IR 05000237/1991015
| ML17174A766 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/26/1991 |
| From: | Phillips M, Salehi K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17174A765 | List: |
| References | |
| 50-237-91-15, 50-249-91-14, NUDOCS 9107010025 | |
| Download: ML17174A766 (9) | |
Text
. Reports N U.S. NUCLEAR REGULATORY COMMISSION
REGION III
50-237/91015(DRS); 50-249/91014(DRS)
Docket No ; 50-249 Licenses N DPR-19 and DPR-25 Licensee:
Commonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Facility Name: Dresden Nuclear Power Station, Units 2 and 3 Inspection At: Dresden Site, Morris, Illinois and 1400 opus Way, Downers Grove, Illino1s Inspection Conducted:
through June 6, 1991 Approved.By: Inspection Summary Inspection on Mav 13 throuqh June 6, 1991 (Reoorts N ~237/91015(DRS); No. 50-249/91014(DRS))
t4~/q1 Date l/z6h!
Date Areas Inspected:
Routine, announced, safety inspection conducted of the licensee's design change process (IP 37700).
Results:
One non-cited violation, and two open items were identified during this inspectio The non-cited violation was related to the control of critical drawings in the critical drawing file (Paragraph 2.f).
The open items were related to the meaning of the training complete signoff on modification packages (Paragraph 2.b) and the failure to revise the drive and core flow correlation for cycle 13 based on the results of completed post-modification testing of the modified recirculation pump (Paragraph 2. g).
Although some minor discrepancies were identified, the overall quality of the modification approval letters and safety evaluations was goo They tended to be comprehensive and addressed all potential effects of the modification on system operation In addition, the post-modification testing criteria were complete and addressed the design requirements for the sistem PDR ADOCK 05000237 G
- .
DETAILS Persons Contacted Commonwealth Edison Company (CECo)
- J. Eenigenburg, Station Manager
- M. strait, Tech staff Supervisor
- K. Peterman, Supervisor of Regulatory Assurance
- K. Kociuba, NQP Superintendent B. Christel, Assistant Tech Staff Supervisor L. Gerner, Technical Superintendent
- J. Harrington, NQP Maintenance Group Leader
- F. Kanwischer, Services Director G. King, Temporary Alteration Coordinator
- D. Lowenstein, Regulatory Assurance Staff
- J. Paczolt, Lead Reactor Engineer
- D. Sanderson, Mod Coordinator S. Stiles, Training Supervisor
- L. Young, Training
- R. Tate, Tech Staff
- L. Taylor, ENC Regulatory Assurance U.S. NRC
- D. Hills, Senior Resident Inspector Illinois Department of Nuclear Safety
- R. Zuffa, Resident Inspector, IDNS
- Denotes those present at the exit meeting held on June 6, 199 The inspectors also interviewed other licensee employees during the course of the inspection, including members of the technical, operations, and corporate engineering staf Review of Design Changes (37700)
The inspection focused on the implementation of design changes and included a review of seven plant modifications installed on Unit 2 during the last refueling outag The modifications were selected utilizing probalistic risk assessment insights generic to boiling water reactor~.
The review was conducted to determine if these changes had been conducted in accordance with programmatic and regulatory requirements, and if all technical issues had been adequately addresse The review of the modification package included review of design specifications, 10 CFR 50.59 safety evaluation, post modification testing
- criteria and results, procedure and drawing updates, FSAR changes, and training related documentation/implementatio The inspectors also examined the installation of modifications, where appropriat Discussions were held with licensee staff involved in the modifications, which included system/design engineers and project and operations personne The licensee's modification program was controlled by DAP 5-1, "Plant Modification Program," revision 19; and Nuclear Operations Directive NOD-TS.5, "Design Control for Operations - Plant Modifications," Revision The first document controlled site personnel activities, while the second docume.nt governed corporate design engineering activitie Safety evaluations were performed by the site utilizing DAP 10-02, "10 CFR 50.59 Review Screening and Safety Evaluation, 11 Revision Although some minor discrepancies were identified, the overall quality of the modification approval letters and safety evaluations was goo They tended to be comprehensive and address potential effects of the modification on system operation In addition, post-modification testing criteria were complete, and addressed the design requirements for the system The following modifications were reviewed and no concerns were identified unless otherwise noted: Ml2-2-87-054, Install New Flow Element and Corresponding Transmitter in the EDG Cooling Discharge Line This modification installed local flow indication for the emergency diesel generator cooling water lines to meet a Regulatory Guide (RG) 1.97 commitmen The new flowmeter was also to be used for IST testing measurements because of the difficulty in utilizing installed instrumentatio The inspectors identified one concern with this modificatio This concern dealt with the installed instrumentation not having been included in a surveillance program to ensure that it would remain calibrated, although the instruments were part of the RG 1.97 program and were to be used to perform IST testin The licensee does not tag plant instrumentation to indicate that they are within calibratio Rather, the Instrumentation and Control Department maintained calibration cards for the instruments, and all other groups relied upon I&C to maintain instruments within current calibratio The
- *
inspectors were told that the IST testing to be performed would rely on the installed instruments calibratio However, the inspectors determined that the I&C group would not have performed routine calibrations on the instrument because they had not received a request from onsite engineering to place the instrument into the calibration progra During the inspection, the licensee developed a procedure to calibrate the instruments, and indicated that this calibration would be performed on a six-month cycle in accordance with the manufacturer's recommended frequenc The failure to include these instruments in the calibration program is identical to the concerns discussed in this regard in NRC Inspection Report 237/91016 and 249/9101 This item was forwarded to the Resident Inspector for. followup in the above referenced report Ml2-2-89-020; MCC 29-9 Power Feed to "A" SBGTS This modification, completed in November 1990, removed the 480 VAC power feed to SBGT Train "A" from buses powered by Diesel Generator 2/3 which was controlled by Battery-Instead, it connected the 480 VAC Train
"A" SBGT loads to the 29-4 bu This change removed the dependence of both SBGT trains on a single batter The inspectors identified one concern related to inadequate training or notification of appropriate licensee personnel concerning the implementation of this modificatio The inspector verified that even though the modification record form indicated that training had been completed, 25% (21 out of 84) of the licensed personnel had not received training nor were they provided with required reading for the implementation of this modificatio It appeared that the form had been signed as training completed based on all specified training sessions having been held rather than ensuring that all personnel had received the trainin The intent of the training department had been to provide required reading concerning missed material for personnel who failed to attend training session The licensee should determine what is meant by the signature block "training completed" on the modification record for This is an open item pending receipt of clarification (237/91015-01; 249/91014-01)
c.
Ml2-2-89-053, Add Protective Relay to LPCI Swing Bus Logic and Initiate Autotransfer Feature This change added protective relays to the swing bus transfer logic to sense over/under voltage or under frequency conditions and then initiate a bus transfe The inspectors did not identify any concerns with this modificatio M12-2-90-013A, Install Alternate 125 VDC Battery with Tie to Allow Existing Battery Tests This modification installed a 125-VDC alternate battery in the Unit-1 High Pressure Coolant Injection Battery Roo In addition, it provided the interconnections to the 125-VDC distribution system for Unit-This modification would allow testing of the unit 2 battery without requiring a dual unit outag The inspectors identified one concern with this modificatio The unit 1 HPCI room did not have adequate ventilation to ensure long-term battery operabilit If the cross-connection was initiated during unit 2 operations-and the Unit 1 HPCI room temperature exceeded that allowed for the alternate battery, the potential existed for the battery to be inoperable, thus rendering the swing EDG inoperabl The licensee corrected this concern by modifying the procedure to ensure that if the alternate battery was utilized for normal operation, the Unit 1 HPCI room would be checked to ensure acceptable temperatures existe M12-2-90-0l8, Modify EOG Cooling Water Pump Discharge Piping and Install New Dual Plate 6-inch Check Valve This modification replaced an 8-inch check valve at the discharge bend from the diesel generator cooling water pump with modified piping and a dual plate 6-inch check valv The modification was performed to reduce wear on the previously-installed check valv The inspectors did not identify any concerns with this modificatio M12-2-90-025, Change Standby Gas Treatment (SBGT) Logic This modification, installed in February 1991, changed the logic for the standby gas treatment system to include isolation of both units 2 and 3 reactor building ventilation systems upon an SBGT autostart signa The inspectors identified two concerns regarding this modification, both related to updating required document *
- The first concern dealt with the updating of procedure The inspectors found that the alarm and operational procedures had been properly updated shortly after completion of the modification; however, surveillance procedure DOS 1600-7 had not been revise Without appropriate revisions to the surveillance procedure the system would not.have been properly tested as required by the technical specifications. The functional test had been adequately performed as part of the post-modification tes The licensee promptly revised the procedure during the inspection to incorporate testing the modified logic so that the test would be properly performed when next require The second conc~rn related to the update of critical drawings in the control roo The inspectors identified that the drawing for train A had been updated, but the drawing for train B was out of date and did not indicate that it was under revisio The failure to ensure that the critical drawings had been updated to reflect the as-built configuration is a violation of Criterion VI of Appendix B to
-
10 CFR Part 5 The licensee initiated an immediate investigation and determined that the drawing had been revised, but had been improperly filed in a separate non-critical drawing rack that had been moved to the control room due to construction in the old Unit 1 control roo Drawings in the non-critical rack were not required to be updated to reflect the current plant configuration. The licensee's corrective actions included removal of critical drawings from the non-critical rack, clearly separating and labeling the critical and non-critical drawing racks, providing training to personnel responsible for drawing updates, and ensuring that all critical drawings were the correct versio Based on the licensee's actions, the criteria of 10 CFR Part 2, Appendix C, Section V.A have been met and no notice of violation is being issue (237/91015-02; 249/91014-01).
M12-2-91-001, Replace 2A Recirculation Pump Shaft, Impeller, and Cover This modification replaced the shaft, impeller, and cover to the 2A recirculation pump with newly designed component The new impeller was about 1/2" smaller in diameter than the old one, and that of the 2B
.recirculation pum The inspectors identified one concern regarding the licensee's failure to update the core flow correlation used for calculating adherence to the fuel thermal limit requirement *
3.
The post-modification testing for this design change was reviewed and determined to be appropriat The test performed in April 1991 correctly generated a new correlation between the drive flow and total core flo This correlation is normally performed after each outage to determine the effect of crud buildup during the previous cycl However, the results of the new correlation were not utilized in the current thermal limits calculation As a result, the plant computer was using the previous cycle's correlation for this comparison at the time of this inspectio The average difference between the previous values and those measured during the post-modification test were between 5 and 6%.
By comparison the acceptance test criterion recommended by Advanced Nuclear Fuels (ANF), the licensee's fuel manufacturer, was 2.5~.
Since the thermal limit values were significantly below the Technical Specification established limits, the effect of this difference had been negligibl However, if they had opPr.ated close to thermal limits ailu the WT vs WD correlation from the previous cycle were used to determine core flow, the potential existed for the operators to be unaware that they had exceeded fuel thermal limit Step 15 of section I of procedure DTS 8148, "Station Computer Nuclear Program and Data Verification While Using POWERPLEX," revision 10, required that as soon as possible update the substitute core flow correlation (WTC vs WDC) into the compute However, the amount of time specified by "as soon as possible" was not specifie The failure to update the core flow correlation is an open ite In addition, the lic~nsee was asked to clarify the meaning of the term "as soon as possible" in the procedur (237/91015-03)
Temporary Modifications A review of the recently issued revision 14 to DAP 07-04,
"Control of Temporary System Alterations," indicated that it was an improvement over the previous revisio The revision also adequately addressed a licensee audit finding that justification had not always been specified for extending the time an alteration was allowed to remain temporarily installe The licensee's assignment of a temporary alteration coordinator and use of a computerized method of tracking temporary alterations were enhancements to the temporary alteration progra However, one concern was identified concerning the ability to provide second level review approval via telephone.
- Safety Evaluations The licensee's procedure for performing safety evaluations, DAP 10-02, 11 10 CFR 50.59 Review Screening and Safety Evaluation," revision 4, and the safety evaluations for each of the above design change packages (modifications and temporary alterations) were reviewed against the requirements of 10 CFR 50.5 The inspectors verified that 10 CFR 50.59 safety evaluations were done for the modifications evaluated in this inspection and for all of the current temporary alterations on both unit The inspectors found, with the exception of one modification and one temporary alteration, that the safety evaluations were of good quality and reflected sufficient knowledge of the system requirements, the updated safety analysis report, and the Technical Specification *
With regard to the modification of the impeller and shaft of the recirculation pump, the inspectors found that the 10 CFR 50.59 P.valuation had not specifically auuressed pump seizur A similar modification at Quad cities ha determined that pump seizure characteristics had not been adversely affected, but this fact had not been incorporated into the 50.59 evaluatio Regarding the temporary alteration, installing electronic test equipment in the HPCI logic system, the safety evaluation had not considered the impact of a malfunction of the new equipment on the remaining components of the system~
The licensee indicated that no electrical failure of the test equipment could have affected the operability of the HPCI syste As in the first example, this information would have been part of the 50.59 evaluatio.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involved some action on the part of the NRC or the licensee or bot Two open items determined during this inspection is discussed in Paragraphs 2.b and 2.g of this repor Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) on June 6, 199 The inspectors summarized the scope and findings of the inspectio The licensee acknowledged the statements made by the inspectors with respect to the items discussed in this repor The inspectors also discussed the likely informational content of the inspection report with regard to documents or
- processes reviewed by the inspectors during the inspection and the licensee did not identify any such documents or processes as proprietar