IR 05000237/1996007

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Predecisional Enforcement Conference Repts 50-237/96-07, 50-249/96-07,50-254/96-07 & 50-265/96-07 on 960501. Violations Identified.Major Areas Discussed:Apparent Violations,Root Causes & Contributing Factors
ML17187A420
Person / Time
Site: Dresden, Quad Cities  
Issue date: 05/10/1996
From: Ring M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17187A419 List:
References
50-237-96-07-EC, 50-237-96-7-EC, 50-249-96-07, 50-249-96-7, 50-254-96-07, 50-254-96-7, 50-265-96-07, 50-265-96-7, EA-96-114, EA-96-115, NUDOCS 9605170256
Download: ML17187A420 (77)
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Text

U.S.. NUCLEAR REGULATORY COMMISSION

REGION III

REPORT NOS. 50-237/249/96007CDRS); 50-254/265/96007CDRS)

EA NOS.96-114; 96-115 FACILITIES

. Dresden Nuclear Station, Units 2 and 3 Quad Cities Nuclear Station, Units 1 and 2 License Nos. DPR-19; DPR-25; DPR-29; DPR-30 LICENSEE Commonwealth Edison Company Opus West III Downers Grove, IL 60515 MEETING Predecisional Enforcement Conference May 1, 1996 Region III Offic Warrenville Road Lisle, Il 60532-4351 DATES OF ORIGINAL INSPECTION February 14 through April 1, 1996 INSPECTORS G. Hausman, Lead Engineer D. Hills, Lead Engineer APPROVED BY

'fd,£ ~-to~

M. A. Ring, Chief Lead Engineers Branch 5-/0-qb Date 9605170256 960510 PDR ADOCK 05000237 G

PDR

MEETING SUMMARY Apparent violations identified during the inspection were discussed, along with the corrective actions taken or planned by the licensee. The apparent violations involved a failure to (1) provide adequate design controls to maintain the low pressure coolant injection corner rooms' structural steel design margins (Dresden and Quad Cities} and reactor protection system single failure vulnerability requirements (Dresden only}; (2) take corrective actions to address the previously tdentified potential for several years following your identification of these nonconforming conditions; and (3) submit licensee event reports for these conditions, which were outside the design basis of the plant.

INSPECTION DETAILS Persons Present at Conference R. Baumer, Regulatory Assurance, Quad Cities T. Best, Site Engin~ering, LaSalle N. Chrissotimos, Regulatory Assurance Supervisor, Quad Cities S. Elderidge, Design Engineering Supervisor, Quad Cities D. Farrar, Corporate Nuclear Licensing, Downers Grove R. Gavankar, Chief Mechanical Structural Engineering, Downers Grove J. Hosmer, Engineering Vice President, Downers Grove I. Johnson, Corporate Nuclear Licensing, Downers Grove E. Kraft, Site Vice President, Quad Cities R. Kundalkar, Site Engineering Manager, Dresden F. Lentine, Manager Analysis & Design Engineering, Downers Grove T. Loch, Lead Structural Engineer, Dresden S. Perry, Site Vice President, Dresden R. Rybak, Corporate Nuclear Ucensing, Downers Grove F. Spangenberg, Regulatory Ass~rance Manager, *Dresden R. Temple, Staff Attorney, Downers Grove T. Thorsell, Chief Electrical I&C Engineering, Downers Grove D. Tubbs, Senior Engineer - Nuclear, MidAmerican Energy J. Williams, Assistant Plant*Engineering Supervisor, Dresden U. S. Nuclear Regulatory Commission A. B. Beach, Deputy Regional Administrator, RIII B. Burgess, Enforcement Officer, RIII R. Capra, Director, Project Directorate III-I, NRR B. Clayton, Chief, Projects Branch 5, DRP, RIII G. Grant, Director, DRS, RIII J. Grobe, Deputy Director, DRS, RIII J. Guzman, Lead Engineer, RIII Ha~sman, Lead Engin~er, Quad Cities, RIII P. Hiland, Chief, Projects Branch 1, DRP, RIII D. Hills, Lead Engineer, Dresden, RIII N. Howey, Assistant Office Manager, IONS*

R. Landsman, Project Engineer, Quad Cities, RIII H. Miller, Regional Administrator, Rill G. Norris, Enforcement Specialist, Office of Enforcement C. Pederson, Director, DNMS, RIII P. Pelke, Enforcement Specialist, RIII M. Ring, Chief, Lead Engineers Branch, DRS, RIII J. Stang, Project Manager, NRR Predecisional Enforcement Conference A Predecisional Enforcement Conference was held in the NRC Region III Office on May 1, 1996. Three apparent violations of NRC regulations were discusse The inspection findings were documented in Inspection Report Nos. 50-237/239/96005(DRS) and 50-254/265/96005(DRS}, which were transmitted to the licensee by letter dated April 11, 199 *

The purpose of this conference was to discuss the apparent violations, root causes, contributing factors, and the licensee's corrective action The licensee's presentation included a discussion of the apparent violations, their safety significance, the circumstances which caused the apparent violations~ and an outline of corrective actions taken or planne *

The NRC representatives questioned the licensee to clarify the extent *of the licensee's investigation and corrective action A copy of the NRC slides and licensee's handbuts used during the presentation are attached to this repor Attachments: NRC Presentation ComEd Presentation

...., -

,..

  • U.S. NUCLEAR REGULATORY COMMISSION

REGION III

COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR STATION QUAD CITIES NUCLEAR STATION ENFORCEMENT CONFERENCE MAY 1, 1996 10:00 A.M. (CDT)

REPORT NOS. 50-237 /249-96005 REPORT NOS. 50-254/265-96005 EA 96-114 EA 96-115 REGION III OFFICE e

801 WARRENVILLE ROAD LISLE, ILLINOIS (Slide # 1)

DRESDEN AND QUAD CITIES STRUCTURAL STEEL e

CHRONOLOGY DATE Prior to 1991 1991 1994 *

1995 219 *

3/96 DESCRIPTION Contractor modifications to LPCI corner rooms'

structural steel cause FSAR design stress levels to be exceede Structural steel problem identified at Dresden and Quad Citie o Quad Cities prepares. DCN to reinforce some Unit 2 beam Dresden operability evaluation written to address structura_l steel problem.

o D3R13 outag D2R14 outag o Quad Cities operability evaluation written to address structural steel proble o Dresden BRC approves modifications to be completed subsequent to D2R1 NRC identifies untimely corrective actio o Quad Cities commences modifications during Q1R14.

Dresden performs modifications during D2R1 CSL ide.# 2)

DATE 1975 12/93

  • 2196

DRESDEN RPS VULNERABILITY CHRONOLOGY DESCRIPTION Modification to add scram pilot valve solenoid indicating lights caused vulnerability to single failur Specific problem identified in General Electric 10CFR21 report. Operability evaluation written to address problem.

NRC identified untimely corrective action * o Missed opportunity *to install during D3R1 o Minor modification not scheduled for current Unit 2 outage. Scheduled for next refueling outag o Decision *made to perform modifications during ongoing Unit 2 refuel outage D2R14.

CSL ide # 3)

-

APPARENT DESIGN CONTROL e

VIOLATION 10CFR50, App B, Criterion III requires specification of appropriate quality standards *and control of deviations from such standard Contrary to the above, * inadequate design control *resulted in uncontrolled deviations e.

from appropriate standards for:**.

o*. Contractor modifications of Dresd*en *

  • and.Quad Cities, which caused the.

LPCI corner rooms' structural. steel to exceed FSAR allowable stress level o A single failure vulnerability *at Dresden, which could simultaneously prevent multiple control rod groups e

from scrammin CSl ide # 4)

APPARENT CORRECTIVE ACTION e

YIOLATION

lOCFRSO, App. B, Criterion XVI requires prompt identification and correctjon of conditions adverse to quality are promptl Contrary to the above, conditions adverse to quality were not promptly corrected for:

o Uncontrolled load additions to the Dresden and Quad Cities LPCI corner rooms' structural steel, which. exceeded

~F_S_AR_allowable stress level *

o A single failure vulnerability at Dresden, which could simultaneously prevent multiple control rod groups from

scramming.

(SL ide # 5)

. APPARENT REPORTING VIOLATION e

lOCFRSO. 73(a)(2)(ii) requires an LER be submitted for any condition outside the design basis of the *plant.

. Contrary to the above, an LER was not submitted for conditions outside the design b~sis of the plant for:

  • .

e.* o. Uncontrolled load additions to the

.. Dresden and Quad Cities LPCI corner rooms' structural steel, which exceeded FSAR allowable stress levels.*

o A single failure vulnerability at Dresden,

  • which could simultaneously prevent multiple control rod groups from

scramming.

CSL ide # 6)

  • coMED I DRESDEN AND QUAD CITIES STATIONS

.

,.

PRED-ECIS!ONAL MEETIN*G CORNER ROOM STEEL AND R*EACTOR

...

.

PROTECTION SYSTEM.

MAY 1, 1-996 Page 1

A GEN.DA INTRODUCTION.

KRAFT/PERRY I CORNER ROOM STEE GAVAN KAR DRESDEN WILLIAMS QUAD CITIES ELDRIDGE

. 11 RPS - DRESDEN WILLIAMS I ROOT CAUSES &

HOSMER CORRECTIVE ACTION ANALYSIS Page2

.CORNER ROOM STEEL-DRESDEN *2 &* 3 AND

  • QUAD *c1TIES 1 & 2 I

.

\\

  • OBJECTIVES.*

-- To Define the Fun_ctional Design Bases

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.

.

..,

-.To Define the Str*uctural Design Bases

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- To.. Demonstrate How Loads are:

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.

.

Transmitted to the Structural Steel *.

Page 3

DESIGN BASES

  • Functional Design Bases

- Dresden LPCl Hx - Suppression Pool Cooling

- Quad Cities LP_Cl/RHR Hx - Suppression ~ool Cooling and ~hutdown Cooling_

  • Structural Design Bases'.. *

.

.

- Dead Load+ Pipe Ru.pture ~Operating Basis

.

-

. Earthquake (D+R+El Using N.ormal* Allowable AISC Code St~esses ("Elastic").

- Dead Load +Pipe Rupture + Safe Shutd~wn

. Earthquake (D+R+E') Using AISC Code &

"Plastic" Section Modulus Page4

-* *

FLOOR ELEVATION 580 F QUAD CITIES: RHR HEAT EXCHANGER & PIPING

FLOOR ELEV 503 F LPC DRESDEN

LPCI HEAT EXCHANGER

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_ 111111 STEEL GRATING 1-

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  • TECHNICAL*l.SSUE
  • Maintaining Structural Adequacy of the Steel Framing and Connecfions which Support th~ LPCI an~ LPCl/RHR Heat
  • Exchangers

Page 8 **

  • CONTRACTOR INTERFACE

.

.

  • From 1979-1991, Com Ed _Managed 79-

.

.

.

.

14 and Mark I Loadings Programs to Closure (lmpell, NuTech, and S&L) *

.

Page 9

DRESDEN -* 1991

  • WHAT HAPPENED

- Spring Can Tolerances Added to Drawings to Support ISi Inspections. Routine Load Evaluation Interface Between A/E's Identified Unreported Loads on Steel

  • HOW WE RESPONDED

- A/E Performed P.reliminary Analysis ~o Evaluate Load Identified Overstress in Some Beams. No F9rrrmal Analysis

..

..

.

- No ComEd Response

.

.

  • DO WE BELIEVE THE 'RESPONSE WAS PROPER

- No. Personnel Performance Issue with Lack of Response

  • EXPECTED RESPONSE TODAY i

I

- Walkdown.s, PIF, Operability Evaluations, Action Plan to Restore Conformance Page 10

-

DRESDEN: 1993 - MAY1994

  • WHAT HAPPENED

.

.

.

-

Issue of Unresolved* Report of Loads Raised by A/E (June 1993)

  • -HOW WE RESP-ONDED.
  • -

Initiated Walkdown~ to Identify *al.I Pipe Support Attachments to the LPCI Corner Room Structural Steel (July-Dec 1993)

-

Performed a QE-40.1 Operability Determination Using a Qual'itative *Assessment Based *.on Input From Our* A/E (Ja )'

.

.

-

Developed an Action Plan to Pursue a Permanent Analytical Solution to the Issue to be Completed by 9/30/94

.

.

-

Initiated and Followed Action Plan to Demonstrate Steel in Conformance with UFSAR (Febr~a.ry-May 1994)

~

~. '

!

~ -

Pag~ ii

DRESDEN: 1993 - MAY 1994 (Cont'd)

  • HOW WE RESPONDED (Cont'd)

.

.

-

Met with NRC Region Ill to Discuss the Unresolved Loads and the Heat Exchanger Support Steel Issue (March 1994)

- Reviewed the Action* Plan

- Discussed Methodology. As a Result of this Discussion, a Nozzle Load Issue was Identified

.

.

- Nozzle Loads were lric.luded in Action Plan *

  • DO WE BELIEVE THE RESPONSE WAS PROPER

-

No. the Analytical and As"."Built Res~lution was Pursued to be Completed by 9/30/94. Did Not Recognize Full Significance of Nozzle Loads

  • EXPECTED RESPO*NSE TODAY

-

Understand the Safety Significance, Update the Operability Evaluation, Determine Action Plan and Inform the NRC Page 12 *

,.

  • e e

. DRESDE.N:.JUNE - NOVEMBER 1994 I

.

  • WHAT HAPPEN*E Core Shroud Cracking and Other D3R13 Emergent Safety-Significant Issues *were Identified
  • HOW WE RESPONDED
  • - Action Plan Put on Hold *(June 1994) Extended NTS-Items Tra*cking Issue

- Conclud.ed that*a M*odification was the Best Resolution.(August 1994) *

- Initiated Modification Planning for 1995.

- Obtained Approval for a 1995 M:odification Budget Line Item for Designing ahd lm_plementing Fixes for

  • the Steel (S~pte~b~r.1994)
  • Page 13

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<.....

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DRESDEN:* JUNE-NOVEMBER 1994 {Cont'd).

  • DO WE BELIEVE THE RESPONSE WAS PROPER

- No. The Modification was to be Implemented in 1995 Should Have

- Communicated with the NRC on the New Schedule

  • * EXPECTED RESPONSE TODAY

..

- Restore the Steel Stresses to Witl1in. UFSAR Limits by

Analysis or Modifications * Before Start up from the Refuel Outage, or Gain Concurrence on Resolution Plan with NRC

  • Page 14

Dresden: Dec 1994 - May 1995

  • WHAT HAPPENED

-

Dres~en Stopped all New Modification; Planning (December)

- Analysis Action Plan Review Initiated (December)

-

Corporate Engineering Recommended Modifications (January 1995)

  • HOW WE RESPONDED

-

Requested A/E Cost Estimates for Analysis *

-

Requested Corporate Engineering to Support Analysis and

  • calculations
  • DO WE BELIEVE THE RESPONSE WAS PROPER

-

No. Deferred the Opportunity for the 1995 Modification

'

'

'

- *Potential UFSAR Nonconformance was Not Made a Priority Page 15

~"

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DRESDEN:DECEMBER1994-MAY 1995 (Cont'd)

  • EXPECTED RESPONSE TODAY
  • - Restore the Steel to Within UFSAR Limits* by Analysis or M*odificatio.ns Bef9.re Sta~.up from the Next Refuel Outage, or Gain Concurrence

.

.

on* Resolution Plan* with the NRC Page 16 *

DRESDEN:JUNE1995-FEBRUARY1996

  • WHAT HAPPENED

-

Decision Made to Pursue Modification (June 1995)

  • HOW WE RESPONDED

-

Initiated Modification Planning (June)

-

UFSAR Nonconformance Confirmed (July)

-

Obtained IRB/BRC Approval for t997*and *1998 Installation (October)

-

Funding was Authorized for ~esign (~ovember)

  • * -

D3SW Corner Room Design *eegan (January 1996)

-

PORC Requir~d Additional Justification for Startup (January 1996)

  • DO WE BELIEVE THE RESPONSE WAS PROPER

-

No. Resolution was *not Timely

  • Did Not Upgrade Operability Evaluation
  • Did Not Communicate the Status to the NRC Page 11 *

DRESDEN: JUNE 1995 --FEBRUARY

.1996 (Cont'd)

  • EXPECTED RESPONSE TODAY

'

.

-- Restore the Steel Stresses to Within UFSAR Limits

  • Before Start Up from the Next Refuel Outage or Gain Concurrence on the Resolution Plan with*the NRC Page 18 *

DRESDEN:* FEB 1996 -.MARCH 1996

  • WHAT HAPPENED

- NRC Raised Questions About Open Operability Assessment Prior to Uni~ 2.Start-Up *

  • HOW WE RESPONDED

- Quantitative Assessment Performed to Demonstrate Operability to Support: *

  • Continued.Operation of Unit 3

. * Restart for Unit 2

- Decision Made to Re*pair Ste~I Prior to Start-Up*

  • Structural Steel Conformance Achieved for Unit 2 Prior to Start-Up including Nozzle Loads
  • Dresden Committed to lnstal' Modifications to Restore Unit 3 to Full C~mpliance *by the End of D3R14 (scheduled 9/96 - 11/96)

Page 19 *

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DRESDEN: FEBRUARY - MARCH 1996

  • .*... {Cont'd)

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"

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  • DO WE* BELIEV*ETHE RESPONSE WAS PROPER

- No. Initial Decision was to Stick With the 1997/1998 *

Schedule. The Final Decision was to Restore the Steel Stresses to Within *UFSAR Limits Prior to Starting up from D2R14 and D3R14

  • . EXPECTED RESPONSE TODAY

.

'

- Restore the Steel Stresses to Within UFSAR Limits Before Start Up from the N~xt Refuel Outage

Page 20

CONCLUSION*s

  • The Structural Steel was Always Operable Dresden was Always Safe
  • * We were Untimely in Resolving the * *

Undocumented Piping Loads

  • Until February*1996, We were not.Sufficiently Sensitive to UFSAR Conformance**

--",

.

  • We will Restore Both Units to UFSAR Conformance Prior to Their Return To Service from their Refueling Outages Page 21

QUAD CITIES: 1991

  • WHAT HAPPENED

- During Walkdowns f~r Rigging Assessment Quad Cities Identified (March)

- Pipe Support Loads Not Included* in Analysis of Record

.

.*

- Original Construction Beam Copes in Unit 2 'A'

Ro * HOW WE RESPONDED I

I I

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!

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- Analysis Indicated Overstresses in Unit 2 as a Result of Beam Copes and Rigging Loads Page 22

  • Quad Cities: 1991 {Cont'd)
  • HOW WE RESPONDED (Cont'd)

- ECNs Issued and Installed to Correct Identified Conditi.on

- Work Completed In 1992

- Cales, Transmittals And Approval* Letter Indicated Steel Within Design Allowables as Result of Fixes

  • DO WE BELIEVE THE RESPONSE WAS PROPER

- No, Personal Performance Issue; Other Additional

. Loads Not Pursued

  • EXPECTED.RESPONSE TODAY

- Would Initiate a PIF *Perform Ope~ability Determination and Restore to FSAR Conformance Page 23

QUAD CITIES: 1992 - 1994

  • WHAT HAPPENED

- The Individual Planned to Reconcile Pipe Support Loads by Using Load Monitoring System (LMS.)

- Resolution was Not Tracked *

  • DO WE BELIEVE THE RESPONSE WAS PROPER

.

.

I

- No, there was Reliance on One l.ndividual to Keep Resolution on.Track *

  • EXPECTED RESPONSE TODAY

- Write.a PIF and Follow to Resolution Page24

e e

e QUAD CITIES: MARCl11994

  • WHAT HAPPENED

- March 1994, Notification.of Need to Include Heat Exchanger Noz~le Loads

  • HOW WE* RESPONDED

- Reconciliation of USI A-46 to Occur Through the Use Of SQUG Criteria and Continuati9n of the LMS Task

  • DO WE BELIEVE THE RESPONSE WAS PROPER

..

.

-*

- No,* SQUG Program was in Progress with Hx Included

.on Draft List, But no Positive Controls were in Place to Ensure Closure

  • EXPECTED RESPONSE TO.DAY I

- Positive Tracking Mechanism S\\lch as NTS would Track Item to Ensure Resolution Page 25

QUA_D CITIES: NOVEMBER -1994

  • WHAT HAPPENED

- November 1994, a Corporate Question to Site Engineering on Existence *of Problem at Quad Cities

  • HOW WE RESPONDED.

- Because of 1992 Fixes, Quad Cities Site Engineering Concluded that Non-Conforming Conditions did not Exist Page 26 --

--

.

,.

. e QUAD CITIES: NOVEMBER 1994

  • (Cont'd)*
  • DO WE BELIEVE THE RESPONSE WAS I

PROPER*

- No, Communic*ations were Informal Between Personnel with no Detailed Historical *

Knowledge* of the Issue

  • EXPECTED RESPONSE TODAY

-

- Formal Communications Between Stations and

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-

. with Corporate Engineering Page 27

.I T

QUAD CITIES* 1995

  • WHAT HAPPEN*ED.

.

'

- In August 199~, Further Questions by Corporate and Site Engineering Deter~ined Problem Existed at Quad Cities

  • HOW WE RESPONDED *

- PIF.Written, Performed Operability Asses~~ent

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- Initial Qualitative. Ope.rability Determination Not Approved By POR ~ Commenced Immediate Compensatory Action of Jacking Up Heat Exchanger in Conjunction with

- Analysis and Design Work Initiated to Bring Into Conformance Page 28 *

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QUAD CITIES:* 1995*(Cont'd)

  • DO WE BELIEVE THE. RESPONSE WAS PROPER

-.

  • ..
  • -Yes

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  • EXPECTED RESPONSE. TODAY-Same

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Page 29

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  • QUAD CITIES: OCTOBER 1995
  • WHAT HAPPENED

- Resolution Plan Presented To PORC (Oct)

  • HOW WE RESPONDED

- Pla*n Showed Design.For* Unit 1 to be Issued By

. December 1995 with.Installation for Q1R14

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I

- Plan was ~pproved, Question was Asked

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.

About Possibly Installing On-Line

- Design Work Initiated.

Page 30 *

  • QUAD CITl.ES:. OCTOBER 1995

.* {Cont'd)

  • DO WE BELi.EVE THE.RESPONSE WAS PROPER

....,*,*

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- Yes, Plan Indicated.Gompletion Prior to End of Next Refuel Outage _

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  • EXPECTED RESPONSE TODAY*.*_.,

- Same, However V\\f ould Emphasize Specific Time Interval for Placing Component Back in Conformance

. Page 31

  • QUAD CITl.ES: NOV - o*Ec 1995
  • WHAT HAPPENED

- Preliminary Design Work Demonstrated that

  • Extensive Reinforcements Would Be Required

. - Engineers Involved Determined that More Time Would be Required to Complete Desig*n. Work.

~ Schedule was Moved to Allow Possible On Line Installation Immediately Following Q1 R14 Page 32 e*

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QUAD CITIES: NOV ~DEC 1995 (Cont'd)

  • DO WE BELIEVE THE -RESPONSE WAS PROPER*

- No, Potential Delay Beyond Start-Up Should Have Been Brought to Upper Management for Decision.

..

..

.

  • EXPECTED RESPONSE TODAY

- Clear Expectations would Be in Place for when

.conformance with the UFSAR is to be restored Page 33

QUAD CITIES: FEBRUARY 1996

  • WHAT HAPPENED

- February 1996, Discussion Between Design Supervisor and Site Engineering Manager

  • HOW WE RESPONDE*o

- Contrary To SEMs Belief -.Work:"scope*was.Not in Current Outage *..

- Decision Made by SEM and Station Manager to Perform Repairs During Q1R14

.

.

- Structural Steel Conformance Will be Achieved for Unit 1 Prior to Start-up Page 34

  • QUAD CITIES: FEBRUARY 1996 (cont'd)
  • DO WE BELIEVE THE REPONSE WAS PROPE.

~

-Yes

  • EXPECTED RESPONSE TODAY

- Same *

Page 35

  • QUAD CITIES CONCLUSIONS

- The Structural Steel was Always Operable and Quad Cities was Always Safe

- We were Untimely in Reconciling the Undocumented Piping Loads * **

- We will Restore Both Units to UFSAR Conformance Prior to their Return to Service from their Refueling Outages._

Page 36

  • CORNER ROOM STEEL REPORTABILITY.

Page37

DRESDEN.RPS DESIGN BASIS

  • , UFSAR Section 7.2.1 Definition

. - Prevent the Release of Radioactive Materials* in..

Excess of CFR100 Limits as a Consequence of Any OBA

- Prevent Fuel Damage Following Any Single Equipment Malfunction or Operator Error*

- Function Independently of Other Plant Controls and Instrumentation

- Function Safely Following Any Single Component Malfunction *

Page 38

e*

.......

. e DRESDEN RPS-: 1971-1977

  • 1971 Original Design

- Featured Scram Pilot Solenoid Indicating *

Lights on Control Room Front Panels

- Indicating Light lsolatio*n. Resistors Enclos.ed in Metallic Scram Contactor Boxes

  • . *
  • 1977 Modified Design*.*.

- Added New Solenoid Indicating Lights on Control Room Back Pariel.s :

.

.

~ Indicating Light Isolation Resistors Installed on Motherboards in Control Panels Page 39

Dresdens R.P. VAC RPS BUS

\\

HOT SHORT

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\\.

I I

SCRAM CONTACTORS for GROUP 1 (TYPICAL OF 4, OPEN ON SCRAM SIGNAL)

CU.RR ENT UMffiNG

. RESISTOR 1 PER GROU {SHOULD BE IN SEPARATION BOXES)

INDICATOR *

LIGHT

.

SCRAM PILOT. VN...VE SOLENOID SOLENOIDS FOR OTHER RODS IN*

GROUP 1 SCRAM PILOT VN...VE. SOLENOID CIRCUIT

{TYPICAL OF * ~ AND "~)*

. fi

~CURRENT UMffiNG

~ ~CONTACTOR BOX INDICATOR LIGHT

  • RPS RESISTORS --.

MOTHERBOARD _j

  • **

r =*

. RPS CIRCUIT BREAKER

~ *

-

JI

.. S RESISlQRS

  • DRESDEN. RPS: DECEMBER 1993
  • WHAT HAPPENED

- GE Notifies Dresden of -Potenti~I lnadeq~ate Separation in RPS. *

  • HOW WE* RESPONDED

- Dresden Issued Operability.Assessment-

- No Deviation from UFSAR Section on RPS*

.

.

- Develop Action. Plan with Intent to Modify the Resistors

- QC Found this Issue Not Applicable

Page43

~**

.

DRESDEN RPS: DECEMBER 1993

-

  • DO WE BELIEVE THE RESPONSE* WAS PROPER

- Yes. Not a UFSAR Deviation. Action Plan Addressed Modification Planning and* IRB review by February 1994 and Was Tracked by NTS

..

  • EXPECTED RESPONSE TODAY-Same i.

- Page 44

DRESDEN RPS: 1994

  • * WHAT HAPPENED

- Rebaselined UFSAR Issued in January 1994*

- Rebaselined UFSAR D~scribes Detailed Segregation*

Requirements as Defined in GE Design Specification

  • HOW WE RESPONDED *

..

- No Review of Open Operability Evaluations to the New

.

.

UFSAR was Performed

  • DO WE BELIEVE THE *RESPONSE WAS PROPER

.

.

. -- No. We Should have Reviewed the Open Operability *

Evaluations

  • EXPECTED RESPONSE TODAY

- Open Operability Evaluations Should be Reviewed Page 45

DRESDEN RPS: FEB 1994 -'MAY1995

  • WHAT HAPPENED

- Emerging Issues and Outage Extensions.

  • HOW WE RESPONDED

- No Signifi*cant Progress on Modification Planning was Made* and NTS Items Extended Without Senior Management Approval *

Page 46

DRESDEN RPS: FEB 1994 ~ MAY 1995 (Cont'd)

  • DO WE BELIEVE THE RESPONSE WAS PROPER

- No. Operability Eva*luation Action Plan* was Never Revised

- Management Process to Review NTS Extensions did not Exist

  • . EXPECTED RESPONSE TODAY * *. *

.

.

  • .

- Review Open.Operability Evaluations Against UFSAR

- Change UFSAR or Implement _Modification Prior_ to Startup from Current Refueling Outage

- Since late 199S, Policy: Requires NTS Item Extension Approval by Senior Management (SVP or Station Manager)

Page 47

DRESDEN RPS: JUNE 1995 - JAN 1996

  • WHAT HAPPENED

- Scram Cont~ctor Boxes Inspections and Modification Planning Completed. (July)

  • HOW WE RESPONDED

- Modification Approved by Dresden. Manag~ment (Augusij

-. - Installation Approved f~r -the N~xt Two Refueling Outages (1996 and 1997)

- Lead Unit 3 Design Completed (October)

  • DO WE BELIEVE THE RESPONSE WAS PROPER

- No. UFSAR Deviation was Not Recognized

.

.

Page 48

DRESDEN RPS: JUNE 1995

- JAN 1996

  • {Cont'd)
  • EXPECTED RESPONSE TODAY

- Perform a UFSAR Change or Modifi.cation Prior to Startup from the Current Refueling* Outage

- R*eview and.Resolve Open Operability Evaluations Against the UFSAR i.

Page 49

DRESDEN RPS: FEB - MARCH 1.996

  • WHAT HAPPENED

,- NRC Region Ill Raised Issue ~f Open Operability Evaluation

  • HOW WE RESPONDED

-

Reviewed the Operability Evaluation to Rebaselined UFSAR

-

Identified Deviation from GE Desig_n Specification Referenced in RebaseUned UFSAR

-

Initiated Analysis which. Demonstrated Capability to Resolve Deviation by 50.59. Installed Configuration was in Accordance with RPS Design Basis

  • * *

-

Decided to Implement Unit 2 Modification In D2R14: to Add Margin Instead of Doing a UFSAR Change

-. Updated Operability Evaluation f9r Unit 3 Page 50

  • DRESDEN.RPS: FE.B - MARCH 1996

{Cont'd)

-Reviewed all Other Open Opera,bility Evaluations

.

I

.

-Verified Full Qualification for Unit 2 Operability Evaluations or Reviewed Resolution Plans with NRC Region Ill

.

.

.

-Scrubbed Key Backlogs fo*r Other*Actual or Po.tential.

UFSAR Discrepancies.

  • -Resolved Findings from Backlog Reviews*

--Revised. IRB/BRC._Policy to Identify Cor~ective Action

  • Window for Operability Evaluations to-be Until the Next Refueling.O.utage rage si

' *

I:;,~

-

-

. :

-

,

  • ,-;. ~*.,* -., :. ~

DRESDEN RPS: 1996

  • DO WE BELIEVE TH.E RESPONSE WAS PROPER-Yes
  • EXPECTED RESPONSE TODAY *

- Same Resolve Issue by UFSAR Change*or Modification During Current Refueling Outage

  • - Review and Res.olve Engineering Work Against UFSA Page 52 *

DRESDEN RPS* R.EPORT ABILITY

  • Basis For Decision..

- 50. 73 (a). (2) (ii) Requires Reporting if the Ev.ent *Or Condition Resulted in the Plant Being Seriously Degraded, or in a Conditio~.Outside the Design Basis of the Plant, as Described in the Rule

.

.

  • . - Design Basis as.Defined in 1~CFR5 NUREG 1022 Draft 2 Guidance" Page 53

DRESDEN RPS REPORT ABILITY CONCLUSIONS

- RPS was Not seriously Degraded Since no

.

.

.

Credible Hot Short Condition Could Occ.ur which Would Result. in Failure of RP With any Single Con:iponen~ Fai*lure, RPS Would Have Functioned Therefore ~t Continuously Met the System Functional Goal It Continuously Met the. Design Basis of the Plant

-

Condi~ion was Not Reportable *

Page 54

DRESDEN RPS CONCLUSIONS

-, RPS was Alway*s Operable* and Therefore the Plant was Sa~

- Met the Design Basis but Not the Licensing Basis

- We were Untimely in Resolvin~f the UFSAR Nonconformance

.

.

.

- We will Restore Both *units.to UFSAR *

Conformance Prior to Their Return To Service from Their Refu~ling Outages

. I Page 5_5

ROOT CAUSE & CORRECTIVE ACTION.

ANALYSIS

  • Process

- Analyzed Time Line to Define Causal Factors.

- Focused on 2 Periods-1/91-1/94 (ComEd Decentralization)

- 1/94-(Current Engineering M.odel)

. - Categorized Causal Factors Into 4 Primary *Causes

. i

- Defined Short Term and Long Te.rm Corrective Actions

.

.

.

Page 56

e PRIMARY CAUSES 1991-1994

  • Ineffective ComEd Processes to Deal with Transition to a Decentralized Model

-

Multiple Turnovers of Cognizant Engineers & Plant Leaders

- Evolving Processes for Approving Work

- Programs Shutdown with.Open. Issues and No one Accountable to Close or. Trend.. *

- Multiple AE Interfaces

  • Ineffective Focus on Technical Issues.

- Input from Contractors Not Evaluated or Challenged

- Lack of Technical Knowledge to*ChaUenge Contractor

- Technical Experience On Site Not Sufficient to Walkdown and Recognize Complex Problems *

Page 57

. PRIMARY CAUSES 1991 - 1994 {Cont'd)

  • Ineffective Engineering Management Processes

- No Process* to Manload Scope an*d Manage Work

. - Backlogs Not Ro.utinely Evalu~ted for Significance

- No Engineering Business Plan Aligned to Site Goals Page 58

1994 -1996 e

PRIMARY CAUSES

  • * Ineffective Focus on Technical Issues While* In Transition *to In House Engineering Model

- With Multiple Attempts, Unable to Close Problem in Timely Manner

- Allowed a Change in Design Model Without *Recognition of lmplication*s (Inclusion of Nozzle* Loads)

  • Ineffective Engi~eering Management Processes

- Same as '91"-'94 i

  • Ineffective Understanding of the ComEd Process for Resolution of Nonconforming Conditions

- Need for Tim~ly Res.o~ution of UFSAR Nonconformance

  • Not Well Understood Page 59

Process for Resolving Degraded and NoaConforming Conditions Identification.....

I UFSAR Nonconformance Prompt Action --

Operablllty Assessment... Reporting * Interim Operation

..

Page 60

  • Resolution

. I Change Plant Practice to Conform to UFSAR I qB I

Perform 50.59

...

. AMO Prepare UFSAR Change package Follow-up I

I Include in Next UFSAR Update

  • Primary Causes

'91-'94

- Ineffective Process for Transition to Decentralization (Issue: Corrective A<;tion Timeliness).

  • Sb.Qrt Term Actions (Complete)

- Chiefs/SEMs Developed

List of Potentially Significant Issues (1995 - Complete)

_ Page 61

Long Term Actions (9/96)

Responsibility

- (None-Decentralization Complete)

Primary Causes

'91-'94 and '94-'96 Short Jerm Actions (Complete)

Long T~rm Actions (9/96) Responsibility

- Ineffective Focus on Technical Issues (Issue: Design Control)

- Ineffective Engineering - Review D/Q backlogs for

- D/Q Perform Mod Design Control Assessments (9/30/96)

Management Process Other UFSAR Nonconformances (Issue: Corrective and Resolve Before Startup Action

- For Other Operatihg Units, * *

Timeliness)

Review Operability and UFSAR.

Rebaseline Backlogs and Resolve by Significance

- Define.an Engineering Management Process and Self-Assess Page 62-All Sites Implement Performance Meetings (6/30/96)

Kundalkar Hutchinson Hosmer

,,.

Primary Causes

'94-'96

- Lack of Understanding of Nonconforming Condition Process (Issue: Corrective Action Timeliness)

Short Term* Actions (Complete)

Long Term Actions (9/96)

ResponsibiUty

- Conduct Awareness Training - Conduct Awareness for Eng Managers Team Training for Sites Page 63

- Develop Continuing Traini~g_ Module

. (9/30/96)

  • Site VPs Lentine

Process for Resolving Degraded aa Identification I

I I

.....

UFSAR Nonconformance

NoaConformiag Conditions Prompt Action

~

~

..

Operability Assessment Reporting Interim Operation

..

Page 64

  • Resolution

.I

.

I Chan.ge Plant Practice to Conform to UFSAR I qB Perform 50.59 ANO Prepare UFSAR Change Package Follow-up I

I Include in Next UFSAR Update

v'

-

SELF ASSESSMENT RESULTS OF ENGINEERING'S MANAGEMENT PROCESS

-* Weakness in Three Areas:

.

.

-- Periodic Evaluation of Backlogs, Especially Open Operability Ev_aluations, Agair)st Significance Measure (Significance Measure to Include FSAR Conformance) _ -

- *

i

- Use of Cost/Schedule Tools by aU Engineering

- Functions (Currently Used in Mod Group)

- Common Performance Indicators and _Performance

'

.

Meetings Page 65

~ :

... J

  • '

CONCLUSIONS

  • At No Time were these Events Safety Significant
  • Current Organization had and has Technical Skills to Define the Nonconformance* and Restore Margin to the FSAR Criteria
  • ComEd did not Meet Expectations for Communi~ation with.

NRC Regarding Resolution Plans

  • Weaknesses Exist ln Engineeri*ng Man*agement Process and the Process for Re.solving Nonconforming Conditions that

. Require Long Term Ac~ions.

. :

  • Appropriate Causal Factors an~ Co_rrective Actions have been Identified and Will Be Closed *
  • Corrective Action Plan will be Completed by September 30, 1996

'

Page 66

t:.

.* *

CONCLUSIONS (Cont'd)

  • -With Respect to ComEd's USFAR Conformance.Review:

- ComEd Culture _Places Appropriate Importance on a_n Accurate UFSAR (Rebaseline Programs Have Raised Expectations); but we Have Not Been Timely in

Resolving Identified Nonconformances

- Reviews at All Six Sites Finding Some Unresolved Nonconformances; but they Have Been Able to be *

Resolved by Established, Routine Change P.rocesses (50.59s, UFSAR Changes)

.

_

- Additional UFSAR Reviews Initiated* as a Result of ComEd's Self-Assessment will b.e Completed by 9/30/96

- Trainin*g in Progress to Improve Awareness of UFSAR Conformance Issue *

Page 67

.

  • --..........
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