IR 05000237/1990027

Insp Repts 50-237/90-27 & 50-249/90-26 on 901117-1229. Violations Noted.Major Areas Inspected:Previously Identified Insp Items,Ler Followup,Plant Operations,Maint/Surveillance, Engineering & Technical Support

ML17202U960
Person / Time
Site:	Dresden
Issue date:	01/17/1991
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17202U958	List: IR 05000237/1990027 ML17202U957 ML17202U959
References
50-237-90-27, 50-249-90-26, NUDOCS 9101280062
Download: ML17202U960 (25)

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U. S. NUCLEAR REGULATORY COMMISSION REGION I II Report No f90027(DRP); 50-249/90026(D*R-P)

Docket Nos~ 50-237; 50-249 License.No DPR-19; DPR-25 L i.censee.:. Conurionwea lth Edi son Company P~ 0. Box 767 Chicago, IL 60~90 Facility Name:

Dresden _Nuclear Power Station, Units 2 *and 3 Inspection At:

Dresden Site, Morris, IL I

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Insp.ection Conducted:

November 17 _through December 29, 1990 Inspectors:

Approved By:

Hills Peck

... 1//7/'l/

.Date Inspection Sununary

• Ins ectioh durin the December 29 1990 eport o.

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Areas Inspected: Routine unannounced resident inspection of previously identified inspection items, licens~e event reports followup, plant operations, maintenance/surveillance, engineering/technical support, safety assessment/quality verification, systematic evaluation program items and report revie.

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Results:

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Two violations were *identified. for which Not1ces of Violation are being issue One dealt with a failure to fdllow procedure in regard to maintenance practices on 10 CFR 50 Appendix R emergency lighting batteries (paragraph 2).

The other involved.a failure to report to the NRC an fngineered Safety Feature (ESF) actuation in accordance with 10 CFR 50.72 (paragraph-4.e).

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9101280062 910117 PDR ADOCK 05000237 I..

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• . Five violations were identif;ed for which Notices of Violation are not being

. issued in accordance with the exercise of discretion delineated in 10 CFR 2, Appendix C, Section V.A.or V.G.1. *These involved a failure to adequately

control the* status.of under ves.sel platform co.vers such that a source range monitoF (SRM) was subsequently damaged during movement (paragraph*2), a

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• failure to follow procedure involving radiation prbtection practices

• .(paragraph 4), a failµre to follow procedure regarding a main steamline plug installation such that a small portion of _the reactor cavity drained to the

-~rywell (paragraph 5.a), a failure to maintafn records for a.standby gas**

treatment system (SGTS) *written safety evaluation (paragraph*5*.b} and a fa~lure to post a proposed imposition of a ~ivil penalty (paragraph 7.c).

Six unres_o.lved items were also identified. the inspector's identification

• that the service air supply to three of the. Unit 3 drywell purge an~

ventilation fan dampers had been "disconnected is pending review of system design and the role of the operators in the event (paragraph 4.c). The failure of electrical wiring diagram 12E2697 to. reflect actual plant configuration which resulted in an unexpected ESF actuation is pending review of licensee corrective actions (paragraph 4~e). The inspector's identification of the licensee's usage of a temporary pump and hose assembly to augment filtering of the reactor cavity water during refueling without a procedure or temporary alteration is pending further review of safety implications and 10 CFR 50.59 aspects *(para9raph 4.f). Failure of a primary containment.integrated leak rate test 1IlRTJ due to a leaking torus to reacto~

building vacuum breaker is pending review of the adequacy of post-maintenance testing (paragraph 5.b). The failure to obtain a technical specification change and initiate ~orresponding surveillance calibration requirements for a modification to the generator load reject scram on turbine control fast closure is pending further review of 10 CFR 50.59 implications (paragraph 5~c). Inspector concerns regarding conformance to Generic letter 82-12 guidelines on overtime is'pending review of further plant* ~taff groups

{paragraph 7.b).

Plant Operations

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A review of the Operations Department in regard to overtime policy indicated that inst~nces of exceeding Generic letter 82-12 guidelines was minima However, certain concerris were raised in that fuel-handlers, except for the fuel handling supervisors, were not included and the level of approval for exceeding the guidelines* delitieated in administrative procedures did not appear consistent with Generic L~tter 82-12 inten.

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The inspectors noted th~t general housekeeping and contamination control had deteriorated during the Unit 2 refueling outage as compared to recent previous refueling outages.. The licensee* planned to implement a_ new material condition/housekeeping/safety inspection program in January 1991..

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• I Maintenance/Surveillance Two inst~nces of failing to follow procedur~ inv6lving maintenance personel were noted. These involved maintenance practices on 10 CF~ 50 Appendix R emergency lighting batteries and main steam line plug installation. However, both actually occurred prior to licensee corrective actions to address

personnel pe~formance problems delineated in inspection report 50-237/90023; 50-249/9002.

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A review of the Maintenance Department° in regard to overtime policy indicated.*

• that instances of exceeding Generic Letter 82-12 guidelines was minima Engineering/Technical Support Subsequent to the Notice of Violation and Proposed Imposition of Civil Penalty dated November 28, 1990 involving a IO CFR 50.59 violation, the inspector identified concerns which indicated additional poor past practices regarding the licensee's safety evaluation proces For example, a failure to maintain records of a written safety evaluation involving SGTS is identified as a non-cited violation *. In addition, two unresolved items needed further review wiih regard to 10 CFR 50.59 requirement These includ~d a failure to obtain a technical

• specific~tion ch~nge regarding a ~odification to the generator load reject scram function.and the use of a temporary pump and hose assembly, without a safety evaluation, for the reactor cavity water filtering syste The root causes associated with the failure to post a proposed impostion of a civil.penalty were repetitive to the cause of a previous violation involving a failure to ensure personnel were properly* trained on specific administrative requirement The licensee already had plans to address this concern with a new administrative.requireme~t training program to be implemented in the spring

. of 199 The inspectors noted that staffing of *the plant.Technical Staff had increased substantially. Staffing was regarded as a weakness in the last Systematic Assessment of Litensee Performance (SALP) perio The licensee.did not apply the Generic Letter 82-12 guidelines on overtime to the plant technical Staf Instances were identified where these guidelines were exceeded, most notably during the refueling-outage wi~h the ins~rvice testing/inservice inspection group~,.No problems were_ noted_ during non-refueling outage. period Safety Assessment/Quality Verification The inspectors noted that the rate of events*indicative of personnel performance problems decreas~d substantially duting the second half of the Unit 2 refueling outage as a result of licensee management actions delineated in inspection report 50-237/90023; 50-249/90023 *

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DETAILS Persons *Contacted

• commonweal th Ed is on Company

• E. Eeriigenburg, Station M~nager

• L. Gerner, Technical Superintendent t. Mantel, Services Director *

• D. Van Pelt, Assistant SL!perinte*ndent - Maintenance

• J. Kotowski, Production Superintendent.

J. Achterberg, Assistant Superintendent - Work Planning

• G. Smith, Assistant Superintendent-Operations

• K. Peterman, Regulatory Assurance Supervisor M. Korchynsky, Operating Engineer

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B. Zank, Operating Enginee~ 1 J. Williams, Operating Engineer R. Stobert, Operating Engineer M. Strait, Technical Staff Supervisor L. Johrison, Q.C. Supervtsor

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J. Mayer, Station Security Administrator

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D. *Morey, Chemistry Services Supervisor '*

D *. Saccomando, Health Physics Services Supervisor K. Kociuba, Qua,] ity Assurance Superintendent *

• D. Lowenstein, Regulatory Assurance Analyst

• J. Harrington,- Nuclear Quality Programs Inspector

• G.. Kusnik, Quality Control Inspector

• D. Booth, Master Electrician

• C. Oshier, Lead Health Physicist

• R. Whalen~ Assistant Technical Staff Supervisor

• D *. ~ulati, Master Instrument Mechanic

The inspectors also talked with and interviewed several other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, and contract security personne *Denotes those attending one or more exit interviews conducted informally at various times throughout the inspection perio

• ~reviously Identified Ins~ection Items (92701 and 92702)

(Closed) Vi.olation (50-?37/89022-02): **A penetration in a three hour fire rated wall of the reactor building was not included in design documents,*. -

and modifications were not controlled as requ.ired by the licensee's fire protection plan which was implemented i.n accordance with 10 CFR* 50.48(a).

The inspector performed visual observation and reviewed documentation to

, verify :,that appropriate corrective actions were* implemente The inspettor has no other ~oncerns in this area *

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. (ClosedJ*Op~n Item (50~237/90009702):.The i~spector Visually verified th9t the problem related to legibility of the medium *range drywell *

pressure strip chart recofder indicator scale had.been co~rected. The inspector has n6 other concerns in this are * *

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• {Closed) Unresolved Item (50-237/90023-04):

Concern regardihg. the -

discovery of damage to the 'Unit 2,.SRM 22, following the suspen~ion of core alterations on November 12, 199 The damage resulted when the SRM was withdrawn during an instrument response chec~ and the drive mechanism came in*co~tact with an*tind~r vessel ~latform access hole cove The contact with the access cover resul~ed in the SRM beco~ing dislodged approximately three feet below the fully inserted position. Subsequent to the damage, fourteen fuel bundles were loaded into the SRM 22 core quadrant. Technical Specification 3.10.B. required SR~ 22 to* be operable and fully inserted to the normal operating level in the core during ~ore alterations in that quadtant of the reactor vessel~ Review of licensee fuel handling records revealed that SRM 22 did indicate the expected neutron response during fuel movement while the instrument was in a degraded cond~tio On November 6~ 1990, work was complted under the Unit 2 reactor to

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install new SRM probe connectors per Work.Request (WR) 9543 Durin~ the probe replacement, platform access hole covers were utilized to minimize the potential for personnel injury.during the under vessel wor The work instructions accompanying WR 95435 did not address or control the use of the platform access cover However, a hand written memorandum was ~ssued to all instrument maintenance. (IM) supervisors req~iring that the access covers.be remo.ved prior to the withdrawal of any of the SRMs for the performance of the.instrument response check. Additionally, a caution tag was placed in.the control room instructing the operator not to withdraw the SRMs without first receiving permissio*n from the IM supervisor. This same methodology was utilized without incident during the previous Unit 3 refueling outag On November *12, 1990, operations personnel received erroneous permission from the IM supervisor prior to the ~ithdrawal and subsequent damage to SRM 2 Tri prevent ~ecurrence of this event, the licensee planned to tevise the applicable procedures to control the ~se of platform access covers Under the Out-Of-Service progra..

The failure to provide.adequate measures t"o prevent inadvertent operation*

.of the SRM drive~ in relation to the status of the platform covers is.

considered to be a violation (50-237/90027-0l(DRP)) of 10 CFR 50, Appendix B, Criterion XI However, the ~riteria of 10 CFR 2,.

Appendix C,Section V.G.l; for discretionary enforcement was*determined to be applicable and, therefore, no notice of violation is being issue The,tn~pector ltas. no further concerns i~ this are *

(Closed) Vnresolved Ite~ (50~237/89013-02(DRS)}; 50-249/89012-02(DRS)):

The lic,ensee indicated.that the fire fighting foam concentrate shelf life would be verified and, if testing_ is required, it would be schedule Ac'cordirlg to the licensee action item report -(Item Number 237-100-89-01302)

the licehsee had replaced the foam ahd.had initiated Dresden Fire Protection Procedure (DFPP) 4114-07, "Annual Fire Fighting foam Sampling." The inspector's review of the procedure found it to be acceptabl Based on the licensee's actions, this item is considered close {CJosed) Unresolved Item (50-237/88010-b3(DRP); 50-249/88012-03(DRS)):

The simultaneous ipurious opening of the Target*Rock Valve and Electromatic Relief Valves has a tremendous impact in reactor coolant

.. inventory based on the limited capacity of the. Contro'l Rod Drive ( CRD)

Hydraulic System to restore or maintain reactor coolant inventor Due to the significance of this issue and its generic implications, this issue was referred to the Office of Nuclear* Reactor.Regulation (NRR) for resolutio NRR Safety Evaluation forwarded by letter dated July 6, 1989, from B~ Siegel, NRC~ to T. Kovach, CECo, accepted the licensee's modification to install two new control cables in a separate tray to rectify the potential that existed for fire induced multiconductor cable fault in two control cables associated with Unit 3 Target Rock Valve and Electromatic Relief Valve The licensee provided the inspector with modification close out form (Number M12-3-88-24) that indicated that the work of installing two new control cables in a separate tray was comp.lete This item. is considered closed~.

• (Closed).Unresolved 1tem (50-237/90023-06(DRP)):

The inspectors identified six Appendi.x "R" emergency lights with the electrolyte level below *the add line. Dresden.Electrical Surveillance (DES) 4153-02,

"Emergency Lighting Month.ly Inspection", stated that "Electrolyte level shall be at the full line".* However, contrary to the established*

• procedure, *the liGensee.indicated _that a practice had been followed such that the,emergency lights need only be fil.led-when the* electrolyte level was at or belo~ the add line. The licensee further indicated that also contrary to the.established procedure~ the.determination to add distilled water was at the discretion of*the mainte*nance personnel *. Conversations with the emergency light vendor and review*of.the v~ndor technical manual indicated that allowing th~ electrolyte level to fall below the add line could cause damage to the batter *

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(iteniee follow-up of the October 19, 1996, irispector observations identified extr,emely low or empty electrolyte levels in the.following.emergency lights:

Emergency Light Number

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271 274..

27 A 352 Electrolyte Level Empty Empty Empty Empty Extremely Low Jhe licensee's response to this unresolved item 'dated.December 14, 1990, from T. J.. Kovach, (CECo), to A. B. Davis, (NRC), *contained a deviation report (12-2/3-90-123) which inC:luded an event summary, root causes and corrective actions (which included replacing several emergency l_ights)

for Units 2 and 3. *Based on our review of this report and supporting documentation, it was determined that due to the number of emergency lights Dbserved With extrem~ly low or n6 electrolyte, and.the lack of adherence to the emergency lighting inspection procedure that this*

unresolved item has been. upgraded to a violation (50-237/90027-02(DRP))

• .of Technical Specification Section 6.2. *Based on prompt and thorough action to prevent recurrence and commitments to revise the emergency lighting procedure, no response to this violation is required and the NRC has no further questions regarding this matte Administrative Closure of Items NRC Region JII management reviewed the existing open items for the Dresden Station and determined that the following open items will be closed administratively due to their safety significance relative to emerging priority issues and to the age of the ite The licensee is reminded that commitments directly relat.ing to these open items are the responsibility of the licensee and should be met as* committe NRC Region III will review licensee actions by periodically sampling administratively closed item /84027.:.01 50-237/85003-BB 50-237/87M6-03

.50-237 /89022-0l'

.~50-*249 /85003-BB One cited and one non-cited violation and no devi~tions were identified in this are * Licensee Eve~t Repo~ts (LER) F~llowup (90712 and 92700)

Through direct observations, dis.cussions with.licensee personnel, and review of r:-ecords, the fo 11 owing event reports were reviewed to determine that reportabi l ity requirements were fulfil led, immediate corrective action was accomplished, and corrective action to prevent recurrence had b-een *accomplished in accordance with.Technical Specifications. * *

... (Closed) LER *(237/90006(DRP)): Target Rock: Safety-R.elief Valve Failed Ope Thii event and correspondin9 corrective actions were di~cussed in inspection report 50-237/90019(DRPJ; 50-249/90019(DRP).

(Closed) LER (237/90007(DRP)):

Unplanned Primary Containment Group V Isolati6n. This event and corresponding corrective actions were

~is~ussed in_ inspection report 50-237/90019(DRP); 50-249/90019(DRP).

(Closed) LER *(237/90008.(DRP)):

Failure of HP.CI Steam *Line High Flow Isolation Differential Pressure Transmitter. This event arid corresponding corrective actions were discussed in inspection report 50~237/90019(DRP); 50-249/90019(DRP).

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(Closed) LER* (249/90006(DRP)):

Failure to Establish Appropriate Fire Protection Due to Procedure.Defi.ciency. This event and corresponding corrective actions were discussed in inspection report 50-237/90017(DRP);

50-249/90017(DRP).

(Closed) LER (237/90012(bRP)).:

Fuel (6ad Core Monitoring Requirements Violated Due to Management Deficiency. This event and corresponding corrective acti-0ns are discussed in paragraph 2 of this repor No violations or deviations were identified* in th.is are.

Plant Operations (61715, 71707 and 93702) *

The inspectors observed control room operations, reviewed applicable logs*

• and conducted discussions with. control room operators during this perio The inspectors verified the operabi 1-ity of.selected emergency systems, re.viewed tagout records an.d 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 e~~essive vibrations and to verify that maintenance requests had been initiated for equipment in need of mairitenanc The inspectors rioted th~t general housekeeping and contamination crintrol had~deteriorated ~uring th~Unit 2 refueling outage as compared to recent* previous refueling outage The licensee planned to implement a new ma.terial condition/housekeeping/safety inspection program in January 199..

The inspectors identified that a licensee Quality Control inspector failed to don the required protective clothing while performing a hold-point inspection in a contaminated ar~a contrary to the requirements of Dresden Administrative Procedure (OAP} 12-25, "Radiation Work *Permit Process," Steps E.* 6 and F.1.e.5*, and Radiation Work Permit (RWP) OG067A, *

on*Oecember 3, 1990 *. * The individual subsequently became contaminated and alarmed the Personnel* Contamination Monitors (PCMs) when attempting to leave the Radiological Controlled Area (RCA).

Following receipt of the PCM a la rm, the individual' fa.iled to con.tact the Radiation Protection Department (RPO)~ per the requir~ments of OAP 12-13, "Personal ~xternal Contamination Surveys~" Step F.8.f,.and proceed.ed to perform self decontaminatio Fai~ing to foll~w the requirements of OAPs 12-13 and 12~25 in regard to radiation protection practices is considered to be a violation (50-237/90027-03(DRP)) of Technical Specification 6.2.B which required adherence to radfation control procedure~. Following a

discussion of the incident.with the inspectors on December 4, 1990, the individ:ual then notified the RP The RPO documented.the incident and completed the *appropriate corrective action of counselling the individual involved as to the proper health physics practices at the Dresden

Statio As this was considered to be an isolated occurrence, of minimal safety significance*and*the appropriate corrective action had been completed, a Notice of Violation is not being issued in accordance with 10 CFR 2, Appendix C~ Sectioh V.A~ The inspector has no further conce~ns in this are *

Each week during_ routine activities or tours, the inspector monitored the licensee's security program to ensure that ob.served actions were being

. implemented according to their approved security pla The inspector

• noted* that persons within the protected area* displayed proper

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photo-identificati6n badges and those individuals requiring escorts were

• properly ~scorted. The inspector also verified that checked vital areas were locked and alarmed. Additionally,._ the inspector also verified.that observed personnel and packag.es ent~ring th.e protected area were searched bY, appropriate equipment or by han.

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The inspectors performed a detailed walkdown of the acce~;ible portions of the Unit 2 containment *spray -system (CSS), which is a subsystem of the low pressure coolant injection* (LP.Cl) system *. The inspectors concluded that the CSS was. prop~rly aligned and in adequate condition. The inspectors.*

verified the pro~er positioning of.numerous is~lation*valves and electrical barriers in containment penetrations *. * In addition, the inspectors performed a walkdown of th~ drywell with licensee *personnel to ensure that material and equipment utilized duri_ng the refueling outage was

• properly removed*or* setured:

The inspectors reviewed ~elected new procedu~es and ch~nges to procedures that were implemented durin.g the inspec:tion.period~ The r.eview consisted

,,q.f.a veri,fication for.accuracy, correctness, and.compliance with regulatory reqli i rement *

The inspectors verified tha:t-the licensee_ had implemented contr'o.ls to

assure guidelines presented in Generic.L~tter.82-12, 11 Nuclear Power.Plant Staff ~orking Hours 11 were followed for licensed operators.. These

r*estrictions were delineated in DAP 7-21; 11Station Policy o*n Reactor Operatdr and Senior Reactor*Operator Manning Levels.and Overti~e,

Revision 1,.which conformea;o :the Generic Letter.. The licensee had *alsd eitended.these guidelines t~ Level 1 equipment oper~tors in*accord~nce

- with the licensee's Nuclea*r Operations'Directive ('NOD)

OA~13, "Overtime Guidelines.

The licerisee ~id riot apply these guidelines to Level 2'

equipment operators because.' thei were not invo-lved :in safety *related work.* Although the li~ens~eindicated th~ guidelines were applied to th fuel handling.supervisors, the fuel hand le rs t.hemse l ves wer*e not *covere ~.~.

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• The licensee*.had developed an in-house* comput~r program which operations engineering *assistants utilized to track hours worked. and* to assure the. *

guidelines were met.. The licensee. identified*-four cases during the year of 1990 where these o~~rtime guideli~es had been exceeded~ Only one of these had bee*n pre-approved by management in accordanceJwith *OAP 7-2 The others involved administrati~e errors,_one of which occurred~. *

subsequent to utilization o'f"the computer tracking program 'implemented to correct the.se error*s and resulted from a *fai'lure of *operations engineering assistants to_ promptly enter -hours: into the compute '

Licensee corrective action* involved couns~ling of*the engineering assistants on the event to ensure.prompt data entry.. There had *been no identified occu~rerices since thai crirre~~ive actio r *

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The. inspectors noted that"DAP 7-2L required pre-approval to e">cceed the

• overtime guidelines by_ the* Assistant Superintendent.Opera.t-ions or his

• designee._ The licensee :indicated that th,is designee \\'fas.the Operating

• • Engineer jn charge of personne However:~ Generic_ Letter 82-12 indicated*

that such-deviation be authorized by* the plant manager or his deputy or

,higher lev~ls of managem~nt. The Station Manager was ~equired to review and sign: the Overtime De~iation*Authorization for~ only subsequent to th overtime being worked.* The.intent.was thaf only Senior Man~gernent be able to authorize rii~jor deviations from the overtime guideliile At Dresden the pre~authorization prescribed in the~dministrative procedures was from two supervisory *levels.below t~e plant manager with a P.ossibility for a *

designee at three levels below the plant ~anager. Therefore, this practice did not appear to meet the intent.of the generic lette However, the one instance where.pre*-approval was giyen in 199.0* was by the P~oduction

Superintendent, one level below the plant'~anager, which.appeared.cqnsistent

.with the Generic Letter 82-~2 gtiidelines *.

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Inspector* concer~s *resulting from this revi.ew arid comparison to.licensee

/commitments with respect to overtime guidelines are discussed i paragraph *

Various pperational.occur~ences w~r~ also reviewed as follows: On flovember 23, 1990, with Unit 2.shutdown in a refueling outage, a

• scram was received due* to noise.spikes.on Intermediate Range Monitors (IRM} 13* and 15. All SRMs aQd IRMs actually received spike At the time, one cor:itrol rod was pa.rtially withdrawn for testing. The.cause was tdentified to be a voltage spike due to a faulty relay in the control logic for* the !.:ow Pressure Coolant*

I.njection (LPCI) syste The relay was replaced.* A similar occurrence with IRMs spiki~g high occurred on December 20, 199 The licensee has continued to investigate the cause of the spiking problem *

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On November 27 1990, Unit 3 entered a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limiting condition for operating (LCO) in accordance with Technical Specification 3~7. due to a failure of Nitrogen Makeup Valve A0-1601-5 During the nitrogen makeup surveillance, this valve.failed to close completel This was of concern since this valve also served as a containment isolation valve. Technical Specifications* would have allowed closing other valves upstream of this line to provide the isolation function such that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> tCO would not have been entere However, one of these valves, A0-1601-58, was in.the pumpback system which provided drywell/torus differential pressure control. Since closing this valve would have caused difficulties in maintaining the required differential pressure, it ~as left open and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO was entere However, repairs were completed prior to actualJy initiating *a shutdow During a plant walkdown on December.?, 1990, *the.inspectors.. noted that an access door to the Unit 2 drywell purge and ventilation system downstream of ventilation fan 2-5708A, was open about one to two inche As. this formed a port.ion of the. secondary containment isolation boundary, the concern was that this provided approximate.ly a 72 square inch hole from *the' turbine ~uilding through this

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boundar As described in paragraph 6.b., although Unit 2 was in a refueling outage, the current SGTS lineup would cause suction to be

.drawn from'this area. even if the actuat1on was on Unit 3. *It was not clear whether this breach was large enough to prevent f.ulfi llment of SGTS function (i.e., the"abil ity to pull a 0.25 inch differential pressure to the atmo$phere in secondary containment.)

The licensee ran the system with the access door in the as-found

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condition' to ensure*thaf had the SGT*s been called upon, the suet.ion created in the ductwork would have pulled* the ~cces~ door shu As such, the inspectors ascertained that th_e operability of SGTS was

, not affected by -the open access doo No apparent cause cou_ld be

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• The inspectors a*lso note_d o.n December 7, 1990, that the Service Air

.Supply to three of the Unit-3 drywell purge and ventilation*fan

.dampers had been disconnected..

No temporary alteration tags were attached to the air lines or to the dampers' operators. Following notification to the licehsee, the. licensee reconnected the airlines to the dampers which changed position from open to close (The system was not in operation*_at th~ time~)

A revie~ of Dresden* operating Procedure (DOP) 6600-1, "Normal Venting of Drywell and Torus", Revision 5~ indicated that it require~ disconnectfon of the air operators on the drywell purge fan inlet and outlet dampers and blocking or tieing the dampers in the*

open_position prior to the operation. This was necessitated since the dampers automatically opened and closed in conjunction ~ith fan operation and the fan was not actualiy o~erated in this procedur A*step was also included to retonnect the air operator and unblock or untie the dampers when the operation was complet A review of the operating history of this system indicated that it was *last used for venting Unit 3 OR December 5~ 1990, for containment pressure control. This should.have been performed in accordance with DOP 6600- However, lt was questionable whether step E.1.b(2) was followed in that the air supply was found disconnected~ _This is considered to be an unresolved item (50 7237/90027-04(DRP)) pe~ding further review

. of operator involvement and safety significanc On December 8, 1990, while Unit 2 was in the refuel mode, eight

. *Group II automatic primary contai.nment isolation valves closed following the lifting of a field ~ire on a main control room terminal bloc The lead was lifted to facilitate* a resistance an me~gering check of the Main Steam Isolation Valve (MSIV) pilot solenoid cdils, per DES 200-39, "Main Steam Isolation Valve Electrical Maintenance." Further review indicated that an interruption of*multi~le neutral gro~nd circuits occurred when the lead was lifted. This resulted in a loss.of power to the associated

.seal-in relays, which maintained each of the -affected Group II isolation valves in their open positions *. Electrical wiring diagram 12E2697 indicated that the neutral ground circuit was *.

design~d to be wired,- in daisy chain fashion, on the _cabinet side of the respective *terminal bloc The drawing also showed four leads terminated on the cabinet side of the effected terminal point *

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accommodate :a maximum. of three leads...In apparent compensation for this design deficiency;. one of the four wires*, the neutral ground circuit for.the Group II valves, wai.placed on the field side -0f the terminal block, sharing :the same connection p,oint as the* MSIV pi lot solenoid coil *

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QES 200-39-matched the configuration as described on Diagram 12E269 When DES 200-39 was performed, the electrician found two leads on the field side ter~inal p9int. *The -lifti~g of the second lead resulted in the valve closure. The apparent root cause of the eveht was a discrepancy between the plant configuration. and the "as-built" drawing A rev*iew of past revisions to Diagram 12E2697 revealed_

that the origtnal plant de~ign tonfiguration also specified the

. termination of four leads on the cabinet side of the terminal block point. -Based on the physical limitations* of the cabinet side terminal block point~ the undocumented wiring tonfiguration was estimated to*

have existed since initial plant startup.. This is consider~d an unresolved item (50~237/90027-0S(DRP)) pending NRC review of licensee

• corrective action The licensee failed' to recognize that closure of the Unit 2 Group II containment isolation valves was an ESF actuation and also failed to make the four hour report to the NRC as required per 10 CFR 50.7 The licensee indicated that the rationale for not reporting was that the loss of power occurred in the control circuitry and not the logic circuitr In other words, the logic circuitry did not de-energize to open a corresponding contact in the control circuitry to cause the closur As such, the licensee did not classify this as an ESF actuation. The 1 icensee based *this distinction on NUREG 1022, "Licensee Event* Report System,"Section V, which stated. the following:

Actuation of mult,ichannel ESF Actuation Systems is defined as actuation

_of enough channels to complete the.minimum actuation logic ( activation of sufficient chann~ls to cause activation of the ESF Actuation System).

T~erefore, *single.channel actliations, whether caused by failures or. otherwise, are* not reportable if they do not complete the.minimum actuation logi,-,

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It was evident that the li'censee had inferred a meaning that was not intended nor supported by the other *portions.of* NUREG 1022 or its *

supplement The paragraph noted by the licensee w~s.intended to *

specifically explain the non-t"eporta~i'lity of.*single channel actuations versus**multichanriel-actuations. *No further meaning can be inferred and, iri fact, this.paragraph made rio.attempt to define

• the logic portion of* the circuitry. as separate and distinct fro*m

. other portions of the actuation circuitry (i.e. control circuitry).

Section IV of NUREG 1022 provided* a* restatement of the guidance for 10 CFR 50.73 from the statement of consideration which indicated that the criteria were based on the nature, course and consequences of the e~ent and not 6n initiating events or.causes of event In addition,Section V of NUREG 1022 indicated that the NRC was interested in both events where an ESF*was needed and events where an.ESF operated unnecessarily since they should not be.challenged frequently or unnecessarily;

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10 CFR 50.72(b)(2)(ii) specifically.required the* reporting of any condition that results in a manual or automatic actuation of any Engineering Safety Feature (ESF).

Additionally, 'NUREG-1022,

"Licensee Event Report' System," Supplement No. 1,Section II.6,

. clarified that an ESF actuation includes any automatic, spurious, or manual action that results in the actuation of the device to perform its intended functio In the case of the Group II-isolation valves, the intendeq ESF safety function was the automatic closure of the valves. All ESF actuations were required to be reported (except those expected actuations that result from and w.ere part of preplanned sequence during testing)..

The~failure to make the required report was considered to be a violation (50~237/90027-06(DRP))

of 10 CFR 50.72(b)(2)(ii). Following receipt of upper motor guide bearing high temperature and high vibration alarms on recirculation pump 38 on December 15, 1990, both recirculation pumps were reduced to minimum spee Recirculation pump 38 was shutdown and it's car.responding suction valv.e was closed in accordance with Technical Specifications. Total power reduction during the event was froin about 95* to 25 percent

• rated thermal power.. The unit remained in single loop operation at the end of the,inspection.perio On December 22, 1990.a drywell entry was made to visually examine the recirculation pump motor, take oil samples and ch,~ck :a pump motor vibration s_witch. **During the subsequent local leak rate. test (LLRT) on the drywell personnel

. interlock doors on Dec~mber 23, 1990,.the inner door seal faile *Unit 2 was shut down, the seal was repafred and Unit 2 wasretu.rned to seryice on December 26~ 1990 *

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In the course of observing refueling qperations on November 18~*

1990, the inspector noted that.a temporary vacu_um pump and hose assembly we*re utilized to augment the filtering capability of the fuel pool clean..:up system. This temporary vacuum pump was sjtuated on the top;guide of the reactor vessel and pumped refueling water through a hose which_exite(! the drywell cavity, ran several feet

• across the refueling floor, entered the refueling pool, and led to

.the fuel poo*1 skimmer. surge tan Various concerns were identified including; (1) whether the use of the pump was controlled by procedures or as part of a temporary alteration/modification program, (2)" whether consideration was given to the possibility of rupturing the vacuum hose and lowering the level in the refoeling pool, and* (3) the *

availability of indicators and alarms for the refueling pool leve This is* considered a_n unresolv.ed item (50-237/90027-07(DRP)) pen~ing

.further review in regard to these concern One cited and one non-cited violation and no ~eviations were identified in this-~re *

• Maintenance and Surveil.lAnces (62763, EI726, and 93702) Maintenance Activities Station maintenance activities of systems and components listed below were observed or reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or st'andards and* in conformance with Technical Specification The* following items were con'sidered during. thfs review:

The Limiting Conditions for'.Operation (LCOs) were met while components or systems were removed from service; approvals were obtained* prior to initiating the work; ~ctt~ities were accomplished using approved procedures and were i_nspecfed as applicable; functional testing and/or ~alibratio~s 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 were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is* assigned to saf~ty-related equipment maintenance which may affect system performanc,.

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Environmental Qualification Preventive Maintenance on the

. U~it 2 High Radiation Sample Target Rock Solenoid Valve Environmental Qualification Preventive Maint~n~nce on the Unit 2 Main Steam:Isolation Sblenoid Valves.'

Unit 2 SRM. Cable Routin Pl~~t-Process Pipe ~abelin Calibration of the Unit 2 Turbine C6ntrol Valve Pressure Switche..

On November 21, 1990, during performance of an LLRT, clean de-min.eralized water (CDW) was secured to.the Unit 2 drywell. This

• caused a plug in ~ain Steamline (MSL) "A".t6 deflate and provide a drai.npath from the reactor cavity._ (The reactor cavity was flooded above the main steamlines at the time.). As the corresponding inboard MS IV had been removed for m.a i ntenance," leakage entered the drywe 1 This was discovered while investigating the receipt of multiple drywell s4mp level *alarms in a short perio Up to one inch of cavity level was lost during the even Further revie~ indicated the cause to be a failure to follow procedure during MSL plug installation on October 13, 199 *

The work package for thjs activity prescribed installatfon in accordance with Dresden Maintenance Procedure (DMP) 200-31, "MSL Plug Installation and Removal~". Jhe,pr6cedure prescribed inflation of the seal with servic~ air.*

H~wever, upon.completion it was noted that air leakage cau.sed bubble to form in the reactor cavity which obscured fuel handler vision. The maintenance supervisor, havi~g been reminded that CDW had in the past been used to inflate the

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seals, had the source switched. to CDW, contrary to procedure requirements and without informing appropriate management., As

,outage planning was predicated on the.ass_umption that the inflation source was in*accordance with the procedure, the LLRT was allowed t6 commence on.the~DW lin In fact, the LLRT on the

Service*Air Line had ~een purposely postponed so as to not affect the seals. Failing to-follow the procedure is considered to be a violation (50-237/90027-0B(DRP)) of 10 CFR 50~ Appendix B,

Criterion ~owever, this.event was'indicative of, and in the same time frame as-the-types of problems encountered di.iring the first part of the current Unit 2 ~efueling outag The actual.failure to

. follow procedure occurred prior to the corrective actions taken by plant management as.des.cribed in inspection.report 50-237/90023; 50-249/90023.to address these problem As such, this event, had it been discovered in the previous inspection period, would haYe been

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included as ~n additional example in the corresponding notice of violation issued with that repor As** the licensee had already

. taken appropriate cor.rective actions *to address this type of concern, a Notice of Violation *is not*being issued in accordance with exerc~se of discretion d~lineated in 10 tFR 2, Appendix C,Section V. *

. Surveillan~e Activities I

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Ttie inspectors observed* *surveillance testing, including required Technical Spe'Cification -surveillance testing, and verified for actual activities observed that testing was performed in accordance with adequate p~ocedures. The inspectors also verified that test instrumentation was calibrated, that Limiting Conditions for

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Operation were met 1 that removal and restoration of the affected components were accomplished and that.test results conformed with Technical Specification and procedure requirements. Additionally, the inspectors ensured that the test results 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 6r.~eviewed portions of the following test activities:

Nuclear Instrumentation Surveillance Reactor Vessel Leakage (Hydrostatic) Test Standby Liquid Control Inservice Testing Control Rod Drive Friction Testing*

Single Reactor Recirculation Pump Operation Surveillance Control Rod Drive Insertion Timing On December 17 ~ 1990, the Unit 2 torus to reactor bu.ilding vacuum breaker (2-A0-1601-20A) was discovered*to be leaking excessively into the torus basement area following the pressurization*of the drywe 11 to 13 _pounds per square.inch *(psi g) during the performance of the ILRT.. Maintenarice _personnel were dispatched and tightened the bolts on the inboard vacuum breaker.flange. This effort resulted in the 'sealing of. the flange--.mating -surface and the drywell was subsequently pressurized *to 48-psi The primary containment leakage rate through the degraded flange could not be quantifie However, the leakage rate was estimated to be well in. excess of the Technical Specification limit.of 1.6 percent, by weight, of the cont*inm~nt air, per 24 houis; at 48 psig. A review of past

• maintenance activities indicated the vacuum breaker was replaced during the last.refueling outag Further evaluation of the work package identified that the licensee failed to perform an ILRT or LLRT on the effected containment.volume following the replacement Df the vacuum break~r. *This.issue is considered to be an unresolved item (50-237/90027-09(DRP)). pendin~ revie~ of specific:.contiinment leakage testing requirements. *

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• The inspectors reviewed maintenance department overtime practices in consideration 6f Generic Letter 82-12 and 83-14 guidelines.*

Maintenance 'Department Memorandum (MOM)* No. 65 prescribed

. application of the guidelines to appropriate personne However, the MOM did not prescribe a break of at least eight hours.between..

work periods as indicated in Generic Letter 82-12 and NOD OA.1 No

• actual occurrences were noted, however, where this had been

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Attual implementation of MOM No. 65, began in mid-199 The methodology utilized for tracking and pre-checking was dependent on the specific maint~nance maste During the inspection, the

maintenance masters were provided with printouts from the payroll computer system which had been programmed t.o indicate personnel who had surpassed the guidelines. This was to *be utilized to prepare the overtime se.mi-annual report to the Vice President of BW *Operation Throu~h this printout, the licensee identified numerous unexpected instances of electrical maintenance exceeding the

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72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in seven day guidelines. This was because that group had been applying that guideline based on a fixed week and 'not on a

• rolling during any seven day period. *The other groups had applied this correctly~ As a result, the electrical maintenance'group changed to a rolling seven day period and the distribution of the computer printout was changed to two week intervals. Although in some *cases, tracking methodology uti.lized was not very* formal, this did not appear to be a problem except as noted abov The* total

. number of deviations wa~ minimal;. however,.additional deviations were expected the last week of the Unit 2 refueling outa~ *

Insp~ctor conc~rn~ resulting from this.revi~w and comparison to li.censee commitments wit~ respect toovertime guidelines are discussed in paragraph One non-cited v.iolation and no deviations were identified in this are.

Engineering/Techni~al S~pport (i1707 and 93702) The inspectors reviewed the guidelines in £eneric Letter 82-12 in comparison to overtime worked by the p lanf technical staff. The licensee indicated that the plant technical staff was not covered under Generic Letter 82-12.and, therefore, the guidelines were not applied to this group. The Technical Staff Sup~rvisor had issued a memorandum on October 6, 1990, that delineated corporate direction that TechnicaJ Staff personnel worki.ng on safety related work, not.

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work more than 18 'hours :-continuously. This was in r_esponse to a rec~nt event at Braid~ood in whi~h technical *~taff personnel worked excessive' hour The memorandum emphasized fitness for duty responsibility.* The licensee had taken measures to minimiie

• extended work_ houri at the start of ~he current Unit 2 refueiing.*

outage by developing a planned schedule for the technical staff major testing_ evol1:.1tions based on.. 12 to 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> work days and adding personnel to backshifts to spread out the wor The licensee*

identified two instances during th~ current outage in which* *

personnel exceeded 18 ~ontiriuous work hours~ One was. for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> with prior Technical Staff Supervisor approval and *in the other instance the individual was sent home just after 18 hour~.

Th~

licensee did not have a formal tracking mechanism to assure the self~i~posed 18 ho~r gui~eline was not exceeded~ but instead informally re~ied upon the.individual and the Technical Staff group leader *

The inspector re~iewed a sample of tHe licensee's dailY atiendance report fo~ Techni~al Staff personnel for the month of November 1990, in* which a refueling outage ~as condticte The format was primarily for pay purposes only, such that a 11 instances of exceeding

guidelines would not necessarily be identifiable. However, it appeared that several instances of exceeding Generic Letter 82-12 guidelines had occurred with some of this involving types of work applicable to.the Seneric Letter *. A similar. sample review fo October 1990, a non-outage.month did not identify any such instance In addition~ these insta~ces appeared to be heavily

~~pendent on the group within the Tech~ical Staff, most notably with the inservice inspection/inservice testing grou A staffing increase from 67 to 85 -individuals between May and November 1990,

• indicated a _concerted effort to increase the size of the pl ant technical staff. * (The l~rge workload was considered a weakness in the last Systematic.Assessment.of Licensee Performance (SALP)

period.)

In the same time period, the normal attrition of experienced personnel was about e*qual to th_e hiring of experienced perstinnel. Therefore, the net effect ~f the increased staffing was the. addition of recent co 11 ege graduates with little or no

• experience. *However., these individuals would* be expected to gain experience as.time progressed and to alleviate the total workloa '.

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Inspector concerns resultjng from this review and comparison to licens~e commitments with respect to overtime guidelines a*re. *

discussed in.paragraph 7. : '

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b. * On November 30, 1990, ihe lic~nsee.identified a problem with.the SGTS lineup which could* potentially allow *flow to bypass the SGT *Among other locations; the SGTS took a suction from each unit's reactor buflding v~ntilation system.. (RBVS).

In 6rder to address a problem identified in the mid-1970i, *the licensee had *tagged the reactor building ventilation to SGTS isolation valves open with their corresponding breakers racked out such that they would not

• close on an automatic signal. The original design called for the isolation valve on the unaff~cted unit to.automatically close on *a*

SGTS automatic start signal. This.was to prevent flbw from.the affected unit's RBVS from entering the still *normally operating RBVS

• on the unaffected unit,* which would exit to the environs without passjng through the SGT The liCensee was. concerned that following an initiation signal on one unit and corresponding closure of the opposite unit's RBVS to_SGTS isolation valve, an ~utomatic start signal on the other unit would then result in total isolation of.the SGT Therefore, a single failure could disable the SGT The licensee could find no record of a 10 CFR 50.59 safety evaluation for the racked out isolati6n valve breakers~ The li~ensee. had planned on modifications to*th~ logic to address the original*

concerns but the modifications were cancelled pr_ior to implementatio The licensee indicated th~t justification*was that operator actions could be taken to initiate reactor building ventilation isolation on the unaffected unit when an automatic signal was received on the opposite unit. This was reflected in procedures such that' the o~posite unit's RBVS would be manually lined up to the SGTs*o~ a single unit.initiati9n signal.. While reviewing applicability of motor operated.valve testing to these valves on November 30~.1990, lic~nsee p~rsonn~l reviewed these previous actions and questioned whether adequate justification had been utilized. The licensee conducted an offsite dose analysis assuming no operator actions with both isolation valves remaining open. These results inditated doses ~ell below 10 CFR 100

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guidelines. The licensee.. planned to develop a modificati6n that would cause both RBVS to automatically lineup to the SGTS on a

• .single unit initi.ation. - The licensee also planned to perform a review of existing out:..of-services *to ensure that similar long standing cases of system changes through out-of-service did not exi.s As indicated in enfor*cenient conference report 50-237 /90023; 50-249/90023, the licensee also was developing reforms to the

10.CFR 50.59 safety evaluation proces*s at the fac.ilit "'..

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Although the facility change was.perfo.rmed through a.n out-of-service, the nature and long ~term existence cle~rly i.ndicated the necessity

. of performing a lO CFR 50.59 safety evaluation to ensure that an unreviewed safety que-stion did not e.xis In addition, the inspectors*

considered the justification* for c:ance ll ing modifications to rectify the various concerns to be inadequate-in that an appropriate basis was not provided a~ to utilization of mariual operator attions in place of the automatic functio Failure to maintain records, which include a written safety evaluation of this -facility change, is considered to be a violation (50-237/90027-lO(DRP)) of 10 CFR 50.59(b)(l).

However, as.this issue was licensee identified, an unreviewed safety

• question by definition did.not actually.exist, appropriate corrective actions were initiated or planned and due to *the age of the initial change, a notice of vi6lation is not being issued in ac~ord~nce with

. exercise of discre~ion delineate~ in lO*CFR 2, Appendix t,Section V. *

• On December 19, (990: the license~ informed the resident inspectors of a problem in regard to Technical Specifications not reflecting a previous modificatio The reactor*protection system (RPS) scram on

~ene~ator load reject was ~odifie~ in 1983 as a result of a GE Technical Information Letter (TIL) recommendation *. The liinit

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swi.tches on the control valve fast acting solenoids which.Provided the scram signal were replaced by pressure switches which actuated on.low Electrohydraulic Control (EHC) oil pressure.at each control valve. Technical Specification Table 4.1.1 required a functional che~k s~rveillance to be performed on this scram functio However,_

Technical Specification Table 4.1.2*did not require a cbrresponding calibration check to be performed sJnce it actually was written for the old design. Technical* Specification Ba~is indicated that this was, in fact, an "on/off" type swi,tch for which calibration was not applicabl However, the "new design" pressure switches can be calibrated. Since it was not required, the licensee was unsure whether calibration of these.switc~es had ever been performe Since the licensee had performed ~equired functional checks but.not necessarily calibration* checks on this SCl'.'am function, its

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operability was questionabl The generator load reject scram wa.s a limiting safety *syst~m setting which anticipated the rapid increase in pressure and neutron flux from a contrbl valv~. closure due to load rejection coincident with a 'failure of the bypass valves and corresponding Minimum Critical Power Ratio (MCPR) consideration This was riot an inunediate pr_oblein since TecHnical Specifications allowed this scram function to be bypassed at less *than 45 percent steam flo Unit 2 was stfll shutdown for a refueling outage and

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Unit 3 w~s at less t~an 45 percerit steam.flow since it ~as in single loop operatfon due to recirculation pump motor problem This. is considered an unresolved item (50~237/~0027~ll(DRP)) pendin~ further review of this modification with* respect to 10 CER 50.59 requir~ments.*

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No violations or.deviations ~ere identified.in.this are.

Safety' Assessment/Qual"ity Verifi"cation (40500) The *inspector observed the licensee~s Start~Up*On-Site Review *

Cammi ttee meeting *held on December _ 11, 1990.. * These meetings we".' routinely held prior to start-up to review plant work activities accomplished during the refueling outag The content and conduct of this meeting appeare*d to effectively. _contribute to the prevention-0f problems during start-up monitoring a~d evaluating the current plant statu The inspector revie~ed previous l icensee/NRC correspondence to determine licensee commitments to Generic Letters 82-12, "Nu.clear Power Plan.t Staff Working Hours", and 83-14 "Definitions of Key Maintenance Personnel.~ In a letter from T. J. Kovach (CECo} to A. B. Davis (NRC).dated October 4, 1989, the licensee responded to NRC concerns that CECo ~id not appear tb have sufficient measures in place to ensure that safety-related work was not jeopardized by personnel having worked too many hour The licensee committed to develop a new corporate Nuclear Operations Directive (NOD) that was to ensure.uniform overtime pol icy governing safety-re lated work in accordance with the guidelines.included in Generic Letters 82~12 and 83-14. This commitment indicated that the NOD would provide guidance *applicability beyond the Techni ca 1 Specification minimum shift crew composition and that included in this would be maintenance personnel and chemistry and radiation protection personne As su.ch, the commitment was not clear as to what other groups beyond those specifically m.entioned would also be include The commitment also indicated an appropriate level of management would be.. de~ignated to assure that overtime was approved prior*to

• the work occurring *. The subject NOD~ OA.13, was issued on March 15, 199.

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As indicat~d in par.graphs 4 and 6.a, NOD~OA.13 did not extend the guidelines to the fuel handlers or to technical staff personnel and, as-such, inclusion of these groups was not reflected in plant practic As the fuel handlers performed safety related work in the movement of fuel assemblies and the technical staff performed in'"'.plant safety-related work such as local leak rate testing and inservice inspections, the licensee's commitment would appear to apply

.to _these groups. :In addHion, as described in paragraph 4, although

- the one*pre-appro~ed bvertime devi*tion for -Operations during 1990 was from an appropriate level of management~* that allowed by*

OAP 7-21 was not consistent *With Generic Letter 82-12 guidanc In addition, MOM No *. 65 did not contain a requirement for a break of-eight hours between shifts in accordance ~ith Generic Letter 82-12 and NOD. OA.1 This is considered an unresolved item (50-237/90077-12{DRP)) pending completion of this inspection activity with respect to other plant organizations. * On November 30, 1990, the licensee received a Notice of Violation and Proposed Imposition of Civil Penalty associated with the use of a temporary samp.le pump in the drywell manifold sampling syste On December 17, -1990, the inspectors observed that the Civil Penalty had not been posted. This is considered to be a violation

. {50-237/90027~13(DRP)) of 10 CFR 19.11 in that the Proposed Imposition of a Civil Penalty was not posted within the required two days of receipt. - Discussions with station Regulatory Assurance personnel, the group which was responsible for initiating the posting process

' per Dresden Administrative Procedure (OAP) 2-17~ "Required Posting of Documents",. revealed some confusion existed over the posting re.quirement The responsible supervisor believed it was not required to be pQsted until the station submitted their response-to the Notice of Violation and Proposed Imposition of Civil Penalt The license_e posted promptly following.identification by the inspector The cause of the posting failure was related to the inadequate training

. of Regulatory Assurance group personnel of the requirements of OAP 2-The problem of inadequate training of_ administrative requirements was identified as the root cause associated with a past violation of 10 CFR 50, Appendix.a, Criterion II~ as delineated in inspection report 50-237/90023; 50-249/9002 As a ~esult of the previous violation, the licensee was developing a program.to matrix administrative training requirements-with.position descriptions with full implementation planned for the spring of 1991~

The.purpos~d training program was to ensure personn~l were'adequately trained on the administrative

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procedu*res -they were required know*to perform their specific dutie As this was considered to be an isolated occurrence in regard to pos~ing requirementl and ftppropriate corrective actions had been formulated to address the root caus~, a Notice of Violation is not being issued in accordance with 10 CFR 2~ Appendix C~ Section The inspectors have no further concerns in this are *

• One no~-cited violation an~ no deviations were identified in this are.

Syste~atic Eval~ation P~ogra~ (SEP) Items NUREG 1403, "Safety Evaluation Report related to the full-term operating license for Dresden Nuclear Power Station *

11 Table*2.1 identified SEP

• Integrity *Plant Safety -Assessment Report hPSAR) topic resolutions to be confirmed by the NRC Region III office. Of' the 22 items in that report, eleven were indicated as already closed in. previous inspection.reports, leaving eleven remaining items to be close The intent is for.the 1 icensee to verify closed the remaining items with* iden.tification of the closing rationale to the NRC and a sam~le NRC inspection of these it~ms to gain reasonable confidence in the licensee's informatio Any items not yet closed would be identified to the NRC with anticipated closure date In that endeavor, the inspectors verified actual completion of the following items which.the licensee indicate~ were close Item 18 -*Topic VI-10:~,2.12 (Supp.I)

It~m 19 - Topic VI-10.8~4.23;2 Item 22 - Topic VIII-2~ 4.2 Completion of this sample inspection as the licensee finishes th determination of the status of the remaining SEP items is consioered an open item (50-237/90027-14(DRP)).

No violations or deviations were identified in this ate ~

Unresolved Items

• Unresolved items are matters about which more information is required in*

order to ascertain whether it is an acceptable item, an open item, a deviation or a violatio Unresol~ed items disclosed d~ring this inspection-are diicussed in-paragraphs 4.c, 4.d, 4.f, 5.b, 6.c and 7.b.*

1 Open Items Open items are matters which have been discussed with the licensee which will be further reviewed by the insp~ctor and which involved some actions on the part of the_NRC or licensee o~ bot The one open*item disclosed

• during the inspection is discussed in paragraph 8.

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1 Report Review:

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Dur~~g* the inspection period, the inspector reviewed the lic~risee'i Monthly Operating* Report for October 1990 *. The inspector confirmed that the information provided.met.the requirements of 'Technical Specification-6.6.A.3 and Regulatory Guide 1.1 *

• 1 Eiit Interview

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The inspectors met with licensee represent~tives (denoted in Paragraph 1)

on pecember 28, 1990, and informally throughout.the inspe~tion 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 inspection. The licensee did not identify any such documents/processes as proprietary~ The licensee acknowledged the finding~ of the inspectio