has replaced.the existing drywell atmosphere thermocouples with (8) new environmentally qualified thermocouples on Unit 3 during the Spring 1988 refueling outage and is presently replacing Unit 2's thermocouples with (8) EQ thermocouples during the Unit 2 refueling outage which started on October 30, 1988.

The Unit 2 and Unit 3 drywell atmosphere temperatures are recorded on the Isolation Condenser/Drywell Atmosphere Temperature Recorder 1340-1

• (Honeywell) located in the control room on front pan-els 902-3 and 903-3 *

. The temperatures that are checked/recorded and their location descriptions are as fo 11 ows:

. Unit 2 and 3 Point 5, "A" Reactor *Recirculation Pump Motor Are Thermocouple TE 2(3)-5741-lO Point 6, "B" Reactor Reci rcul ati on Pump Motor Are Thermocouple TE2(3)-5741-10B.. Point 7, Air Inlet to 11D 11 Drywel-1 (D/W) Cooler. Thermocouple TE2(3)~5741-11 Point 8, Air Inlet to 11A 11 D/W Coole Thermocouple TE2(3)-5741-11A.. Point 9, Main Steam Line (MSL) Relief Valve Area.p South.*

. Thermocouple TE2(3)-5741-12B.. Point 10, MSL Relief Valve Area - Nort Thermocouple TE2(3)-5741-12 Dr~sden Operating Procedure (DOP)

5750~11 requires a daily surveilJance of the drywell atmosphere temperature. This task is accomplished by an operator taking only the reado~t of Point 5 which is located adjacent to a major *heat source in the drywell, the "A" reactor recirculation pump

motor (reference General Electric Design Specification 22Al031 Revision 0).

Dresden has no Technical Specification limit on drywell temperature In addition, it appears that the administrative controls (procedures)

utilized to limit the drywell average temperature to 150 degree Fare inadequate since only one data point (#5) is trended.*

The licensee's recorded average temperature trending of data Point 5 fo both drywells during the warmer sununer months of 1987 and 1988 are as follows:

Month Unit 2 (degrees F)

Unit 3 (degrees F)

1987 1988 1987 1988 April 128 13 May 15 June 15.9 15 July 157 15.4 14 August 150 15.3 14 September 15.7 12.5 Since these temperature readings only represent a single recorded point source inside each drywell, located in the vicinity of a major heat source, the NRC inspectors assessment is that these temperatures do not represent the actual average drywell temperatur. I

. Dresden's average drywell temperature, using only data Point 5, from Ja*nuary 5, 1987 to February 7, 1988, for Unit 2 had a low of 133.25 degree F and a h1gh of 149.23 degree F. * Unit 3 had a low of 120 degree F and a high of 135.6 degree Even if the licensee were to trend all 6 temperatu~e readings provided*

to the 1340-1 (Honeywell) recorder, it still would not be an adequate representation of the average drywell temperatur Si nee the 1 icensee does not have any temperature sensor located at the upper levels of the

• drywells. Located in the upper region of the drywell are two EQ valves, an Isolation Condenser valve 1301-1 and a High Pressure Coolant Injection valve 2301- *

The licensee previously recognized the potential for temperatures within the drywell to be elevated above those specified design limits in the FSA The normal drywell temperature at which Dresden is license~ to operate is an ambient temperature of 135 degrees F to 150 degrees F per Section 5.2.2.1 of the FSAR. *The licensee uses a normal operating.

temperature of 150 degrees F in their equipment qualification program when calculating the remaining qualified lifetime for all equipment inside the drywel Even though the licensee has recorded temperatures in excess of 150 degrees F in the drywell, these recorded temperatures were near equipment which provides significant heat input to the drywel The licensee believes that they are operating within the design basis of 150 degrees F based on the majority of recorded data and lowequipment failure rates. However, the licensee does hav~ a concern abotit the potential frir elevated temperatures at the higher drywell levels based on the tempera-tures recorded at the lower levels in the drywel The licensee has taken the following steps toward improving the drywell temperature concern: Tested Unit 3 drywell ventilation system during the previous refueling outage to evaluate its performance and determine if deficiencies existed in the syste Performance testing revealed that system improvements were warranted to provide better air flow and drywell cooling throughout the drywel Initiated a Modification Request (MR) R12-3-87-25 on June 26, 1987, requesting engineering support to enhance the drywell ventilation syste Issued an Action Item Record (AIR) to track the status of the Modification Request and to include Unit 2 drywell ventilation system in the modificatio e. * Sargent & Lundy Engineers were contracted to perform a Unit 2 drywell/temperature ventilation study and make recommendation to improve the drywe 11 environment during the refueling outage which started on October 30, 198 *

In addition*to above, on November 4, 1988, the licensee informed the NRC of their findings during the Unit 2 initial drywell entry inspection performed on November The inspection revealed that the seal tight protective covering on the various power and cont~ol cables to the Isolation Condenser (MOV 2-1201~04) and High Pressure Cool-ant Injection (MOV 2-2301-04) systems steam supply valves showed evidence of elevated drywell temperature The licensee also informed the inspectors that a detailed investigation would be initiated on November 12, 1988, after the drywell was released for access following defueling activities. This investigation included removal of both valve motors, inspection of the motor operator intervals and inspection of the external power and contr61-cable *

These valves are located in the upper region of the drywell on :the forth evaluation near the drywell wal Both of these are. safety-related environmentally qualified (EQ) motor operated valve In addition, two safety-related non-EQ vessel head vents are the only other major components.located on the forth elevatio Both valves 1301-04 and 2301-04 are normally open and required to close only on a primary containment isolation signa On October 30, 1987, the 2301-04 valve was verified to be operable by responding to an inadvertent Group 5 primary containment isolation. Additionally, both valves were verified to be operable periodically per Technical Specification surveillance A revfow of machinery history revealed that both of these valves had been-Overhauled during the previous refueling outage ending in April 198 On November 14, 1988, the licensee notified the NRC of the investigation results. **Both valves experienced elevated temperatures and had signifi~

cant damage to the external power and control cable insulation, evidence by cracked and brittle insulation. Additionally, some internal damage was _evidenced by the degrading of the Mobil ux EP~o grease and one bearing lowing dried greas The bearing was the open loading bearing for 2301-0.

This bearing is used only in open direction and would not have prevented the valve from meeting its isolation requiremen As noted above, 2301-04 had demonstrated the ability to isolate during the inadvertent Group 5 isolation. The investigation also revealed that both motors, all internal wires, gears and switches (limit and torque) were not damage The inspectors, including a EQ specialist from* Region III, verified these conditions by independent inspection and evaluation of the motor winding megger dat The licensee is continuing to investigate the extent of possible damage to other components with direct observation by the NR The licensee has determined that a possible root cause of the event was the drywell internal ventilation syste During the initial entry

. inspection on November 4, the licensee discovered that all four of the ventilation covers for the above vessel head region were close Without forced air circulating in the above vessel head region, the air cavity temperature would continue to increase from the exposed vessel head meta The licensee is continuing to investigate the root caus Although no violation or deviation is identified, the inspectors are crintinuing to evaluated the even.

Management Meetings (30720)

On September 20, 1988, a meeting was held at the NRC Headquarters Office at One White Flint North in Rockville, Marylan The meeting was between NRC and Corrunonwealth Edison*company Corporate and Dresden Station Management to discuss Dresden's performance update, which included a discussion of plant improvement On Octobe~ 20, 1988, a meeting was held at the Dresden Stationr The meeting was between the NRC and Station Management to discuss recent licensee performance results and receive NRC feedbac.

Management Changes On September 12, 1988, the Commonwealth Edison Company announced the following management changes at the Dresden Station:

Mr. J. Wujciga, formerly assigned as Production Superintendent has been reassigned to a newly created Quality First Organization.

position within the Projects and Construction Services group. *

Mr. L.* Gerner assumed the position of Production Superintenden Mr. _Gerner was formerly the Superintendent of Performance *

Improvement at Dresde *

Mr. C. Allen, formerly the LaSalle Licensing Manager, was reassigned to th'e position of Supervi-sor of Performance Improvement at the Dresden Statio Mr. D. Adam changed from Rad-Chem Supervisor, to Assistant to the Assistant Superintendent - Technical Service *

Ms. D. Saccomando changed from Lead Health Physicist to Health Physics Services Superviso Mr. D. Morey changed from Lead Chemist to Chemistry Services Superviso Ms. L. Jordan changed from Genera 1 Hea 1th *Physicist to Heal th Physics Group Leader/Operations/ALAR Mr. L. Oshier changed from General Health Physicist to Health Physics Group Leader Technical Mr. K. Whitum changed from General Chemist to Chemistry Group Leader Technica Mr. D. Malauskas changed from Principal Chemist to Chemistry Group Leader Operation..

1 Report Review (30713)

During the inspection period, ttie inspectors reviewed *the licensee's Monthly Operating Report for October, 198 The ins.pectors confirmed

• that* the information provided met the requirements of Technical

Specification 6.6.A.3 and Regulatory Guide 1.1 Additionally, the inspectors reviewed the licensee's Unit 3 Sununary Startup Test Report for Cycle 11.. The inspectors confirmed that the information provided met the requirements of Technical Specification 6.6..

The inspectors reviewed the following Startup tests contained within the

. Startup Test Report:

Core Verific~tion and Audit, Control Rod Operability ~nd Subcriticality Check, TIP System Synunetry - Uncertainty, and initial Criticality Comparison.. The inspectors verified that all startup tests were satisfactory. and all acceptance criteria were me ~Startup Test No. 1, "Core Verification and Audit." This test verifi~d that the core was-1 oaded in conformance to the reference core desig The results of the test revealed that two fuel assemblies were found to be incorrectly seated due to the improper sealing of their perspective

• fuel support pieces. After the fuel handlers correctly resealed the fuel support pieces, the core was offic{ally verified ~s being properly loaded and consistent with Advanced Nuclear Fuel Cycle 11 Core Design on June 2, 198 Startup Test N_o.. 2, "Control Rod Operability and Subcriticality Check."

This test verified that no local reactivity irregularities existed, control blade coupling and proper operabilit The results of the test revealed that after.core loading, every control blade was withdrawn to verify mobility of control blade. *All control blades passed their over travel check Proper withdrawal and insertion times were verified and subcriticality was confirmed for each control blade.

.., Startup Test No. 3, "TIP System Synunetry.,. Uncertainty." This test performed a gross symmetry check and a detailed statistical uncertainly analysis on the Traversing In-Core Probe (TIP) Syste The results of the test revealed that the maximum absolute deviations for all TIP pairs were well within the acceptance criteria. The Statistical tool, X2, used to measure the consistency between the actual TIP error distribution and that assumed in Advanced Nuclear Fuel (ANF) error analysis was also well within the established limi *

- Startup Test No. 4, "Initial Criticality Comparison". This test performed a critical Eigenvalue comparison as required by Techni~al Specification 3.3.E. This was done by comparing the predicted control rod pattern to the actual control rod pattern at criticality taking into account period and temperature coefficient corrections. The results of the test revealed that the actual criticality was within 10 % K/K of the predicted criticality after corrections were made for temperature and perio Unit 3 went critical on June 25, 1988, at 11:00 a.m., utilizing an A-Z sequenc The moderator temperature was 195 degree F and the period was 120 second *

• N~ deviations or violations were identifie.

Exit Interview (30703)

The inspectors met with licensee representatives (denoted.in Para~raph 1) *

on November 4, 1988, informally throughout the inspection period, to summarize the scope and findings of the inspection activities, and also met on November.22, 1988, to discuss the equipment damage due to high drywell temperature 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 not identify any suc documents/processes as proprietary. The licensee acknowledged the findings of the inspection.. * *

30