IR 05000010/1985013

Insp Repts 50-010/85-13,50-237/85-30 & 50-249/85-26 on 850820-1031.Violation Noted:Unit 3 Tech Specs Not Properly Updated to Delete Incomplete Ref Section

ML20136G176
Person / Time
Site:	Dresden
Issue date:	11/15/1985
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136G116	List: IR 05000010/1985013 IR 05000820/2010031 ML20136G111
References
50-010-85-13, 50-10-85-13, 50-237-85-30, 50-249-85-26, NUDOCS 8511220276
Preceding documents:	ML20154B565 (26 February 1986)
Download: ML20136G176 (9)

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U. S. NUCLEAR REGULATORY COMMISSION ,

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REGION III

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Reports No. 50-010/85013(DRP);50-237/85030(DRP);50-249/85026(DRP)

Docket Nos.50-010;'50-237; 50-249 Licenses No. DPR-02; DPR-19; DPR-25 '

I Licensee: Connonwealth Edison Company P. O. Box 767 Chicago, IL 60690 l

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Facility Name: Dresden Nuclear Power. Station, Units 1, 2, and 3 (

Inspection At: Dresden Site, Morris, IL '

Inspection Conducted: August 20, 1985 through October 31, 1985 Inspectors: L. G. McGregor I I

T. M. Tongue S. Stasek  ;

j Steve M. Hare

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bh 6 60 Approved By Geoff rey C. Wrigh , Chief ////6If6di Projects Section 2C Date s

Inspection Summary *

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Inspection during the period of August 20 through October 31, 1985 (Report Not.50-10/85013(DRP); 50-227/85030(DRP); and 50-249/85026(DRP).

Areas Inspected: Routine unannounced resident inspection of operational safety, maintenance, surveillances, Technical Specifications, licensee event reports, the Systematic Evaluation Program (SEP), and periodic reports. The

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inspection involved a total of 481 inspector-hours onsite by four NRC inspectors l including 85 inspector-hours onsite during off-shifts.

_Results: Of the seven areas inspected, one minor violation of NRC requirements l was identified. Unit 3 Technical Specification was not properly updated to l delete an incorrect reference section. This situation had existed since 1974 (Paragraph 5).

l l 9511220276 851115

! PDR ADOCK 05000010 G PDH P

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DETAILS Persons Contacted Commonwealth Edison Company

• D. Scott, Station Manager J. Wujciga, Production Superintendent R. Flessner, Services Superintendent T. Ciesla, Assistant Superintendent, Operations R. Zentner, Assistant Superintendent, Maintenance J. Brunner, Assistant Superintendent, Technical Services R. Christensen, Unit 1 Operating Engineer J. Almer, Unit 2 Operating Engineer J. Kotowski, Unit 3 Operating Engineer W. Pietryga, Unit 3 Operating Engineer for Recirc. Piping Replacement J. Achterberg, Technical Staff Supervisor D. Adam, Compliance Administrator J. Doyle, Quality Control Supervisor D. Sharper, Waste Systems Engineer S. Mcdonald, Radiation Chemistry Supervisor J. Mayer, Station Security Administrator J. Schrage, Radiation Protection Supervisor

• P. Lau, Quality Assurance Supervisor

• R. Stobert, Quality Assurance Inspector The inspectors also talked with and interviewed several other licensee employees; including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, and contract security personne * Denotes those attending one or more exit interviews conducted on September 30 and October 31, 1985, and informally at various times throughout the inspection perio . Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs

! and conducted discussions with control room operators during the period from August 20 to October 31, 1985. The inspectors verified the operability of selected emergency systems, reviewed tegout records and verified proper l return to service of affected components. Tours of Units 2 and 3 reactor

buildings and turbine buildings were conducted to oh erve plant equipment

. conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests tad been initiated for

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equipment in need of maintenanc During the inspection period while Unit 2 was in a maintenance outage, the inspectors verified that surveillance tests were conducted, containment integrity requirements were met, and emergency systems were available as necessar __ __ _ _ _ _

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Throughout the entire inspection period, Unit i remained in a long-term shutdown condition with all fuel removed from the vessel. The inspectors verified that all applicable requirements for Unit I were met during this perio The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection, the inspectors walked down the accessible portions of the following systems to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could degrade performance; and verified that instrumentation was properly valved, functioning, and calibrate Unit 2 Core Spray System (both loops), Low Pressurc Coolant Injection System (both loops), Unit 2 Emergency Diesel Generator, and portions of the Reactor Building Closed Cooling Water System, Unit 3 Isolation Condense Unit 2/3 (Common)

Standby Gas Treatment System, and the Swing Emergency Diesel Generato The inspectors reviewed new procedures and changes to procedures that were implemented during the inspection period. The review consisted of a verification for accuracy, correctness, and compliance with regulatory requirement The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure No violations or deviations were identified in this are . Monthly Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification _ _ _

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The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented. Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

Unit 2/3 (Swing) Emergency Diesel Generator Quarterly Inspection, Unit 3 Control Rod Drive Solenoid Valve Rebuild for CRDs: A-6, B-7, D-7, E-7, F-9, E-5, G-6, F-6, F-7, E-3, H-3, H-1, L-2, K-2, M-4, K-4, H-4, J-5, J-7, M- Unit 2 Rework of Electrical Splices for Drywell Penetrations X204S, X2008, and X205 No violations or deviations were identified in this are . Monthly Surveillance Observation The inspectors observed surveillance testing required by technical specifications for the Unit 2 Low Pressure Coolant Injection System and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed portions of the following test activities:

Unit 2 Core Spray Operability Test Unit 3 Scram Testing of Selected Control Rod Drive No violations or deviations were identified in this are . Technical Specification Review During the inspection period, the Resident Inspector reviewed portions of Dresden Technical Specifications for Units 2 and 3. During the review, the Inspector noted a discrepancy between the two. Unit 3 Technical Specifications Section 3.5.A.7 was not revised to reflect that the referenced Section 3.5.G had been deleted. Section 3.5.A.7 of Unit 3 Technical Specifications states that "If the requirements of 3.5.A carnot

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be met, either 3.5.G shall be complied with or an orderly shutdown of the reactor shall be initiated. . . ." Section 3.5.G had been deleted from both units' Technical Specifications per United States Atomic Energy Commission letter dated April 19, 1974. Section 3.5.G had included a reporting

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requirement as an alternative to shutdown of the reactor if the limiting condition for operation for the core and containment cooling systems could not be met. The reporting alternative was removed so that the specified system must either be operable or the unit brought to a shutdown conditio When the Technical Specifications were revised to indicate the change, the reference to Section 3.5.G was not removed from Section 3.5.A.7 of Unit 3 Technical Specifications. Unit 2 Technical Specifications had been revised properly to show the change. None of the " Controlled" copies of Unit 3 Technical Specifications which were reviewed by the Resident Inspector, including those in the Technical Support Center or Control Room were found to reflect this chang This is considered a violation with 10 CFR 50, Appendix B, Criterion VI for failure to control the issuance of changes to the Technical Specification Although this particular event is of minimal significance, (i.e., the referenced section had been properly deleted) it could cause confusion and delay of proper action by the operator. The station management was appraised of the situation by the Resident Inspector and corrective actions were initiate No other violations or deviations were identifie . Licensee Event Reports Followup 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 Unit 2 (Closed) 85-031-00: Reactor Scram - Spurious SDV Hi-Hi Water Level. The licensee determined that a relief valve on a reactor water cleanup system heat exchanger had lifted allowing system water (420 F and 1000 psig) to drain to the Reactor Building drain header. The scram discharge volume drains to the same header and when RWCU water began draining to the header, it flashed to steam and flowed back to the SDV. The water level in the SDV is indicated by temperature sensors and when a high level was sensed due to the steam intrusion, a scram signal was generated to the reactor protection system. The faulty relief valve was subsequently replaced and the sensitivity of the temperature sensors reduced to prevent spurious trips in the futur (Closed) 85-032-00: Unit 2 Reactor Scram and Group I Isolation. Cause was due to contacts in the mode switch not properly changing state when transferring from the RUN mode to the STARTUP mode during a unit shutdow A procedure change was made to the Unit shutdown procedures for operators to verify correct positioning of mode switch contact _ _ __- _ ___- _-_-_____

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(Closed) 85-033-00: SPING Functional Surveillance Interval Exceede Functional testing was performed upon discovery and personnel involved reinstructe (Closed) 85-034-00: Low Reactor Water Level Scram During Loss of Offsite Power. Licensee determined that the scram was caused by a failure of buses 22 and 24 to transfer power when power to transformer TR22 was lost. This resulted in a loss of one feedpump and a corresponding decrease in vessel level to the scram setpoint. A modification to the fast-transfer circuitry was required to correct a deficiency in design that became evident on the loss of offsite powe Unit 3 (Closed) 85-005-01: Loss of Undervoltage Protection on Bus 34-1. This revision was submitted to update the licensee's corrective actions to prevent recurrence and consists of methods instituted for better communications between individuals involved in testing operation (Closed) 85-015-00: Inadvertent Start of the Standby Gas Treatment Syste The licensee determined the cause to be a personnel error while performing a functional test on refuel floor radiation monitor (Closed) 85-016-00: High Pressure Coolant Injection (HPCI) Room Cooler Inoperable. Cause was found to be a shorted motor contactor coil. The coil and auxiliary contacts were subsequently replace (Closed) 85-017-00: Reactor Building Fuel Pool Channel 'B' High Radiation Trip. Cause was due to cleanup operations of the fuel poo (Closed) 85-018-00: Pressure-Flux Scra Cause was a personnel error while removing a multi-point recorder from the electro-hydralic control circuitry and resulted in closure of all four of the main turbine control valves. During scram recovery operations, difficulty was subsequently encountered in resetting the scram with channel 'B' not capable of being reset for a period of time. Because of this particular configuration, a flowpath for reactor vessel water inventory past the control rod drive seals to the reactor building existed. Once the leakage was identified, corrective actions were taken to stop the' loss of water by manually closing the scram discharge instrument volume vent and drain valves. To prevent recurrence, the closure of the vent and drain valves prior to the resetting of any scram will be required by procedure. Also, discussions are ongoing to determine if further actions, including any physical changes to the equipment involved,~are feasibl .

The Resident Inspectors and a representative from I.E. Headquarters closely monitored the licensee's actions including the determination of root cause, '

corrective actions taken, and associated troubleshooting and maintenance (including the rebuilding of 20 sets of scram solenoid valves that were found leaking following the scram).

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(Closed) 85-019-00: Reactor Vessel Not Vented Below Temperature Limi The head vents were immediately opened upon discovery. Licensee is considering a change to Technical Specifications to modify the minimum temperature limi (Closed) 85-020-00: No Particulate Sample For Unit 3 Reactor Building Ventilation System. Cause was a failure to replace the screen backing in the filter holder during a filter changeout of the sample collector by a Radiation Chemistry Technician. This caused the filter to rip and no sample could then be collected. Upon discovery, the filter was correctly replaced utilizing the screen backin The preceding LERs have been reviewed against the criteria of 10 CFR 2, Appendix C, and when the incidents described meet all of the following requirements, no Notice of Violatiot is normally issued for that ite The event was identified by the licensee, The event was an incident that, according to the current enforcement policy, met the criteria for Severity levels IV or V violations, The event was appropriately reported, The event was or will be corrected (including measures to prevent recurrence within a reasonable amount of time), and The event was not a violation that could have been prevented by the licensee's corrective actions for a previous violatio No violations or deviations were identified in this are . Systematic Evaluation Program The inspectors reviewed the following SEP items for development and implementation per NUREG-0823 criteria and licensee commitments:

4. Installation of Scuppers to Prevent Ponded Water on Roof In response to this topic, the licensee has modified all associated roof parapets to meet the sustained loading from the design

" Probable Maximum Precipitation". The work was done under modification M12-0-83-002 which was subsequently reviewed by the inspector and found acceptable. At present, the physical work has been completed satisfactorily with only the associated paperwork to close the modification package still to be complete Therefore, this item is considered close *

4.1.4 Revision of Emergency Plan to Cope With Design Basis Floodin The licensee, in response to this SEP topic, has completed modifications to its Flood Emergency Plan (EPIP 200-11). However, at present, installation of the required water level monitor on the river intake has not been completed. The work is being done under modification package M12-0-83-001, which was reviewed by the inspecto This item will remain open until the water level monitor has been installe :

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4.18.6 Branch Lines With Single Isolation Valve By letter dated November 18, 1982, the licensee committed to add a second isolation valve to each line identified by the NRC staff as

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having only one. The single valves included 1501-70A and B, 1599-27A and B in the Low Pressure Coolant Injection (LPCI) System, and 1402-10A and B in the Core Spray (CS) Syste In all cases, the redundant valves have been installed, locked closed, and added to the appropriate locked valve checklist. This item is, therefore, considered close .26.2 Bypass of Diesel Generator Underfrequency Protective Trips During Emergency Operation By letter dated September 10, 1982, the licensee committed to implement modifications to bypass the underfrequency protective trips on the Unit 2, Unit 3, and Unit 2/3 Diesel Generators (D/Gs).

Presently the modifications have been completed on the Unit 2 and Unit 3 D/Gs with the Unit 2/3 D/G to be done during the current refuel outage. The inspector reviewed the associated modification packages and found them acceptable. This item will remain open until the modification (M12-0-82-021) has been completed on the remaining D/ .28 Provide Monitoring of D.C. System in Control Room By letter dated October 5, 1982, a commitment was made by the licensee to install battery voltage indicaticn in the control roo In addition, the licensee proposed to monitor battery current, battery changer current, battery breaker status, and changer breaker status which was reviewed and found acceptable by NRR. At present, battery voltage indication has been installed in the control room on both Units 2 and 3 and further modifications are ongoing to install the additional monitoring capability. This item will continue to remain open until all modifications have been completed for this ite No violations or deviations were identified in this are . Report Review During the inspection period, the inspectors reviewed the licensee's Monthly Operating Reports for August and September, 1985. The inspectors confirmed that the information provided met the requirements of Technical Specification 6.6.A.3 and Regulatory Guide 1.1 . Offsite Activities On September 9,1985, the Senior Resident Inspector attended an Emergency Preparedness informational meeting at the licensee's Emergency Offsite Facility (E0F) in Mazon, Illinois. Also attending were state and local representatives and Commonwealth Edison personnel from the LaSalle, Dresden and Braidwood station . _

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On October 9,1985, the Resident Inspectors contacted the local public officials for'Grundy, Will, and Kendall Counties to inform them that a new NRC Senior Resident Inspector had been assigned to Dresden Statio From those contacted, it was determined that a formal meeting was not required to introduce the new SR On October 23, 1985, the Resident Inspectors visited the local public document room (LPDR), which is located in the Morris Public Librar Documents required to be filed therein were found to be included in the system and in a retrievable for . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on September 30, 1985, and informally throughout the inspection period and at the conclusion of the inspection on October 31, 1985, and summarized the scope and findings of the inspection activities. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary. The licensee acknowledged the findings of the inspection.

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