IR 05000237/1992036

Insp Repts 50-237/92-36 & 50-249/92-36 on 921215-930204. Violations & Deviation Noted.Major Areas Inspected:Summary of Operations,Operational Safety Verification,Esf Sys Walkdown,Maint & Surveillance Observation

ML17179A749
Person / Time
Site:	Dresden
Issue date:	02/24/1993
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179A746	List: IR 05000237/1992036 ML17179A745 ML17179A747 ML17179A748
References
50-237-92-36, 50-249-92-36, NUDOCS 9303030073
Download: ML17179A749 (36)

Text

. U.S. NUCLEAR REGULATORY COMMISSION. *

REGION III

Report No ~237/92036(DRP); 50-249/92036(DRP)

.

.

Docket ~os. 50-237; 50-249 License Nos. DPR-19; DPR-25 Licensee:

Commonwealth Edison Company Opus West III

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1400 Opus Place Downers Grove, IL 60515 Facility Name~ Dresden Nuclear Power Station~ Units 2 and 3

,

Inspection At:

Morris, IL Inspection Conducted:

December 15; 1992, through February 4, 1993 Inspectors:

M. Leach M. Peck A. M. Stone P. Lougheed D. Butler *

F. Brush R. Zuffa, IllinoiJ Department of Nuclear S~fety Approved By:

f J

..;J-M'i/1 2 P. L. Hiland, Cttief Date Reactor Projects Section lB Inspection Summary,

Inspection from December 15. 1992. through February 4. 1993 lReoort No /92036lDRP); 50-249/92036{DRP))

,

Areas Inspected: This was a routine, unannounced resident inspection of l.icensee action on previous inspection findings; summary of operations; operational safety verification and engineered safety feature (ESF) system walkdown; maintenance and surveillance observation; engineering and technical support observations; licensee event reports (LERs)~ and management meetings~

Results:

Of the seven areas inspected, no violations or deviations were identified in five area One deviation from a SEP commitment wa~ identified in paragraph One design control violation was identified in paragraph.. 930224

• PDR ADOCK 05000237 G

PDR

Assessment of Plant Operations Operators responded well during both transients on Unit C6mmunication of management expectations regarding shift management involvement during startups, quality of operator logs, and identification of problems during surveillances continue to require*management attentio *

Assessm~nt of Radiological Controls Positive work control of the drywell entrance demonstrated a dedicated effort by radiation protection personnel to minimize ove~all personnel radiation exposure in accordance with ALARA principle Assessment of Maintenance and Surveillance Although internal goals were not met, the licensee appeared better organized and prepared for the Unit 2 outage com~ared to prior outages~

No concerns were i~ehtified with the work activities observe Assessment of Engtneerinq and Technical Support The system engineers knowledge on status of assigned modifitation varied considerably and was considered *a weaknes In addition, a. special inspection report, 50-237/92034, specifically evaluated the engineering and technical support are DETAILS Persons Contacted

• ~. Schroeder, Manager, Dresden Station

- *R. Flahive, Technical ~uperintendent

• T. O'tonnor, Assistant Superintendent 1 Maintenance

• D~Antonio, Onsite Quality Verification Superviso~

M. Korchynsky, Operating Engineer J. Koto~ski, Manager of Operations S. Lawson, Op~rating Engineer T. Mohr, Operating Engineer

• D. Saccomando, Nuclear Licensing

• J. Shields, Regulatory Assurance Supervisor R. Stobert, Operating Engineer M. Strait, Technical Staff Supervisor

• B. Viehl, Modification Design Supervisor

• Indicates persons present at the exit interview on February 4, 199 The inspectors also contacted other licensee personnel including memb~rs of *the bperating, maintepance, security, and engineering staf ;

Licen~ee Actions on Previo~s Inspectidn Findintjs (92701. 92702)

- Violations (Open)

Violaticin (237/91035-0l(DRP: Failure to follow administrative procedure The licensee committed to restructure the operations management oversight program by December 20, 199 The ~ommitment was not met due to organizational changes and emergent priorities: Subsequently, the lic~nsee indicated that, followirig a periodic shift engineer meeting~ the program will

begin on January 24, 1993, with the operations policy issued in early Februar Other corrective actions requiring further ins~ector review wer~:

Operator turnover process _

Effectiveness of recurring* equipment problems list

_ Operations improvement team initiati~es

Submittal of a technical specification request on torus.high temperature This viol~tio~ re~ains open pending additional review; (Closed) Violati~n (249/91035-0l(DRP)l:. Lack of cont~inment inte~rity for an operating cycle due to an inadequate post- _ mai~tenance test. The only items remaining open on this item were completion of the post-maintenance testing data base and training on that data base. Training fo~ work analysts was _completed on

.-- January 14, 1993, and the data base was placed into use on January 25, 1993~ The inspector attended a work analyst training program and concluded that the data base was an effective tool for - ensurihg adequate.post-maintenance testing. All of the corrective actions for the violation W~re co~pleted. This item is tlose Unresolved Items (Closed} Unresolved Item (237/249-92026~01CDRP}}: _The Systematic Evalu~tion Program (SEP) Integrated Plant Safety Assessment for Dresden Nuclear Power Station Unit 2, NUREG 0823, issued February 1983 contained a requirement that the low prelsure coolant injection (LPCI) injection valves 1501-22A&B and the core spray injection valves 1402-25A&B be capable of being remote manually closed following an acciden In response to this requirement, Dresden Statio~ re~ponded via letter dated April 14, 1984, and stated that "a modification to the logic circuitry to the 1501-22A and B and 1402~25A and B valves is underway. * Upon completion of these modifications, the leakage ~onditions und~r which these valves should be isolated will be incorporated in the appropriate procedures as part of the modification package."

The licensee confirmed that the electrical logit for the LPCI injection valves 2(3)-1501-22A and B prevented the valves from .being ~anualJY closed followin~ ~ design basis acciden At the end of the inspection, the licensee was still evaluating how the SEP commitment was to.be me The failure to implement manual clo~ure of the LPCI injection valves is a deviation from the SEP commitment (237/249-92036-0l(DRP)). (Closed} Unresolved Item (237/249-92032-0S(DRP}}: Switch ~anipulations performed on the standby gas treatment system control logic placed the system in a ~ondition outside of its design basis. This issue is discussed in paragraph 6 and is considered close * One deviation to a SEP commitment was identifie _j~ Summary of Operations Unit 2 The unit was in cold shutdown at the beginning of the inspection perio On December 19, 1992, the unit was synchronized to the grid after replacement of the 2A reactor recirculation pump sea The unit operated in coastdown condition until January 17, 1993, when the unit was shutdown for the thirteenth refueling outag On January 29, the unit was defuele **

. Unit 3 The unit operated at power levels up to 100 percent powe On December 25, 1992, a turbine trip and subsequent reactor automatic shutdown from 83 percent power occur~ed due to a failed turbine.. vibration trip card.. The card.was replaced and on Dedmiber 29~ 1992, the unit was synchronized to the grid. *

OnJanuary 16, 1993, in accordance with procedures, the operators manually scrammed the unit f9llowing a loss of instrument ai An instrument air dryer inlet valve failed open causing depressurization of the syste On January 21 the unit was synchronized to th,e gri The unit.op~rated at power levels up to 100 percent power for the remainder of the inspection perio * .No viol~ttons or deviations were identtfied.* Plant Operat i o_ns (71707, 71710 & 93702) The inspeitors verified that the facility was operated iri confor~~nce with the licenses and regulatory requirements and that the licensee's management control system was effectively car~ying out responsibilities for safe operation~ During tours of accessible areas of the plant, the inspectors made note of general plant anq equipment conditions, including control of activities in progres Discrepancies were generally corrected in a timely manne * On a sampling basis the inspectors obse~ved control ~oom ~t~ffing and coordination of plant activities; ob~erved operator adherence ~ith procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was . available and observed the frequency of plant and control room visits by station manager The inspectors also monitored various administrative and o:perat i ng record The specific areas observed were:

Engineered Safety Features CESFl Systems Accessible portion~ of ESF systems and support systems components. were inspected to verify operability through observation of

instrumentation and proper valve and electrical *power alignment.* The inspectors also visually inspected components for material condition *

During the inspection period, the following ESF components were walked down: Unit 2 Diesel Generator Unit 3 Diesel Generator Unit 3 High Pressure Coolant Injection System

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Radiation Protection Controls The inspector~ verified that workers _were frillowing health physic's procedures and randomly examined radiation *protecti-0n instrumentation for operability and.calibratio Positive access controls were observed in the Unit 2 drywel Radiation protection ~taff marined ihe drywell entrance to control work activities. Radiatiorrwork permits (RWPs), along with the* identity of those individuaJs logged onto the RWP, were retrieved-from a local computer termi:j1a l. at the drywe 11 entry, and independently verified to ensur~ that each person entering the drywell was performing work activities in accordance with the proper RW Such positive work control of the drywe 11 entrance demonstrated a dedicated effort by radiation protection personnel to mi niini ze over a Tl personnel radiation exposure* in* accordance

• .with as-low-as-reasonably-athiev~ble (ALARA) principle *

Security

D~ring the inspection period, the inspectors monitored the*_ liten~ee's security program to ensure th~t ob~~rved actions were being implemented according totheir approved secur1ty pla Housekeeping and Plant Cleanliness The inspectors monitored the status of housekeeping ~nd plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matte. .

. . During the week of January 11, 1993, the i nspe*ctors toured those areas of the' plant that wer~ being~prepated for the D2Rl3 refueling outage. The in~pectors focused attention on the equipment staging areas, the r~diatioh barriers, and on the overall organization of the outage work areas. *The inspectors found all areas to be clean; and free of excess debris, and well organized with respect to equipment and material storag Operational Events . Unit 3 Automatic Reactor Shutdown due to Faulty Vibration Card Unit 3 main turbine tripped ~n high vibration on beiring #3 resulting in an automatic reactor shutdown from 83 percent power on December 25, 199 No surveillances or ~ignificant maintenance ~ork were ih progress at the time of the shutdow All turbine vibration re~dings were considered norma All systems responded as expected with the exception rif the 3A feedwater regulating valve which locked up in mid-positio The lock up was caused by electronic interference which was resolved through a temporary alteration to the system.*

• The licensee investigation ~on~luded the indicated vibration on thannel #3 was approximately 1 mil (0.001 inch); however, the reference point for a vibration trip had failed to 0 mil Since th~ desi~n logic for a turbine trip on vibration is one-of-one channel, the turbine tripped~ The card wis of original

. installation and had been calibrated bn a refuelirig outage frequency. *The licerisee *che~ked the ~emaining channels and foond . no other problems. The root cause of the card failure had not been determined at the end of the report period. lhe licensee's .. investig~tion and corrective actions will be evaluated thr6ugh the* inspector's review of the associated licensee event repbrt (LER).

The card was replaced, and on December 29, 1992, Unit 3 went critical and was synchronized to the gri nit 3 Manual Shutdown {Sera~) Due to Loss of Instrument Air Unit 3 was manuallj sc~a~med in ~ccordance ~ith station procedures following a loss of instrument air (IA) on January 16, 199 Th outboard main steam isolation valves were also closed in* accordance with ~rocedures. The loss of IA resulted from a failed open inlet valve on the 3A instrument air dryer tower which caused air* to be exhausted out of the system during the normal cycling proces The service air to instrument air (SA/IA) c~osstie valve did not respond quickly enough to compensate for the decreasing pressure in the instrument air sjste Therefore~.when IA system pressure dropped below 55 psi, the* operators m_anually scrammed the reacto *

~ .. . The cause of the inlet valve and SA/IA cro~s tie' valve f~tlores had not been determined at the close of the report perio The licensee replaced the inlet valve and the crosstie valve solenoid and regulator; A special pcist maintenance test was performed to verify the response time of the crosstie valve. The licensee's long term co.rrect i ve act i ans wi 11 be eva l u*ated concurrent with th inspector's LER review.* In addition, the inspector had the follow~ng observations:

• In October 1992 a work request was generated for the SA/IA crosstie valve due to observed sluggish behavior during the quarterly surveillanc In December 1992 the valve response time worsened; however, a problem identification form (PIF)

was not generated to ~lert ~tation management of the degrading condition. Although the work request was not safety relatedr the PIF may.have resul_ted in its*

• reprioritizatio *

Dresden Operating Surveillance (DOS} 4700-01, "Quarterly Service Air to Instrument Air Auto Crosstie," was used as a post maintenance test. The acceptance criteria stited in step I.11.a required that the SA/IA valve open between 80 to

85 psi. However, it appeared that the valve did not open until the pressure was 62 psi indicating that the valve failed the post maintenan~e test. The test was signed off as acceptable although the acceptance criteria was not me The operability of the valve was demonst~ated in the special test conducted by the system enginee This i s*sue is similar to a pre~ious tinresolved item (249/92032-08) and will be further reviewed in a future inspection concurrent with that unresolved ite * The control room operators showed attentivene~s to the panels, good procedural adherence, and conservative actions with respect to reactivity addition * The Shift Control Room Engineer {SCRE) had limited direct involvement in the st~rtup activities. Managemerit expectations on SCRE involvement in startup activities was not effectively communicate The SCRE was expected to devote a majority of oversight to the unit startu The failure to explicitly commuhicate management expectations to the operators was a noted weaknes b.- Asse~sment of Plant Operations O~erators responded well during both transients on Unit Communication of management expectations regarding shift mana~ement involvement ~uring startups~ qualitj of operator logs, and identification of problems during surveillances continued to . ~equire management attentio * No violations or de~iations were identified; howe~er, an additional example of an existing unresolved item was identifie. . . 5, Monthly Maintenance and Surveillance (62703 and 61726) Routinely, station maintenance and surveillance activities were observed

• and/or reviewed to ascertain that thej were conducted in aceordance witb approved procedures, regulatory guides and industry codes or st~ndards, and in conformance with technical specifi~ation The following items were considered during* this review: approvals were obtained prior to initiating the maintenance or surveillance testing activities~ operability requir~ments were met during those activities; fun~tional testing and calib~ations were performed prior to declaring the component operable; discrepancies identified during the activities were resolved prior to returning-the component to service; qualitY control records were maintained; and activities were accomplished by qualified personnel..

• • . ~*.... -

Maint~nance and Surveillance Related Activities The following maintenance activities were observed and associated work packages reviewed:

• Unit 2 Repair of the (2/3 7,510A) standby gas treatment system fl ow control valve Reactor head stud detensioning and removal

. Eddy current testing of the 2A LPCI heat exchanger tubes ATWS master trip unit removal and replacement 3-Way manifold valve replaceme~t on the main steam line isolation switches, CRD leak testing _ RPS EPA breaker 2A-l replacement Unit 3

1. 3 turbine be~ring 1ogic card replacement The inspector also witnessed p6rtions of the following test activities: *

Unit 2 DIS 1700-01 * DIP 0260-01 DIS 0287-01 * DIS 1400-04 Unit 3. DIS. 0700-06 DOS 1400-01 DOS 1400-05 DOS 1500-03. DOS 1500-05 DOS 1500-06 DOS 1500-10 SP 93-1-6 DOS 4700-01 Main Steam Line Rad Monitor Scram and Isolation Functional Test Refueling Instrument Calibration Auto ~low Down Low Pressure Coolant Injection and Core Spray Pressure Switch Calibration . ECCS Keepfill System Alarm Pressure Switch Calibration

APRM Flow Biased Scram, Rod Block, and Downscale Calibration* . Core Spray System Pump Test with The Torus Available Quarterly Core Spray Syste~ In Service Test. Containment Cooling Service Water Pump Test LPCI System Quarterly Flow Rate Test LPCI System Pump Operability Test with Torus Available . Quarterly LPCI Pump Test

• Unit 3 A Instrument Air Dryer Te~t Quarterly se*rvice Air to Instrument Air *Auto Crosstie Test 9 Maintenance and Surveillance Obser~ations Three of Four-Pressure Switches Out of Tolerance On January 1_7, 1993,.three of the four pressure switches for the Unit 3 generator load reject control valve fast acting solenoid valves wer~ found outside techriical specificati6n (TS) table 3. during an outage surveillanc The switches could not be recalibrated and were replace The licensee calibrated the switch~s everj refuelirig outage and during subsequent short outages unless performed within the last three month In October 1992 three switches were found out~of toleranc~ but within TS requirement At that time, the switches were calibrated within toleranc The root cause for the failures had not been determined at the end of the report perio The --

present Barksdale model h~s a large range which c6ntributed to a higher instrument drift. The licensee planned to replace the models with a lower instrument rang The root cause and associated corrective actions will be evaluated during.the inspector's review of the associ*ted LE Low Pressure Cool,ant Injection Systems Inoperable due to Reactor level Switches Out of Tolerance * _ Two reactor water level switches were found. outside of TS

allowance~ on January 13i 1~93, during a routine calibratio Four reactor level switches in a one-of-two twice logic cause the LPCI system to actuate when low reactor water level i~ sense The two switches which were out-of-tolerance~low would have resulted in delayed LPCI actuatio Therefore~ the licen~ee declared the LPCI system inoperabl The level switches were calibr~ted within tolerance and the system was declared operabl The level -switches had a history of failur Discussion with the t~chnical staff engineer fndicated that within the past two years, co-ntacts on the level instruments have-been out-of-tolerance at leait twenty: time However, this was the first.event where a system was required to be dee-hired inoperabl The l ic_ensee previously increased the calibration fr~quency; however, that - action did not alleviate the problem; TS tables 3.2.1 and 3. required the switches to trip within a narrow four inch band; while standard TS specified a lower limit onl The licensee was _considering a TS change to eliminate the upper level limi The change w1ll permit the switches to be reset conservatively to allow for instrument drift. The inspectors will evaluate the - licensee's corrective actions during review of _the associated LE Unit 2 Refueling Outage Preparation Review The inspectors reviewed preparations for the Unit 2 refueling outag Work packages for the motor operated valve (MO.V) upgrades and a sample of maintenance work packages were reviewe Also, the inspector interviewed a number of system engineets, attended

• outage planning meetings, interviewed work analysts, and attended a post maintenance testing training sessio The inspectors concluded the licensee's goal of having all modification and maintenance packages completed one month before the putage was not achieve However, station personnel were better~repared for this outage than the previous outage The in~pector had the following observations:

Modification travell~r (work package) preparation and parts delivery were behind sthedul Most of the modification packag~s were in the onsite review process as of De~ember 17, 1992, (one month before the outage).

However, a number of packages were waiting on issuance of field change requests or engineering modificatibn addenda in order to complete the travellers~ * Tracking of the status of the * modification travelleis was hampered in that multiple groups would status -the travellers as "complete" as soon as the traveller was ready for onsite review~ The onsite review status was tracked informall The licensee acknowledged problems with control of work packages and was in the process of resolving those issue * The licensee shutdown risk program was proactiv Shutdown risk considerations were factored into the daily outage schedule.* Information about risk significant systems was . provided to station personnel in a widely distributed daily handou Systems needing to remain in service to reduce shutdown risk were posted with caution card * . The* system engineer's knowl~dge of assigned modifications* varied considerably, based on the individua Some system engineers had no idea as to the completeness of a

modification on their system; had no idea how many* travellers were involved; or what post-maintenance testing was require Others were extremely involved and fully* cognizant of all details of the modification * Maintenance department work analysts were better prepared for the outag However, post-maintenance testing (PMT) was still a -proble The PMT task force did.a. pre-outage review of PMTs on all work pack~ges, and found some problems with testing requirement The task force requested a PMT audit. by quality verification. Additionally, the task.force implemented a computerized PMT data base. *

• Training of contractors in the applicability of the administrative procedure for independent verification and in work package co~plet1on was comprehen~ive *and appropriate.*

Brief~ngs of operations personnel on the outage goals and the outage organization enhanced communication of management expectation * *

The ins~ectors ~ill c6ntiny~~o observe the outage activities inc 1 ud i ng work p 1 ann"ing, risk management, communication.of expectations, and conduct ~nd control of work_ activitie Unit 2 Refuel Outage 13 Refueling Activities On January 17, 1993, Unit 2 was shutdown for the thirteent refueling.outag The outage was scheduled for a.thirteen week duratio The outage scope included 70 control rod. drive rebuilds, the reactor ves~el water level indication system modification, and rotor modification~ on 40 _safety related MOV. . The inspector reviewed th~ appliiable technical specific~tions and procedures and observed control room and refuel floor activities * prior to and during the core off-loa The experience of the crews involved in the refueling a~tivities was a strengt No major weaknesses were noted during the inspectio One minor weakness was the overlap among the. various procedures that govern refueling activities. A result of this weakn~ss, for example, was that some positions had responsibilities delineat~d in more than one pr.ocedur This was compensated for by the strength noted abov The inspector relayed this concern to the licensee.* The inspector concluded that th~ licensee was conducting refueling activities in a safe manner1and had no further concern~. \\_*' I' Assessment of Maintenance and Surveillance Although internal goals were not met, the licensee appeared better organized and prepared for th~ Unit 2 outage compared to prior outage No concerns were 1dentified with the wofk activities observe No violations or deviations were identifie. Engineering and Technical Support (37700} The inspectors evaluated the extent to which engineering principles and evaluati6ns were i~tegrated into daily plant activities. This was accomplished by assessing the technical staff involvement in non-routin events, outage-related activities, and assigned TS surveillances; observing on-going maintenance work and troubleshooting; and reviewing deviation investigations and root cause determination a: Engineering*and Technical Support Events Unanticipated Shutdo~n of Standby Gas Treatment During Loss of Instrument Air Event Oh January 16, 1993, operators manually scrammed Unit 3 due to a loss of instr~ment ai As expected, th~ SGTS, Train B, received an initiat~oh signal due to low reactor vess~l water level.. About three minutes later, Train B tripped and Train A automatically initiate Investigation showed that on the loss of. instrument air, the SGTS flow controller lost control of the flow control valv Consequently, the flow control valve failed full ope This resulted in a system flow greater than the controller _ setpoint and a demand for valve closur When in~trument air was restored, the controller became operable and forced full closur~ _ * of the flow control valv Tr~in B flow dropped below th~ low - flow setpoint which resulted in Train A initiatidn and Train B trip. *The licensee was reviewing the response provided to Generic Letter 88-1, "Instrument Air System Failures" to assure the stated corrective ~ctions were sufficien Design Basis Requirements of SGTS Not Translated in Procedures As a follow up to LER 249/91015, Revisions 0 and 1, "Unplanned Automatic Initiation of the Standby Gas Treatment System (SGTS) during Reactor Protectidn System Electrical Bus Transfer and * failure of the SGTS to Start during a Preplan*ned Testing Sequen~e," the inspectors. met with the 1 icensee' s cognizant technical staff engineer in order to gain an understanding of the control switch manipulations associated with the SGTS, As

• explained by the system engineer, and as described in the Dresden Operating Procedure (DOP) 7500-01, "Standby Gas Treatment System Operation," it was customary to place one train of SGTS to the "On Position," while pl~cing the non-running train to the "Primary

~osition," during surveillanc~ testing.* With the SGTS operating-in the condition described above, an automatic initiation signal received by the SGTS logic would start the non-running trai With both trains of the SGJS runriing, system air flow would then be split between the trains, causing insuff~cient system air flow and de~energizing the heating coils. The heating coil, as described in section 5.3.2.5 of thi final safety.analysis report (FSAR), was designed to reduce the relative air humi_dity to less than 70 percent of the first high efficiency filter. Opeiation of the SGTS, as described above, would not assure proper operation of the heater under auto~initiation crinditions, until manual operator . action was taken to secure one of the operating train ' .

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• The inspector reviewed historfcal memorandOms and litensee event reports pertinent to the SGT In an August 28, 1987, meeting held between operations and-the technical staff, a discussion was held to determine whether there was a concern if both trains of the SGtS were allowed to run simultaneousl This concern was apparently never resolved by either the technical staff or the

~perations department;

10 CFR Part 50, Appendix B, Criterion III requires, in part, that the regulatory requirements as well as design basis requirements for components be correctly translated into procedures and instructions. *Failure to operate the SGTS iri accordance with design basis requirements as well as regulatory requirements is considered a violation (237/249-92036-02(DRP)) of Appendix B, Criterion II I. The 1 i censee implemented immediate corrective actions to ensure proper lineup of SGT Temporary procedure chariges were completed for DOS 7500-02, ~standby Gas Treatment . System Monthly Surveillance and Operability Test" and DOP 7500-01,* "Standby Gas Treatment Operations."

In addition, a memo was distributed to the operators describing the proced~re changes and the system operation. Discussions with the system engineer and regulatory assurance personnel iridicated th~t procedure revisions were implemented on January 29 and February 1, 1993, for DOS 7500-02 and DOP 7500-01, respectivel The system engineer discussed system operation with training personnel; 'The inspectors conclud~d the completed corrective actions, as discussed above,. were reasonable and satisfactory. lherefcire, no response to this violation is require Assessment of Engineering and Technical Support*

• The system engineers knowledge on status of assigned modification varied considerably and was considered a weaknes In addition, a special inspection report, 50-237/92034, specifically evaluated the engineering a~d technical support are.

.* . One viol~tion was identified for the failure to ensure design . specifications -0f the standby gas treatment systems were included in procedures:. Licensee Event Reports {LERsl Followup {92700) Through direct observations, discussions with lice~see personnel; and review of records, the following event reports were reviewed to - determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to ~revent recurrence had been accomplished in accordance with technical specifications.. The LERs listed bel6w are considered closed:

UNIT 2 LER N DESCRIPTION 237/83062, Rev. 2 High Pressure Coolant Injection Motor Gear Onit Signal Coriverter Amplifier Failur /89029, Rev. 3: Elevated HPCI Discharge Piping Temperature Due to Reactor Feedwatet system Backleakag /90002, Rev. 1: Reactor Scram Fo 11 owing Condensate /Condensate - - Booster Pump Failure and Subsequent Loss of Offs jte Powe /90006, Rev. 1: Target Rock Safety Relief Valve Fails Open Due to a Steam Cut Pilot Valve Dis /91028,_ Rev 0 & 1: Violation of Technical Sp~cification on Torus Water Bulk Temperature Due.to Personn~l Erro /91030, Rev. 0: Spurious Closure of 2A Shutdown Cooling Pump_ Isolation Valve Due to Local Contact Pushbutton Contact Failur Regarding LER Z37/8~029, three corrective actions remained to be verified or completed by the licensee:

• *

Installation of permanent temperature monitor on the HPCI discharge pipin The system engineer will be _evaluating an appropriate design by June 1, 199 * Implementation of an infrared thermography program on the LPCI and Core Spray system *

Entering a 10 year pie~entive ma~ntenance 1nspection into th~ surveillance program for valves 2(3)-2301~7,-8, & -10 before the D3Rl3 refueling outag Completion of the above activities is considered an open item (237/92036-03(DRP)). Regarding LER 237/90002, some outst~nding cotrective actions remained open associated with this LER, including:

Engineering evaluation of condensate and booster pump start logic or setpoint ch~nge * lmpleme~tation of a transformer inspection pla * Engineering evaluation of an improved main generator reverse power trip relay schem *

Completion of a 2 1/2 year balance of plant motor operated valve overhaul progra * Include manual emergency start provisions into the operator * training progra Completion of these actions is considered an open item (237/92036-04(DRP))~ Regarding LER 237/91028, this LER was the-subject of a previous violation (237/91035-0l(DRP)). Tracking of corrective actions to.the LER will be done under the violatio UNIT 3 249/87013, Re /89009, Re /92020, Re /92032, Re : 1: 0: 0: DESCRIPTION

• Manual Reactor Scram Due to Feedwater Oscillations During Surveillance Testin Lo~al Leak Rate Testing Limit Exceeded for

.Primary Containment Isolation Valve Containment ls_olation Valve Closure Due to Inadequate Procedure !~adequate 4Kv degraded voltage setting resulted in the control room air filtration unit booster fans being inoperable due to an tnaccOrate calculational assumptio Regarding LER 249/87013, outstanding corrective act i_ons included:

Increasing the gear ratio ori m6tor operated valve 3-1301~3 during D3Rl3 in January 199 * En~ineering ~valuation on use. of 3-element_reactor vessel level control and ensuing design enhancement * Evaluate for design chang~ to add a switchable current source to facilitate reactor water level step change * Evaluat~ using a digital system for reactor feedwat~r pump minimum flow recirculation valve contro * EVal~~te reducing the difference in reactor water level between high and low level alarm * Implementation of modification Ml2-2(3)-89-004 which moved reactor vessel level reference piping outside containment.

The licensee intended on submitting a LER rev1s1on by March 26, 1993, on this event and status of correcti~e actions. Completion* of these* actions discussed above is conside~ed an open item (249/92036-0S(DRP)). Regarding lER 249/92032 the inspectors discussed the LER with the licensee's nuclear engin~ering department (NED).

NED determined that the air filtration booster fans for the control room ventilation system would have less than the required minimum fan contactor pickup volt~g The contactors utilized were a NEMA size 1 motor starte In previous degraded voltage calculations, CECo had not experienced a degraded voltage problem by increasing the size of the contactor's control power transformer which decreased the transformer internal voltage drop during energization Qf the tontacto The safety significance was minima The booste~ fans were required to be manually started within 40 minutes * of a design basis accident.. This LER was generated as a result of CECo's continuing efforts to resolve previously ide~tified inadequate second level degraded voltage protection concerns (see LER 249/92004).

The inspectors concluded the licensee's cortective actions were adequate and considered this LER close In addition, the inspectors reviewed the licensee's PIFs generated during the inspection period. This was done to monitor the conditions related to plant or personnel performance and potential trends.. PIFs and the results *of the investigations were reviewed to ensure that the forms were generated appropriately and dispositioned in a manner consistent with applitable procedures and the quality assurance manual; No vjolations or deviations were identifie ~ Open Items Open ite~s are matters which have bee~ discussed with the licensee which will be reviewed further by the inspector and which involve some action on ~he part -of the NRC or licensee or both. Three open items disclosed during this inspection are discussed in paragraph 7. * 1 Deviations Deviations are items of failure to satisfy a commitment where the - commitment involved h~s not been made a legally binding requiremen A deviation is discussed in_earagraph * 1 Exit Inte~view (30703) The inspectors met with licensee representatives (denoted in paragraph 1) throughout the inspection period and at the.conclusion of the

inspection on February 4, 1993, to summarize the scope and findings of the inspection activiti~s. The licensee acknowledged the ins~ectors' co~ments. The inspectors also discussed* the likely inform~tional content of the inspection report with regard to documents Or processes reviewed by the inspectors during~the inspectio The licensee did not identify any such documents or prpcesses as proprietar \\.

• • • -

ATTACHMENT A DRESDEN INSPECTION REPORT 50-237{92036;50-249/92036

QUARTERLY STATUS REPORT CHECK LIST FORMAT *USE THE BOl(ER PLATE - it will help with much of th~ check list Left/Right Ma~gins set at 1~ Top/Bottom Margins set at l" 4.' Left Justification O. Widow/Orpha*n Protection - On.. 1. 1.

• . 1.

1 Letter Gothic ll cpi (pro) Qu~rterly Status Report title BOLD Use consistent bullets (ALT-7) [#7 on keypad] (We may change the actual bull et used -- with consistent bullets we can rapidly make changes) Center table information under column headings (Sections: 3, 9, and 12) Stngle line spacing between paragraphs and between paragraphs and next area title Spell out months (except for SALP Rating and Trend table h~adtng) . When using dates, do not use (th,nd,rd,etc) * Example: Correct July 6 Wrong July 6th Under headings with no comments, use None (DO NOT USE A BULLET OR.A PERIOD AT THE END).

Dates onl (1) (3) for report are* all the same -- Use months ~or Branch 1 the periods are: January - March

• (2)

April*~ June; July ~ September (4) October - December Headings for each area consistent Headings for each area underline Headings are in the same order as boil~rplate (follow 9-30-92 format) - 1 Tables use saine column heading titles 19. * * Tables use same name for functional areas 2 Tables - for RI projection -.use.. IMPROVING, CONSTANT, and DECLINING 2 Under "Status of Previous SALP Functional Areas" Pl ace the Funct i ona 1 areas in SALP ORDE PAGE 1 OF 2

CONTENT L. Following the performance indicators there should* be a de~cription of each data point. Count and verify each data point is addresse The frillowing are NOT capitalized names of sy~tems names of departments names of*progr~ms names of documents If bullets are used either use all complete sentences or all incomplete phrase FILE NAME We have had files come into the reg-ion with no site designation contained in the file name and no r~ference as to conte~t. Please 'use the follo~ing fbrmat with transmitting your inpu SITE NAME - REPORT QUARTER NUMBER. QPS exampl~: QUAD-3.QPS

• • • • NEW ITEM****

For EACH DRP open item greater than two years old, please provide in bullet form the subject of each item and when you plan on closing the ite *************** PAGE 2 OF 2 \\

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1 R.EsrnENT rnsPEcToR QUARTERLY sTATus REPORT \\ (SuJ A \\ C (_,~~h~~-~ NUCLEAR POWER STATION * \\ \\L_~SGfl~_t_e_m_~_e_r~.1-6~-t_h_r_o_u_g_h~D~e_c_e_rn_ib_e~r~~--~l-9_9_2~~~----\\ . Summary of Operations Since Last Status Report .Unit 2 *operated -continuously in a coastdowon-condition until the end of the status *period wheri increased reactor recirculation seal leakage, seal pressure swings and increased lea_koff_ temperatures caused the licensee to shutdown the plan The reacto_r recirculation pump continued to experience high vibration from the previous status perio The cause of _the pump performance problems was misalignment of the motor/pump combinatio At the end.of the status period the licensee was preparing to startup the uni The unit is scheduled for refuel outage in mid-January 199 On September 18th a control rod mispositionl.ng event occurred with members of the technical staff presen The event was not properly documented or-reported to appropriate management personnel.. Senior* licensee management and NRC personnel became aware of the event on November 24t Unit 3 operated at >90%. power until October 14th when the unit scramme The scrarruned was initiated by a failed condensate/condensate booster pump motor eventually causing a iow water level condition in the reactor vessel when the operating feedwter pumps tripped on low suction pressure.. The combination of past poor maintenance on the condensate motor, a large oil leak at the windings and paint chips from new material condition initiatives led to overheating the windings and an electrical faul The unit was restarted on October 20t On November 7th operators shut the unit down due to a 40 scfm nitrogen leak into the drywel The leakage-source was a main steam line. isolation valve instrument bloc After repair the unit was restarted on November 9th. * In early December one of the old style reactor feedwater pump seals failed~ One of the stator cooling water pumps was.out of service the whole status perio c: Significant Inspection Findings The licensee completed LOCA containment heat removal analysis on December 1st concluding operation of one LPCI pump and one CCSW pump would provide adequate torus heat removal _capabilit However, the analysis mixes 1969 assumptions associated with increased net positive suction head from the accident pressure with a more realistic decay heat curve from c~rrent power upgrade analysi Also, GE determined the heat exchanger duty originally used in Dresden's licensing bases at original license approval was ponconserva~ive and incorrec GE indicated that other facilities beyond Dresden were effe~ted but was not a serious safety concer In the mid-1980s the licensee installed additional piping to Unit's 2 CCSW system to provide backup cooling the control room HVACC's compresso However, the design change did not properly evaluate this intertie and two of the four CCSW pumps were -inoperable.. The licensee provided untruthful statements supporting a change to Unit 2s pressure/temperature curve The main causal factor was poor oversight of contractor personne An increase in somewhat significant personnel errors is being observed in the lat~r part of this statu~ perio The majority of the errors are

associated with implementation of the o:;*-: of service and equipment status control program These-include (This:.: no~ *an all i.nclusive list): Tagging out the wrong H202 analyze= samFle pump Personnel working an offgas recorr~~-:er =an witho~t it being tagged out Tagging out the heating boiler wi:::.. :ut =-ecognizir.g both diesel fire pumps' batteries would ~ffected re~~ering both f~re pumps inoperabl On October 26th operators vi_olated Tecr~..:.cal Specifica::ions when the swing diesel generator was taken out o!.:erv.:.ce withe~:: performing unloaded runs on th~ redundant, operable _dies-el generator When running one. train of standby gas _t:-eatment per the normal operating procedure and an accident signal were r~:eived the second train of standby gas treatment would also start :-ender ing both t_rains inoperabl Both trains feed a conunon discharge hea~er a~d the discharge flow control damper will modulate flow to 4-000 scfm c.= 200*0 scfm a:: the suction of each fa scfm is insufficient to ~ctua"Ce the heaters for the standby gas treatment filter The big: humidity significantly reduces the filter efficiency for iodin The planning and scheduling succ.ess*es n::'-:ed L'"'l during short duration .outages has no~ translated into daily p~~nniThg and schedulin The licensee is no better at implementing -c:..: established schedule today than six months ag * . "\\(0..-- ,__,)- I I....___,, SALP Ratings and Trends_ SALP Ra-ci=.1;- for SALP :::*::rioc (8/01/91-- 31/S2! R: Projectio o: Trend to Date FUNCTIONAL AREAS 0PLANT OPERATIONS

--- No change C. or..:.srh _ * RADIOLOGICAL.CONTROLS . MAINTENANCE/SURVEILLANCE EMERGENCY PREPAREDNESS SECURITY ENG/TEC SUP~O~T SAFETY ASSESSMENT/ QUALITY VERIFICATION c

2

1

3 Statusof Previous SALP Functional Are:.: NO Change Cons::ant Constant Constant ---~ /_.,.--NO c:-:..;:NGE. -.... \\~'- Cons-: ant "Plant Operations - Generally, control rc*:rn operator perform satisfactoril However, the mispositio:ing event cas-: doubt on operator willingness to take direction without S?.J approval fro=i the Qualified Nuclear Enginee SROs continue to exh.:..:it &ome Technical Specification knowledge deficiencies.* Problems i..*ith eqlipm.ent stat~s control continue and out of service problems *appear to be increasin Engineering and Technical Suppcirt - Sys~em E~gineer performance "continues to be personality dependen Engine-er c..:ility to grasp the significance of technical issues continues to be ha:::;:>ered !::>y the g.;ality of the design base Management overvie~ and guidanc~ i.s ~ccasiona:ly lackin This

• applies to CECO and cont~act engineers.

. Safety Assessment/Quality Verification - Station p~rsonnel appear tc be using the problem identificatio~ portion of the new corrective action system wel Further evalµation is needed on root cause evaluation and establishment of effective corrective action Know:-. commitments are being performed on tim LER quality has been poor* especially when engineering involvement is necessar. Major Planned Activities Affecting the Company or Plant Next Refuering*0Utage Unit 2 Unit 3 01/17/93 01/94 Major Management Changes: The ne~*.site vice president is Mike Lyste, new.Technical Superintendent, Roger Flahive was selected: Major organizational and personnel changes.are expected on December 17t Al Pederson has been assigned as mentor for the Assistant Superintendent for Operation *

• New SRI/RI Concern~

Inability of on-shift Operations management to consistently take the leadership rol Parts Dedication Also, the old concerns have not gone awa Those*arei Licensee preparation for refuel outage Licensee implementation of new Technical Specif icat_ions Condition Adverse.to Quality System Recommended Changes to the Master Inspection Piannina System Augment the Resident Staff with another dedicated individual for the duration of the refuel outag Recommend combined NRR/Region III team inspection of licensee's effcrts to transition into new Technical,;:Specifications (Carryover from pre*.-ious status report) i

• Recommend focused inspection on licensee's design bases programs anc resolution of deficiencies from those program Special emphasis.should be given to matters on which. "white papers" are generate.

New Work Items None Evaluation of Key Performance Indicators Reactor Trips While Critical Safety System Failures ESF Actuations Forced Outages Significant Events Onit 2

0 &>

SSF - Unit 3 - 10/5/92, HPCI Inoperable due to signal converter failure ESF - Unit 2 - i0/15/92, EOG Start while closing undervoltage relay

-. cul:::icle c:::io= ESF - Unit 2 ~ 11/27/52, Stindby Gas Treatment Start due to ope=atc= error E.SF - Unit 3 - 10/l4/S2, Cc:itainment Isolation Valve Closure due tc inadeq-.ia-:e test procedure SE -' Unit 2 - 11/15/92, Licensee determines through test that t1.*o contairur.e:-.t cooling water pumps were inoperable* for a number of years* Summary of Licensee S-:renot~s arid Weaknesses Strengths Reduction of ~ad~aste 3acklog Plant Labeling Imp=ove6ents Power Level_ Decisi~ns ;.:hen Equipment Degraded* Security Per:orr....=.n=e Emergency Plan I~p:ementation Weaknesses. Knowl~dge of Jesign an:5. Licensing Basis Work Pr_actices - Inattention to Detail and Communications Operations (routine ar:-:5. equipment control) System Engineers

• Effectiveness *of ~rre-::tive Action System il~

Open Allegation Stat~s 1 Outstanding Item S-:at~s Division DRP DRS DRSS Total !35

14 Over 2 Years

5

1 Other items as rec-.ieste:: bv D~P Branch/Section Chief-1 PRA Status Projected to ::omplete in 1993

DRESDEN STATUS REPORT November 1992 Significant Events

On November 24, the NRC was notified of an alleged September 18, 1992, control rod mis-positioning event and subsequent cover ~P by two lic~nsed operations and three technical staff. personn~l. Region III initially dispatched a DRS Branch Chief to the site to review the incident along with the resident.* inspector The control rod mis-positfoning allocation was substantiate The event was not record~d in station logs nor w~s ~condition adverse tb quality ~eport generate On November 30, a Region III i~vestigation team began an on-site review of the even The team was lead by the Office of Investigation andwas augmented by techni ca 1 personnel. The 1 i censee maintained management riversight shift coverage until December The NRC

• will continue shift coverage at least until December 1 *.

Unit 3 was shutdown on November 7, due to a drywel 1 pneumati cont~ol system nitrogen leak; A main steam line isolation valve instrument block was identified as the leakage sourc The instrument block was repaired prior to restart on November..0 Significant Inspection Findings

A Technic~l Specification requirement ~as violated when a diesel generator was render inoperable for greater than 90 minutes without testing the redundant trai * * An essential service water system was determined to be inoperable_ for an extended period due to improper flow balancing and an in~dequate system interaction analysis during the design of a control room ventilation *modificatio FollO'llfing flow balancing, the licensee d~termined adequate esse~:ial service water flow to the containment heat removal heat exchanges was availabl The NRC is reviewing the event in regard to earlier identified deficiencies with the containment heat removal heat exchange * An-instrument surveillance for two average po~er range monitor channels was misse.0 Other Events a~d Issues o*n November 5, Hearing Examiners from the Ili inois Commerce Commission

• recommended a $423 millon dollar rate increase for Common~ealth Edison compan This was less than the $483 mi 11 oh do 11 ar increase previously awarded the utility but ov.erturned in state court Final Commerce Commission discussion is expected in Januar)' 1993'. Organizational Issues
• On November 12, the licensee anno~nced the selection of Hike Ly~ter as the Dresden Site Vice Pr~sident. The transitional period b~gan on Nov~mber 16 ahd will continue until December 17, at w~ich time the vie~ presiderit ~ill assume site*

responsibilitie * The Technical Superintendent, Sig Berg, was re-assigned as the site Vice President at the Braidwood Statio Mr~ Berg w~s replaced by Roger Flahive.* Al ~Pedersen, Operations Consultant, was ass-i gned to coach the Assist ant Superintendent for Ope rat i an * On November 16, the new site vice presidents began a formulation process to collectively establish norms and expectations for the position, including action and prioritiei for ~ompletion of th~ integrated management action plan (H~AP). The IMAP has bee developed to thart the course for fundamental change in the way licensee does business and to achieve the goals of consistent performance for all the nuclear station Proposed changes will be presented to the Commonwealth Edison Cocnpany Board of Directors on December 16.. Personnel Issues Non.0 Improvement Program Status & Effectiveness Update

• Management [xpectations: Ongoing effort to clarify expectations

~nd initiate appropri~te action when expectations are not me Manageme~t expectations as~ociated with work control are not being llle * Communicationi: Unit operators failed to log several alarm Morning Plan-of-the-Day meetings have significantly improved in qua 1 ity and conten * Prbcedure.Adherence:. One instance of personnel not following* procedures was observe Howev~r, the general station population appears fo have a good concept regarding procedure adherenc * Procedure Quality: Backlog of procedures revisions has been reduced.to 66 The backlog of temporary procedures changes revisions has been reduced to 7 The procedure upgrade program is 80% complet * Engineering and Licensing:- Technical Specification changes/upgrades are*three weeks behind schedule due to lack of operations support in reviewing the Technical Specification change An operations person was dedicated to the review effort in mid Novembe.0. Public Interest Issues

The Morris Daily Herald reported on November i that Dresden was improving faster than*expecte The article was based on the NRC press conference following the Dresden Oversig~t Tean exit meetin * Several local-radio station~. broadcasted details of the rod mis-position allegatio.0 Followup Items from Previous. Reports*

The resident staff is waiting for NRR review or licensee calculations which supported the isolation of all the emergen~y core cooling system_ room coo1 ers from the qua i j fi ed.ater source.,

. The NRC completed review of.the EDSFI degraded voltage concerns and concluded enforcement acti9n~ w~re not warranted~ 9.0 * Oth~r Items of Int~rest. * '*

' \\.' :.

Unit 3 was derated much of the month due to a feed"Wa:er regulating valve anomal * On November 27, a SBGT train was inadvertent s:arted due to personnel erro * The site INPO eva.l uat i ori was performed No-..O!nber -

hr::*~gh November 2 *

On November 18, the licensee received a 3-:.iy 11:~'ance from the discharge water temperature limits by the :*1i~2': En11ironmental Protection Agenc The variance was sough: to ~:air a lift-station transforme Unit 3 was derated a:*:rox~di.:-::ely 50% power* while th~ variarice was in effec * On November 24, a contractor supervisor te~:ed ~=~iti112 for alcohol on a random fitness for duty test. Als.::: nor.*-licensed operator tested positive for alcoho * On November 10, a Hz/Oz analyzer a control ::"itu, "as found in the incorrect position during the performance :.: a si.:**1eillanc The problem was associated with an out-of-serv*:e err~~.

On November 13r the inctirrect H~/02 monitor :ratr "as removed from* service due to.an out-of-~ervice check lis: err8 * On N~vember 7, while performing a Unit 3 d*!well.;~try during shutdow~, *the outer drywe 11. interlock door "as '7:.nd o,:ie The inspectors are following this even * November 6, operations personnel* failed to nainta'1 th*2 one psid - drywell to torus pressure as required by T;-:rinic=.- Spe*:ifications

• • • DRESDEN STATUS REPORT October 1992 Significant Events

Unit 2 operation remained ~t power thrc:iughout th~ month.* Due to

• fuel burnup end-of-1 i fe cc:insioerat ions coast.:.down began on October 1 *

When at power Unit 3 was derated the entire month due to feedwater flow transmitter irregularitie On October 14, the Unit scrammed

• when* a condensate/condensate booster pump motor* failed tripping the reactor feedwater pumps on low suction pressure and initiating RPS on low reactor ve~sel water leve Group II and Group III containment isolations also occurred as a result of the low reactor water level. 'The unit was restarted on October 2 *

On October 8, CECo received a 10 CFR 21 notification on Browri Boveri relays stating the relays ~~re no longer qualifi~d fof high radiation field These relays are used to sense degraded grid ~oltage causing the normal power supply breakers to the ~mergency diesel generatbr buses to.'trip open (starting the emergency diesel generators).

Engineering review determined the high radiation fields caused by shine from core spray piping exceeded the lower radiation dos~ qualification of th~ degraded grid relay Subsequently, on Octo.ber 27 operators pl aced the applicable core . sp~ay pump on both tinits in "pull to lo~k" rendering those. divisibns i~operable and maintaining the degraded grid relays operabl On October 31, the limiting radiation dose components of the relays were replaced and the Core Spray pumps were returned to servic kNRC Waiver of Compliance was granted allowing the relay replacement without shutting dow * Significant Inspettion Findings

Inadequate essential serv-ice water flow was identified due to the installation a number of years ago of two poorly analyzed byp~ss lines. These lines divert flow from t~e containment cooling service water discharge header to the control room air handling unit refrigeration condensing units during a loss of instrument air. The licensee isolated the Jines and declared the control room air handling system inoperabl * An unauthorized modifioation to the HPCI motor gear unit (MGU) annunciator circuit.was identifie The modificatic:in prevented a* failure of the MGU from annunciating in the main control roo It appears the circuit was modified an indeterminate peripd in the pas. 1

On October 20, during Unit 3 startup, Operations personnel observed a level drop.on the secondary side of the isolation condense The level drop occurred when the primary side boiled ~ff the.secondary side water due to a failure to properly fill and Vent the isolation condenser tubes prior to unit restar As a result of the ~ost scr~m review the licensee had identified a leaking isolation condenser valve which shorted Out an -- intermediate range neutron monitoring chann~l. A p~rtial draind6wn of the system w~s necessary to effect valve repair-and post maintenance testin * Other Events and Issues

On October 5, the Regional Administrator.met with the Senior Vice President of Commonwealth Edison Company (CECo) to dis~uss the development and implem~ntation of the Integrated Action Pl~n (lMAP) at Dresde The IMAP provides was developed to address

• corporate pe~formance issues identified by NRC, CECo management; and various industry con~ultant *

On Ociober 6, CECo Engineering determined inadequat~ voltage was* available to a main control room.HVAC relay contacto During the degraded voltage calculation program this typ~ of contactor wa~ not analyze The licensee iricorrectly assumed circuits with this type contactor were within bounding assumption Corrective action inc 1 uded rep 1 acement of the c'ontactors and control power transformer * On October 9, the Iilinois Radioactive Waste Revi~w Commission rejected the proposed low level radioactive waste disposal facility site in Mattinvill~, Illinoi Contingent plans have been formulated to suspend all radwaste shipments for up to two year *

• Ori October shutdow jumpers in attributed 14, a Unit 3 partial Group I Isolation o~curred during The ESF occurred while an electrician was installing preparation for the MSIV fail-safe test. *The event was to an inadequate procedur *

On October 15, Regio~ Ill, DRSS Management met at the station to discuss planned improvement~ to the radiation protection program with the license ** On October is; the ~/3 Diesel Gene~ator auto-started, Group II and Group III isolatiori valves closed and the SBGT system initiat~d when an operator closed the diesel's auxiliary relay compartmen The event-was attributed to improperly mounted undervoltage relays on the auxiliary compartment door causing them to actuat. ' o On (ctober 23, the licensee determined standby gas treatment sys:2m (SBGT) flow would exceed Technical Specification jeq~irements following a loss of controlled air during a.design .basis acciden The 1 icensee performed an operability analysis concluding the system was operable based on an analytical demonstration of 10 CFR 100 guidelines and GDC 19 requirement * On Cctober 24, an inadvertent reacto~ building isolation and SBGT system initiation occurred when an Instrument Mechanic ~nacvertently tripped the reactor building*affluerit radiation IJl()nitor while performing a surveillance on the fuel pool monito The event was attributed to personnel erro *

During the Unit 3 forced outage, planning and scheduling provided _a d.~ i l y safety* assessment of shutdown r.i sk.. The risk assessment ~as discus~ed at each "flan of the Day",meeting and emphasis ~as placed on the identification of thos~ scheduled. a~tivitie~ which con:r~buted to shutdown risk: Additionally, a st~tus sheet wis incorporated into the daily outage schedul * During Unit 3.restart activities, INPO provided three representatives to monitor startup activitie The representatives indicated-more review of work control is neede.0 Orqanizat~onal Issues

Jan Gilligan; Shift Enginee~, and Andy Speroff, Operation Staff Engi~eer were assigned to the newly created positions of Assistant Operating Engineer Mr. Gilligan was replaced on shift by Th6nis Burns,*Operations Staff Enginee * Personnel Issue~

• .

Some supervisors on the radiation protection department were trc.r.sfere * Terri Bennett, a key individual in the operations radwa~te orga~izat.ion transferred to electri~al maintenant * Improveme~t Proaram Status & Effectiveness Update . .

Mana*3ement Expectations: Ongoing effort to clarify expectations . and initiate appropriate action ~hen expectations are not me Hea6~ay is being achieved. . * Cormunication$: Shift engineer log quality improved with a minor deciine in unit operator log quality. *Morning.Plan-of-the-Day meetings have significantly improved in quality and conten * Procedure Adhere~ce: N6 instances of personnel not following procedures were observe The general station population appears . to t.~ve a good concept regarding procedure adherenc * Procedure Quality: Backlog of ~rocedures revisions has been reduced to 77 The backlog of t~mporary procedures changes revisions has been reduced to -8 The procedur~ upgrade program is 77% complete. * ~ Engineering and Licensing: Technical Specification changes/upgrades continued o~ ~chedul VAT corr~ctive action plans are in progres A technical staff task force has been formed to help institute a re-organizatio~ and functional improvements of the techni.ca l staff. A consultant from TENN ERA Company, Roger -Karsk, has been provided t~ assist in the technical staff re-organizatio.0 Publit Interest Issues On October 20, the SALP 11 meeting was held at the Station. -In attendance was the Regional Administrator and the CEO for-the utilit During the meeting; the licens~e concurred with the ~RC evaluatio Some media interest was note.0 Follo~up Items from Previoui Reports The resident staff is waiting for NRR reviw of licensee calculations which supported the* isolation of all the emergency tore cooling system room coolers from the qualified water sourc * Other Items from Pre*vious Reports

After further NRC.review the Generic Letter was considered a waiver of compliance for the "deficient* valve However, operations was unaware of the deficient motor operating valves (MOVs) identified in the response to Generic Letter 8~-10, Supp 1 ement The licensee deviated from _a comi tment outlined in a Safety Assessment (SA) provided to the NRC to trair, operation personnel on the MOV deficiencie The SA addressed the risk factors for continued reactor operati~n pripr to the correcti~n of the deficiencie *

On October 23, an Enforcement Conference was.held at Region III to discuss the EDSFI degr~ded voltage concerns.. The NRC is still evaluating the licensee's respons ~*- ~---

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due to personnel erro The Technical Specification LCO was not violate * A LPCI containment spray vent valv~ was found locked open inste~d of locked close *. I \\ i.. 7 }}