IR 05000237/1993011
| ML17179A840 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/02/1993 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17179A837 | List: |
| References | |
| 50-237-93-11, 50-249-93-11, NUDOCS 9304140135 | |
| Download: ML17179A840 (18) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-237/930ll(DRP); 50-249/930ll(ORP)
Docket Nos. 50-237; 50-249 Licensee:
Commonwealth Edison Company Opus West III 1400 Opus Place - Suite 300 Downers Grove, IL 60515 License Nos. DPR-19; OPR-25 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Morris, IL Inspection Conducted:
February 5 through March 15, 1993 Inspectors:
Approved By:
Inspection Summary M. Leach M. Peck A. M. Stone R. Langstaff I. Yin R. Zuffa, Illinois Department of Nuclear P. L. Hiland, Chief Reactor Projects Section 18 Inspection from February 5 through March 15, 1993 (Report Nos. 50-237/930ll(DRP); 50-249/930ll(DRP))
Areas Inspected: Routine,.unannounced resident inspection of licensee 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 obser~ations; safety assessment and quality verification; and management meeting Results: Of the seven areas inspected, no violations or deviations were identified in four area One violation concerning the failure to maintain control of equipment was identified in paragraph Two non-cited violations concerning delayed NRC notification and failure to timely post a notification of violation were identified in paragraphs 4.a and One deviation from a Regulatory Guide 1.97 commitment was identified in paragraph 6.a.
9304140135 930406 PDR ADOCK 05000237 G
PDR I
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Assessment of Plant Operations Operators responded well during the Unit 3 automatic shutdow The new control room outage structure had a positive effect on work contro The shift engineers were conducting one-on-one discussions with_opetations personnel to reenforce self checking and to communicate expectations. This effort was initiated to improve operator performance and reduce personnel error Assessment of Radiological Controls Work practices were mixe Examples of good controls were observed in the drywell, but poor control of hoses and cables in contaminated areas was also observe *
Assessment of Maintenance and Surveillance The conduct of the Unit 2 refuelling outage was significantly better than previous outage The licensee responded well to the Unit 3 forced outage and coordinated work well for both unit Assessment of Engineering and Technical Support The knowledge and experience level of system engineers has been increased in two way First, experienced people have been moved into the technical staff from other department Second, staff within the technical department have been reassigned such that previous supervisors are now working level engineer Assessment of Self Assessment and Quality Verification The self-identification of prbblems by some departments through the PIF process did not consistently meet licensee expectations.
- * DETAILS Persons Contacted C. Schroeder, Manager, Dresden Station
- E. Carroll, Chemistry Supervisor
- A. D'Antonio. Quality Verification Supervisor
- N. Digrindakis, Technical Staff
- R. Flahive, Technical Superintendent
- B. Gurley, NRC Coordinator F. Kapwischer, Services Superintendent M. Korchynsky, Senior Operating Engineer
- J. Kotowski, Manager of Operations
- G. Kusnik, Quality Control Supervisor
- S. Lawson, Operating Engineer T. Mohr, Operating Engineer
- T. O'Connor, Assistant Superintendent, Maintenance
- 0. Saccomando, Performance Assistant Administrator
- J. Shields, Regulatory Assurance Supervisor R. Stobert, Operating Engineer M. Strait, Technical Staff Supervisor
- B. Viehl, Nuclear Engineering Department Supervisor
- Indicates persons present at the exit interview on March 15, 1993.
The inspectors also contacted other licensee personnel including members of the operating, maintenance, security, and engineering staf Licensee Actions on Previous Inspection Findings (92701, 92702)
Violations
{Closed) Violation (249/91036-0l{DRS)):
Inadequate c~rrective action taken to identify the source of and eliminate leakage from the drywell liner sand pocket region into the torus basemen Leakage through that pathway had the potential to corrode the containment liner in an inaccessible are Corrective action included measurement of the containment liner thickness, investigation of the leakage, and revision of the drywell liner leakage surveillance procedure, DTS 1600- No significant degradation of the containment liner was detected from the ultrasonic testing measurements taken in 1992 when compared to those taken in 198 Although the cause of the leakage had not been determined by the time of the current inspection, the licensee suspected the dryer separator.pit to be the sourc The licensee planned additional investigation during the next Unit 3 refueling outag Licensee action taken in response to water observed coming from Unit 2 Penetration X-130 in September 1992 was appropriat The water was determined to be condensation due to the temperature and humidity conditions in the penetratio No additional water or similar temperature and humidity conditions were observed by licensee monitoring
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of the penetration area through November 199 The suspected source of the moisture was leakage into the drywell liner area from the refueling cavit Stains on the wall below the_ penetration indicated that leakage from the penetration had previously occurred which was consistent with the history of leakage into the drywell liner are Similar stains were identified for Unit 3 Penetrations X-134 and X-14 Because the licensee was addressing the leakage into the drywell liner areas for both units, the inspectors considered the licensee's actions of monitoring for additional water from this penetration area appropriat Based on the corrective actions planned and taken, this violation is close Unresolved Item~
(Closed) Unresolved Item (237/249-92032-09(DRP)):
Numerous equipment status or out-of-service problem This item is closed as part of the inspection activities described in section The licensee's continuing corrective actions will be tracked under the violation discussed in paragraph Inspector Followup Items (Closed) Inspector Followup Item (237/91029-0l(DRS)):
Various concerns with respect to emergency operating procedures including: operator use of the net positive suction head curves for the emergency core cooling system pumps, the net positive suction head supporting calculations, and inappropriate values for maximum safe temperatures and radiation level The inspectors reviewed the revised emergency operating procedures;_
which included separate curves for one pump and two pump configurations, and new values for maximum safe temperature and radiation level The maximum safe radiation levels were raised to 1250 millirem per hour and the maximum safe temperatures were raised to 210 degrees fahrenheit in enclosed area The inspectors also reviewed a l-0w pressure coolant injection lesson plan for licensed operator continuing training which explained the use of the revised net positive suction head curves, and a sample of net positive suction head examination questions which were used in tests following the training. The inspectors also reviewed calculation Chron # 193514, rev 0, "Torus Bulk Temperature ECCS NPSH Limits.
The inspectors had no further question This item is closed; (Closed) Inspector Followup Item (237/91029-02(0RS)):
Differences between the plant specific technical guide and the emergency operating procedure The licensee developed a document titled 11Derivation of the Dresden Emergency Operating Procedures, 11 Draft B, February 1, 199 This document provided an emergency operating procedure to plant specific technical guide comparison with descriptive comment The document had been accepted by the licensee and was maintained in draft form while other enhancements were considered for incorporatio The inspectors reviewed the comparison document and found it provided
- sufficient explanation for the differences between the procedures and the technical guid This item is close **
(Closed) Inspector Followup Item (237/91029-03(DRS)):
Exit criteria for emergency operating procedure The licensee developed specific guidance which stated when an emergency operating procedure may be exite The inspectors reviewed this guidance and the licensed operator continuing training lesson plan which addressed this topi The inspectors had no further questions. This item is close (Closed) Inspector Followup Item (237/88022-0l(DRP); 249/88023-0l(DRP)):
Licensee initiative to incorporate human factors into maintenance procedure The licensee was revising all procedures.to include technical and human factors concerns. This process was essentially complet The resident inspectors will review the adequacy of these procedures as part of the normal inspection progra This item is close No deviations were identified; however, inspector followup of an unresolved item regarding equipment out-of-service problems, discussed below in paragraph 4.a, resulted in the issuance of a Notice of Violatio.
Summary of Operati~ns Unit 2 The unit was in cold shutdown and defueled for the entire inspection perio Unit 3 The unit operated at power levels up to 100 percent power until February 26, 1993, when the reactor automatically shutdown from high reactor pressur Investigation showed substantial damage to the first stage high pressure turbine as discussed in paragraph 4.a. The unit was in cold shut down for the remainder of the perio No violations or deviations were identifie.
Plant Operations (71707, 71710 & 93702)
Tours of accessible areas of the plant were conducted to observe plant equipment conditions including potential fire hazards, fluid leaks and excessive vibration, and to verify that equipment discrepancies were noted and being resolved by the license The inspectors observed plant housekeeping and cleanliness conditions and observed implementation of radiation protection and physical security plant control *
On a sampling basis the inspectors observed control room staffing and coordination of plant activities; observed operator adherence to procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was
available and observed station manager The and operating record licensed operators for the frequency of plant and control room visits by inspectors also monitored various administrative The licensee maintained additional senior Unit 2 outage operations managemen The specific areas observed were:
Engineered Safety Features (ESF) Systems Accessible portions of ESF systems and associated support components were inspected to verify operability through observation of instrumentation and proper valve and electrical power alignmen The inspectors also visually inspected components for material conditions. Specifically, the following systems were inspected by direct field observations:
Unit 2 Unit 2 Diesel Generator Reactor Protection System (RPS)
Anticipated Transient Without Scram (ATWS) Logic Unit 3 Unit 3 Diesel Generator RPS ATWS Logic
Radiation Protection Controls The inspectors verified that workers were following health physics procedures and randomly examined radiation protection instrumentation for operability and calibratio On March 11, 1993, the inspector entered the Unit 2 Drywell to perform a general inspection of the drywell work area While the inspector was in the drywell, a pneumatic hose became uncoupled creating a personnel safety as well as an airborne particulate concer The air supply was secured and the hose recouple The air hose uncoupled a second time and the Drywell Radiation Protection Supervisor called for an immediate cessation of all drywell work and an immediate evacuation. The inspector considered the positive command and control of the work activities to be effectiv During the period, the inspectors noted a weakness in defining contaminated boundarie On several occasions, hoses and cables crossed in and out of contaminated boundaries. This weakness was discussed with the licensee and corrective actions were implemented.
Security During the inspection period, the inspectors monitored the licensee's security program to ensure that observed actions were being implemented according to the approved security pla No discrepancies wer~ identifie *
Housekeeping and Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign materja On March 10, 1993, during a Unit 2 Orywell inspection, the inspector noticed that an orange shutdown safety management
Protect~d Pathway" component sign was lying on a peripheral structural steel support member in the drywel The caution sign referenced the 2A Electromagnetic Relief Valve, but was not attached to the valve assembl The inspector informed a staff m~mber of the Work Planning Department of the caution sig The 2A Electromagnetic Relief Valve was deemed no longer a protected pathway and the caution sign was subsequently removed from the drywel Dresden Administrative Procedure (OAP) 18-05, -"Shutdown Risk Management," section F.l.d stated: "Work Planning will assist Operations in hanging of Protected Pathway Component Caution signs for significant equipment during refuel outages in order to provide greater awareness of protected pathway equipment."
The procedure did not state the responsible organization for removing the caution sign(s) when a component no longer constituted a protected pathwa The inspectors discussed with licensee management the need to assure administrative control of the protected pathway component sign~. Operational Events Inadequate Equipment Control An inspection in December 1992 identified equipment status or out-of-service problems (Unresolved Item 237/249-92032-09) which occurred during November and Decembe The inspectors reviewed additional equipment control or out-of-service problems identified by the licensee during the current inspection perio Since November 1992 these problems included:
On November 13, 1992, the out-of-service card for the 2A hydrogen oxygen analyzer sample pump electrical breaker was attached to the 2B sample pump breake This resulted in
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- the 2B sample pump being inoperable without operations knowledg On December 5, 1992, the 2B off gas recombiner exhaust fan was found disassembled without an out-of-service tagou On December 10, 1992, the out-bf-service tagout to support maintenance for Unit 3 duct work was complete On December 14 the shift engineer determined that the Unit 3 south turbine building vent was not "caution card" tagged as required by the out-of-service tagou Additional review showed that only the first of the two page out-of-service tagout was complete This event initiated a further licensee review of the out-of-service program which identified out-of-service cards hung on the wrong uni On January 31, 1993, two out-of-service cards were found on each of the control switches for two low pressure coolant injection valves (2-1501-5C & 50).
One card on each valve required the valves to be open and the other card required the valves to be close On February 8, 1993, a contractor electrician was observed determinating and terminating 480 volt power cables with only a "caution card" on the motor control center breake The cables were to supply temporary power to the Unit 2 drywel On February 20, 1993, a half scram and a half Group II and Group III isolation. occurred on Unit 3 when an operator performing an out-of-service opened the breaker feeding panel 2203 - 73B instead of the breaker feeding panel 2202 - 73 On March l, 1993, a Unit 3 high pressure coolant injection drain pot high level annunciator was receive An operator discovered the inlet valve to the drain bypass was close The normal position of this valve was locked open and the valve was checked in this position by the same operator and a shift foreman the previous da Although individually these discrepancies were not safety significant, the repetitive failure to maintain equipment control was a concer Technical Specification 6.2.A.l required written procedures for equipment control to be implemente The applicable procedures were Dresden Administrative Procedure (OAP)
03-05, "Out-Of-Service and Personnel Protection Cards," and OAP 07-14, "Control and Criteria for Locked Equipment and Valves."
Failure to maintain adequate control of equipment as discussed above is considered a Violation (237/93011-0l(DRP)) of TS 6.2. **
The licensee was investigating possible changes to the out-of-service procedure and the use of an improved computer syste Delayed Report to the NRC At 1620 on January 22, 1993, the licensee notified the National Response Center, and state and local government agencies of a 20 gallon mineral oil spill. The licensee notified the NRC at 1550 on January 23, 1993, via an emergency notification system (ENS)
phone cal CFR 50.72 requires the NRC be notified within.fou hours of any notification to government agencie The licensee identified this discrepancy and immediately processed a revision to the licensee's reportability manual to clarify the requiremen Failure to provide the required notification is considered a violation of 10 CFR 50.7 However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.(l) of the "General Statement of Policy and Procedures for NRC Enforcement Actions," (10 CFR Part 2, Appendix C (1992)), were satisfie No response is require Prompt Response to Concentrated Waste Spill On February 10, 1993, while transferring concentrated waste to a liner for solidification, approximately 150 gallons spilled onto the radwaste North bay floo The licensee immediately_ stopped the transfer process and initiated actions to contain the spill to mitigate radiological consequence The spill was cleaned up within a few hour The inspectors verified proper radiological control and work practices were use The root cause of the spill was personnel error, in that, the contractor operator failed to verify proper hose lineup prior to commencing the transfer. Contributing factors included poor housekeeping and difficulty in hose identification. Several hoses of similar size and color were found intertwined which resulted in the wrong hose hooked up to the transfer apparatu The licensee implemented corrective actions including rerouting and color coding the various hose The procedure was revised to transfer a small quantity of water to verify proper lineup prior to transferring concentrated wast Based on the licensee's corrective actions, the inspectors had no concern Unit 3 Automatic Shutdown due to High Pressur~ Turbine Failure On February 26, 1993, Unit 3 automatically shut down from 100 percent power due to high reactor pressure. Shortly before the shutdown, control room operators received a computer alarm for high turbine inlet pressure and observed turbine control valves trending ope The operators reduced turbine load approximately five MWe and observed the control valve position stabiliz The control valves again trended open and the operators rapidly reduced turbine load by 50 MWe; however, reactor pressure reached
the high pressure setpoint resulting in an automatic reactor shutdow All equipment performed as expected with the exception of the steam tunnel coolers which turned of Post shutdown review of the transient analysis recorder system sbowed the high pressure turbine first'stage pressure increased and the exhaust pressure decreased which indicated flow blockag Disassembly of the turbine showed the generator side stationary diaphragm blades almost completely closed and the rotating blades significantly damage A piece of metal approximately two inches in diameter was found between the rotating and stationary blade In addition a six inch long by one and one quarter inch diameter bolt and a two inch piece of hexagonal stock were lodged in the turbine side stationary blading. A slug wrench was found at the base of the casin The licensee concluded that the slug wrench, hexagonal stock and bolt displaced metal through the stationary blades to the rotating blade The damage to the stationary blades was caused by the displaced metal impacting the blade The licensee identified the bolt was an internal bolt for a control valve; however, due to the configuration of the control valves, the licensee concluded the bolt was not from a currently installed valv The determination of how and when the foreign material entered the system was under investigation at the end of the inspection perio The inspectors performed an initial review of the licensee's investigation and event followup. The post shutdown report, operating logs, and pertinent alarm printers were reviewed to verify all engineered safety features functioned properly, including RP Operators responded well and brought the unit to a stable post-shutdown condition.. The licensee formed a team consisting of technical staff, turbine generator site representatives, and corporate personnel to conduct a root cause investigatio The post shutdown review was well performed with complete and accurate documentatio The licensee's root cause evaluation and corrective actions will be evaluated concurrent with the inspectors' licensee event report revie Assessment of Plant Operations Operators responded well during the Unit 3 automatic shutdow The new control room outage structure had a positive effect on work contro The shift engineers were conducting one-on-one discussions with operations personnel to reenforce self checking and to communicate expectations. This effort was intended to improve operator performance and reduce personnel error One violation for the failure to maintain control of equipment was identifie One non-cited violation (NCV) regarding late NRC notification was identified.
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Monthly Maintenance and Surveillance (62703 and 61726)
Routinely, station maintenance and surveillance activities were observed and/or reviewed to as~ertain that they were conducted tn accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specification The following items were considered during this review: approvals were obtained prior to initiating the maintenance work or surveillance testing and that operability requirements were met during such activities; functionai testing and calibrations 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 personne * Maintenance and Surveillance Related Activities The following.maintenance activities were observed and associated work packages reviewed:
Unit 2 Rebuild of 2-1501-22A Valve Rebuild of 2-1001-lA and B Valves 2A/B LPCI Heat Exchanger Tube Replacement 2A Reactor Recirculation Pump Motor Removal/Replacement MS IV Rebuild 2B and 2C CCSW Pump Rebuild RPS EPA Breaker 2A-l Replacement Shroud Access Cover Replacement Control Rod Drive Accumulator Replacement High Pressure Coolant Injection Turbine Overhaul Unit 2 Diesel Engine Circulating Oil Pump Replacement 2-1501-27A and B Valve Overhaul Standby Liquid Control Heat Tracing Replacement HCU 38-03 Seal Tight repair *
CCSW flow orifices replacement Rebuild Limitorque 2-1501-22A Unit 3 Main Turbine High Pressure Casing Removal The inspector witnessed portions of the following test activities:
Unit 2 DOS 7500-02 Standby Gas Treatment System Operability Surveillance DTS 0040-03 Section XI Pressure Testing of the Standby Liquid Control System* at Nominal System Operating Pressure DTS 1600-06 Drywell Liner Leakage Inspection
Unit 3 DIS 0500-03 Reactor Water Level ECCS Switch Initiation and Calibration DIS 1500-03 Reactor Water Level 2/3 Core Height Master Trip Unit and Fuel Zone Level Indication Calibratio Maintenance and Surveillance Observations Leakage from Unit 2 Containment liner Identified During the performance of survei 11 ance DTS 1600-06, "Drywe 11 Liner Leakage Inspection," leakage from the containment liner sand pocket region was identified. The leakage had the potential to corrode the containment liner in an inaccessible are As required, a problem identification form (PIF) was initiated to document the leakage and initiate corrective actio Both units had a documented history of leakage since the surveillances were first started in 198 At the time of this inspection, the licensee suspected that the leakage originated from the refueling cavit The inspectors concurred with the licensee in that additional investigation was necessar Control Room Emergency Ventilation System Made Intentionally
- Inooerabl e -
On January 17, 1993, both trains of the containment cooling service water supply to the control room emergency ventilation refrigeration conden~ing unit were removed for pre-planned
maintenanc The cooling water was planned to be out-of-service in excess of 60 day However, Qresden Administrative Technical Requirements (DATR) 3/4.6.4, Ventilation and Air Filtration Systems, only allowed a 30 day out-of-service time for the condensing uni The licensee intentionally rendered the control room emergency ventilation system inoperable for a period in excess of the DATR requiremen While both cooling water trains were inoperable, the licensee performed fuel handling activities and continued to operate Unit The qualified cooling water
- system was installed as a commitment.made to the NRC in response to NUREG-0737, "Clarification of TMI Action Plan Requirements, Item III.D.3.4, Control Room Habitability Requirements." This issue is considered an Unresolved Item (237/93011-02(DRP)) pending review of the licensee's commitment to NUREG-073 Unit 2 High Pressure Coolant Injection (HPCI) Pump The inspectors reviewed the associated work package and interviewed a sample of personnel performing work on Unit 2 HPCI pump.. The inspectors identified some minor discrepancies in documentation of pre-job briefing Interviews with personnel performing the work showed some confusion regarding the exhaust
- elbow flange gasket material occurred; however, this was resolve The work package did not include a requirement to document gasket type for the exhaust elbow upon removal but this information was added to the package at the replacement ste The same type of gasket material that was removed was replacea. The inspectors identified the threads on some studs were slightly damaged when workers were remo~ing the nuts. This did not present a safety concer The licensee decided to remove all the studs from the flange and replace damaged part Assessment of Maintenance and Surveillance The conduct of the Unit 2 refuelling outage was significantly better than previous outage The licensee responded w~ll to the Unit 3 forced outage and coordinated work well for both unit No violations or deviations were identified. *One unresolved item concerning intentionally violating a DATR was identifie.
Engineering and Technical Support (37700)
The inspectors evaluated the extent to which engineering principles and evaluations were integrated into daily plant activities. This was accomplished by assessing the technical staff involvement in non-routine events, outage-related activities, and assigned TS surveillances; observing on-going maintenance work and troubleshooting; and reviewing
- deviation investigations and root cause determination Engineering and Technical Support Events Containment Cooling Service Water A modification completed in January 1985 to the Dresden Unit 2 containment cooling service water system connected Loop A and Loop B by a 2 l/2tt line. The purpose of the modification was to provide backup control room heating, ventilation and air
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conditioning service The modification invalidated the redundant system design philosophy in that the system was changed from a dual system to a single loop syste This deficiency was identified by the responsible station technical engineer on December 22, 1992, and a problem identification form (PIF) was issued for reporting the proble The PIF recommended closing one of the two normally open valves on the 2 1/2" cross-tie to restore loop separation as shown in the original plant system configuratio The Dresden Event Screening Committee recommended the issuance of a problem investigation report (PIR) by February 5, 1993, and assigned the PIR to the appropriate station technical enginee The purpose of the PIR was to determine root cause and action to prevent recurrenc The PIR was subsequently reassigned to the engineering group with a due date of May 1, 1993.
Determination of root cause and action to ~revent recurrence is considered an Unresolved Item (237/93011-03(DRP)).
Inoperable Torus Radiation Monitors Regulatory Guide 1.97, revision 3, "Instrumentation for light-water-cooled nuclear power plants to assess plant conditions during and following an accident," was issued in May 198 The Regulatory Guide listed variables to be monitored during accident condition Primary containment area radiation monitors were included in this lis On August 1, 1985, the licensee submitted a summary report, "Compliance to Regulatory Guide 1.97," which listed the torus area radiation detectors as part of a commitment to the NRC to meet Regulatory Guide 1.9 On August 31, 1987, the NRC issued a letter which stated the licensee provided an explicit commitment on conformance to Regulatory Guide 1.9 In January 1989 the licensee found the torus area radiation monitors disconnecte In 1992 the Unit 2 detectors were abandoned in place and the Unit 3 detectors were remove The failure to maintain operable torus area radiation monitors is a deviation (237/93011-04(DRP)) from the licensee's commitment to Regulatory Guide 1.9 Unit 2 Modification Review:
During the inspection period, the inspector monitored specific onsite activities associated with the licensee's installation of plant modification The inspector verified the activities were in conformance with the requirements of technical specifications, 10 CFR 50.59, and 10 CFR Part 50, Appendix B, Criterion III,
"Design Control." Specifically, the inspector observed installation and testing activities associated with the following plant modifications:
Modification (M)-12-2-89-004~A/B Reactor Vessel Water Level Instrumentation System (RVWLIS):
Relocation of Instrument Reference Leg Outside of Primary Containmen Modification M-12-2-87-042 LPCI Logic Changes: Provided Logic Override for LPCI 2-1501-22A and B such that the valve can either be throttled or closed following an initiation signa No problems or concerns were observed during this revie Assessment of Engineering and Technical Support The knowledge and experience level of system engineers was increased in two way First, experienced people have b~en moved into the technical staff from other departments. Second, staff within the technical department have been reassigned such that previous supervisors were working level engineers.
- No vi~lations were identifie One deviation regarding operability of torus radiation monitors was identifie One unresolved item concerning root cause determination was identifie.
Safety Assessment and Quality Verification CSAQV) (40500)
The effectiveness of management controls, verification and oversight activities in the conduct of jobs observed during this inspection were evaluate Management and supervisory meetings involving plant status were attended to observe the coordination between department The results of licensee corrective action programs were routinely monitored by attendance at meetings, discussion with the plant staff, review of deviation reports, and root cause evaluation report SAQV Related Events Quality First Program The licensee's Quality First program was intended to provide an opportunity for licensee staff and contractors to bring forth concerns about work qualit The individual responsible for the Quality First program was on site approximately one day per wee During the remaining times, indiv'iduals calling the Quality First extension received a message to call another number to find the location of the Quality First individua In addition to the station extension, an "800" number hotline was also available where concerns could be left on an answering machin The telephone extension number for the Quality First office and the
"800" hotline number were not included on the monthly station telephone list nor were the numbers posted near telephones in the plan The lack of readily available information about the Quality First telephone numbers was considered a significant weaknes The availability of telephone numbers and the overall effectiveness of the Quality First program is considered an inspector followup item (237/93011-05(DRP)).
Problem Identification Form Review The inspectors reviewed the licensee's problem identification,
forms (PIFs) generated during the inspection period. This was done to monitor the conditions related to plant or personnel performance and potential trend Problem identification forms and the results of the investigations were also reviewed to ensure that the forms were generated appropriately and dispositioned in a mariner consistent with applicable procedures and the quality assurance manua The following events were reviewed:
Unit 3 High Pressure Coolant Injection (HPCI) system drain valve found out of position
Radwaste Processing Spill of Concentrated Waste
The Unit 3 HPCI system drain valve was found in the closed position. A partial system lineup conducted on the previous day showed the valve was locked ope The inspectors reviewed operator log entries, appropriate surveillances, and work packages, and interviewed personne The inspectors also interviewed members of the licensee's investigation team and determined that a thorough investigation had been conducte Although the root cause was not determined, the licensee identified several contributing factors such as control. of keys which hindered the investigation. The licensee discussed preliminary corrective actions to prevent recurrenc The inspectors had no further concerns regarding the investigation proces The concentrated waste spill is discussed in paragraph 4.a. of this/repor The inspectors reviewed system lineups and procedures and interviewed the individuals involve The inspector also observed the licensee's root cause investigatio The licensee's investigation was thorough and timel The corrective actions which ir.cluded labeling of the area hoses and better housekeeping controls were adequate to prevent recurrenc Event Screening Committee Meeting The inspector attended an Event Screening Committee meeting to evaluate the effectiveness of the integrated reporting program process and communication between departments. Good discussions regarding further investigations and teamwork were generally observe However, several concerns were note Specifically:
The committee initiated four additional PIFs concerning events described in the operator log book While this action was positive, the cause for the operators not originating the PIFs needed to be addresse *
A PIF written on the Unit 2 diesel generator rocker arm found bent after maintenance was discusse Although the team determined further investigation was needed, several members suggested that a work request was sufficient to correct the proble The work request alone would not have determined root cause or prevented recurrenc *
During the discussion on a high radiation door found open, operations and radiation protection department focussed on responsibility for the event; not on the resolution of the proble Teamwork and understanding of the committee's responsibilities were not eviden *
The inspector discussed these observations with licensee managemen Additional meetings were attended by management personnel to en~ure the process was progressing to management's expectations. Subsequently, a NRC Dresden Oversight Team inspector attended a committee meeting and observed no problem The effectiveness of the PIF process will be evaluated in future inspection Failure to Post a Radiological Conditions Violation The licensee received a Notice of Violation for radiological practices (237/93007-02) on March 2, 199 CFR 19.11.(e)
required posting of certain Notices of Violation within two working days of receipt by the license The licensee posted the notice on March 9, 199 Failure to post the notice within the required time frame is a violation of 10 CFR 19.ll(e). However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.(1) of the
"General Statement of Policy and Procedures for NRC Enforcement Actions," (10 CFR Part 2, Appendix C (1992)), were satisfie No response is require Assessment of SAQV The self-identification of problems by some departments through the PIF process did not consistently meet licensee expectation One non-cited violation (NCV) was identified regarding the failure to post a notice of violatio One inspector followup item was identified regarding the Quality First progra.
Management Meetings (30703)
On February 16 through 18, 1993, Mr. Jack Martin, Region V Regional Administrator, visited the Dresden facilit Mr. Martin met with several licensee management personnel during the visit to gain insights on the current status and improvement initiatives. Subsequently, Mr. Martin was assigned Regional Administrator for Region III effective May 31, 199 On February 26, 1993, Mr. A. B. Davis, Region III Regional Administrator, attended the licensee's monthly information meeting at the Dresden sit On March 9 through 12, 1993, the Dresden Oversight Team (DOT) was onsite for the fifth evaluation of Dresden performanc On March 12, the DOT held a public exit meeting with the license Mr. A. B. Davis attended the meeting and toured the facilit No violations or deviations were identified.
17 Inspector Followup Items Inspector followup items are*matters which have been discussed with the licensee which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or bot One inspector followup item disclosed during this inspection is discussed in paragraph.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviation Two unresolved items disclosed during this inspection are discussed in paragraphs 5.b and.
Licensee Identified Violations The NRC uses the Notice of Violation as a standard method for formalizing the existence of a violation of a.legally binding requiremen However, because the NRC wants to encourage and support licensee's initiatives for self-identification and correction of problems, the NRC will not generally issue a Notice of Violation for a violation that meets the tests of 10 CFR 2, Appendix C, Section VII.B.(l). These tests are:
(1)
it was not a violation that could reasonable be expected to have been prevented by the licensee's corrective action for a previous violatio (2)
the violation was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (3)
it is not a willful violatio Two violations of regulatory requirements identified during this inspection for which Notices of Violation will not be issued are discussed in paragraphs 4.a. and.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in paragraph 1) throughout the inspection period and at the conclusion of the inspection on March 15, 1993, to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors'
comment The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectto The licensee did not identify any such documents or processes as proprietar