IR 05000237/1992012
| ML17177A487 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/11/1992 |
| From: | Beverly Clayton, Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A486 | List: |
| References | |
| 50-237-92-12-EC, 50-249-92-12, EA-92-088, EA-92-88, NUDOCS 9206240039 | |
| Download: ML17177A487 (65) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I I I Report N /92012(DRP}; 50-249/92012(DRP}
Docket No ; 50-249 License Nos. DPR-19; DPR-25 licensee:
Conunonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Meeting Conducted:
June 4, 1992 Meeting At:
Region III Office, Glen Ellyn, Illinois Type of Meeting:
Enforcement Conference Inspection Conducted: Onsite March 23 through May 1, 1992 Inspectors:
.
Reviewed By:
Approved By:
Meeting Sununary:
W. Rogers M. Peck K. Shembarger A. Madison P. Lougheed
~
{1~f~t. - -
Richard C. Knop, ChiefJ Projects Section 18
EA 92-088
'-l f-9'2-Date
,),j, *
Date Enforcement Conference on June 4. 1992 <Report No. 50-237/92012CDRP):
50-249/92012CDRPl)
Areas Discussed: A review of apparent violations and areas of concern identified during the inspection, and corrective actions taken or planned by the license The enforcement options pertaining to the apparent violations were also discussed with the licensee. The apparent violations were regarding (1) low pressure coolant system inoperability, (2) Part 21 requirements, (3) deficiencies in the control of quality assurance activities in the corporate office, (4) deficiencies in the corrective action program, and (5) Unit 2/3 diesel generator inoperabilit *920b12 920b240003C~ 05000237 PDR AD PDR G
\\
DETAILS Persons Present at Conference Commonwealth Edison Company C. Reed D. P. Gal le K. L. Graesser L. 0. DelGeorge T. J. Kovach C. W. Schroeder B. J. Adams P. L. Barnes R. D. Branson D. A. Brown T. Burns R. C. Hunnicutt D. J. Kanakares K. K. Kociuba R. D. Kyrouac P. F. Manning W. E. Morgan H. L. Mulderink P. L. Piet R. M. Radtke K. B. Ramsden B. Rybak D. M. Saccomando T. L. *schuster T. W. Simpkin M. C. Strait D. L. Taylor S. L. Trubarch R. J. Ungeran B. M. Vi ehl G. P. Wagner M. E. Wagner J. M. Watson B. M. Wong K. E. Yates Senior VP - Nuclear Operations VP - BWR Operations General Manager, BWR Operations VP - Engineering & Construction Nuclear Licensing Manager Dresden Station Manager ENC Regulatory Assurance Compliance Supervisor PWR MOV Coordinator Superintendent of QA/NS Dresden Shift Engineer BWR System Design Engineer
.
Quad Cities Regulatory Assuranc NRC Coordinator Nuclear Quality Program Superintendent Nuclear Quality Program Supervisor Operating Experience Director BWR Nuclear Operations Station Partner BWR MOV Coordinator Nuclear Licensing Administrator Dresden Regulatory Assurance Supervisor Reactor Systems Engineer Mech/Struct Design Superintendent Compliance Engineering Nucl~ar Ltcensih~-Supervi~or -
Nuclear Licensing Administrator Dresden Technical Staff Supervisor ENC Regulatory Assurance Supervisor Counselor, Sidley & Austin MOV Corp Administrator Dresden Engineering Site Supervisor Nuclear Engineering Manager BSS - Tech Lead
- Compliance Engineer, NLD BWR System Design Supervisor Dresden Onsite Nuclear Safety Administrator U. S. Nuclear Regulatory Commission A. B. Davis C. J. Paperiello B. A. Berson E. G. Greenman B. L. Siegel R. W. Defayette M. J. Farber Regional Administrator, Riii Deputy Regional Administrator, Riii Regional Counsel, Riii Division Director, Projects, Riii Project Manager, Dresden, Headquarters Director, EICS, Riii Acting Chief, Projects Branch I, Riii
U. S. Nuclear Regulatory Commission (Continued)
W. G. Rogers R. C. Knop M. J. Jordan R. M. Pulsifer P. R. Pelke A. Yung M. J. Miller J. G. Luehman*
A. Madison*
SRI, Dresden, RIII Chief, Projects Section 18, RIII Section Chief, Operator Licensing, RIII Acting Chief, Projects Section IA, RIII Enforcement Specialist, Rill *
Engineering Aide, RIII Reactor Engineer, Riii Enforcement Specialist, OE Reactor Inspector, AEOD
- Participated via telephone llljnojs Department of Nuclear Safety R. J. Zuffa Resident Engineer Enforcement Conference An enforcement conference was held in the NRC Region Ill office on June 4, 1992. This conference was conducted as a result of the preliminary findings of the inspection conducted on March 23 through May 1, 1992, in which apparent violations of NRC regulations were identifie Inspection findings are documented in Inspection Report N /92009(DRP); 50-249/92009(DRP), transmitted to the licensee by letter dated May 19, 199 The purpose of this conference was to (1) discuss the apparent violations, causes, and the licensee's corrective actions; (2) discuss several areas of concern; (3) determine if there were any escalating or mitigating circumstances; and (4) obtain any information which would *
help determine the appropriate enforcement action. *
' The licensee's representatives provided additional information concerning the apparent violations. The licensee's representatives described the events which led to the apparent violations, including root causes and corrective actions take The licensee's presentation slides are provided as Attachment 2 to this repor At the conclusion of the meeting, the licensee was informed that they would be notified in the near future of the final enforcement actio Attachments: NRC Presentation Slides CECo Presentation Slides
Attachment 1 U.S. NUCLEAR REGULATORY COMMISSION REGION ill-COMMONWEALTH EDISON DRESDEN NUCLEAR STATION UNITS 2 AND 3 ENFORCEMENT CONFERENCE JUNE 4, 1992 9:00 A.M. (CDT)
EA 92-088 REPORT NUMBER 50-237/92009(DRP);
50-249/92009(DRP)
REGION ill OFFICE GLEN ELLYN, ILLINOIS
ll U. S. NUCLEAR REGULATORY COMMISSION REGION ill COMMONWEALTH EDISON DRESDEN NUCLEAR STATION UNITS 2 AND 3 ENFORCEMENT CONFERENCE JUNE 4, 1992 9:00 A.M., (CDT)
EA 92-088
,.
REPORT NUMBER 50-237/92009(DRP);
50-249/92009(DRP)
REGION ill OFFICE GLEN ELLYN, ILLINOIS*
'
DRESDEN NUCLEAR STATION, UNITS 2 & 3 ENFORCEMENT CONFERENCE AGENDA June 4, 1992 IN]'RODUCTION:
.
Mr. A. Bert Davis, Regional Admin*istrator PURPOSE OF MEETING:
~.
Mr_. Edward Greenman, Director, Division of Reactor Projects CHRONOLOGY OF EVENTS AND *SUMMARY OF APPARENT VIOLATIONS:
Mr. *wait Rogers, Senior Resident Inspector, Dresden LICENSEE PRESENTATION AND DISCUSSION CLOSING REMARKS:
Mr. Davis
. '
LPCI INOPERABILITY CHRONOLOGY OF EVENTS December 14, 1990 Station personnel established the torque switch setting for reactor.
. recirculation valve 2-202-SA using the Liberty Technologies Valve Operation Test Evaluation System (VOTES) methodolog Torque switch setting was reduced from 2.5 to 1.0.
.. JanU:~
__ 4, 1991 Power operation was resumed following completion of the Unit 2 refueling outage August 6, 1991 Valve 2-202-SA was discovered to be unable to close against
- differential pressure when operations personnel attempted
. to close it as part of the routine pump restart sequenc August 10, 1991 Valve torque switch was reset to 3.25, and valve declared operabl APP ARENT VIOLATION Technical Specification 3.5.A.5 states, in part, that from and after the date that the low pressure coolant injection (LPCI) subsystem is made or found to be inoperable for any reason, reactor operation is permissible only during the succeeding seven days
- unless it is sooner made operable, provided that
. certain conditions are met..
- Technical.Specification 3.5.A.s* states that if the requirements of 3.5.A cannot be met, an orderly shutdown of.the reactor shall be initiated and the reactor shall be in the Cold Shutdown condition within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Contrary to the above, from January 4, 1991, until August 10, 1991, a period beyond seven days, reactor operation continued with the LPCI inoperable in that reactor recirculation valve 2-202-5A, a valve required to close to ensure LPCI injection into the core following an accident, was incapable of performing its safety function due to an incorrectly set torque switc PART 21 DEFECT EVALUATION CHRONOLOGY OF EVENTS 8/6/91 Operations engineer performed initial screening of the recirculation valve failure for Part 21 applicability and determined no evaluation was require /12/91 The deviations coordinator completed his Part 21 applicability screening and determined no evaluation was require /4/91 On-Site Review Committee performed fmal screening for Part 21 applicability and.
determined an evaluation was not required..
1/14/92 NRC resident inspectors completed special inspection 237/91036. Licensee began Part 21 evaluatio Part 21 evaluation was completed. Licensee determined a Part 21 defect existed associated *with the VOTES process and proper notifications were mad VIOLATION 10 CPR Part 21 Section 21 requires, in part, that each individual, corporation, or other entity subject to the regulations in this part adopt appropriate procedures to provide for evaluating deviation Contrary to the above, as of February 5, 1~92, the licensee failed to adopt appropriate procedures to* *..
provide for evaluating deviations. Specifically, the Dresden Administrative Procedure DAP 2-8,
"Deviations," did not provide sufficient guidance for evaluating deviations involving software programs, methodologies, and trainin CORPORATE QUALITY ASSURANC PROGRAM DEFICIENCIES CHRONOLOGY OF EVENTS During evaluation of the 2-202-SA failure, the corporate engineering program for motor *operated valve (MOV) testing *
was reviewed and the following issues identified:
The Nuclear Engineering Department (NED) altered architect/
engineer supplied MOV thrust values to address operational and maintenance valve history. These changes were made outside of an established *quality assurance program, the assumptions µsed were not documented,* and the changes were not reviewed and approved to the same extent as the origina.
.
.
No procedure existed to document NED activities with regard to MOV testing, although this was an activity affecting quality. Additionally, because NED normally* implemented its condition adverse to quality program in a program specific
. procedure, the lack of an MOV program procedure *resulted in a lack of a condition adverse to quality procedur When 17 of 39 other valves VOTES tested during the Unit 2 refueling outage required rezeroing and 4 of these valves were found to have thrust values outside the target window, it was not recognized that this was a significant condition adverse to quality and appropriate actions were not taken to document it, and to ensure that actions to prevent recurrence were take VIOLATION 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," requires, in part, that the quality
- assurance program provide control over activities affecting the quality of identified structures, systems, and components
- consistent with their importance to safet Contrary to the above, as of May 1, 1992, the licensee's quality assurance program failed to provide control over the motor operated valve program, an activity affecting the quality of identified components, implemented in the corporate office in that the following criteria of 10 CFR Part 50, Appendix B, were not met: CFR Part 50, Appendix B, Criterion ID, "Desig~
. Control," requires, in part, that design changes be subject to design control measures commensurate with those applied to the original desig Contrary to the above, on November 8,.1991, December 18, 1991, February 22, 1991, and March 12, 1992, as well as other occasions, changes were made to the target thrust value windows for motor operated valves and these design changes were not subject to design control measures commensurate with those of the original desig Specifically, the minimum and maximum thrust values for valves 2-1001-0lB, 3-1001-0SA, 3-1301-1, and 3-3702 were altered by the licensee, and the assumptions used were not documented, and the changes were not reviewed and approved* to the same extent as that of the original desig.. CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" requires, in part, that activities affecting quality. be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance Contrary to the above, as of May 1, 1992, engineering review and calculations of thrust values to support the motor operated valve _program at Dresden, an activity affecting quality, was not prescribed by any procedur Also as of May 1, 1992, no procedure existed to describe corporate engineering required actions when a condition adve~se to quality was identified within the motor
. operated valve progra CFR Part 50, Appendix B, Criterion XVI,
"Corrective Action," requires, in part, that measures. be established to assure that conditions adverse -to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures :
shall assure that the cause of the condition is determined and corrective action taken to preclude repetitio Contrary to the above, on August 20, 1991, corporate engineers identified that 17 out of 37 motor operated valve zero. points were incorrect and that valves 2-1001-2A, 2-1001-2B, 2-1501-0SC, and 2-151-32A had thrust values outside the design windo Howev~r, these significant conditions adverse to quality were not documented, and the cause was not determined nor were actions taken to preclude repetitio INOPERABILITY OF UNIT 2/3 DIESEL GENERATOR 1973
. August 1985 -
November 1986 December 1991 CHRONOLOGY OF EVENTS The diesel generator cooling water pumps were replaced with canned pumps and motors designed for submerged and dry.
operation. Electrical connections were sealed. against water intrusion to the 508'
elevatio A modification package (M12-2/3-84-62)
to replace the Unit 2/3 diesel generator cooling water pump power feeds with a transfer switch to-* meet Appendix R concerns for separation was prepared aqd implemented. The modification package did not address water sealant requirement As part of the modification, new power *
cables were run to the pump motor at elevation 495'. The power feed connection to the motor was not resealed following installation of the new cable Following identification by corporate engineering that sealing of the diesel generator cooling water pumps against water intrusion was required, the power feed to the Unit 2/3 pump motor was reseale VIOLATION A. Technical Specification 3.9.B.2 allows power operation to continue for up to seven days, with certain shorter limits under specific conditions, if one diesel generator is made or found to be inoperable for any reaso Technical Specification 1.0 states, in part, that a component shall be operable when it is capable of performing its specified function. Implicit in the definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal
... water, lubrication or other auxiliary equipment that are required for the component to perform its function are also capable of performing their related support function Contrary to the above, from November 1986 until December 1991, the Unit 2/3 diesel generator was inoperable because the power feeds for the diesel generator cooling water pump motor, a piece of auxiliary equipment required for diesel generator operation, were not sealed against water, intrusion. This was a period in excess of seven day CFR 50.59 states in part that a licensee may make
. changes in the facility as described in the safety analysis report. without prior Commission approval, unless the proposed change involves a unreviewed safety questio It continues that a proposed change sbaJI be deemed to involve a unreviewed. safety question (1) if the probability of occurrence or the consequences of an accident or *
malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased, (2) if a possibility for an accident or malfunction of a different than any evaluated previously in the safety analysis report may be created, or (3) if the margin of safety as defmed in the basis for any technical specification is reduce *.
Contrary to the above, in November 1986, during the implementation of a modification, a change to the facility which involved a unreviewed safety question was made, and prior Commission approval was not obtaine Specifically on August 23, 1985, a safety evaluation performed pursuant to the requirements of 10 CFR 50.59 for modification M12-2/3-84-62 failed to consider submergence of the diesel generator cooling water pump motors as previously evaluated in the safety analysis report. This resulted in the power feed connections to the. Unit 2/3 diesel generator pump not being sealed against water intrusio CORRECTIVE ACTIONS CHRONOLOGY OF EVENTS Four examples of violations were identified which collectively amount to a significant deficiency - or breakdown - within the condition adverse to quality program. The examples are: (1) failure to take corr~ctive *actions to protect the diesel generator
- cooling water pumps against water intrusion, and repetition of violations concerning (2) personnel not being aware of administrative requirements, (3)
personnel failing to report. engineered safety features actuations, and (4) personnel being unaware of - * *
systematic evaluation program commitment Protection of Diesel Generator Cooling Water Pumps Against Water Intrusion 7 /73 Commitment made to install diesel generator cooling water pumps designed for submerged and dry operation. During pump installation, some electrical connections were located below the maximum analyzed flood level of 517' and not sealed against water
.
mtrus1o /89 - Engineering contractors reminded station 5/91 personnel of August 1973 commitments, recommended surveillance of previously*
sealed surfaces and sealing of non-sealed power feeds, junction boxes and cond~it Several operability reviews questioning diesel generator operability were prepared during this time perio /91 Station technical staff issued work requests (D02210, D02211, and D02228) to seal the power feed connections for all three diesel generator cooling water pumps. Work promptly completed on Unit 3 pum However, work.on the other two pumps was not thought urgent and was delaye /91 Corporate engineering regulatory assurance personnel reidentified the operability concern during a review of old operability review They requested the station expedite the work requests, which were then promptly complete /92 An engineering contractor, during a walkdown for degraded voltage concerns, questioned the integrity of 2/3 transfer switch box against water intrusio Following review, the box was seale..
Awareness of Dresden Administrative Requirements Previous violations of personnel failing to follow Dresden administrative procedures (DAPs) occurred as follows:
A. A violation was issued on December 7, 1990, (237/90023-01) concerning a failure, between April 1 and August 30, 1990, to maintain the Control Rod Drive Accumtilator High Water/Low Pressure Alarm Log in accordance with the requirements of DAP 9-12, "Procedura Adherence Deficiencies". Part of the corrective actions to this violation were to:
Review the ongoing training program to ensure that personnel involved in activities addressed in each administrative procedure are appropriately traine B. A violation, with an associated civil penalty, was issued on November 28, 1990, concerning an inadequate safety evaluation on a temporary modification (237/249-90022-01; EA 90-168).
One of the corrective actions to this violation.
was identical to the one described for.violation 237/90023-01,above. *
These corrective actions were ineffective as attested by the following recurrences:
A. On March 7, 1992, during performance of Dresden Operating Surveillance (DOS) 6600-03, the Unit 2/3 Diesel Generator vent fari and fuel oil transfer pump failed to transfer to Unit 3 power when expected. DAP Form 9-llA, Procedural Comment Supplement, was not completed, as required by the procedure, when the f allures occurre B. On March 7, 1992, during performance of DOS 6600-03, several steps were performed locally by station personnel. The test leader, stationed in the control room, signed off on these steps without directly observing step performance and without including initials of personnel actually performing the steps as required by DAP 9-1 C. On April 1, 1992, the standby liquid control storage tank air sparge inlet valve *3-1101-36 was identified to be open and unlocked although it was* required to be locked closed and independently verified in the locked closed
- position. When the valve was manipulated on March 20, 1992, personnel did not use an approved procedure or outage checklist, and an operator was not in continuous attendance, as required by DAP 7-14, "Control and Criteri~ for
- Locked Equipment and Valves."
.
.
-
-
Reporting of Engineered Safety Feature Actuations Violations were previously issued for failing to make notifications of inadvertent engineered safety feature actuations as required under 10 CFR 50. 72:
A. A violation was issued on January 17, 1991, (237/90027-06) concerning a December 8, 1990, failure to report an unplanned engineered safety feature (ESF) actuation in accordance with the requirements of 10 CFR.SO. 72. Corrective action was to issue a memorandum to operations personnel defining an ESP actuation as any unplanned or unknown occurrence involving actuation of an ESP train which resulted in completion of desired ~epositioning of any piece of-equipment. ** *
- *
,
B. A violation was issued September 12, 1991, concerning a July 4, 1991, failure to report an unplanned ESP actuation (237/91022-10). The corrective actions to this violation were:
( 1) provide training to the shift engineers and shift control room engineers;
(2) clarify ESP actuation guidance provided to operations personnel;
-
(3) develop, and provide to the operators, a flow chart to help ascertain reportability requirements; and (4) place a copy of NUREG 1022, Licensee Event Reporting. System, in the control room to aid in reportability determination These corrective actions were insufficient to prevent
. further failures to report as described below:
A. On March 14, 1992, the high pressure coolant injection (HPCI) suction valve (3-2301-6)
unexpectedly opened during the Unit 3 integrate leak rate test when high drywell pressure provided an ESF actuation signal to the HPCI system. Shift
. operations management failed. to recognize the.. ;
valve opening as an unplanned ESF actuation, and did not report it until March 18, 199 B. On April 19, 1992, the low pressure coolant injection minimum flow.valve (3-1501-13A)
unexpectedly closed twice when valves 3-1501-38A and 3-1501-38B were cycled during performance of Dresden operating surveillance DOS 1500-1,
"LPCI Valve Operability Test" on Unit 3. Shift operations management did not recognize the closings of the minimum flow valve as an unplanned ESF actuation, and did not report the closures until April 20, 199 Consideration of Systematic Evaluation Program Commitments A non-cited violation was discussed in a July 15, 1991 inspection report (50-2371910ll(DRP); 50-249190011(DRP)) concerning a February 8, 1991, temporary alteration (TIA) which provided an interlace between class IE electrical equipment and non-safety measuring and test equipment (M&TE). This was contrary to an systematic evaluation program commitment to incorporate the* electrical isolation philosophy of IEEE 384 and Regulatory Guide 1. 75 for plant *modifications whenever practical. The corrective action to the violation was to revise DAP. 10-02,
. "10CFR50.59 Safety.. Evaluation/ Screening" to --
,.
incorporate a safety evaluation screening review work shee Although the DAP was revised, it was not used when on March 19, 1992, M&TE was installed, under TIA m~7-92, to monitor voltage on the auxiliary compartment of ESF 4160 VAC Bus 34-1. This TIA again provided an indirect interface between Class IE electrical equipment and non-safety M&TE. The 10
. CFR 50.59 safety evaluation did not address the.
probability or the consequences of a malfunctioning M&TE or the bases for why the Class IE circuit would be protected following a malfunction of the M&T VIOLATION 10 CPR Part 50, Appendix B, Criterion XVI,
"Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetitio Contrary to the above:
A. On several occasions between November 1989 and January 1992, the licensee identified that a previous commitment to seal the diesel generator cooling, *
- water pumps against water intrusion to elevation *
517' had not been met. However corrective actions were not taken until June 1991 for the Unit 3 pump, December 1991 for the Unit 2 and Unit 2/3 pumps, and January 1992 for the Unit 2/3 transfer switc B. Corrective action to violations issued November 28, 1990, and December 7, 1990, failed to preclude repetition of station personnel being unaware of Dresden Administrative Procedure requirements as identified in the following examples: On March 7, 1992, during performance of a surveillance test, Form 9-1 lA of Dresden administrative procedure DAP (9-11),
"Procedure Usage and Adherence" was not completed although conditions existed that required it to be use.
On March 7, 1992, *during performance of a surveillance test, the test leader failed to document the initials of the individuals actually performing the surveillance steps as required by DAP 9-11 "Procedure Usage and
- Adherence. " On March 20, 1992, the requirementS established in DAP 7-14, "Control and Criteri~
for Locked Equipment and Valves", were not implemented when the Standby Liquid Control *
storage tank air sparge inlet valve was opened and unlocke * C. Corrective actions to violations issued January 17, -
1991, and September 12, 1991, failed to preclude repetition of operations management failing to recognize and report unplanned engineered safety feature actuations under 10 CPR 50. 7 Specifically:
1. On March 14, 1992, operations management failed to make a required 10 CFR 50.72 report when the Unit 3 high pressure coolant injection suction valve unexpectedly opened during surveillance test performanc. On April 19, 1992, operations management failed to make a required 10 CFR 50.72 report*
when the low pressure coolant injection minimum flow valve unexpectedly closed during surveillance test performanc D. Corrective actions to a non-cited violation discussed in an inspection report on July 15, 1991, failed to preclude repetition of station personnel not incorporating previous commi~ents when_
performing safety evaluations as follows:
On March 19, 1992, plant staff failed to recognize the need to evaluate and incorporate the requirements of IEEE-384 into the safety evaluation for a temporary alteration which installed measuring and test equipment on the auxiliary compartment of ESP 4160 VAC Bus 34-1, as required by DAP 10-02 "lOCFRS0.59 Safety Evaluation/ Screening."
1855:1
.
ENFORCEMENT CONFERENCE
.
DRESDEN NUCLEAR STATION JUNE 4, 1992 AGENDA Introduction D. Galle Corrective Actions Program
- 2/3 DGCWP Issues T. Schuster Closure C.Reed Attachment 112
APPARENT VIOLATION 237(249)/92009-05 CORRECTIVE ACTIONS DEFICIENCIES*
Overview of Dresden Corrective Actions Processes 1855:2
.*
APPARENT VIOLATION: Deficiencies in the corrective actions-program (237(249)/92009-05)
Overview of Corrective Actions Processes
Dresden has several corrective action processes each of which is appropriate ~o its area of concer Those processes share certain characteristics but are not consolidated into a single master progra The March 1992 Inspection Report 237(249)/92002 identified several events for which corrective actions were not effectiv In addition to addressing the specific events, Dresden management, in April 1992, responded to the concern more broadly by requesting the Corporate Safety Assessment Department to determine whether additional actions are needed to ensure that corrective actions at Dresden effectively preclude recurrence of event *
In May 1992, the Safety Assessment Department and an industry consultant conducted a review of the overall corrective actions program at Dresden Station..
-
. *-
.*
.
.
~...
.
.
In general, the observations of this review included only additional examples of the types of weaknesses identified by the Dresden Situational Review Team in the Fall of 1991. These weaknesses were in the areas of communications, empowerment, and commitment managemen Action plans h~d been previously developed to address the three areas of weakness and are included in the Dresden Management Action Plan. Implementation of the plans is underwa Dresden has evaluated the Safety Assessment Department review. It is clear from the assessment that additional action is necessary in the area of corrective action :3
Overview of Corrective Action~P-rocesses (Continued)
Overall Corrective Actions
Recent exten_d~ discussions by Senior Station Management have.
addressed increasing the effectiveness of the commitment management process, which underlies the effectiveness of corrective actions. Several practices are being strengthened with the initiation of a station policy on commitment management. The policy to be implemented by July 31, 1992 will:
Establish Management's expectations
- the seriousness of issues
- integrity of solutions Establish consequence management
- enforcing expectations
- re-enforcing positive action Address accountability
- management approval of commitments
- management monitoring of progress towa_rd fulfilling commitments Resource management
- ensuring adequate resources are applied to commitments
- critically review commitments with respect to scheduling
- * establishing a commitment coordinator for each department Implementation of the Integrated Reporting Program (IRP) has begun. IRP brings together several existing corrective action programs (i.e., DVR/LER/PCE/ROR) into a single process. IRP will guide Oresden's corrective actions responses:
methodology to identify problems m~thods for investigating those problems identification of root cause(s)
development of corrective actions to prevent recurrence provide data that can be used for trending 1855:4
...... _ -*.
Overview of Corrective Actions Process (Continued)
Overall Corrective Actions (Continued)
Interim near term actions will be taken:
Beginning June 1, 1992, a sample of previously implemented corrective actions will be evaluated by the Performance Assessment Department as part of their functional area assessments. Results of the evaluation will be documented as part of the assessment repor Quality Programs & Assessments will evaluate the effectiveness of corrective actions implemented for NRC violations issued from June 1991 to May 1992. A report of the evaluation results will be issued to the Station by September 30, 1992. The Station will take the necessary actions to address the report findings..
Corrective Actions Specific to the Examples of Violation
The detailed response and.corrective actions to t.he. three examples of the apparent violation are included in Attachment A. Two of the corrective actions warrant special note:
- 1855:5 To address concerns with personnel awareness of Dresden Administrative Procedural requirements, Dresden management will:
-
Validate and control a matrix of administrative requirements for which each station position, both management and bargaining unit, is responsibl Provide each station person an index of DAPs for which they are responsibl Establish requirements for the periodic review of required DAPs by all station personne :Develop a process to ensure that revisions to -OAPs are evaluated for identification of necessary training with respect to that revisio. --- *-
-
Overview of Corrective Actions Process (Continued)
Corrective Actions Specific to the Examples of Violation (Continued)
A detailed guidance document on reportability (Tenera Reportability Event Decision System (TREDS)) has been procured and is being customized for CECo's operatio TREDS consists of flowcharts to guide the operator through various types of events and directs the operator to more detailed guidance information to assist in making a reportability determination for a particular event. TREDS will be incorporated into a controlled CECo Reportability Manual providing identical guidance to all six nuclear station :6
.1
.... ----
.
APPARENT VIOLATION 237/92009-01 LPCI OPERABILITY
Background
Response
Root Cause
Safety Significance
Corrective Actions*
\\
1855: *
Background
In August 1991, the LPCI SA valve failed to close when require *
lnoperability of the SA valve resulted from the misinterpretation of the MOV VOTES trace, due to valve stem anomalies leading to subsequent mis-setting of the closing thrust value. These issues will be covered in the LPCI Operability discussio *
The misinterpretation of the VOTES trace resulted from a vendor training issue and ultimately resulted in a Part 21 notification. This will be covered in the Part 21 discussio * * In response to the SA valve event we reevaluated all Dresden Unit 2 MOV's set during the Fall 1990 Unit 2 outag *
The MOV reevaluation and MOV ProQram in general will be covered in the MOV Program discussio *1855:8
APP-ARENT VIOLATION: The lP-CI system may have been inoperable
.
-from January 4, 199l, until August 10, 1991, Response a period of time 9reater than the 7 day allowed outage time (237/92009-01 ).
The LPCI SA valve would not perform its intended closure function from January 4, 1991, until August 10, 1991, due to a previously unrecognized anomaly in the VOTES testing proces *
The Technical Specification LCO for the LPCI System was entered when the 5A Recirc Discharge Valve failed to close upon demand on August 7, 1991. The 7-day action requirement was observed until August 10, 1991, at which time a correct torque switch setting/thrust value was installed in the 5A Recirc Discharge Valve motor operato Root Cause
The LPCI 5A valve became inoperable due to the misinterpretation of the VOTES trace, due to valve stem anomalies that were not apparent to the valve tester :9
loo.F __ --
-
Apparent Violation 237192009-01 (Continued)
Safety Significance
The safety significance of the 5A Recirc Discharge Valve's inability
- to close further than mid-stroke was evaluated by Siemens Nuclear Power Corporation and subsequently reviewed by CECo Nuclear Fuel Service The original "limiting" LOCA analysis of record was a LOCA with the assumption of a failure of the LPCI injection valves to open. Adding the failure to close of the 5A Recirc _Discharge Valve has no effect on this analysi Of the original "non-limiting" LOCA analyses, the one affected most by the additional assumption of the SA Recirc Discharge Valve failure to close is the failure of a single diesel generator. Failure of the valve in the partially open position has the effect of decreasing the flow rate to the Reactor Vessel by allowing injection flow to be siphoned off through the Recirc Pump and its suction to the break. The new Peak Clad Temperature was calculated as 2195°F, with a maximum local metal/water reaction of 5.32o/o. Both calculated parameters still comply with the 1 OCFRS0.46 acceptance criteria of 2200°F and 17% respectivel Therefore, the LPCI system was capable of performing its intended function with inoperable SA valv *
The safety significance of this event is minimal. Partial degradation of the LPCI system did not result in design parameters exceeding acceptance criteri. Conclusion LPCI valve inoperability was a singular event due to limited industry experience_ with VOTES testing. It resulted, despite a timely expert review and an attempt to interpret an anomalous VOTES trac Since then, accumulating experience with VOTES methodology, training on VOTES software and broader, proceduralized review of anomalous traces should preclude recurrenc :10
..
Apparent Violation 237 /92009~01 (Continued)
Corrective Actions
NED re-analyzed the VOTES trace. A new zero coordinate was established for the trace. This new zero marker allowed for a higher torque switch setting than previously analyzed. MOV 5A's torque switch setting was raised and the valve was returned to servic On October 30, 1991, during an outage, a VOTES test was performed on the SA valve and verified proper thrust requirements. The VOTES system calibrator was attached to the stem for the whole valve stroke and used as the force sensor to eliminate the effects of valve yoke movemen Other Actions
NED has re-analyzed VOTES traces from all six CECo nuclear stations and determined that no similar anomalies of VOTES data were identified..
The vendor has recently trained Commonwealth Edison Station *
MOV Coordinators to use the new VOTES software. Should any uncertainty in data interpretation exist, the Station MOV
Coordinators will contact NED for proper dispositio *
The Station MOV Coordinator will also revise Dresden Maintenance Procedure (DEP) 040-10, "VOTES System Operating Procedure," to include enhanced independent review requirements and thrust window acceptance criteria by September 30, 199 Pending the procedure revision, the Dresden Station MOV Coordinator will obtain independent review of all VOTES diagnostic analyses.
. 1855:11
... -- - --
..
- -APPARENT VIOLATION 237/92009-02 PART21
Response
Root Cause
Conclusions
Corrective Actions 1855:12
APMRENT VIOLATION: The statior1_procedure for Part 21-reportability does not provide adequate guidance on the identification and evaluation of deviations (237/92009-02).
Response
The Dresden Part 21 screening process did not determine that the VOTES testing process contained a deviation which needed to be evaluated as a potential defec *
The process at Dresden Station for screening deficiencies for Part 21 applicability is adequate for hardware issues. However:
The procedure OAP 2-8 did not amplify on the 10 CFR 21 language to better clarify non-hardware deviation Training and implementation of OAP 2-8 focused on deviations.
in components (hardware oriented).
- Deviation Reports documenting events from 1990 to current were re-reviewed for 10 CFR 21 reportability. The events were independently screened by the* ENC Part 21 Coordinator and the Dresden Onsite Nuclear Safety Group Supervisor. 811 Deviation
- Reports were reviewed. No additional events were identified that should have been transmitted by Dresden to ENC for Part 21 evaluatio *
From 1989 to May 1992, CECo has evaluated 103 issues Company-wide for Part 21 reportability. Three involved *
non-hardware deficiencies and one of the three resulted in a Part 21 notificatio Root Cause
The Dresden procedure and personnel training highlighted hardware related deficiencie Conclusion
The fail_~re to identify the VOTES testing deficiency for Part 21 applicability represents a weakness in the Dresden progra *
Based on the CECo Part 21 evaluations, the weakness does not appear to be system wide across CECo and is isolated to this even :13
9:.._ -
..
AJWarent Violation 237/92009-02 (Continued)
Corrective Actions
In May* 1992, the Tech Staff Supervisor issued a letter to all On site Review Participants clarifying Part 21 reporting requirements, specifically covering the requirement to report non-hardware defect *
OAP 2-8 has been revised to include specific guidance on the identification *of non-hardware defect *
The Onsite Review Reference Manual that is used by Onsite Review Participants was revised to include detailed information of Part 21 reportabilit *
Dresden Training Department will develop.training materials on this event and Part 21 reporting criteria by June 30, 1992. Training of appropriate personnel will be completed by July 31, 199 *
Station events are reviewed in the daily events screening meetin This meeting, chaired by Regulatory Assurance and attended by other Station Departments will review the events for 10 CFR 21 applicabilit *
To ensure corrective action effectiveness, the Corporate Part 21 Coordinator will review Dresden Deviation Reports issued from August to December 1992 for Part 21 applicability. The review will be completed and a report issued by January 31, 199 *
1855:14
~
... _ -
.
APPARENT VIOLATION (237(249)/92009-03)
MOVPROGRAM
- Response
-
CECo MOV Program
- * MOV Design Basis Review
- MOV Testing Program
- Chronology
- Conclusions
- Actions Taken 1855:15
---.
APPARENT VIOLATION: MOV Program Deficiencies (237 (249)/92009-03)
Example a: Failure to incorporate MOV Program activities into procedures specific to the activit Example b: Failure to control design change Example c: Failure to implement prompt corrective actions when valve thrust values outside the design specification were foun Response (Examples a and b)
Commonwealth Edison (CECo) MOV Program
CECo's QA manual (Quality Requirement 5.0) requires that actions for design and operations activities be described in documented instructions, procedures, et *
CECo's implementation of the requirements in Generic Letter (GL)
89-1 O is described in the GL 89-10 (MOV) Program Documen This document provides the necessary procedures, instructions
...
and administrative controls to support the MOV Program. The MOY Program Document provides a systematic and -auditable program plan to meet the commitments in CECo's response to the NRC for GL 89-1 :16
MOV DESIGN BASIS AND TARGET WINDOWS ALLOWANCE FOR GENERIC ASSUMPTIONS TARGET THRUST WINDOW (DETERMINED BY CECo)
ALLOWANCE FOR GENERIC ASSUMPTIONS VALVE / ACTUATOR STRUCTURAL LIMIT (CALCULATED BY A/E)
MINIMUM REQUIRED THRUST (CALCULATED BY A/E)
r r
I
Response Example a ar1d b (Continued)
Commonwealth Edison (CECo) MOV Program (Continued)
The MOV Program was developed to ensure that all MOVs in safety-related systems will perform design basis functions. The three major components of the program are: Design basis reviews to ensure proper MOV design integrit.
Testing program to verify MOV performance within the design basis.* Maintenance program to ensure long term operability of MOV *
The MOV Program documents Were reviewed during NRC MOV Inspections at four CECo plants, including Dresden, and were found generally consistent with the intent of GL 89-10. Several NRC concerns were identified and are b~ing addressed by CECo resulting in an improved MOV Program. None of these concerns related to the adequacy of documenting program activities into.
instruction '
,
MOV Design Basis Review
CECo has retained an experienced A/E, to perform design basis review and reconstitution for all MOVs in the Program (refer to diagram). Design limits are calculated under the A/E's QA program, based on a CECo specificatio *
The A/E calculates design limits for the MOV which includes a minimum thrust limit (to overcome the design basis dP load) and a maximum thrust limit (to preclude MOV structural damage).
- To facilitate CECo's setting of the MOV torque switches, the Corporate MOV Group defines a "window" within the design limi This window is called a target thrust windo *
The MOV Program instruction, MOV-WP107, initiated in January 1991, ~rovides the methodology for generating a target thrust windo *
Based on CECo's "window" definition, the A/E began to provide a
"calculated target window" to support the CECo process along with the design limits. This "calculated target window" is not the design limi : Response Example a and b (Continued)
MOV Design Basis Review (Continued)
As long as target thrust windows are within the design limits, generation of the window is not a design activity and is not a design chang The target thrust window methodology was reviewed as part of the Byron MOV Program Inspection (IR 454(455)/91003) and was found generally consistent with the intent of the Generic Lette However, the target thrust window instruction does not provide for documentation of the assumptions used to determine the windo Only the resulting window settings are documente The tar~et thrust windows assist the station in setting MOVs within the design limit. In addition, they include conservatisms which may avoid the need to change MOV settings after additional information has been developed from CECo's MOV Testing Progra Based on the recent NRC review and internal *cECo audits, it was recognized that the documentation of the assumptions used_ to
- determine target thrust windows could be improved as discussed in the actions take :18
Response Example a and b (Continued)
MOV Testing Program
The station sets the MOV torque switch within the target thrust windo *
The MOV's setting is verified by tes *
If a test shows that the MOV cannot be set within the target thrust window, the Corporate MOV Group is contacted for further evaluatio MOV Program Conclusions
Design limits are calculated by the A/E, as directed by CECo, under their approved QA progra *
The CECo target thrust window is a "recommended administrative window" to assist the station's setting of MOVs. It is within the design limit and is not a design chang *
MOV Program activities are controlled by the CECo MOV Program Document and associated instructions which are appropriate to the circumstance *
CECo believes that the facts do not support Apparent Violation.
Examples a and :19
Response Example c Dresden MOV's
--- -*
On August 7, 1991, the failure of the SA Recirculation Discharge Valve led to the LPCI System being declared inoperabl Investigations showed that the MOV thrust setting was in error due to a previously unrecognized problem with zeroing the VOTES
- trac After the VOTES testing problem was recognized, the Corporate MOV Group reevaluated the 39 MOV VOTES tests that were performed during the Fall 1990 refueling outag The 39 MOV's thrust settings, except the LPCI 5A recirc valve, were within design limits and were acceptabl An updated version of the VOTES software was used for the reevaluation. This software provided better resolution of VOTES trace data resulting in more accurate thrust output values. Using these more accurate values, 17 of the 39 MOV's VOTES traces were rezeroed. No field adjustments were mad (Note: VOTES trace rezeroing means setting a new zero reference point on the data trace. This zero reference point is used to evaluate MOV thrust output).
- conclusions
Apparent Violation, Example e's characterization that "valve thrust values outside the design specification were found", is based on a disagreement of what constitutes the desi~n basis. Because a target thrust window is not the design basis, all MOV as-left settings were within design basis limit *
All deficiencies associated with the 39 MOVs were appropriately dispositioned by the Corporate MOV Group. The fact that the VOTES trace reference point was reset on 17 valves is not significant with respect to the design limit and does not constitute a conditiq_n adverse to qualit *
CECo betieves that the facts do not support Apparent Violation Example :20
- ... __,
Response Exam~ (Continued)
Actions Taken
All previously generated target thrust windows for the six C ECo nuclear stations have been reviewed and found to be within the MOV design limit *
In response to recent NRC reviews and internal CECo audits, a MOV Group Technical Guidance document for the generation of target thrust windows was developed and issued on May 7, 199 This Technical Guidance incorporated the methodology from MOV-WP107 with additional requirements for consistent documentation of assumptions when generating target thrust windows. The Corporate MOV Group personnel have been trained on the Technical Guidance. The Technical Guidance will be added as an addendum to the next revision of the MOV Program*
Documen *
The Corporate MOV Group letter that transmits MOV data sheets to the sites prior to MOV testing, will more clearly define the actions that are required by the station when performing VOTES testing on MOV *
A VOTES Test Evaluation Checklist has been issued to the sites for their use when evaluating diagnostic tests on MOV :21
. 1855:22
.
APPARENT VIOLATION 237(249)/92009-04 & 05a
- 2/3 DIESEL GENERATOR COOLING WATER PUMP (DGCWP) ISSUES
- Chronology
- #2/3 DGCWP Operability
-
Response.
-
Conclusions
- 1986 50.59 Evaluation for #2/3 DGCWP Modification
-
Response
- * Corrective Actions
- Identification/Correction of Conditions Adverse to Quality Response
-
Corrective Actions
Chronology - #2./3 DGCWP
..... -- -
. --
-
10/72 CE Co committed that "The diesel generator cooling water pumps and motor will be replaced with equipment designed for submerged and dry operation."
10/73
- 213 DGCW motor/pump assembly replacement completed via modification. *
11/86
- 2/3 DGCWP transfer switch modification was complete /88
- 2/3 DGCW motor/pump assembly replaced due to failed internal heat exchange /91 The seal at the bottom of LB elbow and junction at flange for the #2/3 DGCWP is sealed under a NW :23 -
AP~ARENT VIOLATION: Ttle-Unit2/3 DGCWP was inoperable from
-
November 1986 until December 199 Response
CECo acknowledges that the LB elbow seal and flange gasket were missing for the #2/3 DGCW *
An extensive review of installation and design features has been recently conducted, including input from the A/E and pump manufacture *
The review demonstrated that a water tight seal exists within the electrical lead outlet assembly which interfaces with the
owner-supplied couplings and conduit. A potted seal is installed around the power cables in the lower flange of the two-flange fitting located approximately two feet above the DGCWP motor. This seal prevents water intrusion into the.motor assembl *
The pump vendor has recently been contacted. It was verified the DGCWPs supplied to Dresden had an integral seal in the motor assembl * * A spare pump has been inspected to verify existence of the. internal sea *
New cable was never pulled, nor terminated, below the 508 foot elevatio *
During the 1986 modification, the original 30 foot power feed pigtail supplied with the motor/pump assembly was withdrawn and repulled..
During the 1988 replacement the 30 foot power feed_pigtail supplied with the new motor/pump assembly was use Seals installed in 1991 actually provided a redundant seal to the manufacturer-installed sea Although the redundant LB elbow seal and flange gasket were not reinstalled after the 1988 pump replacement, this condition did not adversely affect the ability of the pump to operate in a submerged environmen :24
..
.... -- -*.
Apparent Violation: #2/3 E>GCWP Operability (Continued)
Conclusions
Pump design features were sufficient to assure continued pump operation after submergence to the 508 foot leve *
The #2/3 DGCWP was capable of supporting EDG operation while submerge *
The #2/3 DGCWP and its associated EOG were OPERABLE..
1855:25
.... --
. -- *-
APPARENT VIOLATION: An inadequate 50.59 Safety Evaluation was pertormed for the #213 DGCWP transfer switch modification in 1986 (237(249)/92009-04).
Resp_onse
Neither the 1986 modification nor the 1988 pump replacement proposed any modification to the existing DGCWP submergence protection features. Therefore, those features were not a concern related to the safety evaluation performed under 10 CFR 50.5 *
In 1986, the 50.59 review did address the safety significance of the transfer switch modification and concluded that plant safety was not compromised by the modification. Plant safety was enhanced by the modification, as electrical isolation of the common DGCWP was improved. The 50.59 for the 1986 modification was adequat *
The flange gasket may not have been reinstalled during the modification installation in 1986 and was not reinstalled during the pump replacement in 1988. We believe this resulted from deficient work practice Corrective Actions
The flange seal was restored in December 1991, by installing a seal at the flange interfac *
Substantial improvements in the Dresden work instructions written for NWRs have been made subsequent to the 1986 modification and 1988 DGCWP replacement. These improvements included the establishment of a Maintenance Department Work Control Team. This team, in 1991 focused on NWR package improvement. These improvements should be sufficient to assure that design features disturbed by work processes are rest9red to their design configuratio :26
APPARENT VIOLATION:
CeGo failed to identify and correct
- "
-
conditions adverse to quality (237 (249)/92009-0Sa).
Response
CECo agrees with the NRC that a number of opportunities presented themselves to identify and correct the apparent DGCWP design deficiencies related to submersio In addition to the corrective action program changes made at the station, as stated earlier, corrective actions are being. taken by the Nuclear Engineering Departmen Corrective Actions
NED personnel have been sensitized to issues that have the potential to become operability concerns. ENC QE-40.1,
"Operability Evaluations" was revised earlier this year to better address operability compensatory actions and operability assumptions. NED personnel have gone through an operability training course that emphasized proper completion of the operability assessment per procedure QE-40.1 and dispositioning of operability concerns in a time frame that is commmensurate with the safety significance of the issu,
ENC will implement a system which will more effectively and consistently evaluate, track, and resolve conditions adverse to quality. ENC is currently evaluating the Integrated Reporting Program (currently being implemented at the nuclear stations) for this application. A decision on the proper system for ENC will be made by June 30, 1992. Full implementation of the system will be by December 31, 199 :27
--- --
ATTACHMENT A Response to Apparent Violations 237(249)/92009-05b-d
. 1855:28
Deficiencies in the corrective actions program ExamP-le:
Corrective actions failed to ensure adequate personnel awareness of administrative procedural requirements (237(249)/92009-0Sb).
RespQOSe *
Dresden acknowledges that prior corrective actions did not completely ensure that personnel were aware of all applicable administrative requirement *
Subsequent to the November 1990 violation (IR 237(249)/90022)
and the December 1990 violation (IR 237(249)/90023), Dresden developed a list of 66 DAPs for periodic station training. A compilation including the 66 DAP's titles and purpose statements was issued to each department. * The department heads were responsible for reviewing the material with their workers during departmental meetings~
In May 1991, during an audit on procedural adherence, CECo's Nuclear Quality Programs (NOP) identified that personnel were not following applicable procedures (DAPs).
Dresden responded with individual training on the $pacific DAPs identifie *
In November 1991, NOP elevated their finding to a Management Attention Item because of ineffective corrective action Dresden responded that the Station Training Department, in conjunction with station department training coordinators, would develop a position specific matrix for all existing DAPs. The matrix would include all station positions, within both management and bargaining unit, and would be developed by January 30, 199 :29
Apparent Violation 237(249)/92009-0Sb (Continued)
... --..
~ -
..
Response (Continued)
Station management would utilize the matrix to determine needed training for existing personnel and that training would be completed by June 30, 199 *
A position specific matrix was developed and training commence A recent review of the matrix and the methodology used in its development showed that the matrix was not fully adequat Because each Department Head identified the DAPs necessary for their personnel, there was inconsistency across the station *in the designated OAP requirements and in the method of trainin *
By a letter to all station employees dated December 5, 1991, the Dresden Station Manager clearly conveyed senior management's expectations regarding procedural adherence, including DAP Subsequent events showed that even more explicit guidance is necessar Corrective Actions
Dresden management will:
- Validate and control a matrix of administrative requirements for which each station position, both management and bargaining unit, is responsibl *
- Provide each station person an index of DAPs for which they are responsibl Establish requirements for the periodic review of required DAPs by all station personne Develop a process to ensure that revisions to DAPs are evaluated for identification of necessary training with respect to that revisio The apove actions will be completed by September 30, 199 Dresden-management will request NQP to review the effectiveness of the above actions subsequent to their implementatio *
In the interim, OAP awareness training will be provided based on the current matrix and will be completed by August 31, 199 :30
Apparent Violation 237(249)/92009-0Sd.(Continued)
Response (Continued)
The training provided on the revised OAP 10-2 requirements was not sufficient to ensure adequate awareness of the checklist requirement *
Cross reference to the checklists was not included on the 50.59 form to prompt the prepare Corrective Actions
The Technical Staff Supervisor distributed a memo to all 10CFR50.59 Safety Evaluation Screeners and Evaluator referencing this event and the need to use the Sat ety Evaluation/Screening Worksheets when screening or reviewing safety evaluation *
OAP 10-2 will be revised by July 31, 1992, to require Safety Evaluation.Screeners and Evaluators to document their screening/evaluation of plant design changes on a checklist similar to that used by the Nuclear Engineering Department (NED). This checklist requires the user to provide a written negative confirmation of design issues included on the worksheet *
Appropriate training on OAP 10-2 will be provided by-the Technical Staff Supervisor supported by a Corporate person familiar with the NED checklist. Training will be completed by July 31, 199 :34
APMRENT VIOLATION: Deficiencies in the corrective actions-program Example: Corrective actions failed to preclude repetition of untimely ENS. notifications (237(249)/92009-0Sc).
Response Dresden acknowledges that prior corrective actions were not effective to ensure that ESF events were recognized and timely notifications mad *
As part of the February 15, 1991, response to the IA 237/90027; 249/90026 violation on ESF reportability, Dresden acknowledged the NRC position on ESF reportability delineated in the July 12, 1990, internal NRC memo from C.E. Rossi to G.C. Lainas. In summary, the memo states that an event is reportable whenever ESF components are caused to actuate regardless of the portion of circuitry involved (except for expected responses during testing or components properly removed from service).
- This position was a significant change in Dresden's ESF notification guidance. Notifications had been made based on a
- "system" actuation. The new position now require~ notification of a
"component" actuatio *
Operating management provided a definition of the new position via an Operations Memo and held discussions with the operator *
Despite this, untimely ESF notifications occurred in August and September 1991. Additional actions were taken to reinforce the definition of ESF "component" actuations. However, in March and April 1992, three ESF event notifications were not timel *
Additionally, the guidance to operating shift management on what constit~t<:?s "preplanned" or "proRerly rernov~ from service" wa~.
not suff1c1ently clear to permit a timely determination of reportab1ht :31
AP~ARENT VIOLATION 237(249)/92009-0Sc (Continued)
Corrective Actions
A detailed guidance document on reportability (Tenera Reportability Event Decision System (TREDS)) has been procured and is being customized for CECo's operation. TREDS consists of flowcharts to guide the operator through various types of events and directs the operator to more detailed guidance information to assist in making a reportability determination for a particular even For ESFs this guidance includes recognition of an ESF event, clarification of preplanned evolutions, and when ESF
systems/components are properly removed from servic TREDS will be incorporated into a controlled CECo Reportability Manual providing identical guidance to all six nuclear stations. The Reportability Manual will be issued to the station for their us A lesson plan on use of the Reportability Manual has been developed. Training will be conducted by the Training Department supplemented by a Corporate person familiar with 10 CFR 50.72 reporting requirements. Full implementation at Dresden will be by August 31, 199 Prior to implementing TREDS and supplementing the Dresden IR 237/90027; 249/90026 violation response, CECo will request a technical meeting with NRC Riii to discuss its Reportability Manual and the guidance provided on 10 CFR 50. 72 reporting. This *
meeting should result in a mutual understanding of CECo's reporting policy for compliance with 10 CFR 50. 72. -
In conjunction with the implementation of the CECo Reportability Manual, Dresden will develop a single procedure outlining the station process for making reportability determinations and notifications. This procedure will be implemented by August 31,
199 :32
APP-ARENT VIOLATION: Deficiencies in the corrective actions program Example: Corrective actions failed to preclude repetition of personnel not incorporating previous commitments when performing safety evaluations {237{249)/92009-0Sd).
Response Dresden acknowledges that prior corrective actions were not effective to ensure that personnel were aware of the revised OAP 10-2 administrative requirement *
A non-cited violation {IR 237/91016; 249/91015) involved the inadequate preparation of a 10 CFR 50.59 evaluation for a temporary alteration on the Unit 2 HPCI system. Specifically, the need to evaluate the effect of a malfunction of non-safety
,
equipment on a safety-related system was not recognized by the evaluato *
In response, Dresden revised procedure OAP *10-2,"10 CFR 50.59 Review Screening and Safety Evaluation," in April 1991 to incorporate a Safety Evaluation/Screening Review Worksheet which addressed electrical separation criteri *
In March 1992, a chart recorder was installed on the non-safety,
related portion of the ESF Bus 34-1 to monitor voltage performance. The chart recorder was connected to a circuit that contained a fuse, thus protecting the safety related side of the circuit. However, the appropriate 50.59 checklist was not use Individuals involved were not aware of and did not review Checklist 5 of OAP 10-2 "1 O CFR 50.59 SafetY Evaluation/Screening Worksheets Electrical Issues,"* when performing the safety evaluation. A part of these. worksheets asks if safety related
.*
circuits are isolated and separated from non-safety related circuits.
. 1855:33
..
.:;
r I
.
508'
Transfer Switch Junction or
Pull Box:
- --------------------------------------------
.Elevation DGCWP Pump Motor Power LB Elbow l
Feed _ __..,
Pigtail DGCWP Motor
- 495" Elevation
-J
,
'
r
- ~
LB Elbow i
Flexible Conduit
- LB Elbow Seal
,... __
Field Installed Seal
~==:-- Gasket Missing