IR 05000237/1988025
| ML17201Q456 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/04/1989 |
| From: | Bongiovanni A, Lougheed P, Maura F, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17201Q454 | List: |
| References | |
| 50-237-88-25, 50-249-88-27, NUDOCS 8905180319 | |
| Download: ML17201Q456 (27) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION II I Reports No. 50-237/88025(DRS); 50-249/88027(DRS)
Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
Dresden N8clear Power Station, Unit 2 and 3 Inspection At:
Morris, Illinois Inspection Conducted:
November 1, 1988 through March 30, 1989 Inspectors: ~
Team Leader 0Jv1l?~~t.6c~7 IVM1'W A. M. Bongi6vanr?i
,;JPOn.~~
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1 R~~e
.
Approved By:~~f Operational Programs SectiQn Inspection Summary Insoection on November 1, 1988 throuqh March 30, 1989 (Reports No~ 50-237/88025(DRSS); No. 50-249/88027(DRSS))
.s/1/g9 Date
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Date 1
. s/'l/f1 Date Areas Inspected:
Routine, announced team inspection of modification safety evaluations, installation and testing of modification, procurement of'
components and dedication of commercial grade component for safety-related application (Part 21), followup of event at site, and followup of previous inspection item This inspection was conducted in accordance with Inspection Modules 37700, 37828, 38703, 92701, and 9370 Results:
Three violations were identified in two of the five areas inspected:
(1) a violation of 10 CFR Part 50, Appendix B, Criterion III, failure to revise station procedures to include design assumptions affecting the specific functions of the compo_nents; (2) two examples of a violation 8905180319 890508
~DR ADDCK 05000237 PNU
- of 10 CFR Part 50, Appendix B, Criterion XI, failure to obtain engineering approval before changing the requirements and acceptance criteria of two post modification tests; and (3) a violation of Technical Specifications Paragraph 6.2.A.3, failure to follow procedure controlling the opening of the Reactor Building material interlock inner doo Open items were identified relating to weaknesses in the station review of the completed modification packages (Paragraph 3.b(3)); as-built drawing control program (Paragraph 3.b(4)(b)); and dedication of commercial grade equipment (Paragraph 4.0).
The licensee displayed a weakness in the area of review of completed package This weakness appears to be due in part, to a lack of attention to detai Weaknesses were also noted in the receipt and dedication of commercial grade items for safety-related applicatio These appear to be related to*a failure to identify and inform the receiving organization of the critical characteristics of the component The packages reviewed indicated that the concerns identified in the SSOMI have been adequately addresse Overall the design calculations and 10 CFR 50.59 safety evaluations appear to be of good qualit They provide evidence of strength in these areas.
- *
DETAILS Persons Contacted Commonwealth Edison Company (CECo)
J. Achterberg, Technical Staff Supervisor
- J. Brunner, Assistant Superintendent, Technical Services
- B. Christel, Modification Group Leader
- R. Dyer, Modification Group Engineer G. Eckert, II, BWR Engineering Department E. Eenigenberg, Station Manager L. Evans, Maintenance Foreman
- R. Falbo, Regulatory Assurance Assistant
- L. Gerner, Production Superintendent R. Geier, QC Supervisor R. Johnson, Group Leader, Technical Staff
- M. Pape, Quality Assurance G. Paryz, BWR Engineering Department
- K. Peterson, Regulatory Assurance Supervisor M. Reed, BWR Engineering Department, Site Engineer B. Schroeder, Plant Performance, Technical Staff C. Schroeder, Services Superintendent R. Stachniak, Assistant Technical Staff Supervisor S. Stiles, Training Supervisor R. Whalen, Mechanical Group Leader Sargent and Lundy Engineers D. Beutel, Component Quality Sr. Engineer H. McCullough, Quality Assurance R. Knoebel, Sr. Structural Engineer C. Soltis, 'Sr. Electrical Engineer A. Walser, Sr. Structural Engineer The Okonite Company J. Klein, District Manager G. Newberg Construction Company B. Brown, QC Supervisor E. Cook, Engineer Morrison Knudsen Company G. Glover, Service Representative
NRC * * DuPont, Senior Resident Inspector, Dresden Units 2 and 3 Ridgway, Senior Resident Inspector, Dresden Unit 1 Higgins, Senior Resident Inspector, Quad Cities Phillips, Chief, Operational Programs Section, DRS The inspectors also interviewed other licensee employees including members of the operations, maintenance, technical, training, quality assurance, regulatory assurance, and BWR Engineering staf *Denotes those attending exit meeting of March 30, 198 I Action on Previous Inspection Items (Closed) Deficiency 2.2-7 (249/86012-09(DRS)):
SSOMI team concerns regarding the adequacy of 10 CFR 50.59 safety review The inspectors reviewed OAP 10-2, Revision O entitled, 11Title 10 of Code of Federal Regulations Part 50.59 Review Screening and Safety Evaluations, 11 and concluded that if implemented as written, it would provide improved guidance for conducting safety evaluation The inspectors reviewed training records for the procedure and determined that adequate training was provided to all personnel who prepare, review or approve the evaluations. During this inspection period, the inspection team reviewed several 10 CFR 50.59 safety evaluations for modifications and had no concern This item is considered closed. (Closed) Unresolved (249/86012-62(DRS)):
No specific valve line up for performing the local leak rate test on primary containment isolation valve The inspector reviewed the following procedures to verify that valve line ups were incorporated:
DTS 250-1 DTS 250-3 DTS 1600-1 MSIV Local Leak Rate (Dry) Test MSIV Local Leak Rate (Wet) Test Local Leak Rate Testing of Primary Containment Isolation Valves The inspector verified that all containment isolation valves as listed in Table 5.2.2.5 of the Update Final Safety Analysis Report were included in DTS 1600-1. This item is considered close.
Modifications Modifications Reviewed The inspectors reviewed the safety evaluations and design packages, witnessed the installation and testing, and reviewed the procurement documentation of the components utilized for several modifications performed during the 1988 refueling outage of Unit All documents and work in progress were reviewed against the requirements of 10 CFR Part 50, USAR, Technical Specification, and Dresden Administrative Procedure The modifications reviewed, and the specific items included in the review of each, were as follows:
(1)
Modification M12-2-85-83 (M12-3-85-83)
(2)
(3)
This modification replaced the existing 250vdc battery with new lead calcium cells of larger capacit The battery capacity (8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rating) was increased from 913 amp hours to 1420 amp hours while decreasing the number of cells from 120 to 11 New battery racks which maintained the seismic qualification of the battery were installe The review included the design calculations to determine the load profile, to size the battery, and to seismically qualify the battery racks; the 10 CFR 50.59 safety evaluation; the post installation testing procedures and test results; the installation procedures; the procurement and receipt documents; the training lesson plans and records; the revised station procedures; changes to the USAR; and the control of as-built drawing In addition, the inspectors witnessed various steps during the installation of the battery racks, the battery cells, and the post-installation testin Work being performed was compared to drawings issued for construction and the control of work modifications through the use of ECNs and FCRs was monitore Modification M12-2-85-94 (M12-3-85-94)
This modification which improved the reliability of the emergency diesel generator, replaced the diesel turbocharger, spring drive gear assembly, and the stubshaft/idler gear assembly in accordance with the manufacturer's (Electromotive Division of General Motors) recommendation in Power Pointers No. 2P-79 and 2P-81, and Maintenance Instruction MI 9587, Revision The modification was performed over two refueling outages, with the stubshaft assembly and the idler gear installed during January-March 1987 and the high capacity turbocharger and new spring drive gear during this outag The review included the 10 CFR 50.59 safety evaluation, the installation procedure, post-installation test procedure and test results, the procurement and receipt documents, the lesson plans and training records, changes to the USAR, and the control of as-built drawings and spare parts record Modification M12-2-86-03 This safety-related modification replaced the shaft packing on the Unit 2 torus to reactor building vacuum breakers (20 inch check valves) with new style bronze bushing The installation of the new bushings was an upgrade to the external seals, which was similar to a completed modification to the 18 inch torus to drywell breaker The review included the design and procurement information, the 10 CFR 50.59 safety evaluation, quality control requirements, and the installation procedure performed in November 1988.
(4)
Modification Ml2-2-86-18 This modification resulted from a commitment to resolve several human factors discrepancies in the Control Rod Drive (CRD)
syste The design changes involved replacing the manual CRD discharge valves, 2-0301-2A and 2B with motor operator controlled stop check valves, replacing the existing flow indicators with new programmable indicators, disenabling the obsolete CRD cooling water pressure control valve, 0302-10, and upgrading the control switch for the CRD water pressure control valve, 0302-The review included the design and 10 CFR 50.59 safety evaluation, post-modification testing procedure, training lesson plans and records, procurement and receipt documents, the installation procedure, and the control of as-built drawing The inspector also witnessed various steps during the installation, and later compared the changes involving MCC 2~-1 and valve 0302-10 to the as-built drawing (5)
Modification Ml2-2-86-29 This modification changed the Low Pressure Core Injection (LPCI) minimum flow valves M0-1501-13A and 138 logic to provide the operator with the ability to close the valves with an accident signal present. The change was necessary in order to meet the closed loop isolation function required by 10 CFR Part 50, Appendix A, General Design Criterion 5 The modification interlocked the valve logic with the stationary contacts on the pump breakers so that if the pump was isolated in the pull-to-lock position, the operator could close the valve for isolation purpose The valve would automatically open to provide the required minimum flow path if the pump were to start. The review included the design and 10 CFR 50.59 safety evaluation, post modification testing procedure, training lesson plans and records, and procurement and receipt document (6)
Modification Ml2-2-86-31 This modification altered the logic of the High Pressure Coolant Injection (HPCI) minimum flow valve, M0-2301-14, to provide the control ro9m operator the ability to close the valve with an accident signal presen The existing valve control switch was replaced with a pull-to-lock (P-T-L) feature to allow valve closure under any accident condition. With an isolation condition present, the valve would remain open since low flow conditions would be presen The new P-T-L switch would permit closure of the valve under low flow conditions to comply with the closed loop isolation function required by 10 CFR Part 50, Appendix A, General Design Criterion 5 The review included the design and 10 CFR 50.59 safety evaluation, post modification testing procedure, training lesson plans and records, and procurement and receipt document *
(7)
Modification M12-2-87-09 (8)
(9)
This modification was performed to provide continuous pre-lubrication of the emergency diesel generator crankshaft bearings, and to correct a problem which restricted repeated fast starts of the engine during the period of 15 minutes to three hours following engine shutdown after a run during which the engine oil reached operating temperatur This modification was performed in accordance with the manufacturers* (Electromotive Division of General Motors)
Maintenance Instruction MI 9644, Revision The review included the 10 CFR 50.59 safety evaluation, the installation procedure, witnessing various steps during the installation of the modification, post installation test procedures and test results, the procurement and receipt documents, the training records, the revised station procedures, the control of as-built drawings, changes to the USAR, and a _comparison of the work in progress to the drawings issued for construction and to MI 9644, Revision Modification M12-2~87-13 This safety-related modification installed speed control valves between the air operated cylinder and the directional solenoid on the flow pipes to the torus vacuum relief valve The additio~ of th~ speed ccintrol valve would allow slower and more controlled cycling of the relief valves, thereby reducing the wear on the valve components (e.g., valve seat).
A tamperproof lock box assembly was also to be installed over the new control valve The review included the design information, the 10 CFR 50.59 safety evaluation, quality control requirements, the installation procedure, the receipt and procurement documents, and the dedication process of commercial grade components to be used as safety-relate Modification M12-2-87-20 This safety-related modification replaced the Unit 2 control switch for the isolation condenser condensate return valv Replacement of the 3-position with a 4-position.switch was an upgrade which added a 11 spring return to auto from close, 11 to reduce the possibility of an inadvertent override of the auto initiation signal (problem identified in a past LER).
The review included the design and procurement information, the 10 CFR 50.59 safety evaluation, quality control requirements, and the installation procedure performed in December 198 (10) Modification M12-2-87-47 This modification (non-safety-related) changed the setpoints on the standby condensate booster pump (CBP) logic to eliminate the time delay between the standby CBP (auto) start and the running CBP trip (problem identified in a past LER).
The
- -
review included the design and procurement (safety-related)
information, the 10 CFR 50.59 safety evaluation, quality control requirements, and the installation procedure performed in December 198 (11) Modification M12-3-88-24 This modification, reviewed at the request of the Senior Resident Inspector, separated the ADS logic cables because of Appendix R concerns:
a hot short across, multiple connectors of a single cable could cause all ADS valves to go ope The modification disconnected some connectors in the original cable and added two new cables to provide s~paration. The review included post installation testing procedures and test results, procurement and receipt documents, and the control of as-built drawing The design package and 10 CFR 50.59 safety evaluation were not reviewed as this is an issue being resolved by the Region and NRR (Inspection Reports No. 50-237/88010(DRS); No. 50-249/88010(DRS)).
(12) Modification M12-2-88-56 This modification replaced the existing 125vdc battery with new lead calcium cells because some of the previous battery cells had failed during normal surveillance test The modification also involved the replacement of the battery to distribution panel cables with smaller size (from 500 MCM to 250 MCM)
cable The review included the design calculation to determine the load profile, to size the battery, and to show the adequacy of the new cables; the 10 CFR 50.59 safety evaluation; post installation testing procedures and test results; the installation procedures; the procurement and receipt documents; the revised station procedures; changes to the USAR; and the control of as-built drawing In addition, the inspectors witnessed various steps during the installation of the battery ceJls and cables, and the post installation testin (13) Alternate Service Water Temporary Modification This temporary modification, which required a two-unit shutdown, was comprised of three separate parts:
(a) A total of seventeen valves were replaced on the service water strainers and the recirculation pump MG-sets oil cooler These changes were considered like for like replacements and were done under a work reques Additionally, a vent line with isolation valve was added to the top of each strainer (vent openings were plugged).
This was done under modification M12-2/3-88-1 (b)
Since the aforementioned work necessitated isolation of the entire supply side of the service water system, a temporary
- modification was used to provide cooling to essential loads from the Containment Cooling Water (CCW) system through the RBCCW and the TBCCW heat exchanger (c)
In order to make the temporary connections between CCW and the RBCCW and TBCCW heat exchangers, a permanent modification was made to provide a blind flanged isolation valve on the inlet side of the heat exchanger (Modification M12-2/3-87-57)
This modification was reviewed for technical adequacy and pre-implementation plannin Discussions were held as to the intent of the temporary modification with the Auxiliary/
Support Services Operations Manager and the responsible technical support enginee The third-party review package, prepared by an outside consulting firm, was reviewed, as were the special procedures used to control the installation and removal of the temporary modificatio The 10 CFR 50.59 safety evaluations both for the temporary modifications as well as the individual work requests were reviewe The overall attention and detail that was placed on planning and implementing this temporary modification was superio Inspection Findings In general, the design reviews and 10 CFR 50.59 safety evaluation were of good qualit Work Request packages containing detailed installation procedures were used to control the modificatio The modifications were processed in accordance with OAP 5-1 (revision depending on when work on package was performed)
11 Plant Modification Program 11 which implemented the CECo Station QA Manua All of the areas reviewed, including design documents and safety evaluations, installation, testing, training, station procedures requiring revision as a result of the modification, document control, drawing updating, etc., were found to be satisfactory except.in the areas as noted below:
(1)
Design Control In doing the sizing calculations for the 250vdc battery the designer assumed that five motor driven pumps would be manually shed at specified times, following a loss of power to the station and of the battery charger The five motors to be shed and the time at which each was to be shed were as follows:
(a) At 30 minutes into the event:
Emergency Turbine Bearing Oil Pump and two Recirculation Pump MG Set Coastdown Lube Pump (b)
At 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event:
HPCI Turbine Auxiliary Oil Pump.
(2)
(c) At 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> into the event:
Emergency Generator Hydrogen Seal Oil Pum No calculations were performed to demonstrate that in the absence of this load shedding the 250vdc battery could perform its safety function (maintain a battery terminal v6ltage > 210vdc) for the required length of four hour The inspectors reviewed the station procedures and determined that the design assumptions had not been (nor were there plans for them to be) incorporated into the procedur These assumptions were also applicable to the Unit 3 250vdc battery which had been replaced during the Spring 1988 refueling outag Upon being notified of the problem, the licensee issued an Operating Order on December 6, 1988, directing the staff to shed these loads within the specified time perio On January 11, 1989, Procedure DGA-3, Revision 0, was approved which replaced the Operating Orde Failure by the licensee to ensure that all design assumptions of a safety-related modification are correctly translated into specific procedures is a violation of 10 CFR Part 50, Appendix B, Criterion III (237/88025-01;
.249/88027-0l(DRS)).
Testing The inspectors identified two concerns in the area of testin (a)
In Attachment A of its approval letter for modification M12-2-85-83 dated March 21, 1988, the BWR Engineering Department (BWRED) specified the testing to be performed following completion of the installation wor A similar requirement existed for modification M12-2-88-5 One of
- the requirements was for the comparison of the terminal voltage of the battery to -the sum of the individual cell voltages prior to connecting the battery to the bu The acceptance criteria required that if the overall battery voltage was less than the sum of the individual cell voltages then the connection of all cells be rechecked for reverse polarit Step 5.7 of Procedure #28-Lead Calcium Batteries, used by the Operational Analysis Department (OAD) to conduct the construction tests, used the product of the minimum acceptable cell voltage of 2.03 volts times the number of cells to compare against the overall battery voltag By using the lowest allowable cell voltage the purpose of the BWRED requirement was voided for it would require several misconnections to drop the overall.battery voltage below the product calculated by OA The licensee could not produce a document showing that BWRED had approved the change in testing created by the OAD procedur This
(3)
(b)
unauthorized change is an example of a violation of 10 CFR Part 50, Appendix B, Criterion XI (237/88025-02A(DRS);
249/88027-02A(DRS)).
Another BWRED testing requirement was the dielectric adequacy of the insulation of the battery feed cable This meggering test at> 500 volts was required prior to connecting either end of the cabl The acceptance criteria set by BWRED was > 50 megohm The test was performed by DAD using Electrical Construction Test Procedure #24-Power Cable The acceptance criteria had been changed from 50 megohms or higher to
> 1.6 megohms (non-conservative).
The licensee had no documentation to show that BWRED had been informed of the change and had approved the reduction (by a factor of 31)
in cable insulation resistanc The tests applied to both modifications, M12-2-85-83 (250vdc battery) and M12-2-88-56 (125vdc battery), were performed in December, 1988, and had results in excess of both acceptance criteria (> 1000 megohms).
This unauthorized change in the acceptance criteria is another example of a violation of 10 CFR Part 50, Appendix B, Criterion XI (237/88025-02B(DRS);
249/88027-02B(DRS)).
Attention to Detail The inspectors identified a general concern with a lack of attention to detail in the review of completed modification installation and testing results package (a)
Another construction test required applying a 200 amp load on the battery and comparing the bus voltage to the battery voltag The acceptance criteria limited the ~oltage drop to 0.5 volt A review of the results showed the bus voltage to be higher than the battery voltage by 0.2 volts, a physical impossibilit The licensee agreed that the data recording had been reversed and added a note to the modification package so statin (b) A review of 25% of the battery racks anchor bolt installation records for modification M12-2-85-83 showed that in one case (WV-22) the bolt projection had "shrunk" 3/8 11 after torquing; obviously a measurement erro Two other similar cases had been detected during the witnessing of the racks installation and had been corrected after being pointed out by the inspectors to the contractor doing the installation wor Accurate readings are essential since the amount of anchor bolt slippage is limited to a maximum of l/2 11 *
The licensee agreed to remeasure the torque reading and correct the record accordingl **
(c) A review of the diesel generator lube oil post modification test results showed; on Page 9, the new turbo oil pump discharge pressure as 3 psi The acceptance criteria required a pressure > 25 psi A review of the test engineer 1 s field notes showed the actual recorded pressure to have been 38 psi The official record was correcte The above examples of obvious errors in modification packages which had already received all the required reviews and approvals are indicative of a lack of attention to detail by the many reviewers which had already signed and approved the modification package This weakness in the review process is an Open Item (237/88025-03(DRS)) pending future improved performanc (4)
Procedures The inspectors identified two concerns in the area of Procedures and Documentation Contro (a)
The documentation for modification M12-2-86-31 indicated that no procedures would be affected by the new switc The inspector was concerned that the intent of the modification was not satisfied since no procedure directed the operator to place the switch in the P-T-L position for containment isolatio The licensee agreed with the inspector's concern and revised the following procedures to include conditions when the switch would be placed in the P-T-L position:
DOP-2300-3, Revision 11, High Pressure Coolant Injection System Manual Startup and Operation DOP-2300-6, Revision 2, High Pressure Coolant Injection System lnc*l Manudl Operation The inspector reviewed the revisions and had no further concern (b)
During the review of as-built drawing control it was noted that if a copy of a controlled drawing was requested the requester would be informed of all the outstanding ECNs and FCRs; however, if the request was to merely look at the controlled drawing in the Document Control Room the requester would not be informed of the outstanding ECNs and FCR The controlled drawing was not marked to identify that changes were pendin When questioned by the inspectors the document control personnel were aple to produce the outstanding change document This weakness in the drawing control program (failure to always inform the requester of all outstanding changes on a drawing) is an Open Item (237/88025-04(DRS); 249/88027-03(DRS)).
4.
Procurement and Dedication of Commercial Grade Components for Regulatory Related or Safety-Related Applications The inspectors reviewed the administrative and quality assurance procedures applying to procurement of commercial grade safety-related, and regulatory-related (fire protection) item These procedures had been recently (late 88) revised by the licensee in order to address the EPRI guidance on use of commercial grade items for safety-related applicatio The inspectors interviewed the site QC supervisor, the storeroom receipt inspector, a QC inspector, and a QA enginee The inspectors also watched a receipt and QC inspection of two shipment From these interviews, the inspectors determined that the l.icensee places great reliance on vendor The receiving process, to a large extent, is merely a paper check to see that the numbers on the received product match those on the accompanying documentation and those on the purchase orde Although a visual inspection is performed by QC and QA, this appeared to be focused on gross failure During the course of the interviews, the inspectors noted that the storeroom receipt inspector depended upon his memory as to required storage level, preventative maintenance, and shelf lif When questioned, he stated that no procedures exist~d to determine these items, and that he knew what was required because he had done it so ofte This appears to be a weakness in the receiving progra Additionally, the storeroom receipt inspector stated that he often did not open the packages, if the part number was printed on the outsid The QC inspector stated that he normally did look at the part, but did not do a detailed inspectio The QA engineer stated that he mostly 11doubl e-checked 11 Q The fra i 1 ty of thi ~ approach is i 11 ustrated by the fact that, during modification M12-2-86-18 the licensee found during testing that the stop check valves installed were actually globe valve The valves came in with the wrong part number (but which matched the documentation) and were accepted through the entire receiving progra According to licensee Procedure DQP-4.51, 11 Procurement Document Control for Operation - Processing Purchase Documents, 11 the dedication process is based on (1) an engineering evaluation that certain standard catalog items are acceptable, (2) procurement of these items from a vendor on the licensee 1 s approved vendor 1 s list, and (3) the receipt inspection described abov In an interview with the QC supervisor, he indicated that regulatory-related items (other than security) could be bought as totally non-safety-related (no documentation required) and that there were no requirements that need be imposed on the Additionally, comments were made concerning procurement of commercial grade items that 11a lot of these vendors didn 1 t have QA programs, which is acceptable since safety-related components weren 1t bought from them.
This appears to conflict with the requirements of the DQ When combined with the 13 *
apparent inadequacies of the receiving program, it appears that the licensee does not have adequate control over the commercial grade progra For example, although DQP 4-51 requires that regulatory-related components be accompanied by a certificate of conformance (CDC), Purchase Order 431373 (fire wrap) did not impose any requirements on the vendo The item was procured as non-safety-related, although it was classified as 11 regulatory-related 11 in the stores compute When the item was received, a OAP ll-5A, 11 Part Classification Evaluation, 11 was performe This evaluation, done in March 1987, concluded that the item was non-safety-relate However, in August 1988, even though a procedure
- for classification of regulatory-related items had been issued in March 1988 (OAP 11-20), the part was upgraded to regulatory-related based on the March 1987 OAP 11-5A for The upgrade was based solely on a QC receipt inspection (basically counting the boxes as no documentation accompanied the purchase).
The inspectors reviewed a recently completed procedure for the dedication of commercial grade electrical components for safety-related application (OAP 11-15, Revision 0).
While the procedure goes a long way to meet the actions proposed by the NRC in Generic Letter 89-02, the inspectors are concerned that the testing of these electrical components is only being done at the rated voltage and frequenc In many safety-related applications the critical characteristics of the component are below and above the rated valu For example, a relay operated by the 125vdc may have to perform satisfactorily in the range of 105 to 137 volts, therefore, testing at 125 volts during the dedication process offers no assurance it will perform its safety function at 105 or 137 volt The licensee was advised to develop a dedication process which first establishes the critical characteristics of the component or system being upgraded for safety-related use, and then ensuring through measurements, tests, etc.,
that those critical characteristics are me The weakness noted in the receipt inspection of commercial grade components, and the dedication process to regulatory grade or safety-re.lated grade is an Open Item (237/88025-05(DRS); 249/88027-04(DRS)).
The licensee was encouraged to develop a procurement, inspection, and dedication program which complies with the guidelines in EPRI NP-5652, 11Guidelines for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications (NC lG-07),
11 as amended by NRC's Generic Letter 89-02,
"Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products.
Defective Cable Event On January 10, 1989, the licensee informed the inspectors that during the performance of modifications M12-2-87-9, 11 0iesel Generator Lube Oil SysterT],
11 and Ml2*-2-86-18, 11 Install MOV on CRD Pumps Discharge and Upgrade of Flow Controllers," an electrical cable problem was foun The cable in all three reels exhibited cuts in the insulation of the single conductor The defective cable was being installed to power the new diesel generator lube oil pump and the new CRD MO valve The cable
(5200 ft) had been purchased by CECo Purchase Order No. 302871 MC-81 from the Okonite Company and had been received in three reels, #23531A, 2353181, ~
and 235318 As soon as the problem was discovered, the 1000 ft of cable used in the above noted modifications was replaced and the entire PO was tagged and returned to the main warehous On January 27, 1989, the inspectors attended a licensee meeting with the Okonite Company
_
representative during which the list of specific items to be addressed by the vendor, as described in a letter from Commonwealth Edison to Okonite, dated January 13, 1989, were discusse In addition, the vendor representative obtained samples of cable from all three reels for analysis at their corporate laborator By letter dated February 6, 1989, the Okonite Company submitted Engineering Report No. 453 with the results of its investigatio The investigation results and planned corrective actions are: The lack of damage to the outer jacket demonstratea that the damage occurred prior to application of the fill and jacke The records showed that the singles were all tank tested and spark tested successfull The cabled singles were spark tested prior to jacketing and passe Thus, the damage occurred after cablin The final cable was spark tested and tested conductor to conductor dr The damage was not detected in the final spark test since the jacket will hold the test voltag The conductor to conductor test did not detect the defects since the cuts were not lined up, i.e.,
a cut on the red conductor was separated by several inches from the next cut on the black conductor and so forth.
The most likely point of damage was in the extruder applying the fill materia A sharp edge on the fixed tool that guides the core to the die would cause the damage observed and in the pattern observe If this is the case, this is a si~gle incident limited to this run of 5140 ft. of cable since tools are changed for each ru The cause of tool damage is unknow Corrective action is hPing take11 via instructions for careful C}(umi11dtion and check off of tool conditions prior to machine set up by the operato The possibility exists that the damage occurred on sheaves and/or roller guides at let off and take ups leading to the extruder or after the spark tester at cablin Okonite is convinced that this is not of high probability since the severity of the damage is such that it would have been seen on this run by the operator In any event, corrective action is being taken to ensure against the above by installation of a spark tester behind the entrance to the extruder Further corrective action involves dissection of at least 5 to 50 f of finished cable and visual examination of the cabled store.
The vendor and the licensee have agreed that the damage was an isolated event, and that based on that and the corrective actions being implemented a Part 21 notification is not require The inspectors have no further concern No violations or deviations were identifie.
Secondary Containment Integrity - Unit 3 Operating On November 15, 1988, during a walkdown of the Units 2 and 3 Reactor Building, the inspectors noted that the Unit 2 Reactor Building trackway inner door was open and a truck containing the equipment for the Unit 2 tor~s sand blasting operation was blocking the capability to close the inner doo The inspector also noted that the Unit 3 Reactor Building M~terial Interlock inner door was open and no one was posted to close the door under certain conditions, as required by Administrative Procedure OAP 13-14, Revision 1, and its Temporary Change #88-3-19 This is a violation (249/88027-04(DRS)) of Technical Specifications Paragraph 6. The inspectors notified a member of the technical staff and the control room (SCRE).
The licensee took prompt action to close the Unit 3 Reactor Building Material Interlock inner doo The licensee started an investigation of the event and determined that: The door was originally opened at 7:30 a.m. at the request of POPE Mechanical Contractor The requirements of OAP 13-14 were followe The inspectors had verified that during their earlier discussion with the SCRE in the Control Roo Two violations of OAP 13-14 occurre The first between 9:20 and 9:50 a.m., the second between 11:30 a.m. and 11:45 a.m. (Times are approximate).
The inspectors discussed with licensee management their finding and requested test data to demonstrate secondary containment integrity with both interlock inner doors ope The inspectors were supplied with the pre-outage secondary containment test data which shuWt:!Ll that a satisfactory test harl h.. en pedur*111ed on October 22, 1988, with all doors clo~t:!L !he licensee could not provide results of a satisfactory test ever performed with both inner doors opene The inspectors witnessed spec~al test SP 88-11-163, which was performed on November 20, 198 The test demonstrated that the Standby Gas Treatment system could satisfy the Technical Specification requirements during all conditions except when the Unit 3 Reactor Building material interlock inner door was opene In addition, to the prompt action taken by the licensee to close the Unit 3 material airlock inner door the licensee has posted permanent signs at the airlock inner doors warning of the requirements for secondary containment integrit The licensee has also modified surveillance test Procedure DTS 1600-22, 11Secondary Containment Leak Rate Test, 11 to incorporate all the testing conditions of special test SP 88-11-16 LER No. 88-018-0, Docket No. 050249 was submitted by.the licensee on December 15, 198 '
'
Based on the prompt corrective actions taken by the licensee this item is considered closed and no response to violation 249/88027-04 is r~quire.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot O~en items disclosed durin the inspection are discussed in Paragraphs 3.b(3) and (4), and Paragraph.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on March 30, 198 A telephone call was held on April 13 with Mr. Brunner to further discuss the inspection finding The inspectors summarized the scope and findings of the inspectio The licensee acknowledged the statements made by the inspector The inspectors also discussed the likely informational content of the inspection report with regards to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents/processes as proprietar (
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50-'231 I fft';;r CHICAGO, IL 60690 Initial Typing:
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STATION Received Start UNITS~ 2, AND 3
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I N FOR HAT I ON NOT I CC . * 1.IC[NSEE EVENT REPORT SGR NON-COHPLIANC£ C 1*2*3-~*5) .SSF NO VIOLATION 10 CFR 2, ~~~ APP. c sec. WON - OPEN.ITCH
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SAFETY EVAL. REPORT .... 73 71 SAFEGUARDS REPORTS *. ~. SIGNIFICANT SAFETY FINDING THREE-HILE ISLAND ACTION ITEMS UNRESOL~ED ITEMS WITHDRAWN ..... ,............ -... ~"-' I*,*
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