IR 05000237/1990021

Insp Repts 50-237/90-21 & 50-249/90-21 on 900821-22,0917-21 & 1011.Violations Noted

ML17202U853
Person / Time
Site:	Dresden
Issue date:	10/18/1990
From:	Danielson D, James Gavula NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17202U851	List: IR 05000237/1990021 ML17202U850 ML17202U852
References
50-237-90-21, 50-249-90-21, NUDOCS 9010260034
Download: ML17202U853 (10)

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U. S. NUCLEAR REGULATORY COMMISSION REGION I I I Reports No.. 50-237/90021{DRS); 50-249/9002l(DRS)

Docket Nos:

50~237; 50-249 Licensee:

Commonwealth Edi~on Company Opus West II I 1400*0pus Place

.Downers G~ove, IL 60515*

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• Licenses No. DPR-19; No. *DPR-25 *

• Fa ti 1 i ty Name-: * Dresden* Statfon - Uni ts 2 and 3

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Irispecti9n At:

Dre~d~n Site -

Merri~, IL 60450 Commonwealth Edison Compahy Corporate Office Downers Gro~~~ IL* 60515 * *

. Inspection Cqnducted:

August 21-22, 27-28, and September 17-21, l990, at*

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• Approved* *sy:

Dresden Site

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October 11, 1990,. at Co.mmonwea lth

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Corporate* Office

...y Jpv,~~Jh~

.* D. H. Danielson, Chief Mctterials. and* Proces~es S~ction *

Edison.Company

. //',l~J4/)..

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. Inspection Sum111ary Ins ectidn on August 21-22, 27-28, Se tember 17-21,: and October 11, 1990

• Reports No. 5 -2 7 90 21 DRS ;

1 DRS

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Areas Inspected:

Routine safety inspection of inservice inspection (ISi)

component support inspection acti.vities (70370).

Results~. One violation was identified (inadequate corrective action - *

Paragraph 2.e.). During this i~spection, the following strengths and weakne~ses were noted:

0

The critical aspects bf the Section XI component support *inspection

. prograrn have improved "significantly in recent year The ISI staff member's technical competence, pride of ownership, and

. positive attitude have ~ontributed_to the observed program improvement The current program is having to compensate for past weaknesses in both component support inspections and construction practic~s. *

9010260034 901018 PDR ADOCK 05000237 a~

PNU

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• • • DETAILS P~rsons Contdcted-commonwealth Edi son Company (CE Co)'

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• E. Eenigenburg, Dresden Station Manager

-. *L. Gerner, Technical Superintendent _

~M. Strait, Technical Staff Supervisor

• *G. Whitman, ISI Coordinator M. Horbaczweski, ISI/IST Group Leader*

- *G. Frizzell,- NED Site 'Engineer

• B. Viehl, Engineeting De~ign Supervisor

• Do~ PSD ISI/Materials Group

+Richter, Nucltar Licensing Administrator P. Donrivini Design Sup~~visor

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NUTECH Engineers J. Young, iSI Inspectot ABB Impell Corporati~ri (Impell) *

_ s: Ramsey, Division Manager

+J. Ramuta, Section,Mdnager

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+J. Burghoffer~ Supervising Engineer

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U. _s.. Nuclear Regulatory Commission (U.. S. NRC) *

• D. Hills, Resid~nt. Inip~~tor (D~esde~)

• Denote~ th0se attending the interim exit interview at the Presden site on ~eptember 21, 199 +Denotes those attending the exit interview at CECo corporite offices on October 11, 199.

ASME Section. XI Component Support Inspections (70370) Background The Dresden inservice inspection (ISI) program is cu~rently based on the 1977 tdition with th~ Summer 1979 Addenda of Section XI -0f the AShE Code_,

Since acceptance standards for component supports were not given in this editior1 or addenda, the acceptance standards from the 1980 Edition of the*Code have been utilized in the progra Pruceoure ~nd Pro~ram Review The following procedures were reviewed for compli~nc~ with NRC requirements and licensee commitments:

0 DTP 2, o"Inservice Inspection Plan, 11 Revision 8, January 199_0. -

CED! No. 12-90-1, 11 Examination of Constant and Variable Sprihg Type Component.Suppor:ts, 11 Revision 1,-January 199 SPPM VT-3/4-J, 11 VT-3/4 Visual Inspection _Performed for Section-XI, 11 Revision 1, *November 19 No viOlations or *deviations were identified~

The.components included in the !SI Program are *cu-rrently-listeCl in the tnservic~ Inspectjrin history bi~ders. For eac~ 10-year interval, a recurd of all inspections for eac~ examination category. and each class of sYste~ i~ kep This record cbniists of marking a specific component when it receives an inspectio Efforts ~r~ cu~rently

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underway to incorporate this information into a_ computer database for greater efficienc *

• The informat.iur1 listed-in the binders was generated using the Dresderi _Inservice* Inspection Isometrics.-

Th~se drawings show relative locations of items included in the IS! _progra As a

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result of previously discovere:d inadequacies by 'the liC:ensee and ihe NRC, these.drawings wer~ revised in 1987 t~*update the information contained in these drawing In partic~lar, pipe support information changes which result~d from IE Bulletin 79-1(

and Mark I Reanalysis Programs were incorporated into the drawing Prior' to that,revision, the IS! Program had not.been systematically updated to account for rnodifi cat ions made to the f ci.ci 1 ity. -

f:i. comparison between_ the isometric drawi-ngs and the component supprirt information listed in the binders revealed that pipe supports designated as 11 guides 11 on the drawings were not included on the lists ir1 the binder Conversations with the licensee iridicated that this_ was an interpretation carried over from the IS! program's initial_ implem~ntatio Accordi~g to the licensee, this interpretation was based on a.concept that 11 guides 11 were pipe restraints which would, only see loads during a seismic event and as such, would not see any normal operating load O~ that basis, there was no need to look for-~

servi~e induced problems with these supports unless*a seismic event o~curre Whe~ questioned by *the NRC inspector,.the licensee could nbt provide the basis fo~ this interpretatio As an additional complication, the revision to the isometrics evidently did not use the above interpretation as a basis for designating supports as either 11 guides 11 or 11 hangers

• _Instead, this designation was based on hovi the support was constructed~ - If it contained any vendor supplied catalog item, it was designated as a

'i ':

hdnger; otherwise, if it wa~ constructed using only structural

'member~. it was designated as a guid The licensee recently discovered this discrepancy and instead of attempting to evaluate each support to deterii1i ne if it saw any normal opera.ting loads, it was de.c.i.ded to include *all of the*se "guides" in the ISi progq Although the correct decision was reached, the basis of this decisio~

was questionabl Any pipe restraint may see an operational load if abnormal events such as waterham~er or severe vibration occu *

.therefore, all pipe.supports should be included in the program to look for_these. service induced problems..

• The consequences of. this.deficiency were minimized for the

_following reason The. percentage of component supports required*.

to-be inspectedduring each 10-:year interval is approximately 2 By neglecting these *supports, the licensee still. has inspected over.

. 50% of the total *population of component supports which is wel above the.requirement. *In addition, the only*. potential prpblem with not *includjng thes~ supporis pertains td the expansion of the

_.inspections due to an identified deficienc In that case, the Code requires that adja*cent supports,also re.ceive an inspectio If the ddjacent supports happen to be guides, the program. wi 11 skip these and go to th*e next supports _identified as hangers. *However, based onthe latest ISI in'spections, this shortcoming was eliminated when..

the ISI.. co0rdinator routinely expanded the inspection on very conservative bases and i-n many cases~* included.guides in these*

expansion populbtions...* Based on the above, in the. NRC inspector's 6pinion, the noted program weaknesses did not cau'se a significant s*afety impac *

A detail'ed review of the ISL isometrics by the NRCi.nspector distlosed th<lt the flued head anchor structures ass6ciated with the

, drywell* pip1r:ig penetrations had not been incorporated on the drawings and as such, were not listed in the ISI history binders:

The consequences of this bverstght were minimized since all of the flued head anchor structu~es w~re recent]~ modified and had received

. a baseline ISI inspection as a now normal part of the CECo

• modification proces During the inspection, the ]i~ensee committ~d to upgrading the drawirigs in question by incor~orating the flued head anchor structure.designations in the upcoming ISi drawing revie In addition, on Drawing No. ISI 212, Sheet 2 of 2, "CRD Scram Discharge Volume Hest Bank," Revision B, October 23, 1987, the designation. for ~upport M-1188D-1123 did.not. include an integral

• welded attachment (IWA) symbo As such, the IWA for this support was *not included in the Category C.;.C item in the ISI binde Accordinq to the licensee, this error will also be corrected in the upcoming-ISi draw1ng revisi~ ' 4

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.Pipe Suppdrt Surveill~nces Th~ NRC.inspecior accompani~d an ISi contractor during ins~ections of the following component supports:.

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• M-3208-14 ~od Hanger, LPCI Discharge M-3208-08Strut,.Core Spray Test Line M-3209-02 Vertical Strut, Core Spray Discharge M-3209-04 Spring Hanger, Core Spray Discharge M;...3209-23, U-Bo lt Restraint, Core Spray Di sc,harge'

M~3214-38 Rod. Hanger, LPCI discharge

M-11510-10 2-Way Guide, HPCI Disc.harge The ISi i.nspector used individual support drawings.durihg each inspection.. The inspections were thorough and.consisted of.detailed hands-on rev.iews. *The ISi 'inspector was familiar with the

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applicabl~ procedures ~nd used ~onser~ati~e acceptance standard~.*

Recordable.i~djcati-0ns, if.any, were ~ppropriatelj documented.

... d. * Records Review*

• v*isual inspection data.forms fo'r the Dresden *1989 Unit 3 component support examinations were reviewed by the NRC inspector. *The level~-

.. of deta*i l documented on the forms-gave a pos'*itive indicatibri as to the extensive nature of th~ examination An initial sa~ple.bf 130 supports was ex~anded by an addition~l 93 supports due to* the *

possibility of service induced discrepancies.*< A.total of 54 'support were id~ntified as havi~g recordable indications and required some

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form of corrective action. A significant portion of.*the discrepancies**

were not attributable to service induced problems and as such~ were technically beyond the scope of the ISi inspections;-

However, since the compreh~nsive nature of the ISi inspectio~s hav~ id~ntified these..

other issues, they have*been resolve The consequence of this,

unfortunately,. is thi:it the !SI system has to deal with these other*

dtscrepancies which potentially detract from focusing on service induced problem The fundamental problem in the system is that there are no.baseline

'ISi. inspections on most of the support With nothing to comp~re to, it is difficult to determine if discrepancies ar~ servJ~e induced problems or lef~ over co~struction issue Given no.basis tn.the contrary,'* the.ISi coordinator has had to assume discrepancies are service induced and has had to expand the ISi sample siz In this s~nse, ~he current program i~ paying the price for the weak ISi

• program of the pas The recordable indications for the 54 supports can b~*c~tegorized as fol lows:

• 4 minor miscellaneous discrepancies; 11 spring can settings out of* tolerance; 12 as-built discrepancies.(mainly spring can size difference~);

11 loose or missing 16cking devices; 11 loose or misaligned clamps or'misadjusted supports; _and 5 inoperable supports due to missing bolts. or. deforn:ied.rod hangers;

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All of the recordable indications classified as.as-built.discrep*ancies were reviewed and found to be insignificant: Deviation reports.were initiated and the design documents were upgrade~ to r~flect the as-built configuratio Wor.k reql.iests*were initiated for all.other

~iscrepancies and the prescribed corrective actions were complete prior to declaring the systems operable for startu Except for the minor discrepancies and loose locking devices, all of the discrepancies

• were reviewed by. enginee_ring for operability consider'cition In most**

cases, _even though the supports were structurally.intact, analyses*

were performed assuming the supports* were not ther In every case, the associated pipiilg system was determined to be "operable" \\'lith the existing deficienc :During: the NRC i~spector's review of the engineering evaluatio~s, it*

was noted that most of the supports ~ss~med to.b~ inoperable could *

have performed*their design function, and therefore could technioally be considered operable._ Based on this, the-:ext.ent of the operability

~valuations was.. conser~ativ 'Hbwe~er~.two concerns were raised during th~ in~pection reg~rding the co~tent of'. these evaluitions a~d the context in which these eval'uations were performe * _ *

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For most of the* supports with dtscrepanci"es, the engineering firm ".

'*associated with the design calculations was contacted to evaluate.. -*

the discrepanc Although most of these discrepancies did. n.ot cause_

the support to be inoperable, there were*at least two instant~s where supports were rendered inoperable.* Supports M-3409-:33 and*

M-1200D-105 hid bolts and nuts completely missing from a *pipe.clam~

and a.~-bolt respectively~

The first concern identified was in regard to the context -in which the evaluations w~r~ performed.* The discrepanci~s were corrected

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through the Work Request system, but the evaluations were not performed under the Discrepancy Record syste According to Procedure

• SPPM VT-3/4-1, Paragraph 5.2.1, supports with a nonconforming condition require an evaluation of the discrepancy in accordance with. Commonwealth Edison Company Quality Assurance Manual, Procedure Q.P. 15-53, uNonconforming Materials, Parts an_d Components for Operations - Inspection and. Test" specifies that a Discrepancy Report be initiated for equipment that does not conform with inspection

requirement This concern was previ.ously identified during a licensee's QA audit in September 198 Refer to Paragraph 2.e. of th~s inspection report for further disposition of this ite The second concern pertained to the content 6f the operability*

t:Vdluatiun* As directed by corporate engineering,". the operability evaluations performed by the consulting engineering firms did not

_consider all design basis load case Instead, the only loads.

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evaluated were those which had actually occurre Using this ~pproach, gravity, pressure and therma 1 loads were considered whereas seiSmi c; LOCA or other design basis loads were not considered~ This li~ited approach verified that the piping system was not damaged as a result of the as-found discrepancy but it did not determine* if the system was operable when the discrepancy existed. This concern was also' *

previously identified durihg the September 1988 QA ~udit. Refer to Paragraph 2.e. of this inspection report for further disposition of this item.. *

This approach is _apparently a corporate policy and therefore will.*

apply to all six C~Co. site The apparent source of this policy is

• corporate en9ineering's questionable interpretation of NUREG-1022~

"Licensee Event Report System - Description of System and Guidelines

. for Reporting".

Page C-10 _of this document discusses inoperable sirnbbers and coritains the statement,.".... snubbers are designed for low probabi*lity.seismic event.sv,ihiC:h did not occur."

Using th as a *basis, corporate engineering cone 1 uded that the* operab i 1 ity evaluatibns di~ no~ need to crinsid~r design* loads which have not occu.rred when determining repodability. This policy, which is inconsistent.\\<Ji th a 11 *prev iou.s Jy encountered interpretations,. has yet to_ be formally issued and is currently *only in draft forn~.~. *

e. * licensee Self-Assessments.

• • The licensee initiated several activities to asse*ss the adequacy an_d effect.iveness of' the Dresden* ISl progra From Qua 1 ity Assurance, QA Audit, Report Number 12-88-33 was conducted onsite in September 198 The NRC inspector noted that several of the audit team members *

had significant ISi experience and as s~ch, provided soli~ technic~l directior:1. to the aud-it team. *The finding and* two open items documented*

during the audit de~onstfated a good working kn9wledge of ASME Section XI requirem.ents on the part of the audit tea The audit finding given in the report had two parts. *Item A stated:

"Component supports requiring corrective actions were not documented on Deficiency Reports when engineering evaluation was required."

Item B stated:* "Specific criteria for evaluation of componen supports requiring corrective action is not documented."

These items are identical to the NRC inspector's two concerns previously discussed in Paragraph 2.d. of this inspection repor *

.The licensee responded to the QA audit finding on September 23, 198 In the response, -the corrective action t_o prevent recurrence was a revision to Procedure DTP-2, "Inservice Inspection Plan".

The revision added a step to the procedure which delineates when an engineering i:valuation was required and when a Discrepancy Record had to be initiate To the extent that it was applicable, this action corrected a portion. of the problem, but it still fell short of a complete solutio The procedure revisibn addre~sed a specific situation wheri the as-built confi~uration would not -Or cotild not be returned to the a designed configuration*.

On this basis, there is a "change" to the design that had to be documente The added step in the procedure assured that this would occur with an appropriate ~ngineering ev_aluation to confirrri its acceptabilit However, the revised

.procedure did not assure that Discrep.ancy Records were initiated-for*

inoperable supports and as such, did not prov id~ for trendfng of the discrepancies, root cause detetminations, notification of appropri~te lev~ls of managem~n~ or corrective actions to preve~t tecurrenc This is considered to be inadeq~ate cor~ective action with regard to the QA Audit Finding Part A and is ao example of a violatirin of 10 CFR 50, Appendix B,. Criterion XVII, "Corrective Actio.n 1i

(237/90021-0lA; 249/90021.:.0lA).

tn ~ simil~~ mannei~ t~e revised procedure did hot provide any documented direction for p~rforming ertgineering evaluations except when the as-built.config~ration* could not or would not be returned to the designed corifi~uratio Fo~ inope~able supports, a determination must be made as to the operability of the sys.tern in the as-found configuratio Not only was there. no,guidance given* as to when these evaluations were to.. be performed,.. but the methodology *

and criteria t.o be used. in these evall,lations was not docum~nted. Since*

this aspect \\vas not' adequately corrected after being cited.in the QA..

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Audit Finding~ Part B, this is consid~red another ex~mple of a

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.. violation of )0 CFR 50, Appendix B, Criterion XVI;. "Corrective*

Action" (237 /90021-0lB; 249/90021-0lB)..

Beyor\\d. the normal. self~assessment activity of a QA aud.it, the licensee had been aggressiveiy pursuing more detiiled reviews to deter~ine the*

adequacy of the Dr.esden ISI prograf1,Initially, a corporate overview of ISI activities was performed at all six CECo station The.intent of this ov~rview was to get a p~eviously unavailable perspective ori how each site conducts ISI activitie~. Eventually, a mtire uniform and consistent approath to ISI is expected from this effor As. a result of this overview, a detailed and comprehensive review of the Dresden ISI program was initiated by the sit Using.an outside engineering firm, a line by line, component by component review of the ISI classification and safety-related boundaries was performed on a P& ID basi Two reports were issued with recommended.changes and upgrades to the scope of the ISI progra The review*efforts were basically a reconstitution of the bases for the ISI program at Dresde The recommendations made by the reports are currently being reviewed by the licensee and any recommendations not followed~

will be appropriately justified. *The NRC inspector considered this review to be a very positive and proactive self-assessment effort.*

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Licensee Event ~~port (LER) Review (Open) LER (237/89029-01):

Elevated HPCI Discharge Piping Temperature Due

to Reactor Feedwater Back.Leakag This*LER documents the October 1989 event in which leakage past the HPCI pump discharge valve and check valve occurre An NRC.Augmented Inspecti6n Team (AIT)'. investigated the event and issued NRC Inspection Reports N ~237/89023 and No. 50-249/89022 with their result Section E of the LER discusses the licensee's immediate and long term corrective a~tions~. Each corrective actipn was assigned a tracking number by CECo's*Regulatory Assurance Departmen The NRC inspector reviewed the

.AIT 1 s'report and confirmed that all of the licensee's *commitments had been entered into the tracking syste *

Of" thE: '27 action items ident'ified by the licensee, items 1-7, 9-10 and 14 were completed and closed out as of this inspection. _The remaining 1 items _are.rnainly outage related repairs' or modificatfons to HPcI*valves. *

• Thes,e*iteins are scheduled for completion during the 1990 Unit 2 outage and 1991 Unit 3* outag Acticiri Item 8 for verification cif HPCI piping integr.ity*using ultraso'nic examination was completed for Unit 3 i Feb.Y'.uary 199 No recordable indications were identifie Comp~rable

.,. examinations for Unit 2 are scheduled for the.*current outag *

One programmatic actioh which :has not.been closed out is the routine.

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monitoring of low* pressure low: temperature to high pressure high te~perature interf~ce b6undarie The lice~s~e has completed an initial review of the LPCI. and core spray systems using thermographic techniques. T~ere were no indications of an~*valv~ back. leakage at *that ti~e. The action item is

• * sti 11 considered open because a long term program has not yet bee d_evelope lhe licensee is incorporating these pressure isolation valve

. interface reviews into.a much broader thermograph1c i'nspection progra This broader program is currently being developed but no firm date ~as given for completio *

Pending completipn and review of the outstanding action items, thi~ LER is considered ope.

Review of Piping Analyses During a followup inspection to address concerns about the HPCI event

. ~valuation, the following analyies were reviewed by the NRC inspector:

0 Impell Calculation, D2 HP~I Operability Evaluation, Revision 0,. *

February 23, 199 Impell Calculation, D2-HPCI-02C, Revision 10, February 23, 199 *r*"

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lhe first analysis evaluated the operation of th~ HPCl system ~t elevated t~mperatures due to the valve backleakage with the as-found conditi.on of the degraded pip~ support This was an historical evaluation since all of the degraded *pipe supports had been repaire A te~perature of 350°F

.. WdS assumed for.the portion of the pipe within the steam tunnel *and a temperature of 275°F was assumed for the rest of the *discharge pipirig.

. The first iteratiOn of the analysis concluded that a t.wo-way restraiilt would exceed its operabili.ty capacit A subsequent analysis demonstrated that withou.t that support; the system still met the established operability*

criteri The second ana.lysis established the basis for ir:it~rim* operation of the HPCI system with the revised valve lineup *.. Ch9nges to the design basis analysis were not required sirtce ¢~sign pressures were used over the length_

of the HPCI discharge line.. The thermal load case was not modified:. *

.*because theelirilir1atibn of the system backflow preventedheatiilg of the lin The analysis List:d an operating.temperature of 165°F for piping outs.ide the steam tunnel *area*:

.*Nu violationi or de~i~tions were noted during th~ reviews of* these*

analyses..

Exit Interview-The Region III ins*pector. met with the licensee representative,s {denoted *in*

• Pardgraph: 1) at the conclusion of the inspection' on October.11, 1990..

The irrspector summarized the purpose and finding's of,.the'.inspection.. Tti'e licensee representatives adnowledged this informatio The inspector also discus~ed*the likely information content of the inspection report with regard to documents or processes reviewed during the inspectio The. licensee representatives d_id nut identify any such docum~nts/processes*

as proprietar *

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