IR 05000237/1988026

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Insp Repts 50-237/88-26 & 50-249/88-26 on 881123-890106.No Violations or Deviations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Operational Safety Verification & Followup of Events.Problems Identified by Licensee Listed
ML17201M310
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 01/23/1989
From: Ring M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17201M309 List:
References
50-237-88-26, 50-249-88-26, NUDOCS 8902010093
Download: ML17201M310 (21)
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U. S. NUCLEAR REGULATORY COMMISSION REGION I II Report Nos. 50-237/88026(DRP);.50-249/88026(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 Nuclear Power Station, Units 2 and 3 Inspe~tion At:

Dresden Site, Morris, IL Inspection Conducted:

November 23, 1988 through January 6, 1989 Inspectors:

S. G. Du Pont D. E. Jones P. L. Eng R. M. Lerch J. F. Smith Approved By:

M.. A. Ring, Chief~~~

Reactor Projects Sectio~ l'B"' v~ (!!'

Inspection Summary

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Inspection during the period of November 23, 1988 through January 6, 1989 (Report Nos. 50-237/88026(DRP); 50-249/88026(DRP))

Areas Inspected: Routine unannounced resident inspection of licensee actions on previous inspection findings, operational safety verification, followup of events, monthly maintenance and surveillance observations, licensee event reports followup (onsite), in-office review of written reports on non-routine events, evaluation of licensee self-assessment capability, quality assurance program implementation, meetings, special report reviews, temporary instruction (Tis 2515/81, 2515/99 and 2515/95) reviews and inservice testing (IST) of pumps and valve Results:

No violations or deviations were identified. During this reporting period, however, several events and problems were identified by the license These include the following:

0 During the Unit 2 drywell inspection0during the refueling outage, the licensee discovered evidence of equipment damage associated with elevated drywell temperatures during the previous operating cycle (Paragraph 4.b).

CECo Quality Assurance discovered that a contractor's (Robert Irsay Company - onsite at both the Quad Cities and Dresden stations)

quality assurance program was deficient in controlling traceability 8902010093 890124 PDR ADOCK 05000237 G

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of materials, testing of their quality control personnel and performance of activities. A stop work order was issued on the contractor's activities associated with the control room ventilation modifications (Paragraph 4.h).

Additionally, the following observations were made:

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The licensee's self assessment efforts have been effective in providing improvements in the areas of chemistry, equipment reliability and scram reduction (Paragraph 9).

The licensee's quality assurance staff has been effective in assuring quality operation and plant activities (Paragraphs and 10).

The licensee's IST program implemented by the April 15, 1988, issue of "Inservice Testing Program for ASME Class 1, 2 and 3 Pumps and Valves, Including Augmented NRC Testing" appears to be a well developed and inclusive program (Paragraph 14).

TI 2515/81, "Static 110 11 Ring Di fferenti a 1 Pr~ssure Switches, 11 was resolved (Paragraph 13.a).

TI 2515/95, "MPA-C-02, 11 was resolved (Paragraph 13.c).

TI. 2.515/99, "Inspe'ction of Licensee'.s Implementation *of Requested Actions* of NRC Bu.lletin 88-07, BWR Power Ose:i_llations, 11 required actions were implemented (Paragraph 13.b).

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Violations 237/88011-02 and 249/88013-02 were retracted by the NRC (Paragraph 2).

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DETAILS Persons Contacted Commonwealth Edison Company (CECo)

  • J. Eenigenburg, Station Manager
  • L. Gerner, Production Superintendent
  • C. Schroeder, Services Superintendent
  • C. Allen, Performance Improvement Supervisor T. Ciesla, Assistant Superintendent - Planning D. Van Pelt, Assistant Superintendent - Maintenance J. Brunner, Assistant Superintendent - Technical Services J. Kotowski, Assistant Superintendent - Operations R. Christensen, Senior Operating Engineer G. Smith, Unit 2 Operating Engineer
  • 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 *. l'Ylorey, Chemistry ServiC:es-.. Supervisor

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D. Saccomando, Health Physi~s Services Supervisor*

  • E. Netzel, Q.A. Superintendent

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  • G. Bergan, Onsite Nuclear Safety
  • T. Lewis, Regulatory Assurance Staff The inspectors also talked with and interviewed several other licensee employees, includ_ing 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 various times throughout the inspection perio.

Licensee Action on Previous Inspection Findings (92701 and 92702)

(Closed) Violation (237/85006-0l(DRS); 249/85005-0l(DRS)):

Failure to verify the accuracy of valve remote position indicators every two years and to measure pump suction pressure with the pump idle as required by IWV-3300 and IWV-3100-1, respectively. The NRC inspectors confirmed that DOS 040-7 Rev 5, "Verification of Remote Position Indication For Valves,"

no longer restricts verification of accuracy of valve remote position indicators to inacce;:ssible valves and that DOS 1400-5 Rev. 5, "Quarterly Core Spray System Pump Test, 11 and DOS 1500-10 Rev 8, "Quarterly LPCI System Pump Operabi 1 ity Test, 11 require the measurement of suction pressure *

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before the pump is started. The NRC inspectors also confirmed that this practice was followed during the inservice testing (IST) of four pump This item is considered close (Closed) Unresolved Item (237/85006-02(DRS); 249/85005-02(DRS)):

Failure to include trending and corrective action requirements of IWV-3426 and IWV-3427 in the leak testing data for valves in the !ST Progra These requirements were incorporated into DAP-14-5 Rev. 0, "Leak Rate Testing Program.

This item is considered close (Closed) Unresolved Item (237/85006-03(DRS); 249/85005-03(DRS)):

Determination of proper categories for Core Spray testable check valves 1402-9A and The valves were categorized as AC and so noted in the IST Program, Rev. 2 dated 4-15-88 and in DTS 1600-9, Rev 0, "Augmented ASME Section XI Leak Rate Testing.

This item is considered close (Closed) Open Item (237/85006-05(DRS); 249/85005-05(DRS)):

Evaluation of stroke times for specific valves and modification of the associated maximum stroke times, if necessar The stroke times have been evaluated and new maximum stroke times and alert times have been recorded in DOS 1600-1 and DOS 1600-18 as established by DAP 11-21, 11 Inservice Testing for Pumps and Valves.

This item is considered close (Closed) NQncompliance (237/85006-06(DRS); 249/85005-06(DRS)):

Failure to.establish measures to assure the use of controlled and cali~rated

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measuring and test equipment for testing safety related pumps and valve The licensee**has established :the methods., cont~ol and responsibilities for calibration and control of measuring and test instruments in OAP 11-22, "Control of Measuring and Test Equipment (M&TE).

Vibration instrumentation and strobotachs were confirmed by the inspectors to be included in the controlled equipment list and to be bearing effective calibration stickers. This item is considered close (Open) Violation (249/85005-0?(DRS)):

Failure to establish methods insuring timely identification of conditions adverse to quality. This violation noted that the quarterly and cold shutdown valve stroke data for Unit 3 were not recorded for the entire year of 1984 and that two of the five test data packages for the completed test procedures could not be locate The procedure DOS 1600-1, "Quarterly Valve Timirig," and DOS 160-18, "Cold Shutdown Valve Testing," were revised to provide for the timely analysis of valve test data. Additional control was added by letter dated November 17, 1988, which required that all system engineer reviews (including those of pump and valve inservice tests) would be done in one specific office. The letter implied, but did not state, that the data could not be removed from this office. Upon inspection the data was found to be kept in an uncontrolled manner in a non-fireproof storage faci*lity *. The records could be reviewed without the knowledge or consent of the administrator if the administrator was not present. Although the mechanism for promptly processing the pump and valve !ST results was provided, th~ safeguarding of data p~vent loss or delay in processing has not been planned or implemente Until such plans are prescribed and implemented, this violation remains ope ) '.

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Open Item (237/87029-01): Determination of whether snubbers at the feedwater regulating station were in lockup under normal operating conditions. This item was unresolved in inspection reports 237/88011 and 249/8801 The inspection reports addressed the identical Unit 3 item (249/87028-01) and, as such, this item is administratively close (Closed)

Open Item (237/87023-LL): This item pertained to Licensee Event Report (LER) 237/87023-The LER was reviewed and found to be adequate in inspection report 237/87026 with the exception that a supplemental report was to be issue The inspector reviewed the supplemental LER 237/87023-1 and considers this item to be. close (Closed) Generic Letters (237/88001-GL and 249/88001-GL):

Verify that the licensee has reviewed and acknowledged Generic letter 88-01 on NRC's position on IGSCC in Boiling Water Reactor Austenitic stainless steel pipin The inspector verified that Dresden had received and forwarded information pertaining to IGSCC to corporate Boiling Water Reactor Engineering (BWRE).

These items are considered to be close (Closed) Open Items (237/88001-IN and 249/88001-IN): Verify that the licensee has received and acknowledged Information Notice 88-01, "Safety Injection Pipe Failure:" The inspector verified that the licensee had received the information notice and that data had been sent to BWR These items are considered to be closed *

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(Closed}. Open Items ( 237 L87059-IN and 2.94/87059.;:IN) : Verify 1 i ce.nsee' s action.per Information Notice 87-59~ "Potential RHR Pump loss." The inspector verified that Dresaen compiled data and forwarded the data to BWRE for corporate to answer the Information Notic These items are considered to be close *

(Closed) Generic Letters (237/88011-GL and 249/88011-GL):

Verify that the licensee has received and acknowledged the *Generic Letter 88-11,

NRC Position on Radiation Embrittlement of Reactor Vessel Materials."

The inspector verified that Dresden acknowledged the Generic Letter and forwarded information to corporate engineering. These items are considered to be close (Closed) Open Item (237/88051-IN):

Verify licensee's response per Information Notice 88-51, "Failure of Main Steam Isolation Valves."

The Information Notice addressed the MSIV failure event associated with Dresde The event and corrective actions associated with the Information Notice were resolved by the Augmented Inspection Team (Inspection Report 237/88013) and, as such, this item is considered to be close (Retracted) Violations (237/88011-02 and 249/88013-02):

Per letter

  • n dated December 1, 1988, the NRC retracted these violations based upon information that was not readily available during the inspection documented in inspection reports 237/88011 and 249/8801 (Administratively Closed) Open and Unresolved Items (237/88017-08; 249/88018-08; 237/88017-14; 249/88018-14 and 237/88017-26; 249/88018-26):
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These DET items require a resp,onse by the Office of Nuclear Reactor Regulation (NRR).

The inspector verified that NRR is tracking these issues as items M671542 (237/88017-08 and 249/88018-08), M671582/M671592 (237/88017-14 and 249/88018-14) and M671562 (237/88017-26 and 249/88018-26). These items are considered to be administratively closed on the Region III Open Item Listing tracking syste No violations or deviations were identified in this are.

Operational Safety Verification (71710 and 71707)

The inspectors observed control room-operations, reviewed applicable logs and conducted discussions with control room operators during this 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 reactor buildings and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and 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 pla The inspectors ~bserved plant hou.sekeepin.g/cleanliness conditions and verifie~ implementation of radiation protection controls. During the inspection, the inspectors walk~d down 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 instrumentation was properly valved, functioning, and calibrate..

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 procedure The following systems were inspected:

Unit 2 125 VDC Batteries Low Pressure* C_oolant Injection* (LPCI)

Unit Emergency Diesel Generator (EDG)

High Pressure Coolant Injection (HPCI)

Isolation Condenser Reactor Building Closed Cooling Water (RBCCW)

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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 onsi~e with licensee and/or other NRC officials. In each case, the inspectors verified that the notiftcation 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 q.ctions wou*l d p'revent future. recur~ence. The specific events are ~s fo*11 ows*:.

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On.Novemb~r 13~ 1988, with Unii 2 in a refueling outage, an Es*sential Safety Features (ESF) actuation cc.curre The 118

train of Standby Gas Treatment (SB.GT) automatically started while attempting to re-energize emergency bus 24-1, following testing and as a part of restoring the electrical system back to its normal line up.. When the cross-tie breakers for bus 28 and bus 29 were opened, the feed breaker from bus 29 to Motor Control Center (MCC)

29-7/28-7 tripped causing a half scram, reactor building ventilation system isolation, automatic start of the SBGT, and 118 11 Reactor Protection System Motor Generator (RPS MG) set tri The half scram reactor building vent system, and 118 11 RPS MG set were reset and returned to norma On November 14, 1988, the licensee irtformed the Resident Inspectors of results of an inspection during the Unit 2 Refueling Outage of two environmentally qualified (EQ) motor operators inside the Unit 2 drywell on the *primary containment isolation valves for the isolation condenser and HPCI system The two motor operators were found to have evidence of exceeding the EQ design temperatures with degrading of the grease and damage to one of the motor riperator's open loaded bearings. Additionally, the external wiring demon-strated evidence of high temperatures with some cracking of the cable insulation. The review of the affects of the elevated drywell temperatures on the life expectancies of the equipment and components are being evaluated by the licensee and will be reviewed by the NR. '.***

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On November 18, 1988, two NRG inspectors (Region III EQ Specialist and SRI - Unit 1) inspected the Unit 2 drywell with the licensee's task forc The inspection revealed that the majority of all damage to electrical components was restricted to the 4th floor of the drywell with only minor damage to cable seal tight jackets on the 3rd floor. Additionally, the significant damage. on the upper floor appeared to be localized to the two opposite quarters where the ventilation return ducts were closed. The damage in the other two quarters of the region appeared to be less, due to the open equipment manways between the 4th floor and the above-the-vessel-head regio The damage was assessed as either cracked cable insulation or outer jackets. Where the cable outer jackets were not disturbed for making ~onnections in junction boxes, only the outer jacket received damag However, at the regions where the outer jacket was disturbed, insulation cracking did exist. The equipment that appeared to be affected includes the HPCI (Safety-related EQ) and isolation condenser (Safety-related EQ) steam supply valves, two vessel head vent valves (Safety-related Non-EQ) and a Standby Liquid Control (SBLC) (Safety-related Non-EQ) valv No instrumentation appears to be damaged (all instrumentation is located on the 2nd or 1st floors of the drywell)~ The licensee plans to continue to investigate for the extent of damage by inspecting the internals of the vessel head vent valves, air solenoids and the SBLC valve. 'Additionally, all damaged compone_nts will be repaired or replaced. The two EQ motor operators have.been rep.laced* and other components.are being replaced with-onsite store The licensee has also formed a task force to determine the root cause for this event and the associated temperatures that existe The apparent cause has been determined to be due to an inadvertent ventilation lineup of the internal drywell ventilation. The task force determined that the four ventilation ports to the region above the vessel head were found to be closed since April 19, 198 The licensee obtained samples of the degraded grease from the two EQ valves for analysi The inspectors observed the internal components associated with the two EQ valve The internal damage was limited to only one bearing and the Mobilux EP-0 grease which showed significant degradatio All of the internal wires, switches and the motor windings were not damage For Unit 3, the inspector verified through direct independent observations during the Unit 3 drywell closure following the dual unit maintenance outage on December 8, 1988, that all four ventilation ports and both equipment manways were in the open positio The licensee has requested an evaluation by Bechtel on the life expectancies of all equipment internal to the Unit 2 drywell. This evaluation is expected prior to the Unit 2 restart in February 1989 and will be reviewed by the NRC *. The investigation into this subject is ongoing and will be further documented in the next Resident Inspector Office report. The Division of Reactor Safety

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is also involved in the investigation-of this issue. A decision regarding any violations associated with this subject is deferred pending completion of. the investigatio On November 22, 1988, Dresden informed the Resident Inspector that a shipment of approximately 830 micro curies of mixed isotopes was sent from Zion Station to Dresden Station in an. unlabeled package by commercial carrier. The source was ~pparently packaged properly by radiation protection including a proper label on the inside container but was inadvertently placed in a unmarked outer box by the shipping room and shippe On November 27, 1988, during a Unit 3 scheduled shutdown for a dual Unit Maintenance Outage, the unit scrammed while at 17% power (111 MWe).

The scram occurred while the main turbine was being shut down for the outag High vibrations were received on the #1 main bearing and a subsequent turbine trip occurre The pressure switches appeared to trip because of the resulting vibration related to the turbine trip, this resulted in the closure of the Main Steam Isolation Valves (MSIVs).* Since the mode select switch was in the run mode an immediate reactor scram occurre The inspector verified that all systems responded as expecte The licensee's inspection of turbine bearings and turbine alignment did not reveal any abnormal condition The conclµsion of the li~ensee's investigation determined that the cause of the scram was spurio4s and the unit started up on. December 8, l988, *without any prob.lems..

Additiona1Ty, no vibrations were experienced during a subsequen shutdown and startu *The scheduled reactor shutdown commenced on November 26, 1988, in support of a dual unit maintenance outage, Unit 2 was already in cold shutdown and defuele The major activity during the dual outage involved significant maintenance on the service water system Unit 3 vessel and fuel pool cooling was provided during the outage by a temporary piping system supplied by the Containment Cooling Service Water system, which was not be affected by the main service water system maintenance outag On November 29, 1988, while performing the Unit 2 Refuel Floor Radiation Monitor Channel B surveillance, an unexpected trip of ventilation occurred resulting in an automatic start of the Standby Gas Treatment (SBGT) "A" trai The surveillance required a O.wnsca,le trip of ventilation, however; when the downscale trip check was energized, an upscale spurious trip occurred because of switch contact problem During the review of the completed surveillance, it was determined that the upscale trip was unexpecte The licensee notified the NRC via the ENS after the revie Both Units 2 and 3 were shutdown during the event, Unit 2 was in a refueling outage with all fuel removed and Unit 3 was in cold

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shutdown for a scheduled maintenance outag Cause of the event was subsequently determined to be a contact closure proble Repairs were made and subsequent testing was satisfactor During a bolting operation, an 8 inch Grinnell pipe clamp cracke The transverse crack was lo~ated approximately 1/2 inch from the formed bolt hole extension, and was approximately 7/16 of an inch in depth, in a cross section of 1/2 inc The pipe clamp was being installed on a non-safety related cleanup system return line as part of a non-safety related modification during the Unit 2 refueling outag The cause of the failure will be investigated by the licensee's System Material Analysis Division (SMAD).

The failure is also being evaluated by the licensee for the potential of being reportable under 10 CFR Part 2 The results of the licensee's and the manufacturer's evaluation determined that the material of the clamp met specifications but that the cause of the 11brittle.ness 11 of the material was not determine Further evaluations are being performed and will be monitored by the NR On December 9, 1988, Commonwealth Edison informed the resident inspectors at Quad Cities and Dresden that due to previous concerns with heating, ventilation and air c:£1nditioning (HVAC) contracts at other sites, an audit of the Robert Irsay Company was performed by CECo Quality*Assurance.(QA).. _ The Irsay Compa-ny is involved with duct work for the control room ventilation modifications* at Quad Cities and Dresden. *The initial audit, performed approximate*ly three months ago, raised some concerns regarding procurement of material to be used in safety related portions of HVAC work at the two site On a followup audit to see if these concerns were corrected, CECo QA identified several ne~ concerns as well as some repeat items. During the time between audits no safety related work was allowed to be performe As a result of the second audit a stop work order was issued to the Robert Irsay Company regarding any safety related wor Some examples of the concerns raised are as follows:

1. Certification of conformance on weld rod was not maintained; Implementation of Irsay*s QA program was inadequate, e.g., traceability of materials was lacking, testing of their quality control personnel was not done, construction of duct work did not conform to design drawings, and independent audits of their QA program were not performe CECo QA has conducted an audit of all documentation associated with this contract and has taken control of all Irsay records at Dresden and Quad Cities. Currently, the procedures and Quality Assurance process are being reviewed and approved by CECo based upon Irsay's corrections. This issue is still open and being addressed by CECo QA at both Quad Cities and Dresde The Quad Cities Resident Inspection Office (RIO) has the lead for this issue in terms of tracki~g via the open items lis No violations or deviations were identified in this area.

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  • Mo!Jj:!)_!.tl1,9intenance Obs~rvat_ion (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 ite~s wer~ 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 testing 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 were implemented; and, fire prevention controls we,re 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 following maintenance activities were observed/reviewed:

0 Replacement of isolation valves in*the main service water system, including the isolation valves to the recirculation pump motor generator *

Biennial inspection of the Unit 2 emergency diesel generato Repairs to fire door 83 to the Unit 2 125VDC battery roo The replacement of the isolation valves to the service water system required an extensive temporary alternate cooling water path to both Units 2 and 3 Reactor Building Closed Cooling Water (RBCCW) heat exchanger The inspector observed the activities associated with the installation, hydro testing and functional testing of the tempora.ry piping installed between the Containment Cooling Service Water (CCSW) pumps and ~BCCW heat exchangers. The alternate cooling path provided CCSW for the RBCCW system through the Low Pressure Coolant Injection (LPCI) heat exchanger inlet valve The inspector verified that the alternate cooling path

  • adequately provided heat removal for both units' spent fuel pools and the Unit 3 shutdown cooling syste The inspector also observed the pre-planning, which required coordination of several onsite and offsite organizations, such as, onsite engineering, technical, operations and maintenance staffs and offsite corporate and consultant engineering staffs. All of the activities associated with the Service Water Maintenance Outage; pre-planning, development and installation of the temporary alternate cooling path, replacement of the isolation valves and restoration of the service water system, were performed in a timely and safe manner indicating excellent management and quality involvemen No violations or deviations were identified in this. area.
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      • 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 instrumentqtion 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 2 HPCI turbine overspeed trip testin SBGT automatic actuation surveillanc *Unit 2 diesel generator operability surveillanc Unit 3 Reactor vessel low""""water level ECCS Initiation surveillanc HPCI-monthly pump and valve-v~rificatio~.

Common Units 2 and 3*

2/3 diesel generator operability surveillance*.

  • During the post maintenance testing of the Unit 2 diesel generator, after the completion of.the biennial diesel generator inspection (2-G-88-131), the voltage regulator did not functio The licensee conducted an investigation into the cause and discovered Lhat the brushes for the field rheostat n~tor*had been remove During the investigation, it was determined that both the Unit 2 and 2/3 biennial diesel generator inspections (2-G-88-131 and 2/3-G-88-72) were being conducted by the Electrical Maintenance (EM) foreman at the same time, and that the field rheostat motor brushes were removed during these inspection The sequence of activities is as follows:

During the 2-G-88-131 (Unit 2) inspection, the EM determined that the brushes in the field rheostat motor needed replacement. Spare brushes were issued from stores and installed in the Unit 2 field rheostat motor, completing requirements for step F.l.d of 2-G-88-13 Even though both inspections were being conducted together, the Unit 2 inspection had completed step F.1.d ~rior to the EM crew on the Unit 2/3 inspectio When the EM crew on Unit 2/3 progressed to step F.l.d, the field rheostat motor brushes on the Unit 2/3 diesel generator also needed replacing, however, no new brushes were available in stock. Since both biennials were under supervision by the same EM Foreman and the Unit 2/3 diesel

-generator was needed to support other activities in the near future, the EM Foreman replaced the brushes in the Unit 2/3 with those in Unit Several errors were made at this point, the most important of which is that the Unit 2 biennial inspection did not have step F.1.d voided, instead the EM crew completed the biennial without noting the lack of brushe The diesel was returned to operations for performance of post maintenance and operability testing. The error was discovered during t~sting, since the voltage regulator could not function without the field rheostat moto The licensee's investigation found that, because the brushes are required to be replaced by the biennial inspection, the EM Foreman -believed that a work request was not required on the Unit 2 work since the biennial inspection was controlling the activit As a corrective action, the licensee issued the Maintenance Department Memorandum #49, "Removal of Parts and Equipment for One Unit, for Use on the Other Unit.

The inspector reviewed memorandum #49 and found that adequate controls *

were initiated by the memorandu In addition to requiring a work request, notification to the Unit Operating Engineer allows the operations department to maintain status of equipment availabilit The administrativ~ procedure DAP 15-1, "Work Requests, 11 is also befng revised to in~lude the requirements of memorandum #4 In addition, the

  • 1;ce*nsee is *evaluating the. activity controls associated with: inspection.

ty,pe surveillances, since inspections require replacement of compon~nts which are found to be worn or defective, it is not apparent that work -

requests would be required, and normal repair activities are automatically under the control of the work request proces The inspector found the licensee's corrective actions to be timely, effective and adequate to prevent recurrence. Additionally, following the evaluation of the controls associated with inspection, surveillance and repair activities, improvements will be initiated through the

maintenance improvement plan.* The inspector has no further concerns with this issu No violations or deviations 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 accordance with Technical Specification LER 237/88006-00:

Loss of Primary Containment Nitrogen Inerting Makeup System Due to Damage Caused by Personnel Erro The event associated with this LER was previousl1 reviewed and resulted in a violation documented in inspection report 237/8800 The LER was reviewed and found to be satisfactor I- *

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LER 237)88015-00: High Pressure Coolant Injection (HPCI) Isolated Upon Discovery of a Failed High Steam Flow Isolation Flow Transmitter Due to Unknown Caus The event associated with this LER was previously addressed and resolved in inspection report 237/8801 The LER was reviewed and found to be satisfactor LER 249/88005-00:

HPCI system intentionally made inoperable to facilitate pre-planned preventive maintenance testing. Overspeed trip testing of the HPCI turbine requires the turbine to be uncoupled from the HPCI pum This test is a once per year or whenever station operations permit surveillance of the overspeed trip syste The test was performed while the unit was being shutdown for a refueling outag The inspector found the LER to be satisfactor *LER 249/88012-00:

Primary Containment clean demineralized water isolation valve discovered open due to procedure inadequac The event associated with this LER was addressed and resolved in inspection report 249/8801 The review of the LER found. the documentation of the event, root cause and corrective actions to ~e adequat LER 249/88017-00:

Reactor scram due to Spurious Main Steam Low Pressure signals caused by vibration. The event associated with this LER is addressed in Paragraph 4 of this report. The LER was found to meet the requirements of 10CFR73.

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  • Denotes those preteding LERs that were reviewed against the criteria of
  • 10 CFR 2, Appendix C, and the *incidents described met all of the following requirement Thus no Notice of Violation is being issued for these item The event was identified by the licensee, The event was an incident that, according to the current enforcement 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 to prevent recurrence within a reasonable 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-Office Review of Written Reports on Non-routine Events (90712)

The inspector reviewed the following licensee Event Reports (LERs) to ascertain that the information reported satisfies the requirements of 10 CFR 73, corrective actions contained within the report are appropriate to prevent recurrence and the cause classification is accurate. Addi-tionally, this review ascertains whether additional reactive inspection effort or other NRC response is warranted; or whether a potential Generic or a 10 CFR 21 issue is presen *... *..

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LER 237/88017-00:

High Pressure Coolant Injection (HPCI) system was intentionally made inoperable to.facilitate pre-planned preventive maintenance testing. The test required the HPCI turbine to trip for verification of the turbine overspeed trip setting. The test was accomplished as part af the Unit 2 shutdown for refueling on October 29, 198.

A similar LER (249/88005) documented the inoperability of Unit 3 HPCI for overspeed trip testing. The inspector ascertained that this lER was complete and accurate and that a Generic or 10 CFR 21 issue did not exist. Additionally, an onsite evaluation was also determined to be not warrante *LER 237/88018-00:

Leak rate limits for the drywell head seal and Main Steam Isolation Valve (MSIV) 2-203-10 exceeded the "as found" limit The head seal was discovered to have an "as found" ]eak rate of 491.37 standard cubic feet per hour (scfh) and the MSIV 2-203-10 of 12.99 scf The licensee used the maximum pathway method for Type B and C local leak rate testing and determined that the total "as found" leak rate was 623.917 scfh, which exceeded the Technical Specification limit of 493.116 scfh. Additionally, the MSIV leak rate of 12.99 scfh exceeded the limit of 11.5 scfh. The cause of the head seal leakage was attributed to improper seating of the outer gasket due to an installation procedure deficienc The MSIV leakagP. was attributed to seating surface wea The. ".through'~ leakage was determined to-be minimal becaus.e the redundant outboard MSIV 2-203-2D was verified to comply within the limit and the drywel.l head was properly seated on the full Circ.umference of the inner gasket. Both the MSIV and outer gasket will be repaired during the current Unit 2 refueling outage and tested prior to the unit startup in February 198 OMP 1600-5, "Drywell Head Replacement and Installation of Shield Blocks" will be revised to require a Quality Control inspection to ensure that the gaskets are properly inserted prior to installing the drywell hea Procedure OTS 1600-15, leak rate testing procedure, will also be revised to include troubleshooting guidance should a double-gasketed seal show significant leakage during an "as left" leak rate tes The LER and corrective actions appear to be accurate and adequate. This LER is considered to be close LER 237/88019-00:

On ~ovember 29, 1988, while performing the Refuel Floor Radiation Monitor Calibration and Functional test (DIS 1700-15),

the reactor building ventilation system tripped and the "A train of Standby Gas Treatment (SBGT) system automatically started. The licensee's troubleshooting efforts determined that the root cause of the event was due to a faulty trip check pushbutton switc When the trip check switch was pushed, a momentary high radiation monito; signal appeared, initiating SBG The faulty switch was replaced and the surveillance test was satisfactorily re-preforme *Denotes those LERs that were reviewed against the criteria of 10 CFR 2, Appendix C, and the incidents described met all of the requirements (see Paragraph 7 of this report). Thus, no Notice of Violation is being issue *... *.:

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No violations or deviations were identifie.

Evaluation of Licensee Self-Assessment Capability (40500)

The inspector ascertained through review of documentation and observation of onsite and offsite review activities that the licensee 1s ability to.

evaluate the effectiveness and implement corrective actions based upon self-assessment programs was satisfactor The inspector attended both onsite and offsite review committee meetings. *

During the CECo Nuclear Safety Department quarterly offsite review meeting, the facility 1s trend in deviation reports and LERs was reviewe The evaluation contained data pertaining to cause code and corrective action between June 1984 and September 198 The review indicated significant reduction in deviation reports (DVRs).due to personnel and design errors between 1987 and 198 The rate of personnel errors decreased from 2.3 DVRs per month to 1.8 while design errors decreased from 2.1 to 1.0.. The reduction in personnel errors has been a steady decrease since 1985 when errors occurred at a rate of 6.1 DVRs per mont Component failure DVRs have also demonstrated a reduction in occurrence rate from 14.1 DVRs per month to 11.7. However, increases occurred with both procedure and management errors. This is primarily due to efforts to improve the station's classification accuracie The rev.iew also considered the effectiveness of.corrective actions implemented by the faci H ty.-in over 30 systems, components or functional areas, including: Feedwater Regulating Valve (FRV), failures to pump drywell sumps, events involving work planning and uncoupled control rod drives (CRDs).

Many of the areas demonstrated that the corrective actions implemented by the facility were effective in that no recurring

  • events occurred in 1988. These areas include:

FRV, Reactor Protection System (RPS) power supply transfer, fuel pool high radiation, failure to pump drywell sumps, diesel generator air start failures, fires in electrical breakers and uncoupled CRD The reduction i11 personnel errors effort was significant in preventing recurrence in RPS power transfer and drywell sump pumping errors. All other areas except ESF actuation demonstrated a reduction in recurrenc The inspector also observed that several self assessments had been conducted by the Dresden onsite and corporate offsite staffs. These include a Chemi~try/Radiation Waste Self Assessment, Corporate Assessment of QA effectiveness, Safety System Functional Inspection (SSFI) on Unit 2 HPCI and a special self Systematic Assessment of Licensee Performance (SALP) conducted by the NUS corporation (led by a previous RIII Regional Administrator).

  • 10. Quality Assurance (QA) Program Implementation (35502)

The inspector performed an evaluation of the effectiveness of the licensee 1s implementation of its Quality Assurance (QA) Progra The overall effectiveness of the licensee 1s QA Program implementation is directly related to the licensee 1s performance in specifk functional

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disciplines, which is reflected in its operating history. Therefore, operating hjstory is an indication of the effectiveness of the implementation of the QA Progra The evaluation was conducted by review of the following: Inspection Reports for the past 12 months (November 1987 through November 1988) SALP reports for the past 2 years (SALP"6 and SALP 7). Outstanding Regional Open Items List (OIL). Licensee corrective actions for NRC inspection finding Licensee Event Reports for the past 12 months (November 1987 through November 1988).

In addition to the above revfew, the facility's recent operating history and the collective knowledge of the resident and region based inspection staffs was also used in the evaluation proces Dresden's operating history has shown steady improvement over the last two SALP period The number of LERs has decreased (53 in 1987, 40 through November 1988), and the number of personnel error DVRs has.also shown improvement.:(24 in 1987~ 14 through November 1988);* personnel *

contaminati ans have decreased from 874 in 1987 to 47t through November -.

198 The licensee has also completed a record dual unit run without a scram of 403 days (a scram occurred while shutting down for a planned maintenance outage).

No negative performance trends were noted and based upon the, review, the inspector has concluded that the QA program at Dresden is effectively implemente lL Meetings During this inspection period, several meetings were held with the license On November 16, 1988, members of NRR and the Region met with the licensee to discuss the Detailed Control Room Design Review (DCRDR)

and the schedule of implementing the changes to the control room during the Unit 2 refueling outage. Also, on December 6, 1988, members of the Divisions of Reactor Safety and Reactor Projects and NRR met with the licensee to discuss the licensee's corrective actions associated with the Unit 2 elevated drywell temperature.

Report Review

During the inspection period, the inspectors reviewed the licensee's Monthly Operating Report for November 198.

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1 Temporary Instruction Verification The inspector verified that the licensee had initiated the required actions contained in the referenced Bulletins and Information* Notice TI 2515/81, 11Static 110 11 Ring (SOR) Differential Pressure Switches (25581)

The Temporary Instruction required verification of the licensee's response to Bulletin 86-0 the bulletin addressed the reliability problems associated with SOR Series 102 and 103 differential pressure switches used in nuclear facility application. These SOR series were found to not meet the General Design Criterion 21, 11Protection System Reliability and Testability.

The licensee verified that neither series 102 or 101 were used at Dresden for ESF actuations or the reactor protection system. This temporary instruction is considered to be close TI 2515/99, 11Inspection of Licensee's Im lementation of Re uested Actions of NRC Bulletin 88-07, BWR Power Oscillations

25599 The inspector verified through interviews with three Shift Control Room Engineers (SCREs), 11 Nuclear Station Operators (NSOs) and five Shift Engineers (SEs) and Foremen (SFs) that training ~~d b~en recei.ved pertainin"g to the LaSalle* power oscillation event

~f March g, 198 In addition, the inspector verified that the licensee had implemented new training instructions pertaining to power oscillations and an operating order 16-88, 11Interim Operating Restrictions to Preclude Regional Neufron Flux Instabilities.

The operating order was written on October 28, 1988, as an interim procedure based upon GE's recent analysis to determine the severity of power oscillations. This analysis was presented by GE to the BWR Owner's Group Stability Committee on October 27, 1988, The inspection also verified thro11oh intervil:!WS and walkthroughs with selected NSOs, SCREs, SEs and SFs on all six operating shifts, that they had been thoroughly briefed of the requirements of the operating orde The review of the operating order revealed that instructions were provided for prompt corrective actions whenever the unit enters the 11detect and suppress 11 regions of the operating ma The operating order also restricted operation near these regions to compensate for any existing deficiencies in control room instrumentatio This TI is considered close TI 2515/95 (MPA-C-02) (25595B)

The inspector verified by review of as-built drawings 12E-6582D, 12E-6582E, 12E-7582D and modification packages M12-2/3-79-23 that the licensee has installed reactor recirculation pump trips that are actuated by either low reactor,vessel water level or high reactor vessel pressure. This TI and MPA are close '.

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Inservice Testing (IST) of Pumps and Valves (73756)

The inspectors reviewed the implementation of the licensee'~ second 10 year interval !ST progra The program was implemented in accordance with the provisions contained in the interim Safety Evaluation *enclosed in the NRC letter dated September 1, 198 Additional attention was provided in areas in which previous deficiencies had been identified, such as, details of test performance, trending, valve stroke timing, controls for measuring and test instruments and proper disposition of test dat The inspectors witnessed the Inservice Testing (!ST) of four LPCI CCSW Pumps 3A, 38, *3c, and 3D in accordance with the IST program for pumps and valves "Quarterly Containment Cooling Service Water Pump test for the Inservice Test (!ST) Program,

DAP-~1-21, Rev 3, dated November 1988; DOS 1500""'.2, Rev 7,. dated August 198 The testing was performed as required, but the following deficiencies associated with pump shaft leakage*were note All four pumps exhibited substantial leakage at the shaft packin Some packing was projecting between the case and the shaft on Pump 3 The discharge valve on Pump 3C exhibited.extensive leakage and the _test was curtailed pending correction.* All four of the pump discharge valves were repacke,

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The inspector observed that the pumps an~*motors were marked for vibration tests i~ 12 positions which were recorded and stored in the memory of the test instrument, however, only two positions identified in procedure DOS 1500-2. were used to provide acceptance data for the !ST progra The remaining positions were used for maintenance informatio The inspectors also reviewed a sampling of the documentation used to implement the Dresden !ST progra These include the following documents:

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0 Inservice Testing Program for ASME Class 1, 2, & 3 Pumps and Valves, including Augmented NRC Testing, Rev 2, NRC Submittal, Dresden*

Nuclear Station, Units 2 & 3, dated April 15, 198 Dresden Station Quarterly Report BOP/IST Vibration, Third Quarter, 198 Procedure DOS 040-7, "Verification of Remote Position Indicator for Valves Included in the Inservice Test (!ST) Program," Rev 5, dated August 198 Procedure DOS 1400-5, "Quarterly Core Spray System Pump Test wit Torus Available of the Inservice Test (!ST) Program, 11 Rev 5, dated August 1988.

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0 Procedure DOS 1600-18, 11Cold Shutdown Valve Testing, 11 Rev 7, dated July 198 Procedure DOS 1500-10, "Quarterly LPCI System Pump Operability Test with Torus Available for the Inservice Test (!ST)

Program, 11 Rev 8, dated September 198 Procedure DOS 1500-2, "Quarterly Containment Cooling Service Water Pump Test for the Inservice Test (!ST) Program.

Procedure OAP 14-5, "Leak Rate Testing Program, 11 Rev 0, dated November 198 Procedure OAP 11-12, "Control and Calibration of Stopwatches,"

Rey 2, dated April 198 Procedure OAP 11-22~ "Control of Measuring and Test Equipment (M&TE),

11 Rev 0, dated April 198 The review of the !ST program revealed that the program is more than adequate in meeting the requirements, however, the initiation of the program is currently not fully complet The portions of the program that have.been initiated, are considered to be satisfactory. Additional reviews of the !ST program will be conducted by the NRC during future inspections and. NRR is also currently reviewi.ng the program* for adequac to the ASME cod No violations or deviations were identifie.

Installation and Testing of Modifications (37828)

The inspector observed portions of the installation and testing of various plant modifi~ations during the Unit 2 refueling outag The inspector verified that the installations were properly prepared for testing and the test procedures were developed, reviewed and approved prior to performanc The inspector also reviewed several procedures to verify that correct pre-requisites, precautions and acceptance values were prescribed. Portions of the following modifications were observed:

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M12-2-85-94, installation of a new high capacity turbo charger on the Unit 2 diesel generato M12-2-86-24H, rearrange core spray panel control switches on control room pane Ml2-2-87-9, modify Unit 2 diesel generator lubrication oil syste M12-2-87-39, replace the ADS time delay relays with-Agastat relay Ml2-2-88-13A, replace the trim on the 28 feedwater drag valve.

Ml2-2-88-13B, replace the operator on the 28 feedwater regulating drag valve with an electro-hydraulic controlled operato \\}

No violations or deviations were identifie.

Exit Interview (30703)

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

on* January 6, 1988, and informally throughout the inspection period, and summarized the scope and findings of the inspection activitie 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 such documents/processes as proprietary. The licensee acknowledged the findings of the inspection.

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