IR 05000237/1993020

Insp Repts 50-237/93-20 & 50-249/93-20 on 930619-0816. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Operational Safety Verification & ESF Sys Walkdown & Maint & Surveillance Observations

ML17179B119
Person / Time
Site:	Dresden
Issue date:	09/14/1993
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179B117	List: IR 05000237/1993020 ML17179B116 ML17179B118
References
50-237-93-20, 50-249-93-20, NUDOCS 9310050115
Download: ML17179B119 (29)

Text

U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report Nos. 50-237/93020(DRP); 50-249/93020(DRP)

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

Commonwealth Edison Company Opus West III 1400 Opus Place - Suite 300 Downers Grove, IL 60515 Facility Name:

Dresden Nuclear Power Station, Units 2 and 3 Inspection At:

Morris, IL Inspection Conducted:

June 19 through August 16, 1993 Inspectors:

Approved By:

Inspection Summary M. Leach M. Peck A. M.. Stone J. F. Smith R. Zuffa, Illinois Department of Nuclear Safety P:l tLU..

P. L. Hiland, Chief Reactor Projects Section 18 Inspection from June 19 through August 16, 1993 {Report No /93020{DRP); 50-249/93020(0RP))

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' Date 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 observations; engineering and technical support observations; safety assessment and quality verification; and management meeting Results: Of the eight areas inspected, no violations or deviations were identified in four area The following violations were identified:

A violation was cited for inadequate control over station activities affecting the quality of identified structures, systems, and component Management expectations had not been adequately communicated or reinforced to plant personne The violation is discussed in paragraph 7.

9310050115 6~86~~37 PDR ADOCK PDR G

'*

A violation, with numerous examples was cited for the failure to follow station procedures. This violation represented a negative trend in procedural adherenc The examples are discussed in paragraphs 3.a, 3.b, 4.a, 4.b, and *

A violation was cited for failure to control a contaminated water lea The licensee failed to identify and correct the potential causes for the increase in contamination events. This violation is described in paragraph *

A violation was cited for the failure to submit a licensee event report within 30 day The additional management support to the event screening committee process should prevent recurrenc The violation is discussed in paragraph *

A non-cited violation for the misuse of work request prioritization is described in paragraph Assessment of Plant Operations The operators performed well during off-normal condition The response to the lift station lightning strike was coordinated and promp Additionally, a shift engineer identified a potential unmonitored release path due to the relocation of the radiological controlled area boundar However, an automatic reactor shutdown occurred due to a personnel error during a routine operatio The non-licensed operator rounds focused on equipment conditions and did not consider the surrounding environmen The operations peer review committee and site overview meeting were implemented and demonstrated management's commitment to improve self-assessment capabilities. However, management involvement in resolving Individual Plant Examination (IPE} findings was insufficient. Also, as discussed in paragraphs 3.a, 3.b, 4.a, 4.b, and 6.a, a negative trend in procedural adherence continued to challenge managemen Several discrepancies with upgraded and revised procedures indicated a decline in attention to detail.

Assessment of Maintenance and Surveillance Good interdepartmental coordination and effective planning was demonstrated during the replacement of the Unit 3 electro-hydraulic control system pressure switc Several examples of failure to follow procedures were identifie Also, the involvement of maintenance personnel in the integrated reporting program remained a concer Assessment of Engineering and Technical Support The licensee's decision to declare the Unit 3 containment cooling service water (CCSW) loops inoperable was conservative and showed good engineering judgmen The submitted request for enforcement discretion was considered goo The system engineer for service water radiation monitors was

knowledgeable of the system and was aggressively pursuing problem resolution With the exception of the Unit 1 radwaste tunnel leakage, problems identified during engineering activities were promptly communicated to operations management and the resident inspectors offic The root cause investigation into the first trip of feed breaker MCC 29-2 and 29-4 was poor; however, increased management attention and support resulted in a more thorough investigation following the second tri Assessment of Plant Support Housekeeping and material conditions in some areas of the station decline Management expectations have not been effectively communicated or reinforce Coordination and communication of the RCA boundary change was weak and lacked adequate management overvie An example of failure to follow radiation protection procedure was identified. The practice of not documenting all contamination events could hinder the station's investigation into the increased number of shoe contamination One violation for failure to take corrective actions regarding a contaminated leak was identifie The licensee recognized the increase in contamination events but failed to identify a leaking hose as one potential caus Assessment of SAOV Management expectations for plant conditions and individual performance were not clearly communicated or reinforce Numerous examples of failure to follow procedures were discussed throughout this report and indicated insufficient management attention.

DETAILS Persons Contacted M. Lyster, Site Vice President

1. • G. Spedl, Manager, Dresden Station D. Ambler, Executive Assistant to the Site Vice President A. D'Antonio. Site Quality Verification Supervisor R. Flahive, Technical Services Superintendent

• B. Gurley, NRC Coordinator

• L. Jordan, Health Physics Supervisor M. Korchynsky, Senior Operating Engineer J. Kotowski, Operations Manager G. Kusnik, Quality Control Supervisor

• T. O'Connor, Maintenance Superintendent R. Radtke, Services Superintendent

1. • J. Shields, Regulatory Assurance Supervisor R. Stobert, Operating Engineer

M. Strait, Technical Staff Supervisor B. Viehl, Nuclear Engineering Design Supervisor Indicates persons present at the exit interview on August 16, 199 Indicates persons present at the re-exit interview on August 26, 1993.

The inspectors also contacted other licensee personnel including members of the operating, maintenance, security, and engineering staf Summary of Operations Unit 2 Unit 2 power operation was administratively restricted to 730 MWe due to indicated reactor level oscillations. The licensee determined the oscillations were caused by induced vibration in the instrument line On July 25, 1993, the licensee exceeded the national pollution discharge elimination system permit limit of 93°F on discharge water temperature when the offsite condenser lift pumps were inoperable due to a lightning strike: Unit 2 power was reduced to decrease heat output to the discharge cana Power operation continued at 730 MWe when temporary power was restored to the offsite condenser discharge pump Unit 3 Unit 3 operated at power levels up to 100% powe On July 10, 1993, while operators attempted to reverse circulating water system flow, an automatic reactor shutdown occurred on main condenser low vacuu The automatic shutdown was caused by management and operator error Power

• operation resumed at levels up to 100% power on July 16, 199 Unit 3 power was also reduced on July 25, 1993, to decrease heat output to the discharge canal. Operation up to 100% power continued when temporary power was restored to the pump No violations or deviations were identifie.

Plant Operations (71707, 71710 & 93702)

The inspectors verified that the facility was being operated in conformance with the licenses and regulatory requirement The licensee's management control to ensure safe operation is discussed in paragraph During tours of accessible areas of the plant, the inspectors made note of general plant and equipment conditions, including control of activities in progres On a sampling basis, the inspectors observed control room staffing and coordination of plant activities; observed operator adherence with 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 operating record Accessible portions of engineered safety feature (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 and Unit 3 Class IE Batteries Service Water Systems Core Spray Systems Plant Operations Observations Unit 3 Automatic Shutdown On July 10, 1993, Unit 3 automatically shut down from a loss of condenser vacuum during a routine circulating water flow reversa Dresden Operating Procedure (DOP) 4400-08, "Circulating Water System Flow Reversal," required condenser suction backpressures of less than four inches mercury prior to initiating the flow reversa However, qualitative information describing minimal operational conditions such as the number of operating circulation pumps and river temperatures was not provide The prerequisites were met with the average condenser vacuum of -26 inches of mercur Only two of three ci~culating water pumps were operable and the river temperature was relatively hig The unit operating

engineer, the shift engineer, the shift control room engineer, and the unit operator all approved the decision to proceed with the routine operation although minimal margin existe Dresden Technical Specification 6.2.A.l stated the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2 dated February 1978, shall be established, implemented, and maintaine Regulatory Guide 1.33, Appendix A.l.c included administrative procedures, general plant operating procedures, and procedures for startup, operation, and shutdown of safety related system Failure to provide adequate qualitative information in the operating procedure is considered a violation of Technical Specification 6.2.A.l (50-237(249)/93020-0la(DRP)). Failure to Perform Independent Verification The inspectors observed ground deteciion activities in accordance with Dresden Operating Procedure (DOP) 6900-06, "125V DC Ground Detection - Unit 2." Operations personnel removed multiple fuses from the annunciator circuits supporting safety related systems but did not independently verify either fuse removal or restoratio An operations engineer indicated that as many as 37 fuses may be pulled at a time in conjunction with DOP 6900-06 without independent verificatio Removal of several of the fuses specified by DOP 6900-06 would render safety related equipment inoperable. Also, an engineered safety feature (ESF) actuation may result from removal of an incorrect fus Dresden Administrative Procedure (OAP) 07-27, "Irrdependent Verifications," required independent verification (IV) to ensure the correct physical location before the removal of fuses that may initiate an ESF actuatio OAP 07-27 also required, as a minimum, independent verification to ensure that all fuses were in the correct position or condition as required for safety related systems. A OAP 07-27 "IV Log Sheet" was required to be completed when no other procedural control existed. Operations personnel did not complete the IV Log Sheet during the ground detection activities observe *

The failure to perform independent verification following the removal of safety related system fuses, in accordance with OAP 07-27, is considered an example of a violation of approved procedures and Technical Specification 6.2.A.l (50-237/93020-0lb(DRP)).

The failure to perform independent verification was also a contributing factor associated with a previous violation (50-237 /92002-03(DRP)).

The previous violation involved the failure to reconnect a power cable on an intermediate range monitor following a surveillanc The licensee's corrective actions included a review of maintenance procedures for inadequate independent verification requir~ments. However, operational related troubleshooting procedures, such as ground checking, were

• not reviewe The exclusion of operational related procedures in the review following the previous event is considered a weakness in the corrective actions progra Discrepancies in Core Spray Lineup Procedures During a core spray (CS) walkdown, the inspectors identified several discrepancies between the actual valve positions and positions required by procedur The inspectors concluded the as-found valve positions were correct and did not have operability concern Further inspection revealed the following:

Numerous contradictions existed between DOP 1400-Ml, "Unit 2 Core Spray System," and DOP 0040-M2 and M3, "Locked Valve List During Operations." The licensee indicated that the locked valve checklist was rewritten as a result of a previous violation. The licensee reevaluated the locked valve criteria to identify valves requiring lock Field changes were noted in the locked valve checklist but were not corrected in the system lineup procedures. Therefore, discrepancies also existed in other system lineup procedure The licensee stated that lineup procedures would be revised to reflect expected valve positions prior to the next Unit 3 refueling outag *

The inspectors performed the Unit 2 CS lineup using revision 11 of DOP 1400-01 and noted several incorrect valve position The operators used revision 9 during the system startup from the last outage. A comparison between revisions 9, 10, and 11 indicated that procedure changes were made without prior authorizatio For example, in revision 10, the required position for a sample valve was closed; however, revision 11 required a locked open positio No justification was documented in the procedure change reques Other discrepancies included changes in valve numbers, location descriptions, and desired position The licensee stated that the errors were made during transition between word processing systems and typist errors when inserting new valve information. Another contributing factor was inadequate review of the procedure changes prior to implementatio The licensee stated a small number of procedures were involve The above observations are considered an Unresolved Item (50-237/93020-02(DRP)) pending further inspector review of the licensee's root cause and corrective actions.

7 Lift Station Failure On July 25, 1993, an electrical fault in the lift station for the cooling lake caused the lift pumps to trip. The operators quickly reduced power to limit the water discharge temperature to the river and changed the lineup of the canals to provide maximum coolin The shift engineer clearly documented the decision making process and subsequent actions in the log boo Overall station response, including coordination and communication, was goo The electrical fault was caused by a nearby lightning strik The licensee was investigating possible corrective actions at the end of this inspection perio Onsite Review (OSR)

The inspectors attended the Unit 3 restart Onsite Review {OSR)

meetings on July 13 and 14, 199 The OSR meeting held on July 13 was effective in the review of the automatic shutdown and the corrective actions prior to restar During the discussion of a failed reactor recirculation flow control system relay, one OSR member recommended replacing the relays in both trains although only one train was affecte In contrast, the OSR meeting the following day was poorly attended and the opportunity for group synergy was misse Individual Plant Examination On July 27, 1993, the licensee met with Region III management and presented the results of the Dresden Individual Plant Examination

{IPE).

The results were completed in January 1993 and included several actions which would reduce the calculated ris The most significant risk reduction involved a change to the emergency operating procedures {EOPs).

During the presentation the licensee stated the EOPs would be revised by August 199 The significant delay in the implementation of a safety significant enhancement demonstrated a lack of adequate management attentio Management involvement in EOP enhancements is considered an Inspector Followup Item {50-237/93020-03{DRP)) pending review of other outstanding changes to the emergency operating procedure Self-Assessment The licensee initiated the monthly Dresden overview meeting and operations peer review committee to improve the station's self-assessment capability. The first Dresden overview meeting was held on July 22, 1993, and involved both management and bargaining unit personnel. A number of issues affecting safety-related activities were discussed. Also, the Operations Department initiated a bargaining unit personnel peer review committee to review recent personnel error events. This self-assessment by the operators had potential for ide~tifying and preventing recurrent

• personnel errors. The effectiveness of the monthly Dresden overview meeting and operations peer review committee will be evaluated during future inspection Two examples of a violation regarding a failure to follow procedure were identifie An unresolved item regarding the adequacy of procedure review was discusse.

Monthly Maintenance and Surveillance (62703 and 61726)

Station maintenance and surveillance activities were observed and/or reviewed to verify compliance with approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specifications (TS).

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; functional 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 The maintenance backlog for non-outage work requests increased from 1500 to 1700 during the inspection period. Also the number of control room work requests, both outage and non-outage, remained approximately steady at 40 for each unit. The inspectors were concerned with the backlog level and will continue to monitor it during future inspection The inspectors observed portions of the following maintenance activities:

Unit 1 Troubleshooting of the Unit 1 fire pump Repair of the Unit 1 diesel driven fire pump Unit 2 Replacement of the 2-0305-103 bonnet on control rod drive D-11 Troubleshooting of the high level alarm for drywell equipment drain sump Source range monitor power cable replacement Reactor level transmitter change-out Replacement of reactor level transmitter Unit 3 Removal of the 3C circulating water pump The inspectors also witnessed portion~ of the following test activities:

• Unit 2 DES 6600-05 Diesel Generator One Month Electrical Maintenance Surveillance DOS 1100-01 Standby Liquid Control System Pump Test DOS 1100-02 Standby Liquid Control Tank Heater Surveillance Test DOS 1100-04 Quarterly Standby Liquid Control System Pump Test for the Inservice Testing Program (including TPC 93-94)

DOS 1400-01 Core Spray System Pump Test DOS 1400-02 Core Spray System Valve Operability Test DOS 1500-06 Low Pressure Coolant Injection (LPCI) Pump Operability Test DOS 1500-08 CCSW Pump Discharge Test DOS 1500-10 LPCI Quarterly Pump Test for IST DOS 2300-01 High Pressure Coolant Injection (HPCI) System Operability Verification DOS 2300-08 HPCI Pump Discharge Line Temperature Monitoring DTS 0300-02 Unit 2 Control Rod Drive Scram Testing Scram and Scram Valve Timing Unit 3 DES 4153-02 Emergency Light Quarterly Inspection DES 4153-03 Dresden l, 2, and 3, Quarterly Balance of Plant Emergency Light Surveillance DIS 500-07 Turbine First Stage Pressure 45% Scram Bypass Pressure Switch Calibration DOS 1500-06 LPCI System Operability Test with the Torus Available DOS 1500-10 Quarterly LPCI Pump Test for IST DOS 2300-01 HPCI Motor Operated Valve Operability Verification DOS 2300-03 HPCI System Operability Verification DOS 2300-08 HPCI Pump Discharge Line Temperature Monitoring Maintenance and Surveillance Observations Failure of Maintenance Personnel to Recognize Acceptance Criteria The inspectors observed an electrical maintenance technician and a supervisor failed to recognize DES 6600-05 acceptance criterio The technician measured approximately 8 amps current on the leads feeding the emergency diesel generator (EOG) immersion heater The technician documented that the test results were within tolerance and notified operations personnel of the successful completion of the surveillance. However, the inspectors noted that the procedure acceptance criterion was approximately 17 amps for the immersion heaters curren The technician did not understand the discrepancy between the measured current and the surveillance acceptance criterion. Following a subsequent review, the electrical maintenance foreman indicated the procedural requirement of 17 amps was in error and the as-found currents were acceptabl The foreman initiated a procedure inquiry form to change the acceptance criterion. to approximately 8 amp A problem identification form (PIF) was not initiated.

The inspectors concluded 17 amps was the correct required current value based on a review of past performances of DES 6600-05 and the system electrical drawing The licensee determined the current probe was plugged into the incorrect test instrument port during test and caused the incorrect readin The currents were remeasured and found greater than 17 amp The immersion heaters reduced the engine oil viscosity to ensure the EOG can start and load within the time frame assumed in the accident analysis. Undetected heater failures could result in an inoperable EO Because the technicians failed to recognize the acceptance criteria was not met, the operations authority did not evaluate the operability of the EOG The safety significance was mitigated by a supervisory circuit which alerted operations personnel to low oil temperature However, the failure of the maintenance technician and supervisor to recognize the importance of safety related equipment test acceptance criteria was considered a significant weakness in the conduct of maintenance progra The failure to ensure surveillance acceptance criterion was met is considered another example of a violation of approved procedure and Technical Specification 6.2.A.l (50-237/93020-0lc(DRP)). Poor Work Control by Control Room Personnel An instrument mechanic (IM) replaced the 15V power supply connector for a Unit 2 source range monitor (SRM) on July 20, 199 Prior to beginning work the shift control room engineer (SCRE) reviewed the work package and authorized the maintenance activit The inspectors noted the power supply was removed which rendered the SRM inoperabl The SCRE and the Unit 2 licensed operator did not recognize the work scope would render the SRM inoperabl The inspectors discussed the observations with the SCRE and concluded the minimal TS required instruments were operabl However, the inspectors noted that the status of the SRM was not entered in the Degraded Equipment Lo Dresden Administrative Procedure (OAP) 07-05, "Operating Logs and Records," required degraded or inoperable equipment to be logged in the Degraded Equipment Lo The log entry was to include a detailed description of how the component was degraded, conditions when the equipment would be required, all associated work request numbers, TS or other requirements, and date and time rendered inoperabl The failure to recognize the impact of a maintenance activity resulting in the failure to follow OAP 07-05 is considered another example of violation of approved procedure and Technical Specification 6.2.A.l (50-237/93020-0ld(DRP)).

11 Misuse of 11A 11 Priority Work Requests The inspectors reviewed a Site Quality Verification (SQV)

corrective action record regarding the use of 11A 11 priority work request classification. Dresden Administrative Procedure (OAP)

15-01, "Initiating and Processing a Work Request," defined "A" priority as emergency work which must be started as soon as possible and continued around the clock until complete The SQV investigation identified the following:

"A" priority nuclear work requests (NWRs) were generated as a scheduling tool and not as a response to an emergency situatio *

Twenty-five NWRs were classified as "A" priority by the operations department between late January and early May 199 *

The "A" priority NWRs were subclassified as "Al", "A2" and

"A3."

Guidance to use these subclassifications were contained in an informal operations and maintenance memorandum and were not discussed in OAP 15-0 *

SQV reviewed ten NWRs and determined that none qualified as an "A" NW Minimal work instructions were provided; additionally, five NWRs did not contain adequate instruction *

One "A" NWR was not started until three days after identification of a priority "A."

Quality control review and release on a separate "A" NWR were completed five days after post maintenance testin The findings were presented to licensee management for resolutio OAP 15-01 will be revised to provide clear definitions and processing of an "A" priority NW The inspectors determined the depth of the SQV review was acceptable. Additionally, the inspectors reviewed equipment performance since the maintenance activities and determined that no rework was necessar The inspectors also reviewed several quality control (QC)

discrepancy records generated during the Unit 2 outage to ascertain the extent of the misuse of DAP 15-01. Deviation report (DR)93-091 was initiated because the modification testing of the intermediate range monitor (IRM) and source range monitor (SRM)

cables were *performed prior to QC release of the work packag Clarification of the testing acceptance criteria was needed and was discussed with the QC inspecto However, the testing was completed prior to QC receipt of the written General Electric clarification. A written explanation or analysis was required by OAP 15-01 for any changes to a ~ark packag *

Deviation report 93-090 was written for work completed on IRM 13 detecto Due to the perceived time constraint, the instrument mechanics started work on safety related IRM 13 using the instructions for the non-safety related SRMs since the work package for IRM 13 was not ready at the tim The IRM and SRM work packages were identical except for a required QC hold point on a weld for IRM 1 When the discrepancy was identified, the IRM weld was inspected and found acceptabl An informal training session (tailgate) was held with IM supervisors on the proper use of OAP 15-0 Performance of non-emergency work without adequate procedures is considered a violation of approved procedur However, a violation is not being cited because the criteria specified'in 10 CFR 2, Appendix C, Section VII.B.(2) were satisfie Maintenance Activities Without a Work Package The inspectors observed an instrument mechanic start a maintenance activity without a work packag The Unit 2 primary containment oxygen analyzer failed at the beginning of a surveillance tes The instrument mechanic performing the surveillance requested permission from the shift control room engineer to troubleshoot the failure. A troubleshooting work package had been prepared in anticipation of the failure but was left in the sho Prior to receiving the work package the mechanic removed several screws on a internal circuit board to identify the faulty componen Dresden Administrative Procedure (OAP) 15-06, "Preparation and Control of Work Request," stated that shift authorization to start work was required on all nuclear work request Performing troubleshooting activities without a work package or written shift approval was considered a weakness in the implementation of the conduct of maintenance progra Inoperable Safe Shutdown Lights The inspectors identified five inoperable 10 CFR 50, Appendix R, safe shutdown emergency lighting sets during a plant tour. These lights are used to provide eight-hour illumination of egress and operator access routes to safe shutdown equipment during emergency condition The following conditions were noted:

• *

Two lights were on de-energized circuits with the batteries discharge One light was found unplugged with the battery discharged.

Two lights had low electrolyte levels and exposed battery plates.

These inoperable lights did not impede operators' traveling to and from safe shutdown equipment. Although this finding was of minor safety significance, these lights should have been identified during shiftly operator round The inspectors notified the electrical maintenance foreman of the degraded condition The foreman acknowledged the conditions and added the lights to a work request for corrective maintenanc However, a problem identification form (PIF) was not writte Dresden Administrative Procedure 02-27, "Integrated Reporting Process, 11 defined a plant problem as a physical characteristic or performance of a system component or part which does not conform to the requirements of the design documents, applicable standards, and/or regulatory commitment for that item. After* further discussions with the licensee a PIF was generated for the de-energized circuits. The time delay in initiating a PIF was considered a weakness in the implementation of the condition adverse to quality progra Scheduling and Coordination of Activities Scheduling and coordination of work activities improved relative to previous inspection period The work planning group developed a tool to measure the three-day rolling schedule effectivenes Schedule efficiency was calculated based on a ratio of the actual finished work requests during a one week period compared to the scheduled number of finishes. The percentage did not determine the accuracy of the daily schedul The licensee was evaluating methods of further refining this measure of schedule effectiveness. During this report period the schedule effectiveness of the three maintenance groups and the operations department was between 80% and 90%.

Two examples of a violation regarding failure to follow maintenance procedures and practices were identifie One licensee identified non-cited violation (NCV) for misuse of "A" priority work was also discusse.

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 activitie~, and assigned TS surveillances; observing on-going maintenance work and troubleshooting; and reviewing deviation investigations and root cause determinations.

Engineering and Technical Support Events Concerns with Engineering Evaluation Assumptions As discussed in Inspection Report 50-237/93011, a modification to provide containment cooling service water (CCSW) to the control room heating, ventilation and air conditioning (HVAC) was completed in January 198 The inspectors determined the modification invalidated the redundant system design philosophy by incorporating a 2 1/2 inch cross-connection between both CCSW train The licensee immediately isolated a manual valve on the cross connection to reestablish train separatio The licensee performed an engineering evaluation and concluded the open cross-connection met all design requirement The cross-connection isolation valve was reopened prior to Unit 2 startup following the refueling outag The inspectors were concerned the licensee's engineering evaluation only considered single failures concur~ent with design basis accident In the case of a single failure of one train after initial system operation, a flow path would exist through the open non-operating heat exchanger discharge valv The diverted flow through the heat exchanger was not quantified by the license However, testing completed in November 1992 (Inspection Report 50-237/92034(DRP)) showed an additional 4 to 11 psi

pressure drop in the CCSW system when flow was diverted to the control room HVA A review of the historical surveillance test data between 1990 and 1992 noted several instances where pump performance was near the limit for the required pressure and flo The technical specification requirement of 3,500 gpm (at 180 psi)

would not have been met after subtracting the additional pressure dro The detrimental effect on discharge pressure and flow would have been more pronounced through a non-operating train with the heat exchanger discharge valve ope This issue will remain open (Unresolved Item 50-237/93011-03(DRP))

pending further review of the licensing bases and a determination if only single failures concurrent with the accident must be considere Unit 3 Containment Cooling Service Water Flow Less Than Design On August 10, 1993, the licensee performed a special test (SP 93-6-61) of the containment cooling service water system (CCSW) to determine system flow characteristics under different pump combination The operators started the 3A pump and observed system flow greater than 3500 gp However, when the operator started the 3B pump only 6000 gpm flow was obtaine Investigation showed that the 3A heat exchanger discharge valve opened only three-fourths of full strok The valve was electrically disconnected and mqnually opene System flow increased to 7000 gp The licensee initiated an administrative 15 *

TS seven-day limiting condition of operation (LCO) because the final safety analysis report table 6.2.4.1 specified a total flow of 7000 gpm per CCSW loo The 7000 gpm flow was not a TS requiremen On August 16, 1993, the licensee initiated a 24-hour LCO unit shutdown after determining a similar problem existed with the 38 heat exchanger discharge valv Enforcement discretion was granted by Region III on August 16, 199 The discretion required the licensee to declare the CCSW system operable by 4:00 (CST) on August 25, 1993, or place the unit in cold shutdown within the following 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The inspectors verified the licensee's compensatory actions stated in the discretion request were complete Inspection of the valves showed that the mechanical dial position indicators (MDPI) were undersize The valves required a two and one-half inch stroke to fully open; however, the MDPI allowed only a two inch strok The licensee had adjusted the limit switch settings based on the MDPI position and not by fully stroking the valves. This issue will be discussed in Inspection Report 50-237/9302l(DRS).

Unit 2 Main Feed Breaker to Two Safety Related Motor Control Centers Tripped On July 6, 1993, during a routine low pressure coolant injection (LPCI) surveillance, the main power feed to two Unit 2 safety related motor control centers, MCC 29-2 and MCC 29-4, trippe Power was lost to the HPCI room cooler, auxiliary systems for Unit 2 diesel generator, and some division II LPCI and core spray valves. Also, the Unit 2 reactor building ventilation isolated and standby gas treatment started as designed. Although not related to the event, the B-phase failed to trip during further testing of the breake The licensee meggered the reactor protection system (RPS) motor generator (MG) set feed cables and did not detect ground The licensee replaced the main feed breaker and restored power to the safety system No further investigation to determine root cause was performed at that tim On July 17, 1993, the main fe~d breaker to MCC 29-2 and 29-4 tripped agai Identical alarms to those received on July 6, 1993, were observe No problems were identified with the main feed breaker and power was restored to the safety related equipmen The operators placed the RPS MG set on reserve powe Further investigation into both events showed that the average power range monitor (APRM) high-high and half scram alarms were received firs The licensee attempted to duplicate the event by manually tripping the feed breaker; however, no APRM alarms were received. This indicated that the events were likely caused by a problem with the RPS MG se However, additional testing did not identify problem The license~ planned to maintain reserve power to the RPS bus until the root cause investigation was completed.

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I I

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• The licensee's root cause determination and corrective actions will be evaluated during the inspectors' review of the licensee event report A LPCI Discharge Check Valve Failure On July 6, 1993, during a routine monthly surveillance, the 2A low pressure coolant injection (LPCI) discharge check valve failed to clos The licensee replaced the check valve and declared the system operabl The valve was a dual disc check manufactured by C&S Valve Compan The valve had been replaced during the Unit 2 refueling outage and opened only a few times during one month of unit operatio Inspection of the valve showed that only two inches of the seal remained intact on the valve bod No other visual seal damage was observe The 3A LPCI check valve experienced similar failure in December 199 Discussions with the manufacturer indicated that no other failures have occurred in industr The licensee reinvestigated the two failures to determine 10 CFR 21 applicability. This is considered an Inspector Followup Item (50-237/93020-04(DRP)) pending review of the licensee's Part 21 applicability evaluation and root cause determination Investigation and Repairs to the Unit 3 Drywell Duct The licensee identified failed containment cooling ventilation ductwork inside the Unit 3 drywell during the forced outag The failures occurred in a sloping surface immediately adjacent to two corners of a diffuser panel and in two smaller sections of vertical ductwor Preliminary inspection of the failed pieces showed no evidence of incipient cracking in the duct materia The licensee observed edges of the fractured pieces vibrating during the initial inspectio In addition, the duct materi~l was found thinner (24 gauge) than that specified for the original ductwork (22 gauge) piece The licensee indicated that the duct sections were replaced a year ag The root cause of the duct failures is considered an Inspector Followup Item (50-249/93020-0S(DRP)) pending review of the licensee's investigatio The licensee repaired and replaced the duct on July 14, 199 Communication of Identified Problems The licensee continued to identify past engineering problems through the FSAR rebaseline effort. Discrepancies concerning the isolation condenser level and the wording of a Unit 2 license condition with respect to valves in the equalizer line between the recirculation loops were identified. The licensee implemented appropriate corrective actions and initiated problem

• identification form Engineers provided prompt notification to operations personne However, engineering contractors identified water intrusion in the Unit 1 radwaste tunnel but did not communicate the problem until six weeks late Service Water Radiation Monitor The Unit 2 and Unit 3 service water radiation monitor systems original centrifugal pumps were replaced with positive displacement pumps in April 199 During July 1993, the inspectors observed continued problems with the monitor The problems were identified during the system engineer's daily monitoring of system performanc The system engineer had identified blockage and was aggressively pursuing a logical program of evaluation and corrective action No violations or deviations were identifie.

Plant Support (71707 and 93702)

The inspectors evaluated the involvement of support organizations in ensuring safe and effective plant operation. Specific areas included:

Radiation Protection Controls The inspectors verified that workers were following health physics procedures and randomly examined radiation protection instrumentation for operability and calibratio *

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 were identifie *

Emergency Preparedness The inspectors verified the operational readiness of the control room technical support center and operation support cente Non-routine events were reviewed to ensure proper classification and appropriate emergency management involvemen *

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 material.

• The high pressure coolant injection (HPCI) rooms for both units were in poor housekeeping condition for the majority of the perio Problems included debris in the sump areas and hoses and cables left in the room In addition, the inspectors observed oil on the floor underneath the Unit 3 HPCI turbine and on two occasions buckets of oil beside the turbin The above findings were promptly corrected by the license During a discussion with the station manager, NRC management expressed disappointment on the condition of the HPCI rooms despite recent similar findings and discussion at Quad Citie Plant Support Related Observations Inconsistent Logging of Radiological Events The inspectors observed the radiation protection technicians in the decontamination room were not recording all contamination events in the logboo Dresden Radiological Procedure (DRP) 1460-01, "Routine Personnel Decontamination," stated that personnel contamination levels less than 100 cpm above background shall be recorded in the Contamination Lo On several occasions throughout the inspection period, technicians failed to document personnel decontamination event On July 16, 1993, the inspector received a foot contamination alarm at the exit portal contamination monitor (PCM).

The duty technician surveyed the shoe and found less than 80 count The technician failed to document the event in the log boo Discussion with other plant technicians indicated that it was not unusual not to log this type even In addition, decontamination techniques varied from frisking without gloves to placing the shoe in the PCM prior to decontaminatin The practice of not documenting all contamination events reduced the ability of the licensee to perform a root cause investigation into increased contamination Failure to log low level personnel contamination events is considered another example of a violation of approved procedure and Technical Specification 6.2.A.l (50-237(249)/93020-0le(DRP)).

Contaminated System Leak On July 19, 1993, the inspectors observed water dripping from a flexible hose on the 38 core spray motor cooling line. The source was contaminated suppression pool wate The water was dripping onto the floor in a radiologically "clean" are Work request 017208 was written on March 23, 1993, to fix the lea Management expectations were that the person identifying the leak would place a catchment under it; however, no catchment was presen The inspectors reported the leak and a catchment was promptly placed under the lea The leak was noticeable from the instrument panel; however, operators failed to recognize the problem during shiftly operator round During the period between March and July 1993, a significant increase in personal contamination events

• occurred at the station. A number of these were believed to originate from the low pressure coolant injection (LPCI) and core spray (CS) pump room The licensee recognized the increase in contamination events but failed to identify the leaking hose as one potential caus CFR 50, Appendix B, Criterion XVI, "Corrective Action,"

required that measures shall be established to assure that conditions adverse to quality such as deficiencies were promptly identified and corrected. The failure to control the contaminated water leak between March 23 and July 19, 1993, is considered a violation of 10 CFR 50, Appendix B, Criterion XVI (50-237/93020-06(DRP)). Radiologically Controlled Area CRCA) Boundary Change During July 1993, the RCA boundary was changed to include a portion of the service buildin The change resulted in lowered background radiation levels at the portal monitors, placed the decontamination room inside the RCA boundary, and provided better control of monitoring both tools and personne During August 1993 a new access control system was placed in servic The inspectors observed the following:

The RCA boundary was changed without evaluating potential radiation release paths. This issue was raised by a shift engineer and required compensatory measures until an evaluation was performe *

The new portal monitors installed required a different response when an individual was contaminate At times, radiological technicians did not correct individuals using the equipment improperl *

New radiation work permit numbers were implemented, but not communicated to station personne *

One individual operator undergoing training was not aware of either of the above changes prior to entering the RC The coordination and communication of these changes were considered wea One example of a violation for failure to follow radiation protection decontamination procedures was identifie One violation for the failure to take adequate corrective actions with regards to a contaminated leak was identified.

• Safety Assessment and Quality Verification (SAQV) (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 SAOV Related Events Unit 3 Drywell Closeout On July 14, 1993, the inspectors accompanied an operations supervisor during the Unit 3 drywell closeout inspectio The following concerns were identified:

The inspectors found a 6" by 14" piece of fire retardant matting, various lengths of duct tape, paper labels, lengths of wire, and a pair of safety glasses after the supervisor left the area *

A piece of sheet metal, most likely from the damaged ducts discussed in paragraph 5.e, was found in a downcomer.

Site Quality Verification {SQV) previous walkdown did not identify the above item *

No operations management above first line supervisors had entered the drywell during the forced outag As previously discussed in Inspection Report 50-237/93017, paragraph 6.a, the last closeout of Unit 2 drywell was also considered wea Management expectations were not communicated to the personnel prior to the Unit 3 drywell closeout performed this report perio CFR 50, Appendix B, Criterion II, "Quality Assurance Program,"

required in part, that control be provided over activities affecting the quality of the identified structures, systems, and components to an extent consistent with their importance to safety. Activities affecting quality shall be accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate equipment, suitable environmental conditions for accomplishing the activity, such as adequate cleanness, and assurance that all prerequisites for the given activity have been satisfied. Failure to ensure control over the Unit 3 drywell closeout is considered an example of a violation of 10 CFR 50, Appendix B, Criterion II {50-237{249)/93020-07a{DRP)).

• Unsecured Portable Equipment On July 16, 1993, the inspectors found a cart containing two 45-gallon drums, a dolly with a 45-gallon drum on it, an industrial vacuum pump, and a vacuum cleaner unsecured alongside motor control center (MCC) 28-1 and the stairway providing operator access to the Unit 2 east low pressure coolant injection (LPCI) roo Also, a coiled length of vacuum hose and a lid for a 45-gallon drum severely blocked operator access to the east LPCI roo No individuals were in the area and it appeared the equipment had been left in this condition during the lunch brea The inspectors contacted the Shift Enginee The Shift Engineer initiated immediate corrective actions due to an operability concern of the MC Approximately one hour later the inspectors observed four wheeled-carts containing scaffold materials adjacent to MCC 29-4, three of which were unsecure Again no individuals were in the are The inspectors again notified the Shift Enginee The unsecured equipment near MCC 28-1 and MCC 29-4 had the potential to render both trains of LPCI inoperable during a seismic even The issue of ~nsecured portable equipment had been the subject of several site quality verification corrective action requests during the past two year Management actions to correct the previous problems were inadequat Failure to ensure appropriate control of portable equipment during maintenance activities is considered another example of a violation of 10 CFR 50, Appendix B, Criterion II (50-237(249)/93020-07b(DRP)).

Improper Maintenance Practice On July 16, 1993, the inspectors observed unsecured equipment including: scaffold material, two electric motors, and a ladder, in the Unit 2 west LPCI and core spray {CS) roo The material remained in this room for at least two weeks without work performe The inspectors had the following concerns:

The condition of the room was brought to management's attention on three occasion Management recognized the room was in an unacceptable condition, but failed to initiate actions to correct the situatio *

Operators failed to recognize the room condition was unacceptable during operator shiftly round The condition of the room resulted from miscommunication between work group No group accepted responsibility for the roo Failure to control maintenance activities affecting the LPCI and CS room is considered another example of a violation of 10 CFR 50, Appendix B, Criterion II (50-237/93020-07c{DRP)).

• Self-Identification and Corrective Action Program Review The inspectors reviewed the problem identification forms (PIFs)

generated to monitor the conditions related to plant or personnel performance and potential tren The inspectors reviewed twelve PIFs classified as level IV investigations by the event screening committee (ESC).

The cause determination evaluations (CDEs) for ten PIFs were adequat The significance of the events was addressed and corrective actions were appropriate to prevent recurrenc The following weaknesses were identified:

On May 12, 1993, an isolation valve for a isolation condenser pressure switch was found closed. A PIF was initiated and determined to be reportable per 10 CFR 50.73 by Operations authorit The ESC reviewed the reportability requirements and determined that since the exact time of valve mispositioning was unknown, the pressure switch was inoperable when the valve was found closed. Therefore, the event was not believed to be reportabl The inspectors reviewed the event and determined that since the valve position had not changed prior to the closed identification, the pressure switch had been inoperable for some period of time. Technical specification table 3.2.2. required two operable instrument channels per trip system.

10 CFR 50.73(a)(2)(i)(B) required the licensee to report any operation or condition prohibited by the plant's technical specification. Failure to submit a licensee event report within 30 days is considered a violation of 10 CFR 50.73 (50-237/93020-0B(DRP)).

The licensee issued the LER and conducted retraining on the reportability manua The ESC meeting was restructured and was attended by more management personne The inspectors had no concerns with the corrective actions. Therefore, no response to this violation is requeste *

On May 19, 1993, a PIF was initiated to address a calibration discrepancy with Rosemount transmitter The licensee recalibrated the identified inoperable safety related instrument The licensee initiated a 10 CFR 21 applicability review and determined that the calibration discrepancy was documented in the nuclear network in 199 The COE for the event was weak in that the above finding and the result of the Part 21 applicability were not discusse The CDE should have addressed how corrective actions for a previously identified industry event were overlooke The effectiveness of the licensee's self-assessment and corrective action programs will be evaluat~d in future inspections.

• Assessment of SAQV Management expectations for plant conditions and individual performance were not clearly communicated or enforce Numerous examples of failure to follow procedures were discussed throughout this report and indicated insufficient management attentio One violation with several examples for failure to ensure quality work was identifie One violation for failure to follow 10 CFR 50.73 was discusse.

Licensee Actions on Previous Inspection Findings (92701 and 92702)

(Closed) Violation (50-237/90023-02(DRP)):

Failure to follow procedures during maintenance and operational evolution In response to the violation the licensee completed the following corrective actions:

Provided additional procedural direction on when to monitor reactor cavity water leve *

Added valves to the locked valve check lis *

Upgraded radiation protection survey maps to include equipment identification number *

Evaluated the need for reactor cavity and dryer/separator pit level indicatio *

Re-configured the adjustment screws on the torus to reactor building differential transmitters for ease of acces Based on the licensee's corrective actions and absence of additional discrepancies, this item is close (Closed) Violation {50-237/92005-02(DRP)): Various concerns with the equipment control progra The inspectors determined the corrective actions were satisfactory with the exception of the control of locks placed on electrical equipmen The issue of locks on electrical equipment will be addressed as part of a previous open item (50-237 /93011-0l(DRP)).

This violatio~ is close (Closed) Violation (50-237/92009-02(DRPl): Inadequate procedure for 10 CFR Part 21 evaluatio The inspectors determined the revised procedure for evaluating Part 21 reports was satisfactory. This violation is close (Closed) Violation (50-237/92014-0l(DRP)l: Fai.lure to follow procedures during full load testing of the emergency diesel generator The inspectors reviewed the revised procedures, completed training records, and surveillance data and determined the corrective actions were satisfactory. This violation is close The inspectors observed a weakness in the documentation of training, in that, the subject information was not included on the training record.

(Closed) Violation (50-237(249)/92032-07(DRP)): Lack of corrective ations for poor aintenance radiological work practice The licensee implemented a maintenance policy enforcing radiological work practice Also, the revised pre-job checklist included a review of radiation work permit requirements and management expectations. This item is close (Closed) Violation (50-249/92023-02(DRP)): Failure to perform technical specification required service water grab sample The licensee implemented a computer tracking system for chemistry related TS surveillances. All corrective actions were complet This violation is close (Closed) Violation (50-237/92032-06(DRP)): Acceptance of surveillance results after repeated cycling of motor operated valv The inspectors determined the corrective actions were complete This violation is close (Closed) Apparent Violation (50-237/92034-0l(DRP)):

Failure to identify and take prompt corrective actions when notified of a degraded low pressure coolant injection heat exchanger duty and degraded containment cooling service water (CCSW) flow condition Inspection Report 50-237/93009(DRP) documented the resolution of the degraded CCSW flow condition The NRC determined no violation existed and the matter is close (Closed) Apparent Violation (50-237/92034-02(DRP)):

Failure to evaluate bounding emergency core cooling system pump net positive suction head and diesel generator electrical loading. This apparent violation was closed per the Notice of Violation and Proposed Imposition of Civil Penalty (50-237/93009(DRP)).

(Closed) Apparent Violation (50-237/92034-04CDRP)):

Failure to obtain prior NRC approval for the safety analysis report changes which constituted an unreviewed safety question. This apparent violation was closed per Notice of Violation and Proposed Imposition of Civil Penalty (50-237/93009(DRP)).

(Closed) Apparent Violation (50-237/92034-05CDRP)):

Failure to incorporate an adequate test program to ensure the CCSW components performed satisfactorily in accordance with the design and technical specification requirement Inspection Report 50-237/93009(DRP)

documented the resolution of the degraded CCSW flow condition The NRC determined no violation existed and the matter is close (Closed) Apparent Violation (50-237/92034-0B(DRP)):

Failure to make required NRC notifications associated with containment cooling issue Inspection Report 50-237/93009(DRP) documented the resolution of the degraded CCSW flow condition The NRC determined no violation existed and the matter is closed.

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(Open) Unresolved Item (50-237/93011-03(DRP)):

Review of the licensee's root cause evaluation and corrective action associated with a modification of the Unit 2 containment cooling service water system (CCSW).

This issue is discussed in paragraph (Closed) Inspector Followup Item (50-237/92026-0SCDRP)}: Completion of licensee initiatives to reduce loss of annunciators due to electrical grounding or shortin The inspectors reviewed the licensee's corrective actions and had no concerns. This item is close No deviations or violatioris were identifie.

Licensee E~ent Reports (LERs) Followup 92700 Through direct observations, discussions with licensee 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 prevent recurrence had been accomplished in accordance with technical specification The LERs listed below are considered closed:

Unit 2 (Closed) LER 237/91002: Reactor Head Closure Stud Outside Allowable Value The corrective actions for this item included ongoing inspections of the studs. This will be examined as part of future inspections of the lnservice Inspection Progra This LER is close (Closed) LER 237/92008 revision 0 and 1: Unanticipated LPCI Minimum Flow Valve M02-501-13B Closure Due to Spurious Master Trip Unit Spike During Calibratio The root cause was attributed to a loose channel select kno An 18 month preventive maintenance activity to verify knob set screws was added to the surveillance progra This LER is close (Closed) LER* 237/92029, revisions 0 and 1: Bellows at Primary Containment Penetration X-125 Found Outside FSAR Design Limits Due to Inaccurate Piping Analysi This LER is close (Closed) LER 237/92031, revisions 0, l, and 2:

Failure of the Outboard Drywell Air Sample Valve 2-8501-58 During Its 24-month Local Leak Rate Testing Surveillance Due to Improper Valve Seating. This LER is close (Closed) LER 237/92038, revisions 0, 1. and 2: CCSW System found Outside Technical Specification Limits due to Inadequate System Interfacing Analysi This event was discussed in Inspection Report 50-237(249)/92034. A previous violation for inadequate test control was cited in Inspection Report 50-237/9300 This LER is closed.

(Closed) LER 237/92039: Standby Gas Treatment "A" Train Unplanned Initiation Due to Miscommunicatio The cause of the event was miscommunication between the nuclear station operator and instrument technicia The design training discrepancies were discussed in Inspection Report 50-237/92036. This LER is close (Closed) LER 237/92040: Critical Date for Completion of Surveillance Was Exceeded Due to a Management Deficienc The surveillance procedure revision resulted in an extended completion tim Emergent work and miscommunication caused extension into and past the critical perio This LER is close (Closed) LER 237/92045 revision l, LER 249/93003 revision l, LER 249/93011 revision I. and LER 249/93012: Spurious Group V Primary Containment Isolations Due to Flow Spikin Numerous spurious Group V isolations have occurre The licensee's preliminary evaluation indicated the isolations were caused by induced pressure transients and over-conservative flow switch setpoint The licensee planned to submit a supplemental report (LER 249/93003-02) following review of the final engineering evaluatio The root causes and corrective actions to prevent recurrence are considered an Inspector Followup Item (50-237(249)/93020-09) pending review of the supplemental repor The LERs and associated revisions discussed above are close (Closed) LER 237/93014: Drywell Equipment Drain Sump Pumping Interval Exceeded Due to Sump Pumps Tripping Thermall The operators took appropriate short term actions when both equipment drain pumps trippe Work requests to repair the pumps were initiated and will be completed when reactor conditions permit a drywell entry. A supplemental report will be issued to discuss root cause and corrective actions. This LER is close Unit 3 (Closed) LER 249/91007: Type B and C Containment Local Leak Rate Testing Limit Exceeded Due to HPCI Turbine Exhaust Check Valve Leakag This LER is close (Closed) LER 249/92007: Unanticipated Valve Movement During the Integrated Leak Rate Test (ILRT) Due to Procedural Deficiency. A late 10 CFR 50.72 notification was made due to operations management error The licensee implemented the reportability manual and revised the ILRT procedur This LER is close (Closed) LER 249/92011:

High Pressure Coolant Injection Surveillance Interval Exceeded due to Turbine Oil Leakag This LER is close (Closed) LER 249/92023 revisions 0 and 1: LPCI System Not Properly Filled Due to Failed LPCI Pump Discharge Check Valv The licensee determined the cleaning solvent chemically attacked the viton seal resulting in failure and concluded th~ 3A LPCI check valve failure was not reportable under the requirements of 10 CFR 2 The licensee

• .

planned to submit a supplemental report to document inspection of similar check valve A recent failure of the 2A LPCI check valve is discussed in paragraph 5.d. This LER is close (Closed) LER 249/93001: Emergency Core Cooling Level Indicating Switch Out of Calibration Due to Instrument Drift. The event was discussed in Inspection Report 50-249/9203 The 10 CFR 50.72 notification was made late due to instrument mechanic miscommunicatio The licensee performed a feasibility study to replace the Yarway switche The results will be discussed in a supplemental LE This LER is close (Closed) LER 249/93009: Isolation Valve for Pressure Switch Found Closed During Surveillance. This event is discussed in paragraph The failure to maintain proper system configuration is considered another example of a previous violation (50-237/93011-0l(DRP)).

This LER is close No violations or deviations were identifie.

Inspector Followup Items Inspector followup items are matters which have been discussed with the licensee which will be reviewed further by the inspectors and which involve some action on the part of the NRC, licensee, or bot Inspector followup items disclosed during this inspection are discussed in paragraphs 3.f, 5.d, 5.e, and.

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 One Unresolved Item disclosed during this inspection is discussed in paragraph.

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.(2). These tests are:

(1)

it was identified by the licensee (2)

it was not a violation that could have reasonably been correcte (3)

the violation was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (4)

it is not a willful violatio..

One violation of regulatory requirements identified during this inspection for which a Notice of Violation will not be issued is discussed in paragraph.

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 August 16, 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 inspectio The licensee did not identify any such documents or processes as proprietary. *

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