IR 05000237/1992020
| ML17177A597 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/13/1992 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A596 | List: |
| References | |
| 50-237-92-20, 50-249-92-20, NUDOCS 9208240089 | |
| Download: ML17177A597 (18) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report No /92020{DRP); 50-249/92020{DRP)
Docket No * 50-249
'
.
Licensee:
Conunonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 License Nos. DPR-19; DPR-2 Facility Name:
Dresden ~uclear Station, Units 2 and 3-Inspection At: Dresden Site, Horris, Illinois In~pett~on Conducted~ Ju)j i~through July 31, 1992 Inspectors:
Approved By: Rogers Pec H. Bongiovanni Markley Riemer Vegel Zuffa, Illinois Department of Nuclear Safety
~~Jo; 1ca~Knoj)1eZJ Reactor Projects Section lB Inspection Summary Inspection from July 7 through July 31. 1992 <Reports No. 50-237/92020CDRP);
50-249/92020CDRPl Areas Inspected: A routine, unannounced s*fety inspection was conducted by resident and regional inspectors and by an Illinois Department of Nuclear Safety inspecto The inspection included followup on previously identified
- terns and licensee event reports; review of operational safety, monthly maintenance activities; monthly surveillance activities; events follow~p;
- regional requests; Tl 2515/115 followup; and Systematic Evaluation Program followu Inspection modules used during this inspection were:
61726, 62703, 71707, 92700, 92701, 92702, and 9370 Results:
Of the 9 areas insp~cted, one violation with multiple ~xamples was identified associated with personnel not'complying with written procedures
{paragraphs 4 & 7). Six unresolved items were identified {paragraphs 3, 5, 7
& 9).
One SIMS item, TI 2515/115, was closed {paragraph 9).
9208240089 92081JL PDR ADOC~ 05000237 Q
Plant Operations Generally, licensed operators carried out their duties properly and
- professionally. Operators were aware of equipment status.and responded t alarm The Unit 3 reduction in power to repair the reactor recirculation motor-generator tachometer was we 11 performed.. Performance of round duties by some nonlicensed operators was poor. Housekeeping continued to be poor in a number of area *
Maintenance/Surveillance The Unit 2/3 emergency diesel generator outage was well performed.* Problems
~ith technical specification surveillance requirements were identified on the service water effluerit monitors. *
Engineering and Technical Support Two instances of weaknesses in the quality of engineering contract services were identified. These involved nonconservative accident analyses and pressure/temperature curves supplied by the NSSS vendor, or its subcontractor *
Safety Assessment and Quality Verification The violation associated with this inspecti.on period reflected weaknesses in management's ability to reinforce procedural adherence at the worker leve Radiation Protection
- DETAILS Persons Contacted C. Schroeder, Station Manager *
- l. Gerner, Technical Superintendent J. Kotowski, Production Superintendent
- T. O'Conner, Assistant Superintendent, Maintenance J. Achterberg, Assistant Superintendent, Work Planriing
- G. Smith, Assistant Supe~intendent, Operations M.. Strait, Technical Staff Supervisor
- R. Radtke, Regulatory Assurance Supervisor
- Denotes those attending the exit interview conducted on July 31, 199 The inspectors also talked with and interviewed other lic~nsee employe~s during the course* of the inspectio *
- licensee Action on Previously Identjfjed Items (92701. 92702) * (Closed) Open Jtem (237/91025-04(DRP)):
licensee actions t~
improve control rod drive (CRD) performance documentatio The system engineer established maintenance and performance data bases extracted from the results of scram time testing of each CR The system engineer was also actively involved in the CRD system working group establish~d to address recurring CRD problem The working group was meeting on a weekly basis to prioritize an establish corrective action plans to address various CRD problem This item is considered clo~ed. * *
- (Clo~ed) Deviation (249/91029-03(DRP)): Failure to meet previous commitments regarding bolting requirements in* maintenance procedures. The licensee's guide to work package preparation was revised to ensure bolting requirements were specified in the procedures and discrepancies from the vendor torquing values reviewed and documente In addition, the station procedure implementing Nuclear Operating Directive (NOD) MA.16,_ "Good Bolting Practices," was under revie In the interim, 47 * maintenance procedures needing additional torquing guidance were identified. The review of these procedures and the vendor manuals were documented on procedure inquiry form Discrepancies and additional guidance will be provided in the procedures after implementation of NOD MA.1 The other aspect of this deviation, inadequate corrective action,*
was discuss~d in inspection report 237/92009(DRP); 249/92009{DRP).
This item is considered close (Open) Open Item (237/91031-0l(DRP)):
long term corrective actions to leakage through primary containment isolation*valves AO 2-220-44 and AO 2-220-4 The licensee revised the Dresden Maintenance. Procedure (DMP) 0040-06, "Safety Related Motor
- Operated Valves Data and Settings,w for repairing these valve The licensee planned to issue a supplement to LERs 237/91005 and 237/91015 by August 1992, discussing replacement of the valves with a different design and extension of the safety-related*
l;>oundary downstream of the two valves. *This item remains open pending issuance of the LER supplements and inspector review of the licensee's remaining corrective actions.*
(Closed) Unresolved Item 237/91022-ll(DRP)): Determination whether the root cause analysis of an Offsite Nuclear Safety Group (OFSG) finding should have identified that a steam line high flow isolation differential pressure transmitter was not being. *
calibrated. The OFSG participant for Dresden indicated a revie was conducted for similar instrument calibration problems but ~one w~re id~ntified. The actions taken in respohse to the OFSG
finding did not identify the generic nature of the problem which..
. was the subject of a violation (237/91016-02(DRP)). *Given that the additional instruments reviewed were not part of the violation, this matter. is considered closed. *
(Open) Open Item (237/90027-14(DRP)):
Perform sample inspection of Systematic Evaluation Program (SEP) Topic resolutions. The inspectors completed verification of an SEP item during this inspecti-0n period as discussed in paragraph 10. This open item
. will remain open for remaining SEP items pending licensee confirmation of _topic closures and resident staff verificatio No violations or deviations were identifie.
Licensee Event Reports Followup (92700)
The following 1icensee event reports were reviewed to ensure that reportability requirements were met, and that corrective actions, both*
immediate and to prevent recurrence, were accomplished in. accordance with the Technical Specifications:
a.*
(Open) LER 249/92008, Containment Cooling Service Water Pump Vault
. Door Leakage Due to Worn Latch Packin *
The only outstanding corrective action to the LER was th~
preparation of a maintenance procedure on the latch mechanisms and door seals. The procedure is expected to be issued before the end of the year. This LER remains open pending licensee issuance of*
the procedure and inspector review of the procedure for adequac (Closed) LER 249/91001, Deenergization of the Reactor Protection System (RPS) due to Procedural Deficienc *
The root cause of this event was a procedural deficiency that failed to account for all four RPS trip channels having SDV bypass contacts in series with relays powered by the A and B RPS power supplies. The procedure was revised to alert the operator that,
- if a reactor scram was in place and a SDV Hi Level present, then a reactor scram would occur when either RPS power supply was deenergized. These actions were sufficient to prevent recurrenc (Closed) LER 249/91011, Loss of Main Control Room Annunci~tor Power due to Design Deficiency.
. On September 23, 1991, a loss of de power to six annunciator panels in the control room occurred; due to a blown fus The fuse was not part of the original plant design but was installed during an annunciator modification in 199 The licensee replaced*
the fuse with a copper link restoring the circuit to the original design configuration. The licensee subsequently installed a copper link on Unit 2 as wel Problems with the copper links on*
these circuits 1 that were identified during this inspection*
period, are discussed in paragraph d~
(Cl~sed) LER 237/91031, Rev 1, Control Rod Drive (CRD) R-JO Failure to Latch Due to Collet Piston Bindin The insp~ctors reviewed applicable licensee documentation and discussed the CRD failure with the cognizant system enginee The licensee determined the binding of the CRD collet piston was from a buildup of corrosion deposit The. CRD was replaced in
.
December 1991, and a CRD performance improvement working group was *
assessing the effects of corr~sion deposits on CRD operabilit (Clos~d) LER 237/91035, Reactor Building Ventilation Damper Isolation due to Setpoint Design Deficienc The inspectors reviewed the licensee's conclusipns and corrective actions. *The li~ensee determined.that an engineering deficiency had resulted. in the automatic closure pressure switches settings being too high so that when the valves cycled open the air pressure decreased sufficiently to drop out the closure switch --
returning the damper to the closed position. The surveillance procedure was revised to establish the pressure switch settings such that momentary air line losses would not in111ediately close the isolation damper (Closed) LER 237/91009, Failure of the Standby Gas Treatment System Charcoal Absorber Leak Test During Seal Leakag On May 17, 1991, the "B" train Standby Gas Treatment (SBGT) System
. failed a Technical Specification (T/S) required charcoal bypass test. The tests were rerun five more tests, with different charcoal absorber housing components being repaired after each failure. However, not until the housing gaskets were replaced did
- the "B" SBGT train pass the T/S bypass leakage surveillanc Because of the problems identified on the "B" train, the "A" SBGT train bypass leakage_was tested in the "as found" conditi.on, and 5.
also found to be in excess of the T/S limits. The "A" trairi charcoal absorber trays were removed and the gaskets on all the trays were replaced. Also two of the four sealing mechahisms had broken pins. *The pins were replaced, the charcoal trays were reinstalled, and the "A" train was satisfactorily reteste The LER atttibuted the excessive leakag~ primarily to degradation of the sealing gasket The charcoal trays were purchased from Barnebey-Cheney on January 3, 1983, and November 1, 1982, respectivel The purchase orders required the contractor furnish Convnonwealth Edison Company with any special instructions, such as shelf life, needed during handling or storage of the part No shelf life information was*
provided and the licensee established an unlimited shelf life for the absorbers assemblie The purchase orders were safety-relat~d and 10 CFR Part 21 was applicabl Durin~ the LER followup the inspectors.observed significant degradation of the neoprene sealing gaskets of charcoal absorbers, ready fot issue, stored in the licensee's warehous The inspectors determined Barnebey-Cheney failed to supply the licensee with the manufacturer's reconvnended five year shelflife limitation on the charcoal absorber The licensee initiated Discrepancy Record (DR)91-071 on July 23~ 199 The D evaluation was not completed until eight* months later on March 26, 199 The completed DR.indicated that a Part 21 deviation did not exist and an engineering review was not require However, because of inspector qu~stions as to why a P~rt 21 deviation did not exist, a Part 21 evaluation had been initiated on July 24, 1991 and completed on March 19, 1992. * The licensee concluded a Part 21 notifitation was not required because the manufacturer's failure to inform the station of a shelf life did not constitute a defect. The Part 21 evaluation included the assumption that post accident dose consequences would have been within_the Part 100 and the GDC 19 limits with the degraded gaskets installed; based upon Dresden specific calculation The licensee revised the Part 21 evaluation on June 8, 1992, to include information froin the Electric Power Research Institute (EPRI) Guidelines for Establishing,. Maintaining, and Extending the Shelflife Capability of Limited Life Items (NCIG-13) Hay 199 The EPRI report stated the shelflife for neoprene can be extended up to 36 years. Based on this new information the licensee is revising the LER root caus Inspector observations associated with this LER followup were:
The licensee's root cause evaluation of the SBGT system failure was wea The licensee did not pur~ue why* seals had degraded or consider shelflife limitation *
The licensee failed to recognize a departure from the technical requirements in a procurement document constituted a Part 21 deviation. This is a previously recognized problem (see inspection report 237/92009; 249/92009).
- *
The licensee's Part 21 evaluation wa~ not timel *
The DR record did not cross reference that a Part 21 evaluation was performe '
The degraded charcoal absorbers in the warehouse had incorrect part number *
The licensee's Part 21 co_nclusion was poor in that it took*
credit for Dresd~n specific offsite dose calculations {n order to remain within Part 100 limits. These Dresden specific calculations might not apply to other licensee with the same deg~aded f i 1 ters. *
SBGT "as-found" bypass tests were not being routinely performed. This appears to be inconsistent with ANSI
.Standard 18.7, 1972, which discusses that surveillance test procedures record the "as-found" condition. This issue is considered unresolved (237/92020-0l(DRP)) pending an evaluation of the licensee's co11111itment to ANSI N1 (Closed) LER 249/92009, Unplanned Reactor.Scram During Bus Undervoltage Test Due to Spurious Average Power Range Monitor Spik.
. - (Closed) LER 237/91022, Control Rod Drive F-3 Drift due to Pil6t Solenoid Failur (Closed) LER 249/91006, Reactor Scram due to degraded Turbine Main Stop Valve Fast Acting Solenoid Valv *
No violations or deviations were identified in this are.
Operational Safety Verifjcatjon C71707)
The inspectors reviewed the facility for conformance with the license and with regulatory requirement a; On a sampl;ng basis the inspectors observed control room
.
activities for proper control room staffing and coordination of plant activities. Operator adherence to procedures or Technical Specifications and operator cognizance of plant parameters and alarms was observed. Electrical power configuration was confirmed. Various logs and surveillance records were reviewed for accuracy and completenes **
Observations included:
. On July 29, 1992, Unit 3 was placed in single pump operation to replace the reactor recirculation motor generator set tachometer. The.inspectors observed three heightened level rif awareness (HLA)
briefing~ associated with the evolution..
The briefings were consistent with the Dresden policy*
statement concerning HLA activities. Clear lines of authority were established during the briefings, and operations personnel were cognizant of plant conditions and alarms throughout the evolution. Operators made good use of repeat-backs and the phonetic alphabe lnplant evolutions were performed with the procedure "in hand." Overall the operating authority maintained a questioning attitude.and a professional demeano *
On June 30, 1992, the inspectors observed an unidentified
.
temporary alteration (T/A) fovolving the Unit.3 control room reactivity control panel and feedwater controller. The T/A consisted of approximately eight jumpers and a chart recorde When questioned, the shift control room engineer (SCRE) did not know why the jumpers were ins~alled. The T/A was installed'on April 4, 1992, per Special procedure 92-4-68, 38 Feedwater Regulating Valve Operability Test (Ml22-3-88-57).
Dresden Administrative Procedure (OAP) 7-4, "Control of Temporary System Alterations," Section E.9, allowed T/As to
- be excluded from the requirements of OAP 7-4 provided the T/As were positively identified. Section E.6 defined
"positively identified" as labeled with T/A card The failure to positively identify the T/A in accordance with the OAP 7-4 requirements is-considered an example of a
violation (249/92020-02a(DRP)) of 10 CFR Part 50, Appendix 8, Criterion The licensee took adequate corrective action by tagging the T/A with caution cards. The use of SPs to control T/As was considered a weak practice since the T/A Control Room Log was bypassed and the SP failed to ensure the plant configuration changes were reflected on the Critical Drawing *
Also, SP-92-4..,6.8, Section E, "Prerequisites," required t documentation of permission from the operations supervisor for each shift for the duration of each test on the "Shift Authorization Sign Off Sheet." The test was initiated on Hay 8, 1992; however, only two signatures, on Hay 11, 1992, and Hay 20, 1992, appeared on the signoff sheet. Plant personnel indicated the SP was in a "suspended" status and did not require the operations supervisor's permission for
-*
other dates. However, OAP 9-9, *special Procedures,*
required a SP in *suspended" status to be denoted as such on the SP In Use Record (Form 9-9A), maintained in the Shift Engineer's office. The log indicated that SP 92-4-68 had been in progress since April 4, 199 The failure to ensure the *shift Authorization Sign Off Sheet* was updated _
contributed to operations personnel not being cognizant of the T/.
The licensee subsequently identified 20 additional examples of completed or suspended SPs where the SP In Use Record was denoted as active.. The failure to update the SP In Use Record, as required by OAP 9-1, is considered an example of violation (249/92020-02b(DRP)) of 10 CFR Part 50, Appendix B, Criterion The licensee took ldequate
_
.corrective action including logging out the 21 procedures.in the In Use Record. -
- On a routine basis the inspectors toured accessible areas of the facility to assess worker adherence to*radiation protection
controls and the site security plan, housek~eping or cleanliness, and control of field activities in progress. Observations included:
The housekeeping and cleanliness of the plant was adequate in a number of accessible areas of the facilit Ho~ever, a portable scaffold located on the third floor of the Unit 2 reactor building between two 250VDC MCC*panels was observed unsecure The Shift Engineer was informed of the discrepancy and the scaffold was secure The inspectors continued to observe poor housekeeping in the Unit 2/3 crib hous~.- Previous tnspection reports documented the poor condition of this area, for example:
50-237/91026(DRS); 50-249/91027(DRS) and 50-237/92005(DRP);
50-249/92005(DRP).
The poor condition of the Unit 2/3 fire pump diesel and battery located in the crib house was of particular concer The battery was dirty and covered with
- acid, the battery rack was corroded~ the diesel leaked oil and was dirty, one of two springs holding the exhaust manifold for the supercharger was missing and the electrical cord for the lube oil heater was cracke *
The inspectors reviewed the 2/3 di~sel fire pump weekly.
operability test procedure (DFPS 4123-05). Step 7 of Attachment 3 required the material condition of the area be checked and cleaned as needed and step 6 of Attachment 1 required the battery racks be checked for signs of damage or corrosion. Failure to adequately implement these steps is considered an example of a viol~tion (249/92020-02c(DRP)) of 10 CFR Part 50 Appendix B, Criterion **
The inspectors discussed the observations with the fire chief, who did not consider the conditions significant. The situation was elevated to plant management's attention and appropriate corrective actiOn was taken in that the batteries were cleaned and the responsibility for keeping the batteries clean ~ere. transferred to the Electrical Maintenance shop. These corrective actions adequately addressed the violatio *
The inspectors will continue to as~ess crib house cleanliness as part of the routine inspection progra *
The cleanup of diesel oil in the Unit 3 em~rgericy diesel generator {EOG) room following the July 15th spill
{discussed in paragraph 7.d) was poor. Oil was still standing behind the EOG and on the opposing end of the generator. Once identified to ripefations pe~s~nnel, the situation was rectifie *
On July 20, 1992, a licensee employee was observed asleep while performing firewatch duties. The employee was sitting on a chair with his head and hands slouched over a handrai The licensee investigated and confirmed that the employee was being inattentive to his duties and the employee was discipline *
On July 13, 1992, the inspectors observed two chemistry personnel* in a Unit 2 reactor building contaminated area without pr_otect i ve cover a 11 s or hood Both of th individuals had signed radiation work permit {RWP) 2G003A which stated coveralls and cloth hoods were required to be worn for entry into all contaminated area OAP 12-25, Revision 0, "Radiation Work Permit Program,-" required protective actions, including the use of protective clothing specified in the RWP, to be implemented in the course of performing each jo The personnel involved beHeved the RWP administrative procedure permitted the omission of coveralls and cloth hoods for chemist technicians performing rounds in contaminated areas. After discussing the situation with radiation protection management, the inspectors determined this was an incorrect assumption. Although Dresden Radiological Procedure {DRP) 1620-01, *"Minimal Protective Clothing" provided guidelines when minimal protective clothing could be worn by personnel entering radiological controlled contaminated *areas, it explicitly stated that permission must be obtained from the Radiation Protection Supervisor. Additionally, the procedure only applied to areas with smearable contamination levels below an*average of 22,000 dpm/100 square centimeters. The two chemistry
.
.i"
personnel had not obtained permission from the Radiation Protection Supervisor and had not reviewed the area contamination radiological survey before entering the contaminated area~ This.is considered an example of a
- violation (249/92020-02d(DRP)) of 10 CFR Part 50,
- Appendix 8, Criterion The licensee's corrective actions included (1) Deletion of DRP 1620-01; (2) Incorporation of the use and control of minimal protective clothing into OAP 12-25 by October 1,'
1992;, and (3) Permission for the use of minimal protective*
clothing to be notated on the individual RW These
. corrective actions were adequat *
. On July 8, 1992, i.nspectors found the Unit 2 low pressure coolant injection.CLPCI) A pump vent valve (2-1501-74A),
- designated as a locked closed valve, to be in the correct position, but inadequately locke The inadequate locking
~as brought to shift management attention twice before *
operations management was* notified and the locking configuration was rectified. Problems with locked valves have been previously identified, and the licensee had committed to correct all locked valve discrepancies. The inspectors will followup on the licensee's overall corrective actions in the next. inspection.report perio Walkdowns of select engineered safety features (ESF) were performed. -The ESFs were reviewed for proper valve and electrical alignment Component~ were inspected for leakage, lub~ication,
.abnormal corrosion, ventilation and cooling water supply
- *
availability. Tagouts and jumper records were reviewed for accuracy where appropriat The ESFs reviewed were:
Unit 2
Core Spray System Unit 3
- *
Unit 3 Standby Liquid Control System
Unit 2/3 and Unit 3 EDGs
Unit 3A and 38 Core Spray System
Unit 3 Reactor Building Ventilation System One violation with four examples and no deviations were identified in this are * Monthly Maintenance Observation (62703).
Station maintenance. activities were observed to verify that they were*
conducted in accordance with approved procedures and work packages,
regulatory or industry guidance, and in conformance with T/S limiting conditions for operations (LCOs).
The inspectors verified that approvals were obtained prior to work.initiation, that quality control inspections occurred, that appropriate post-maintenance functional tests or calibrations were performed, that maintenance personnel were qualified, that parts and materials used w~re pro~erly certified; and that proper radiological and fire prevention controls were implemente The status of outstanding jobs was also reviewed to ensure that appropriate priority was as_signed to maintenance of safety-related equipment which could affect system performanc The following maintenance activitie~ were observed and reviewed:
Unit 2
28 LPC I Heat Exchanger Tube Inspect ion and Pl ugg.i ng
Replacement of Battery Charger Wire on the 24/48 Volt DC Battery-Charger Replacement
.
Replacement of Secondary Containment Vent CR 120 relay
2A Condenfate/Condensate Booster Pump Bearing Replacement Unit 3
EOG Fuel Oil Transfer Pump Discharge Check Valve
EOG Day Tank Solenoid Valve Replacement
Reactor Recirculation (RR) Motor Generator Set Brush Replacement
RR Pump Motor Generator Set Tachometer Replacement
- *
RR Master Flow Control Deviation Meter Rep~ir
Orywell Nitrogen Makeup High Flow Alarm Repair Common
Unit 2/3 EOG.Post Maintenance Work Package Review
. Unit 2/3 EOG Crankcase Pressure Switch Troubleshooting and Repair *
Unit 2/3 EOG Crankcase Pressure Switch Work Package Review
Unit 2/3 EOG Five Vear Inspection
Bus 40, EOG 2/3 Breaker to Cubicle 23-1
Unit 2/3 EOG Breaker at Cubicle 23~1
EQ Surveillance of 4KV Breaker at Bus 23-1 Observations were:
a.*
Work package quality was acceptable for the inspection and maintenance tasks performed on the 2/3 EOG subsystems. There were minor instances where forms or checklists were not completely filled out, but these cases were not conditions indicative of, or contributing to, inadequate physical work qualit Review of maintenance on the Bus 40, cubical 23-1, breaker revealed a post maintenance test requirement (PMTRY, specified in the prerequisite section of Dresden electrical surveillance (DES)
- , that did not appear in the body of the surveillance, nor in the post-maintenance test section of the work package. This *.
test requirement ensured the breaker could not be racked out while the breaker was closed and energized and was for personnel safety rather than operational safety. The licerisee was notified of the work package discrepancy and corrective actions were initiate.
.
.
Poor radiological controls were utilized during the 28 LPCI heat exchanger maintenanc The poor practices included:
An unsecured hose crossing the radiological c9ntrol boundary
. Contaminated tools laying across the radiological control boundary
Standing water in the contaminated a~ea and partially submerging the boundary stepoff pad
A tool bag draped over the boundary magenta rope obscuring the contamin~ted area sig *
A radiation 9ccu~rence report on these items was subsequentl initiated by the license On July 21, 1.992, 24/48 Unit 2 battery charger was removed from service to facilitate replacement of a faulty wire. Operations removed the battery charger from service without utilizing an out-of-service checklist or hanging out-of-service tags on the electrical isohtion boundar The Shift Engineer indicated i had been the practice at Dresden Station to utilize human out-of-servi~es (i.e. someone physically present and aware of the out~of service) for equipment *that will be taken o~t of service for a short duration.. The use of human out-of-services appeared to be in contradiction to American National Standard Nl8.7, 1972, and OAP 3-05, "Out-Of-Service and Personal Protection Cards."
ANSI 18.7, Section 5.1.5, Equipment Control Procedures, require out-of-.
service procedures for the control of the equipment to maintain reactor and personnel safety and to avoid unauthorized operation of equipment. These procedures are to incorporate control measures such as locking or tagging to secure and identify equipment in a controlled status. This is~ue is considered unresolved (237/92020-03(DRP)) pending further review of. the licensee's administrative controls and an understanding of the station's commitment to* ANSI 18.7, 1972, Section 5. No violations or deviations were identifie.
Monthly Surveillance Observation C61726)
The inspectors observed required surveillance testing and verified procedural adherence, test equipment calibration, T/S action statement adherence, and proper removal and restoration of affected component The inspectors reviewed completed surveillance packages to ensure that results conformed with T/S and procedure requirements, that there was
..
independent verification of the results, that proper signoffs oc~~rred, and that any test deficiencies were appropriately dispositione The inspectors witnessed portions of the following test activities:
Unit 2
- *
- *
- *
Unit 3
- * * * * *
DIS 1700-0!, Reactor Building Closed Cooling Water. Radiat~on Monitor Calibration and Functional DIS 1700-01, Unit 2 Main Steam Line Radiation Monitoring System Calibration
DOS 6600-01, Diesel Generator Surveillance Test*
DIS 600~4,.Unit 2 Reactor Wide Range ~ressure Transmitter Calibration DES 4153-02, Unit 2 Monthly Emergency Light Battery Maintenance DOS 1500~02, Quarterly Containment Coo)ing Service Water Pump Test for IST Program
.
DES 8300-10, Inspection and Maintenance of 250V Battery Chargers, DIS 1400-04, ECCS Fill Alarm Pressure Switch Data Sheet.
Calibration DIS 287~01, Auto Blow Down Permissive Low Pressure Coolant Injection and Core Spray Pump D~scharge Pressure Switches DTS 82-36, -Full Core LPRM C.alibration DQP 100.:.06, Traversing End Core Probe *"TIP" System Operation DIS 1400-01 Core Spray Pump Test with torus Available DOS 1400-02 Core Spray Valve Operability test DOS 1500-02 CCSW In Service Quarterly Pump Test DOS 1500-08 CCSW Flow Test No violations or deviations were identifie.
Events Followup (93702)
During the inspection period, several events occurred, some of which required prompt notification of the NRC pursuant to 10 CFR 50.7 The inspectors pursued the events onsite with the licensee and with NRC off i c i a 1 s. * In each case, the inspectors reviewed the accuracy and timeliness of the licensee notification, the licensee's corrective actions and that activities were conducted within regulatory requirement The specific events reviewed were: On July 1, 1992, an intermittent loss of power to several control room annunciator panels occurred on Unit The licensee declared an Alert in accordance with their *emergency pla Emergency response areas were appropriately manned and contact with the control room maintained throughout the event. All personnel performed their emergency response duties in a calm, professional manne approximate1y 500 gallons of oil was ~pilled. The licensee's hazardous materials contractor was notified and the oil cle_aned up allowing termination of the Unusual Event..
The events l~ading to the drain valve being open and the length of time taken to cleanup the oil were still under review at the end of the inspection.* This matter is considered unresolved (249/92020-04(DRP)) pending completion.of that revie. On July 24, 1992, the licensee identified that the radiochemistry analysis of a Unit 3 service water (SW) grab sample was misse T/S Table 3.2.4, Action A, required the analysis be performed every 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s-whenever the SW effluent monitor was inoperabl Discussions with the licensee indicated that the SW sample was obtained at approximately 8:00 p.m. on July 23, 199 The analysis was started, but was delayed due to a hypochlorite truck sample requiring analysis; and was not completed prior to shift en The need to complete the analysis was communicated to the oncoming chemist during the turnover period and was written on the turnover sheet. However, it was not performed during the next
,
shift. At approximately 7:30 a.m. on July 24, 1992, a chemistry supervisor discovered that the sample had not been analyze The analysis was satisfactorily completed by 8:33 a.m. that da Several concerns were raised during this event followup:
The licensee believed the T/S 12-hour sample and analysis requirement applied only to sample collection, not to
~ompleting the analysi *
The licensee indicated that the SW effluent monitors were unreliable and that samples were taken every 12*hours, regardless of monitor operability. They further indicated that this twice daily taking of grab samples had been occurring for year * * *
The cognizant technical staff engineer stated that the SW effluent monitors poor. performance was due to the desig Silt, le~ves, and clams often clogged the sampling lines,
- rendering the monitors inoperabl New monitors had been installed in Unit 1 and were being evaluated for effectiveness. However, no date has been set for making this modification, or other changes, on Units 2 and *
NRC inspection report S0-237/92016{DRSS); 50-249/92016{DRSS), paragraph 7, discussed an April 1992 Nuclear Quality Programs audit finding that the SW samples were analyzed twice daily although the monitors were in service. The audit indicated that the station had no confidence that the monitors were capable to read the lower limit of detectability (LLD) as stated in the action
'.
statement in T/S table 3.2.4. In re~ponse to this fi~ding, additional corporate guidance was provided inditattng that the LLD concern was not warranted and that sampling was required only when the monitors were inoperable. *
This matter is considered unresolved (249/92020-05(DRP)), pending review of the process of.ensuring that surveillances and samples are completed within T/S limitations for inoperable monitors, interdepartmental co11111unication of status of inoperable equipment; timeliness to correct the monitors known design problem, and the evaluation of the licensee's investigation and corrective action During the initial inquiry into the missed SW grab sample, the. SCRE indicated the analysis was not required because the SW.
d~tector was* operable~ and that 12-hour grab samples were taken as a precautionary action, due to pqor detector re 1 i ability. The LCO L~g also indicated the SW detecto~-w~s operabl However, the degraded equipment log indicated the monitor was declared inoperable on April 8, 1992 and the reactor operator stated the detector was inoperabl Inspector review of the last performance of DIS 3900-01, "Service Water Effluent Sample Radiation Monitor Function Test," completed on June 30, 1992, indicated the radiation detector was inoperable due to a plugged sample line and T/S.Action Table 3.2.4 was applicable. The testing/procedure cover sheet documented that a SCRE had reviewed the test result Dresden Administrative Procedure (OAP) 7-5, "Operating Logs and Records," requires entries into LCOs be logged in the LCO Lo Failure to follow the administrative control resulted in the SCRE being unaware of the condition and operational status of T/S required equipmen The SCRE indicated the LCO Log had been reserved for those action statements that had a finite time duration. Traditionally,_LCO actions with an indefinite time period, such as the SW monitor have not been entered into the lo This practice was confirmed through interviews with several other SCRE The failure to en*sure limiting condition for operations action statements are entered in the LCO log, per OAP 7-5, is considered an example of a violation of 10 CFR Part 50 Appendix B, Criterion V (249/92020-02e(DRP)).
. Planned corrective actions included the issuance of a memo to the SCREs reinforcing the requirements of OAP 7-5 and incorporation of th~ logging requirements in the training tycle. The proposed corrective actions were adequat On June 24, 1992,.the 1 icensee performed a two-thirds core height interlock instrument surveillance of all LPCI divisions for both units while the swin~ EOG was out-of-service for overhaul. This matter is considered unresolved (237/249-92020-06(DRP)) pending completi~n of the inspectors' revie On June 26, 1992, the licensee identified the pressure/temperature.
curve provided by the NSSS vendor for Unit 2 was nonconservativ The licensee adopted the conservative Unit 3 cur~e until a v~lid Unit 2 curve could be obtaine On June 17, 1992, the licensee identified that the Unit 3 feedwater transient accident analysis, supplied by the fuel vendor, was nonconservative. -The nonconservatism only existed late in core life, which would occur in the spring of 1993.. The licensee took compensatory measures to have the analysis reperformedbefore the nonconservatisms would become a proble One example of a violation and no deviati~ns were identifie * Reqi~nal Request Regional management requested the inspectors to determine if any compression fittings were attached to reactor coolant sjstem pipin Upon review'*of inspection documentation between February 29, 1992, and April 10, 1992, no observance of any portion of the nuclear boiler instrumentation inside of the Unit 3 Drywell containing mechanical type compression fittirigs was observed. All iristrument piping attached to the boiler appeared to be welded socket type connections assembled in accordance with ANSI 831.1 Power Piping Cod No violations or deviations were identifie.
- Followup of Temporary Instructibn CTI> 2515/115. Verification of Plant Records (Closed) TI 2515/1~5: Prior to the inspectors performing the temporary instruction, the licensee performed a similar evaluation paralleling the scope and timeframe established in the TI. Dresden management identified five instances where four non~licensed operators apparently falsified rounds documentatio Four of the instancef involved Unit 1 fuel.pool performance readings and occurred 3/29/92, 4/23/92, 4/24/92, and 6/8/9 The fifth instance involved crib house equipment performance readings and occurred 3/18/9 None of the identified rounds were required by T /S, and none had any safety significance. * I addition, the licensee identified eight other non-licensed operators who performed 20 other rounds associated with the crib house or the Unit I fuel pool faster than management's expectations to assure quality rounds were being performed. Disciplinary action was given to all the non-licensed operators involved, along with prescribing training for all non-licensed operators.- Based upon a review of the licensee's evaluation and results this TI is considered closed. However, the regulatory aspect of the apparent rounds falsifications issue is unresolved pending further NBC review (237/92020-07(DRP)).
No violations or deviations were identifie.. Systematic Ev~lyation Program Items C92701)
NUREG 1403, "Safety Evaluation Report Related to the Full-term Operating License for Dresden Nuclear Power Station,* Table 2.1, identified 22 SEP Integrated Plant. Safety Assessment Report (IPSAR) topic resolutions to be confirmed by the NRC Region II I offic The following item in that report was confirmed as closed by the insp~ctors: Item 13 Topic III ~ 2/2.l.2 (Supp 1), "Wind and Tornado Loadings".
The initial two hours of this scenario ~as similar to that of a station blackout event. The inspectors confirmed the plant procedures _adequately addressed alternate means of shutdown.if components not enclosed *in qualified structures were lost as a result of wind and tornado loadin~s and that the licensee's c~ping procedures were consistent with thos~ for a station blackout event ~s described in a licensee submittal of April 17J 1989, on station blackou The co~pletion for Item 2 Topic II -
3.b~l/4.1~4 is being tracked as Open Item 50-237/89019-0 Licensee verification of closure and final NRC confirmation of Iteml6 Topic VI - 4/4.18.2 and Topic VI - 6/4.19 will be tracked under Open Item (50-237/90027-14{DRP)).
This latter item was in verification review by the license No violations or deviations were identifie.
Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1) during the inspection period and at the conclusion of the.inspection period on July 31, 199 The inspectors summarized the scope and
results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur