IR 05000249/1986012
| ML17199F932 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/24/1986 |
| From: | Dunlop A, Konklin J, Lloyd R, Stein S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17199F930 | List: |
| References | |
| 50-249-86-12, NUDOCS 8610270258 | |
| Download: ML17199F932 (80) | |
Text
Report No.:
Docket No.:
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH 50-249/86012 50-249 Licensee:
Corrmonwealth Edison Company P.O. Box 767 License No.:
DPR-25 Chicago, IL 60690 Faci 1 ity Name:
Dresden Unit 3 Inspection At:
Dresden Unit 3 Nuclear Station Inspection Conducted:
April 21 - May 7, June 9-13 and July 7-16, 1986 Inspectors:
R. L. t'.loyd,"' Rea tor* construction Engineer
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S. R. Stein, Reactor Construction Engineer k*d/.dzcw11d ~
A. Dunlop, Test Programs Inspector, R-III Consultants:
R. M. Compton, A. R. Jacobstein, M. I. Good, M. D. Sulouff Approved By:
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£ E. Konkfin~Acting Chief Rea~ Construction Programs Branch B61,02702:;a -:*a610Y7*
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SUMMARY 1.. 1 Introduction The following subparagraphs provide introduction to the objectives, format and focus of the Dresden Safety Systems Outage Modifications Inspectio. Objectives This inspection was part of a trial NRC program being implemented to examine the adequacy of licensee manage~ent and control of modifications performed during major plant outage The purpose of this portion of the Safety Systems Outage Modifications Inspection (SSOMI) Program was to examine, on a sampling basis, the installation and testing of selected modifications acco~plished during the outage.. This assessment covered the following areas:
1.1. Effectiveness of controls for conducting modification work activities during outages, 1.1. Accomplishmeni of modification work activities in accordance with the established procedures and commitments, 1.1. Proper inspection and testing of completed modificationsJ and Ll.1. 4 Readiness of affected systems for safe startup and ope rat ion of the plant following the outag. Defiriitions 1.1. Deficiencies: Errors, incohsistencies or pr~cedure violations with regard to a specific licensing commitment, specification, procedure, tode or regulation are described as deficiencie Followup action is required for licensee resolutio.1. Unresolved Items:
Unreso1ved items are potenti~l deficiencies which require more information to.reach a conclusio Foll owup action is required for licensee resolutio.1. Observations:
Observati~ns repr~sent cases where it is considered appropr~ate to call.attention to matters th~t are not deficiencies or unresolved item They include items recommended for licensee consideration but for which there is no specific regulatory require-men No licehsee response is requi.re. Dresden Project Organizatio Commonwealth Edison Company (CECo) is the licensee for the Dresden Nuclear Power Statio As such, CECo is responsible for the design, construction and operation of the facilit General Electric designed and provided the nuclear steam supply syste The original architect-engineer, Sargent and Lundy (S&L)
is still under contract to the license Other firms are also engaged to perform architect~engineering services for the design of modification These architect~engineers are responsible for the detailed preparation of the design basis specifications, drawings, instructions and procedure CECo assume project management ro1e for modifications at stations when outside engineeririg
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firms are employe This entails work scheduling, engineering manpower alloca-tions, establishing the requisite 1 evel of engineering for specffi c a.reas (where.required) and approving the format and content of engineering outpu. Inspection. Effort An announced team inspection of installation and testing activities associated with outage modification work was conducted at Commonwealth Edison's Dresden Nuclear Station during the periods of April 21 - May 7, June 9-13 and July 7-16, 198 This inspection was part of the tri.al Safety Systems Outage Modification Inspection Ptogra ~anagement controls w~re evaluated in Various functional areas using 43 outage modifications as the basis for the inspectio I
.. Overall Conclusions The NRC inspection team concluded that weaknesses exist in the licensee's program for accomplishing outage modification work activitie The team identified concerns in each functional area reviewe Since the concerns appeared to be pervasive, management attention should be directed toward correcting the programmatic deficiencies in addition to resolving individual concern The most significant concerns identified involved (1) inadequate
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design change control, (2) improper installation of equipment, (3) in-adequate procedures and instructions, (4) inadequate quality assurance (QA) and quality control (QC) overview of modification activities, and (5) inadequat~ control of testin These are summarized as follows:
1. Inadequate Design Change Control Numerous examples were noted in which field changes were made without proper dotumentatiun or revie One example w~s the failure to incorporate field changes made in the torus to reactor building vacuum breaker valve actuator piping installation on Unit 2 into the modification package which was copied for use on Unit~. Other instances were identified in which engineering/
safety evaluations were not performed and field change or design change notices
- were not generate Examples include changes to the wiring of the low pressure coolant injection (LPCI)/core spray relay modifications, changes to a fire barrier penetration through the reactor building wall, changes to the materials, configuration and stroke times bf safety-re.lated valves, and changes to the motor connections for the LPCI room cooler modification Discussions with maintenance personnel resulted in a perception by the SSOMI team that personnel c6nsider the protedures and d~awings in the modifications packages to be*guidelines rather than requirement This perception was reinforced by the number of instances identified in which significant deviations from the instal-lation instructions were made in the field with no feedback to allow engi-neering review of the change. 2. 2 Improper Installation of Equipment Significant installation concerns were identified in 27 of the 33 modifications inspected by the tea Examples of installation concerns were the reversed installation of the actuator lines for the torus to reactor building vacuum breaker valves, imp roper Raychem cable sp 1 ices, incorrect terminations, improperly installed snubbers, improperly designed and installed HPCI pipe whip restraints, reactor building penetrations not in accordance with design or work package requirements, and bundling of safety-related cables with nonsafety-related cables in the analog trip system cabinet. 2. 3 Inadequate Protedures and Instructions The team identified significant procedural deficiericies in 36 of the 43 modifications inspecte Examples of deficienties include a lack of acceptance criteria for electrical tests, conflicting Technical Specification requirements for the LPCI room cooler installation, lack of procedures for installation of lead shielding, an unworkable test procedure for the vacuum breaker valve solenoid modification and, contrary to a 1983 Confirmatory Action Letter from Region III, five work requests with instructions for greasing valve seat ;..
1. i Inadequate Quality Assurance/Quality Control Overview of
_Modification Activities The numbers and types of installation and procedural deficiencies identified by the team during the inspection indicate that the QC coverage of installation attivit1es, the QA bverview of the QC inspections, and the CECo review of procedures and records, need to be significantly improve The major.installa-iion and documentatibn deficiencies identified by the team had been previously sighed off.by QC as acceptable.
. 1. 2. 5 Inadequate Control of testing The test procedures rev1ewed cbntaihed numerous errors and omission~, including incorrect equipment references and locations, impractical test sequence steps, uninitialed handwritten trip point changes, latk of verification of test prerequisites, lack of signoffs for test completion or verification of test acceptability, incorrect Techn.ical Specification references, and failure to specify valve stroke times required by American Society of Mechanical Engineers (ASME) Code Secti.on X The team's witnessin,g of test performance and review of test results also i dent ifi.ed a numbe'r of concerns, 1he1 udi ng undocumented deviations from test procedures, lack of evaluations of changes in testing requirements or test conduct, fai 1 ure to record perti.nent test information, and failure to document or evaluate test failures and discrepancie.,
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L3 Summary of Findings by Functional Areas The findings*resulting from the inspection have been grouped into 10 basic functional areas and are summarized belo.More detailed discussions of.the findings, with identification number designations, are included in Section 2 of this repor Table I identifies all the work packages reviewed during this inspection effort and summariies the concerns by work packag. Design Change Control Weaknesses. in design change control were identified in many of the modifica-tions examined by the inspection tea Engineering safety evaluations (10 CFR 50. 59) were either not performed or were inadequately performed for install a-t ion of lead shi el ding, insta 11 at ion of reactor building hose penetrations, electrical jumper installations, and changes to modification test procedure Numerous. handwritten changes were made to i nsta 11 at ion drawings in lieu of the proper formal change process documentatio Several instances of design errors
. or oversights were identified. Examples include an erroneous design change on a pipe whip restraint, designation of new material in conflict with design specifications, and errors on piping and instrument drawings (P&IDs) regarding valve positions ~nd functionin. 3. 2 Do.cument Adequacy and Contra l Discrepancies were identified regarding inaccurate drawings, improperly changed drawings, improper control of Station Procedure Temporary Change Requests (TCRs}
and untimely revision of procedure. 3. 3 Installaiion Procedure Control Inadequacies were noted in work instructions involving specific details relating to design. criteria, i nsta 11 at ion or repa.fr methods, acceptance criteria for inspection and testing, and indication of required or optional QA/QC hold point Modification packages frequently failed to comply with site administrative requirements and in general were disorganized and inadequately controlle The inspection team identified numerous examples which indicated that production personnel considered site procedures and 1nstructions to be guidelines to which striC:t adherence was not require Procedures that 1 acked needed i nformat iOn that were in error were not challenged by field personnel ('craft, QA/QC or engineering) and consequently were nbt corrected. ln at least ~ne ~ase this resulted in repeating improper hardware installations from a previous outag. Installation and Constructio~Controls The inspection team identified physical installatibn deficiencies with 27 of 33 modifications examine Discrepancies wer~ noted in*numerous areas and included improper cable splices; improper wiring; missin~ and undersized welds; piping not in accordance with design drawings, specifications, procedures or as-built drawings; improper electrical jumpers; and loose, damaged or missing material. The large number of discrepancies noted were indicative of a significant lack of attention to detail by engineering and crafts and a lack of involvement by QA/QC in assuring complete and accurate performance of wor *
1. Mainten~~ce Controls ahd Practi~es Numerous housekeeping and maintenance related concerns were noted. in e lectri ca 1 cabinet The provisions for maintaining and verifying cleanliness and control of foreign material exclusion for mechanica1 modifications need to be improve. 3. 6 Test Procedure Control The inspection team iden:tified a generic: concern that test procedures often lacked signoffS for prere(juisites, significant work steps, and satisfactory test completio Tests lacked reference to or verification of valve lineups, had improper or inadequate use of temporary changes and had numerous errors in
.referencing of valves, instruments, relays, procedure steps and Technical Specifications (TS).
Conflicts were noted between surveillance procedures, the fSAR and the TS with regard to contain~ent isolatioh valve...
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Test Conduct and Documentation The inspection team had a concern that test procedures, as with modification procedures, were considered as guidelines onl Tests that had failures or had duplicate sets of data or signatures were not.annotated to explain wh Tests were incompletely or improperly changed by handwritten notes or performed differently ~han detailed in the test protedure without documentatio Test steps were signed off as complete prior to performanc Test procedures were annotated to refer to test evaluations for acceptance of test results but no such evaluations had been performed as 1ong as six weeks after test completio *Although many of the discrepancies identified with the conduct of tests could be considered to be minor or could be resolved, the sheer.number noted indi.-
cated a significant lack of test control and.adherence to procedure As wfth the *modification ins ta Hat ion act i vi't i es, the involvement of the QA/QC
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1. Quality Assur~nce/Quality Control.Prograin Activities The team identified two aspects in the QA/QC program that required strengthen-ing:
Procedures and instructions should include more hold points for QA/QC.
verification of work quality; and QA audits and surveillances shou.ld be refocused on direct observation of field activities, and hardware and final work quality rather *than on procedures and documentatio In general, QA.and QC must become more active, forceful participants in the work activitie Drawings, procedures and tests should be complete ahd accurate prior to performing work and that work should be performed as specified. *
1.3. 9 Qualification and Training of Personnel Although training and qualification of.personnel was found to be adequate in general, one concern was identifie QC personnel used for electrical inspec-tions were primarily experi~nced in mechanical inspections.
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1.3.10 Corrective Actions Long and short term corrective actions presented by CECo management at.the.mid point and end of the inspection appeared to be compr~hensive. The actions should be effective if Dresden personn~l correctly implem~nt the proposed progra However, the program did not address modifications performed during previous outage,- DETAILED lNSPECTION FiNDINGS List of Deficienc~es, Unresolved Items and Observations Item D2.2-1 02.2-2 02.2-3 02.2-4 02.. 2-5 02.2-6 02.2.;.1 02.2-2 02.2-7 02.2-8 U2.2-l 02.2-9 02.2-10 02.2.;.11 02.2-12 02.2-13
.02. 3-1 02.3-2 D2.3-3 Subject lack of documented safety evaluations for installation of lead shielding on saf.ety-related piping and componen:ts Inadequate d~sign of HPCI pipe whip restraint Lack of documented safety evaluation for replacement of CS flow switches Uncontrolled design changes for HGA relay replacement Lack of change documentation for.repair of -EQ equipment
Lack of documented safety evaluations for electrical jumpers
Report Section 2....2.. ~. Inadequate safety evaluations for electrical jumpers 2. Inadequate electrical jumper qu~rterly ~eviews 2. Inadequate safety evaluations for procedure changes 2. Lack of a safety evaluation for design change 2. Inadequate safety evaluation for HPCI pipe 2. whip restraints Design changes accomplished without engineering 2.2.10 reviews Design changes for solenoid valves not controlled 2.2.12 Design* changes for vacuum breaker valves not 2.2.13 controlled Unauthorized modifications to a safety-related 2.2.14 structure
Inadequate safety evaluations and timely completion
.2.2.15 of engineering revi~ws Inadequate control of drawings 2..Improper review of a drawing revision 2. Inadequate control of the Master Temporary 2. Change Request Log
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Item 02.3-4 02.4-1 U2.4-1 02.4-2 02.4-1 02.4-3 02.4-4 02.4-5 02.4-6 02.4-7 02.4-8 U2.4-2 U2.4-3 02.4-9 02.4-10 02.4-2 02.4-11 02.4-12 02.4-13 02.5-1 02.5-2 02. 5-1.
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Subject Report Section Installed CCSW modification not in ~ccordanc~
2. with drawings or design criteria Inadequate acceptance criteria in work packages
.2. Inadequate slope criteria for instrumentation 2.4. and drain lines Inadequate procedur~ control 2. Pro6edures considered to be guidelines 2. Incorrect wiring verification steps signed as 2. being completed Conflicting safety evaluations-2. MMP not revised to be in accordance with T~chnical 2. Specifications QA/QC hold points not includ~d in work packages 2. Inadequate SSC proc~dure. Operating procedure review period not in accordance 2. with ANSI N18. 7 Inad~quate seismic qualification of LPCI room cooler 2.4. Indeterminate seismic installation requi~ements 2.4. Incorrect referen~es to Technical Specifications 2.4.10 P~ocedures to tontrol work r~quests were inadequate 2.4.11 As-built CCSW modificatiDn n6t in accordance with 2.4.12 design or drawing requirements Work accomplished ~utside the scope of the work 2.4.12 package Inadequate control of removal and reinstallation of 2.4.13 mechanical interferences for the RPR project Inadequate foreign material exclusion practices 2.4.14 Installations not in accordante with work package~
2. Electrical installation deficiency not corrected 2. Electrical cable to motor operated valve incorrectly 2. identified
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Item 02.5-3 02.5-4 02.5-2 02. 5-5 02.5-3 02.5-6 02.5-7 02.5-4 U2.5-1 02.5-8 u2.s-2 02.5-9 02.5-10 02. 5-11 U2.5-3 02.5-12 U2.. 5-4 02.6-1 02.7-l 02.7-2
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Subject Report Section Inadequate cable splices 2. Incorrect relay wiring 2.5. Inaccurate uncontrolled drawing used to locate 2. 5. 5. 2 relays in cabinets Installation discrepancies for LPCI room cooler 2. m6tor replacement 110 11 -ring replacement in EQ transmitter not 2. documented in work package Installation discrepancies with replacement of EQ 2. solenoid operated valves Untohtrolled and deficient modifications 2. accomplished on torus to reactor building vacuum breaker valves
~rease used on seals subject to local leak rate te'sti ng Installation of Unit 3 CCSW modification not in accordance with design Installation of Unit 2 CCSW modification not in accordance with design requirements QC inspection for weld. defects ~hclear Installation discrepancies associated with die.sel
~enerator itistrumentation modification Installatibn discrepancies ~ssociated with reactor building penetrations Inadequate installation of snubbers Inadequate installation of Fire Suppression System modifications Main Steam piping 1 ug i nsta 11 at ion not in accordance with drawing Inadequate modification to the security diesel Inadequate maintenance controls and practices Inaccurate test procedures RPR special test procedures lack documentation
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2.5..5.10 2.5.11 2. 5.1. 5.. 12 2.5.13 2.5.14 2.5.15 2.5.16 2.5.. 17.. *
Item D2.7-3 U2.7-1 U2.7-2 U2.7-3 U2.7-4 D2.7-4 D2.7-5 D2.8-1 02.8-1 02.8-2 D2.8-2 D2.8-3 D2.8-4 U2.8-1 D2.8-5 02.8-6 02.8-7 D2.8-8 02.8-3
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Subject Report Section Inadequate test procedures and ~hange control 2. Indeterminate process for turnover of syste~s 2. to operations with completion of testing Limited QC coverage during performance of te~ts 2. Incorrect Technical Specification references in 2.7.~
test procedures*
Test procedure change not in accordance with site 2. procedures
Inconsistencies found between the FSAR and the 2. Technical Specifications regarding tests of containment isolatton valves Test procedure for cycling of torus of reactor 2.7.10 building vacu~m breaker valves was i~adequate Test failure not proper1y documented and evaluated 2. Inadequate documentation for calibration checks of 2. transmitters Header differenti.al pressure transmitters mislabeled 2. in test procedure lhadequate test conduct and documentation of LPCI 2. preoperational test deviations LPCI flow test not properly perf~rmed, indeterminate 2. results not evaluated lest conduct continued without an evaluation of a 2. test failure of a prerequisite step Inadequate test of main steam safety valves 2. Deviation from LPCI/CS logic test 2. Inadequate functional test of motor operated 2. valves Inadequate conduct of bus undervoltage and.fCCS 2.8.10 integrated functional test for Unit 3 diesel generator Inadequate ~onduct of bus undervoltage and ECCS 2.8.11 integrated functional test for 2/3 diesel generator Dresden operating surveillances lacked detail 2.8.12
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Item U2.8-2 02.8-4 02.8-5 02.8-9 02.9-1 02.9-2 02.9-3 02.9-4 02.9-5 02.10-1
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Subject Report Section Temporary electrical jumpers installed an excessive amount of time Indeterminat~ vibratioh readings Lack of documentation for test failure Hydrostatic test not performed per procedure few hardw~re di~crepancies written by QC QA surveillance did not emphasize field observation Lack of trending of distrepanty reports or idenfi-cation of adverse trends Hydrostatic tests accomplished without satisfactory final inspections Lack of field surveillances Inadequately trained QC personnel
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2.8.13 2.8.15 2.8.16 2.8.17 2......10
- Design Change Control
.Design change control was evaluated on a limited basis since the design change process was reviewed in detail during th~ design inspecti6n.part of the SSOM Installation and control bf lead shielding was reviewed in relative detail, and other design change control issues were investigated if weaknesses were identi-fied during review of modification work package. The use of lead shielding was evaluated to det~rmine whether temporary or permanent design changes had been made to plant systems without adequate engineering review CFR 50~59 requires that safety evaluations *be. atcomplished for temporary or permanent design changes to determine whether an.unreviewed safety question exists or whether a change to the Technical Specffications is involve None of the lead shielding installations had documented safety evaluations which violated the requirements of 10 CFR 50.59 (Deficiency 2.2-1);
however, an Impe ll computer program or stress tables were utilized during the Unit 3 outage to deter~ine the maximum amount of lead that tould be i~stalle *
An INPO audit finding, T.S. 4-2 dated July 1982, first raised concerns regarding installation of lead shielding on safety and nonsafety related pipin In additibn, NRC IE Information Notice N ; "Lead Shielding Attached to Safety-Related Systems Without 10 CFR 50.59 Evaluations," was issued. The Dresden Station responded to the INPO finding and the IE Notice by *issuing Dresden Technical Surveillance (DTS) procedure 020-3, "Temporary Installation of Lead*
Blankets, 11 in April 1984. Procedure DTS-020-3 was deleted in January 1985 and replaced by Dresden Administrative Procedure (OAP) 12-12,
"Installation and Control of Temporary Shieldirig.
OAP 12-12 was last revised in June 1986 after concerns were expressed by the SSOMI inspection team regarding the lack of shielding installation proce-dures and 10 CFR 50.59 evaluation The Jurie 1986 revision to OAP 12-li ~equired a 10 CFR 50.59 review only for those lead shielding installations in which additional supports were requ*; red, or where the shieldirig was attached to a support oth~r than a pipe, and not for each lead shielding installation as required by 10 CFR 50. Generally, individuals who authorized the tnstallation of shielding did not wa 1 k down the prospective area prior to shi e 1 ding i nsta 11 a-t ion and relied on craft inpu The Impell shielding computer program assumed that shielding was rigidly attached or fixed to the pipe or component and did not allow for shielding that was draped or loosely attached~ Contrary to the Impe ll program assumption, Dresden did not rigidly fix or attach shielding.. At the time of the inspec-t ion, Dresden had no procedures to contra 1 the methods of installing shieldin Dresden personnel did not appear to be aware or concerned that shielding installation methods were not consistent with the Impell computer code assumption Had a seismic event occurred, possible overstressing of piping or components or damage to other safety-related equipment may have occurred becau.se of shielding shifting or falling shielding.
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Regarding M12-3-84-42 (HPCI Pipe Whip (PWHP) Restraints), the
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premodification hot position measurements for PWHP-1 showed contact between the pipe and the restraint sleeve on one sid The design change was to install *1!.i inch thick shims onto the bottom 180 degrees of the.restraint sleeve inside diamete Therefore, instead of achieving a design clearance around the pi.pe at operating tempera-ture, a greater interference would result_, with additional unanaJyzed loads on the p*ipe and restraint due to thermal expansion.. As site procedures did not require verification of the final clearance at operating temperature, this design error would probably not have been discovered by the licensee..In addition, many high pressure coolan*t injecti'on (HPCI) system pipe restraints had recentlybeen installed, removed or modified for the NRC.IE Bulletin (IEB) 79-14 related modificatio These changes to the supports/restraints, if located in the proximity of the whip restraints, could affect pipe movements and thus invalidate the original hot position measurements taken in 198 There was rio evidence that the effects of these support modifications on the PWHP restraint modification were considered by engineering (Deficiency 2.2-2).
Subsequent to the identification of this design error, the licensee redesigned PWHP-l and removed and reworked the field installatio The review of modi fi cat ion package M12-3-83* 37 (I EB-79-.01 EQ Instru-ment Replacement) not*ed that a 10 CFR 50. 59 safety review had not been conducted subsequent to raising the hydrostatic test pressure from 250 psig to 400 psi~. The modification package contained~
safety review for *the replacement of the tore spray system flow switthes with environmentally qualified flow transmitters and the required testing after transmitter replacemen Modification package M12-3-83-37 did not contain a second *safety review as a result of the hydrostatic test pressure change as required by 10 CFR 50.59
(Deficiency 2.2-3).
- The drawings for modification M12-J... 84-8 (HGA Relay Replacement)
contained a significant number of uncontrolled design change The modification was written with instructions to use specified drawings for installation of the relays and wiring change In many cases the actual i nsta llat ion differed from the dfawings, s foce the drawings reflected another relay modification, M12-3;.82-27, which had not been implemented..Instead of processing design changes, handwritten notes were added to the wiring diagrams to change the wiring requirements or provide instructions on how to proceed since M12-3-82-27 had not been complete Changes to construction drawings, including notes necessary to enable the installation to proceed, should have been submitted as a Drawing Change Request (OCR) or Field Change Request (FCR) in accordance with Quality Procedores (QPs) 3-2 and 6-5 The changes discussed below were not submitted as DCRs or FCRs in viol a-t ion of QP 3-2' "Design Change.Contra 1 'II QP 6-52, II Procedure for Station Construction Department Design Document Control, 11 the requirements in the modificatfon Station Nuclear Engineering Department (SNED) letter dated July 19, 1984, and OAP s~1. In addition, because the mod.ifieation could not be performed in
.accordance with the modi fi cation package wfth*out adding ext~ns i ve notes on the drawings, a disposition should have been requested by the working department iil accordance with QP 3-51, "Design Control for Ope rat ions - Pl ant Mod.i fi ca:t ions."
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The following examples illustrate how design changes were recorded on drawings w*ithout processing design change documents; and as a result, the actual *installation did not conform to the latest wiring diagrams (Deficiency 2.2-4):
Drawing 12E3757D, Rev. Y showed terminal 6 of device 530-i08-(DG)
wired to point HG-1 A hand written note changed HG-13 to AQ-6 and then the note was changed from AQ-6 to AQ-The actual connection in the equipment was to AQ-5 although the current revision of the drawing (Rev. AA) indicated AQ- *
Drawing 12E3757C, Rev. Y had a handwritten note on it stating that wiring should be connected to terminals different from that shown on the drawing if M12-3-82-27 was not complete A note was handwritten on drawing 12E3757D, Rev. Y which required the install at ion of a jumper between termi na 1 s 2 and 10 on device 1530-12 On the same drawing, 12E37570, Rev. Y, a handwritten note instructed personnel to use Revision T of the drawing if modification M12-3-82-27 had not been complete Revision T of the drawing was not in the work p~ckage or on the drawing lis In addition, there were other wiring changes specified in the note ~hich were not in accordance with the drawin Drawing 12E2758, Rev. Y had a handwritten note which required the installation bf a jumpe D.rawing 12E27580, Rev. Y had a handwritten note which described wiring changes to be performed in addition to requiring that Revision V be used if modification Ml2~3-82-27 had not been tomplete Revi.s ion V of the drawing was not on the drawing 1 i st and the drawing was not included in the packag *
Drawing 12E3758C, Rev. Z contained.a note which required specific
- wiring changes to be made. *In addition, a note w~s l~ft on the drawing from a previous revision which required removing certain jumper Although in place, if those jumpers were removed as the note required, the circuit wotild not have functioned correctl Drawing 12E3758D, Rev. Y had a handwritten note which invoked Revision V of the drawing if modification M12-3-82-27 had.not been complete Revision V of the drawing was not on the drawing list or in~luded in the pack~g A review of modifications M12~3-84-49 and M12~3-84-50 (Replacement of West and fast LPCI.Cooler Motors, Respectively) determined that a change was made to the installation packages on November 22, 1985, to ensure that damaged braided insulation on the motor terminal leads was repaired and that equip~ent qualification was maintaine This modification change was performed in compliance with.OAP.5.1, 11 Plant Modification Program.
CECo SNED had originally specified the environmentally qualified (.EQ) splices required for the work and had
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determined the remainaer of the EQ requirement No design change document was initiated to obtain SNED review of the proposed change in scope to the modification (Deficiency 2.2-5).
SNED re~iew was required sirice the Westinghouse EQ manual did not i.nclude the Raychem WCSF-N tubing in its recommended insulating material for the motor lead The EQ report recommended that Scotch 33+, 88 or 130C tapes be used for terminal lead connections; but did not address repairs to the motor leads which are qualified with the braided jacke CFR 50. 59 reviews were not complete~ on jumpers installed prior to December 24, 1985, altho~gh 10 CFR 50.59 was effective on March21, 19°74 (Deficiency 2.2-6).
The plant revised OAP 7-4,
"Control of Jumpers or lifted Leads," to.implement a policy of completing safety reviews on jumpers installed after December 24, 1985, but failed to consider jumpers that were installed prior to that date and were still installed. When the SSOMI inspectian team questioned the policy regarding jumpers installed prior to December 24, 1985, safety evaluations were conducted in accordance with 10 CFR
.50.59 for all jumpers currently installed in the plan Safety eva 1 uat ions that were subsequently conducted on all o 1 der existing jumpers (installed prior to December 24, 1985) were reviewed by the SSOMI team and found to be inadequate in that they did not provide sufficient justification for the response to each question on the safety evaluation for For example, the 10 CFR 50.59 question regarding whether the addition of a jumper wi 11 have an affect on plant safety was typically answered with such unsupported statements as "has.no effect on plant safety 11 (Observation 2. 2-1).
Separate fro~ the 10 CFR 50.59 evaluations, OAP 7-4 required quar-terly jumper reviews which were conducted by CECo technical staf These reviews also did not sufficiently explain why the jump~r must remain 1n plac Terms such as "still required" were used with no accompanying reason regarding why the jumper should continue to remai.n in the plant (Observation 2.2-2).
2. The inspection team identified.a concern.regarding 10 CFR 50.59 reviews of changes made to test procedure One-time changes or permanent changes prior to procedure revision were documented on TCRs for current testin Many of the TCRs which were written to incorporate steps to functionally test modifications had inadequate safety review The reviews either repeated the evaluations
--, performed for the modifications themselves or simply referred to the modification package's safety revie The TCR reviews did not directly address the impact on plant safety of changes being made to the procedures as required by 10 CFR 50. 59 (Defitiehcy 2. 2-7).
2. During an inspection of modification MlZ-2/3-85~34 (Install Reactor Building Hose Penetration) it was noticed that the as-built accepted configuration did not agree with the instructions contained in the work packag Sargent and Lundy reviewed and approved the installa-
- 16 -
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tion of two penetrations through the reactor building wall contingent upon specific dimensional criteria being.me The penetrations installed did not confo~m to the de~ign requirements of Sargent and Lundy, thus negated the initial 10 CFR 50.59 review (Deficiency 2.2*8).
When Dresden was notified of the design discrepancies by the inspection team, a 10 CFR 50.59 re-evaluation was performed, based on the as-built lo.cation of the penetration. During review of the work package for modification M12-3-84-42 (Modify HPCI Pipe Whip Restraints) it was noticed that the 10 CFR 50.59 evaluation was performed based on modifications to three pipe whip restraints whereas the final work package modified only two pipe whip restraints. Within the time constraints of the inspection, the inspection team could not determine whether the lack of a 10 CFR 50.59 re-evaluation was conservative or nonconservative (Unresolved Item 2.2-1)
2.2.10 A walkdown of M12-3-85-50 (Installation of Diesel Generator Cooling Water Pump Suction Pressure ~age) indicated that the modification did not tonform.to the requirements of design documents (Defici~ncy 2.2-9}.
For example:
2.2.10.1 The work package included a sketch and a station tr*aveler which specified that a 1/2-inch 2000-psi bronze valve was required to be installe Step 3 of the traveler was signed off as conforming to this requiremen A second sketch in the work package referred to the valve as a 200-psi valv The QA material tag issued with the valve indicated that the valve had a 150 pound pressure rating arid was made of bras S&L specification K-2202 required the valve to be of a rising stem design; however, the valve installed was a non-rising stem typ Neither the design deviations or the above work package inconsistencies were identified or reported by QA, QC or engineerin.'2.10. 2 * Two sketches included in the work package required the sock-o-1 et and reducers to be manufactured to American Society for Testing and Materials (ASTM) A-106 Gr. The ASTM specification referenced relates to piping, not fitting The 1/2*inch sock-O-let was sized for a 2-to 2~-inch pipe; however it was install~d on an 8-inch diameter pip The S&L specification K-2202 required that fittings be rated at 3000 psi, whereas the work package specified that the sockolet be rated at 150 ps The craft performing the work apparently ignored the work instruction and installed the 3000 psi rated fittings required by the $pecificatio.2.11 Modifications M12-2-84-27 and M12-.2-84-28 (Replacement of Solenoid Operated Valves 2-1601-50A and 2-1601-508), which were performed the previous Unit 2 outage, were.reviewed because of the multiple concerns i nvo 1 vi ng the -same modifications in process on Unit The inspection team questioned whether the Unit 2.modification was als~ improperly installed; however, photographs taken of the completed Unit 2 work showed the air lines to be properly routed (to function as required, but not in accordance with the work package installation schematic).
Since the Unit 2 air lines were properly installed, (verified visually after Unit 2 shutdown) the fi~ld work on Unit 2 did not comply with the issued work instructions which were
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- 2.2.12 2.2.13
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iricorrec There were no indications that the invalid test procedure br ihcorrect piping schematic in the work instructions were dis-covered~ discrepancies documented, and corrective action prescribe In summary, M12-2-84-27 and M12-2-84-28 were not installed or tested in accordance with the work instruction, although QA/QC signoffs and closeout reviews indicated that all work was performed per the work instruction and that no problems were encountere M12-3-84-27 and M12-3-84-28 (Replacement of Solenoid Operated Valves 3-1601-50A and 3-1601-508) involved removal of the solenoid operated air operator valves and replacement with environmentally qualified valve The solenoid valves operate the torus to reactor building vacuum breaker valves 3-1601-20A and 3-1601-20 The modification replaced five port Versa valves with four port Asco valve Numerous design and installation discrepanc.ies were noted by the inspection team in connection with this modifi~ation. Installation discrepancies are outlined in Section Inadequate design control by CECo of this particular modification began with Quad Cities Unit 1 in June 1984 when the air lines were reversed during installation of replacement EQ solenoid valve The Unit 1 erfor was c~ught and subsequently corrected prior to the Quad Cities Unit 2 modification accomplished in March 198 Despite incorrect installation and test procedures, the Dresden Unit 2 modification was properly piped u Dresden technical personnel stated they were not aware of any modifi-cation deficiencies associated with Unit 2 and consequently did not make any corrections to the Unit, 3 modification package Nutech was the contractor responsible for the EQ modification at both Quad Cities and Dresde The Nutech drawing, which was a modifica-tion of the original Sargent and Lundy drawing, showed how to mount the Asco valve oh a plate but did not show how to connect the air line Individual sites determined how to hook up the air lines and operate the replacemeht Asco valves, which proved to be incorrect in some case Had the ihstallati~n errors not been identified and correctly repaired, the vacuum breaker valves would not.have operated as designed in the event of an acciden The purpose of the vacuum breaker valves is to prevent the collapse of primary containment caused by negative pressure fo 11 owing coridensat ion of steam during the late stages of a loss of coolant accident (LOCA).
Procedures and drawings failed to adequately control these design changes and site personnel failed to properly document and correct
- the procedural errors when identified (Deficiency 2.2"".10).
Wo~k Requests (WRs) 39291 and 39292 (Replace Operator Mounting Bolts, Install Anti-rotation ~ars~ Alter Operating Times and Inspect Seats on Valves 3-160l.. 20A and 3-1601-208) were worked by the Station Mechanical Maintenance (MM) Departmen The work requests were written to make variou~ modifications to the torus to reactor building vacuum breaker valves and to the solenoid operated valves 3-1601-50A and 3-1601-:508 being replaced by modifications Ml2-3-84-27
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and M12-3-84-2 At the time of the inspection all work had been completed in the field with the exception of changing the valve cycle time Several design and i nsta 11 at ion discrepancies were noted by the inspection team with regard to the work request Installation
.
discrepancies are outlined in Section Inadequate design control was evident throughout the work requests as follows (Deficiency 2.2~11):
2.2.13.1 The Mechanical Maintenance Department was not aware that the
.Electrical Maintenance Department was replacing the solenoid operated valves (3~1601-50A and 3-1601-508) under the direction of the Moditi-cation Engineering section and M12-3-84-27 and M12-3..;84-2 In fact, part of the work request scope of work was to alter the stroke times of 3-1601-20A and 3-1601-208 by the addition of orifice.s in the exhaust ports of the solenoid operated valve The addition of.
orifices ~ould not work on the new valves and would not comply with vendor requirements for placement of orifice The work request also indlcated that the existing Versa valves had 1/4 inch National Pipe Thread (NPT) exhaust ports whereas the Pratt (vacuum breaker valve vendor) ~esign detail schematic indicated that the Versa valves had 1/2 inch NPT exhaust port Design control for valves 3-1601-50A and 3-1601-508 was not maintaine *
2.2.13.2 Stroke times for vacuum breaker valves 3-1601-20A and 3-1601-208 per Dresden Operating Surveillance test procedure (DOS) 1600-1,
"Quarterly Valve Timing, 11 was listed as 20 seconds maximu The test detailed in Work Requests 39291 and 39292 specified a target stroke time (after the EQ solenoid operated valves were fitted with orifices) of 10 to 25 seconds and stated that there was no technical Specification limit ~or this stroke tim There was no indication that an engineering review (10 CFR 50.59) was accomplished to consider the increase in stroke time or that the o.riginal design bases was consulted prior to prqceeding with the modification. *
2.2.13.3 As a design upgrade for the vacuum breaker valves, the Mechanical Maintenance Department determined, together with Pratt Valve Company, that actuator failures experienced in the past (sheared bonnet bolts caused by slamming the valve closed) could be min1mized ln the future with the addition of "anti-rotation" stop blocks and stronger fasteners. *The 11anti-rotation 11 stop blocks consisted of steel plate welded to the valve to help abso.rb energy when the butterfly disc comes to a stop, while the stronger fasteners would help hold the actuator and valve togethe The work requestiristrut:-
tions specified Society of Automotive Engineers (SAE) grade 8 bolts (carbon steel) although the stock numbers listed on the work request for the bolts corresponded to ASTM A193 grade 8 bolt.s (stainless steel).
Notes on the work request weld map required the fastener materfal to be ASTM Al93 grade There were no drawing revisions or Other formal engineering reviews or documentation of either the
"anti-rotation" blocks or fastener modifications to assure that the proposed modifications were acceptable and that future work on the valves would comply with the latest approved design and material requirement.2.14 2.2.15 2.2.1 Ml2-2/3-85-34 (Reacto~ Building Hose Penetration) was clas.sified as a nonsafety related modification, as. ind1cated on the modifi*
cation approval sheet and the accompanying work reques Section 12.1.1.2 of the.Dresden Final Safety Analysis Report (FSAR) cate-gorizes the reactor buildings as Class 1 critical structures requiringClass 1 seismic desig Consequently, any modification involving core dri 11 i ng through the 1 oad bearing common wa 11 of both Units 2 and 3 should have been *considered as a modification to a safety-related structure. Tethn.ical directives and instructions in the modification package were a collection of several uncontrolled and unsigned sketches and notes. A pen-and-ink change was made to Sketch 1 after the Maintenance/Modification Procedure (MMP) was approved and the modification installed (Deficiency 2.2-12).
.
.
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Modification.M12-3-81-12 (125 Vdc Main Bus 3/Reserve Bus 3) was
.reviewed to verify that operations and other procedures were revised to reflect changes required by the pl ant modification. "It was noted that several procedure revisions required excessive time to be completed and 10 CFR 50.59 reviews did not ap~ear to have been completed in sufficient detail to evaluate the safety impact on the plant of the procedure change being made (Deficiency 2.2-13).
The concerns noted were:
The ch.ecklist (Form 5-lA) contained in the modiT1cation package indicated that DOS 6900-6, 11125 Vo 1 t Stat ion Batte.ry Capacity Test,
would require revision to include plant changes caused by the modifi-catio The procedure.revision was initiated on September 23, 1985,
-and was not *approved unt i 1 Apri 1 11, 198 The procedure revision :actually included two changes; one was a change regarding battery ma.i ntenance practices and the other reflected the change caused by the modificatio The 10 CFR 50.59 safety evaluation performed only addressed the change to the proce-dure due to maintenance practices and did not address the change caused by the modification. It appeared that the modification title and number were simply added to the 10 CFR 50.59.safety evaluation written for the change in maintenance practice.2.15.2 The checklist (Form 5-lA) cont.ained in the modification package also indicated that DOS 6900-7, 11125 Volt DC Ground Detection-Unit 3," required a revision to include.changes caused by the modifica-tio That procedure revision was initiated on June 13, 1983 and was approved on May 9, 1986; an elaps~d time of almost 3 year The procedure revision actually included three change The first was a change adding safety precautions to the procedure ant:! was initiat~d on June 13, 1983. The second change, initiated on December 17, 1984, eliminated unnecessary switchin The final change, initiated Februa.ry 19, 1986, was required to modify the procedure to reflect p 1 ant changes caused by the modif icat i.on. Al though 10 CFR 50.59 safety evaluations.were written for each change when the change was initiated, no 10 CFR.50.59 safety evaluation was made to encompass a 11 the changes at the ti me the revision was made to the procedur The latest safety evaluatfon and procedure change did not take into account any possible interaction with earlier changes nor
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did it ~valuate earlier changes against current pla~t status and current FSAR and Technical Specification requirement The 10. CFR 50.59 evaluations also.did not provide complete justification for the answers provided on the for OAP 9-2, 11 Procedure Preparation, 11 specifies that procedures should be assigned priorities to expedite revision The above revisions should have been assigned a priority A.or B according to the criteria in the procedure; however, no maximum revision completion time was specified in OAP 9-2 for the priority A or B categorie OAP 9-2 appeared to be deficient in that it did not specify a maximum time limit for processing ~evisions and because it did not instruct personnel on how to complete the 10 CFR 50.59 form or r~quire adequate justification for answers listed.
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2.3 Document Adequacy and.Control The adequacy and contra l o_f drawings, procedures a:nd material related to modification~ being accomplished and in some cases, documents which did not specifically relate to modificati~ns were evaluated during the inspectio. A review of drawings for 33 work packages indicated that a number of drawings contained inaccurate information and although some of the errors were found during installation, the drawings were not properly changed by the appropriate change documentation (FCRs or DCRs).
In other instances, the modification packages did not identify the drawings to be changed, or applicable drawings were not incorporated in or identified by the package for use by construction organizations (Deficiency 2.3*1).
Examples include:
2.3. M12-3-83-30 (CS Suction Valve Switches) and drawing 12E3680A Re L required landing a nonexistent spare table conducto Although the appropriate conductor had been us~d, no chahge document was initiated to correct the drawin.3. Ml2-3-84-9 (CS Isolation Valve Anti-hammering) required the use of spare cable conductors, but the cable tabulation drawing for cable 32825 was not listed as an effected drawing and was not change.3. M12-3-84-38 (IEB 79-01 Seismic Restraints) requi_red the use of an i nsta 11 at ion detail on drawing M-3620 $ heet The drawing was not included on drawing transmittals to the construction organizatio In addition, drawing M-3620 sheet 2, Rev. 2 included a note requiring that "All new structural shapes will be A36 latest edition material."
However, the drawing also specified various sizes of structural tube steel for which the appropriate mate.rial specification reference is ASTM ASOO and not ASTM A3.3. Numerous problems with drawings were identified with modification M12-3-84-8 (HGA Relay Replacement) and are discussed in Section 2.2.4, abov. 3.1. 5 M12-3-84-27 and M12-3-84-28 (Replacement of Solenoid Operated Valves 1601-SOA and 160l~5oB) related P&ID M356 was found 'to be incorrec Detail 11A 11 indicated that valves 3-1601-SOA and 3-1601-SOB should fail closed; however, by design the valves should fail ope.3. M12-2-84-27 and Ml2-2-a4...:2a (Replacement of solenoid operated valves 1601-SOA and. 1601-SOB) related P&ID M25, detail 11A" indicated that valves 2-1601-SOA and 2-1601-SOB should fail closed, however, the valves should fail ope The valve depicted in deta*il 11A 11 had five ports while the valve in~talled during this modification had four ports..The drawing a 1 so indicated that va.l ve 2-.1601-20A should fa closed when it should fail ope. Drawing list revisibns were* compared to the drawings contained in modification package One deficiency was identified with modifi-cation Ml2-3~84-8. Revisfon AA was issued to drawing 12E3758 Contrary to OAP 2-7, "Control of Drawings to be Reproduced and Logged to Modifications," the drawing was not sent to the modificaticin
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engineer for his review to determine whether the modification package required revision to include new instructions (Deficiency 2.3.2).
While witnessing a survei 11 ance test, the inspect ion team noted that the Station Security Plan was located on a book shelf in the Shift Engineer's office adjacent to the control roo The Shift Engineer's office is located adjacent to the control room and outside of the contro 1 room vi ta 1 area enve 1 ope. *Once inside the protected area, it can be reached.without passing through any additional checkpoint The Shift Engineer's office is a space normally occupied by shift personnel, but which does not have any personnel assigned to be there at all time NRC inspectors observed occasions when no li~ensee personnel were presen lhe location and storage o'f this copy of the Station Security Plan violated OAP 13-12, "Control of Safeguards Information," Rev. 1, which required that all ~ocuments cohtaining station safeguards information shall be stored in a locked safe or similar GSA approved containe Station management personnel were informed of the situa~
tion by the inspection team and their immediate response was to move the Security Pl an to an appropriate locatio NRC Region I II was notified of the situation and the region has issued a noncompliance regarding this matte. A review, which included all entries made since January 1986, of the TCR Log maintained by the Technical Support procedure coordinator and the Master Temporary Change Request Log located in th.e control room rev~aled deficiencie The Master Log did not reflect the current status of the procedures, no objective evidence existed to document that TCRs were removed from the procedures after their termination date, and th~ Master Log data lagged behind the -information in the Technical Support.procedure coordinator's log by at least 3 months or longer (Deficiency 2.3-3).
The discrepancies included:
2.3. Thirty-three instances were found where the Master TCR Log did not li~t the Dresden On Site Review (DOSR) date which was entered in the TCR log maintained by the Technical Support procedure coordina-to Certain of these instance~ dated back to April 198.3. *seventeen ihstances were fo~nd in th~ Master Log where th~ on-site review date was not entered and the TCR termination date had pa~se In addition, the required entry in the log for these 17 instances to indicate that the TCR was removed from the procedures was not mad Some of these dated back to March 198.3. Thirty-one examples were found where the Master Log showed that the termina-tion date had passed for the TCR but the log did not indicate that the TCRs were removed from the procedu~es. lhese examples dated back to March 198. Drawings were reviewed for completeness and accuracy for several construction package A number of discrepancies were identified (Deficiency 2.3-4):
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2.3. M12-3-84-14 (Unit 3 Containment Cooling Service Water (CCSW) Pump Room Cooler Piping Modifications) contained drawings which.did not reflect the as-built conditio For example:
The design drawings specified 150 psi reversing valves and adjacent flange S&L specific~tion K-2202 re~uired JOO-psi valves and flange P&ID M-360 indicated that flow elements and temperature indicators were installed in the lines between the pumps and the cooler These devices were not.shown on the piping drawings and were not install~d in the fiel The line and cooler designator letters were in error in that 11C 11 designated piping and valves were shown installed to.the 11A 11 and 118 11 designated coolers and the 118 11 designated piping and valves *were shown installed to the 11C 11 and 11 0 11 designated coolers.
. The drawings did not specify any specific orientation for the reversing valve *
Documentation did not exist which indicated the source and QA ac~eptance of eight installed 300-psi flange At the time of the inspection a Field Change Request had not been processed to revise the design drawing requirements or to take exception to the design requirements of the S&L specificatio Subsequently, FCR DM-38 was issued to document a number of chan*ges made to this modificatio See Section 2.3.5;2, below regarding the same modification performed earlier on Unit.3. M12-2-84-14 (Unit 2 CCSW Pump Room Cooler Piping Modification)
contained as-built drawings which did not truly reflect the as-built conditio For example:
The as-built drawings specified 150-psi reversing valves whereas the S&L specification K-2202 required 300-psi valve The line and cooler designator letters were in error in that 11C 11 designated piping and valves were shown installed to the 11A 11 and 118 11 designated cables and the 11811 designated piping and valves were shown installed to the 11C 11 and 11 0 11 designated cooler " In~tallation Procedure £ontrol Installation procedure controls were evaluated in detail to assure that regula-tory requirements were.met, that procedures were adequate to control and properly install the modifications, and that procedures were followe ~ A nu~ber of procedures and modification work packages did riot contain adequate atceptance criteria for the inspection and testing ~f modifi-cations (Deficiency 2.4-1)~ For example:
2.4. Installation test procedures for modifications M12-3~84-49 and 50 (LPCI Room Cooler Motor Replacement) and modifi~ation M12-3-85-26 (Recirculation Pipe Replacement (RPRJ Electrical Interferences)
did not contain adequ~te acceptance criteria for certain motor test Electrical Construction Test Procedure (ECTP) 1, "Electrical Motor Installation Test,t' specified by M12-3-85-26 did not contain quanti-tative acceptance criteria for running current tests, and the instal-lation tests specified and conducted for Ml2-3-84-49 and 50did not contain criteria for running current, insulation resistance, and rotation tests. lb addition, the.LPCI room cooler motor replacement modification packages d.i d not sped fy a pol ad zat ion test which was required by the motor manufacture *
2.4. Modification M12-3-83~16 (Main Steam Lin~.Radiation Monitor Replace-ment) did not provide acceptance criteria for installation test *The procedure required the user to determine whether the data was acceptabl No criteria were provided to allow the user to complete
- this requirement, making thetest results indeterminate~
. The modification package al so did not provide acceptance criteria to determine whether recorders associated with the monitors were adequately calibrate In several cases, the data taken indicated nonlinearit ln addition, modification M12-:3-83-16 did not provide references to determine the validity of trip and alarm points and how they were determine The same point was true of the value of 11Q 11 as to how it was determine This value was used in the trip poi.nt setting of the monitor.4. Check lists MO 202-4A, MO 202~48, MO 202-SA, and MO 202-58 in Special Procedure SP-86-1-9 did not list any acceptance criteria for the number of turns to backseat the valve.4. M12-3-85-50 (Installation of Diesel Generator Cooling Water Pump
. Suction Pressure Gage) did not mention seismic requirements, evaluations, guidelines or limitations as to the length and weight of the components or support requirements involved in the modifi-cation.
. 2. 4.1. 5 M12-3-84-42 (HPCI Pipe Whip Restraints) added shi.ms to two HPCI system pipe whip restraints to provide for the required design clearance between pipe and restrain FCR 04159 specified that a U-bolt on PWHP-1 must be reinstalled and set at the same position found prior to remova However, there was no documentation in the work package showing any as-found location dimensions, nor did the
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work package provide for QC, engineering or craft verification of proper reihstallatio FCR 04159 also specified that the center,shim for PWHP-1 was to be welded at the center 1 ine of th,e pipe* s 11 hot position 11 and that the specified clearance was for the 11hot position.
However, neither the design drawiilg nor the work instruc-tion showed the pipe hot position, and the contractor personnel per,forming the work did not know what the hot position wa In addition, the clearance specified on the,drawing was the ori gi.na 1 dimension shown between the pipe and the,existing restraint sleeve, not to the surface of the new shim In spite of the less than clear instructions, there was no provision to do any inspection of the completed modifications at system *operating tell!perature to assure that the design intent had been me While reviewing this item, the inspection team also. identified design errors on PWHP-1 that would have resulted in unanalyzed loads on the pipe and whip restraint due to thermal expansio This resulted in a redesign of PWHP-1, ripout and rework of the modificatio The work package, including the design drawing, was also inadequate for PWHP-2 in that no clearance (pipe to shims) was specified and therefore.no criteria for acceptability was provided lo field personne The inspection team was also concerned that field engineering, QC and craft pers.onnel fai.led to identify these short-comings and get resolutions from design engineerin Several documentation concerns were a 1 so note The Fi re.Protect ion.
Checklist, Form 5-10, had not been signed of The Modification Checklist, Form 5-lA, indicated that construction testing was required, but tests or acceptance criteria were not detailed or referenced in the work packag.4. M12..:3-85-17 (Removal and Reinstallati.on of Interferences for Recir-culation Piping Replacement) removed and reinstalled instrument sensing lines (2.7 drawings} and drainlines (9 drawings).
Slope requirements for reinstallation were not provided in work instruc- *
ti ons or.shown on 13 instrument line drawings or 5.drai nl i ne drawing Due to significant problems related to instrument line slope at other sites the inspection team requested an evaluation of the lines for which no criteria or inspections were specifie An evaluation by Impell engineers determined that four instrument 'lines were either originally installed or r.einstalled with ai.r and or water trap The Impell evaluati~n also concluded that reversed slopes on drainlines would have no safety significance, and on instrument lines would only affect response time and that only insignificantly. This conclusion conflicts with recommendations of industry standards such as Instrument Society of America (ISA) Standard 2186 which recommends slopes to prevent measurement errors. The Impell evaluation also did not address the buildup of corrosion products and other materials that could eventually lead to line blockage (Unresolved Item 2.4-1).
2..4.L 7 Work instructions of WR 46639 (Replace Packing Sleeves.in.3A CCSW Pump) were limited to 11Replace packing sleeve, inspect wear rings, bearing, repair as required,
and included a reference to Repair Manual 12-MM-Upon review of the repair manu.al, it was discovered that the manual provided detailed instructions for disassembly, inspectiOn, and reassembly including specific quantitative require-
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- 2.4..... *
ments for items such as end-play, gasket dimensions, flinger and.wear ring clearance and casing flange bolt torqu None of these items were addressed in the work ~ackage nor was QA/QC involved for verifi-cation of critical acceptance criteri S&L specification K-2202 was often referenced in SNED approval letters or in an actual work packages to indicate design requirements for repair or replacement component part It was left up to craft per-sonnel to interpret the specification and to correctly choose compo-nent In each case examined by the inspection team where the S&L specification K-2202 was listed as the design requirement, materials were chosen which did not conform to the design specificatio A review of modification packages and applicable test procedures identified many instances where administrative procedure requirements were not me These procedural violations included items such as improper completi'on of OAP 5-lchecklists, not identifying required information (e.g., procedure numbers, equipment serial numbe~s) on
.work request forms, not revising the Modification Approval Sheet based on SNED reviews, improperly made handwritten changes, an.d work traveler steps not signed following completion of work.. Improperly made changes to modifications and procedures included uninitialed and undated pen and ink changes, which ma:de it impossible to determine whether changes were made before or after documents were reviewed and approved (Deficiency 2.4-2).
Although each individual finding was considered to be minor by the inspettion team, taken collectively they were symtomatic of a larger problem which indicated the existence of an attitude at the facility that procedures were merely guidelines to which strict adherence was not required, and an inattention to detail which goes beyond installa-tion documentation of modifications (Observation 2.4-1).
The construction test for modification M12-3-84-8 (HGA Relay Replace-ment) specified that if modification M12-3-82-27 had not been com-pleted, a lower set of signature spaces should be signed to signify test completio The test personnel signed both the upper and a lower set of signature.spaces, making it impossible to determine which wiring had actually been completed on the jo The entire construction test was signed off in this manner (Deficiency 2.4-3).
M12-3-83-39 (IEB 79-01 Instrumentation Replacement) contained conflicting 10 CFR 50. 59 safety review determination The first review, documented on June 6, 1984, indicated that a: change was required to the Technical Specification, but tha:t no change was required for the FSA A subsequent safety review documented on February 28, 1985, determined the opposite; no change required for the Technical Specification but a change required for the FSA Discussfons with the liCensee revealed that both the Technical Specification and FSAR were being changed as a result of the modifi-cation (Deficiency 2. 4-4).
- M12-3-83-40 (IEB 79-01 Instrumentation Replacement):
Fire Stop Integrity and Maintenance Procedure DFPP-4175-1 Rev. 0, dated September 1978, was incorporated into the requirements of this
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- 2..4..4..4...,2..4..
modification through the MMP Form dated February 15, 198 Rev. 0 did not contain the precautions and limitations required by Technical Specification Section 3.12/4.12, Fire Protection, which were later included in Rev. Although Rev. 1 was effective on January 6, 1986, it was not included in any of the three subsequent
.revisions to the MMP (Deficiency 2.4-5).
- Several MMPs and work travelers did not include all of the applicable QC or QA hold points required by site procedures (Deficiency 2.4-6).
Examples included:
OAP 15*1 re~uired that QC hold points be applied to the ~plicing or environmental shields of safety-related cables that are' subject to environmerital qualification requirement Modifications M12-3~84-49 and 50 did not include QC hold points for the repairs made to power leads on ehvironmentally qualified LPCI room cooler motor No QC hold point requirement existed for environmentally qualified work performed by CECo Substation Construction Department (SSC).
As such, no hold point was imposed on splices made to *environmentally qualified instruments under modification M12-3-83-4 No QA or QC hold points were identified in modif1cation M12'-3-83-37 for calibratibn and hydrostatic testing as required by.OAP 15-M12-3-83-40 (!EB 79-01 Instrumentation Replacement) stated that all work under this modification would be performed in accordance with SSC approved procedures which were enclosed with the modification packag None of the enclosed' procedures addressed safety-related activities relative to the scope of the modification such as cable installation, cable termination, raceway installation, electrical equipment installation, installation of environmentally qualified conduit seals, and splicing of safety-related cables (Deficiency 2. 4-7).
OAP 9-2, 11Protedure Preparation, 11 required a review of all operating procedures every four year This was contrary to American National Standards Instit_ute (ANSI) Nl8. 7 which requires a review every two years (Deficiency 2.4-8).
A review of modifications M12-3-84-49 and M12-3-84-50 (Replacement of the West and East LPCI Cooler Motors) reve~led several concerns with the seismic qualification performed on the motors and in the methodology used to demonstrate that the entire cooler was seis-
~ically qualified:
The method of performingseismit qualification of the motor by Westinghouse used only a static analysis procedure which also assumed that the motor would be rigidly mounted in a horizontal plane and would receive the required response spectra (RRS) without amplifi-catio However, the motor was mounted vertically to the cooler which had a complex connection to the floor above and to other point The cooler was mounted flexibly to allow for vibration and swayed approximately two inches when touche Two pipes enter the cooler in addition to the conduit connections to the moto Due to this complexity and the fact that the cooler may_introduce additional
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2.4..4.10
'
amplification to the existing RRS, it could not be assumed that the motor was rigidly mounte Unless this rigidity could be proven considering dynamics at the motor base, the validity of the seismic qualification appeared to be in doub The seismic ~ualification methodology used did not demonstrate that the motor could perform its safety function before and after a seismic even The certification simply stated that it could. No objective evidence existed to demonstrate that the motor would function before and after a seismic event as required by Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1975 (Unresolved Item 2.4...;2).
Torque specifications and instailation details were not provided for the motor mounting as required by the Westinghouse seismic analysis provided with the moto In addition, the existing unmarked lugs were used in.the motor ins ta 11 at ion without a material evaluation being conducted (Unresolved Item 2.4-3).
A review of modification packages also disclosed that Attachment B of OAP 5-1, for a review of the Technical Specifications applicable to the modification, was not correctly complete Several instances were identified where Attachment B did not have the correct reference to the Technical Specifications or did not list sections of the Technical Specifications applicable to the modification (Deficiency 2.4-9).
Examples include:
2.4.10.1 Modification Ml2-3-84-8 (HGA Relay Replacement):
Attachment B did not list the section of Technical Speci fi cations applicable to the modification and did not list any precaution.4.10.2 Modification Ml2-.3-84-49 (LPCI West Cooler Motor Replacement):
An Attachment B form dated November 14, 1985, generated with the origi-nal MMP specified in the precaution section of the form that LPCI and CS was not required, and only.stated 11 LPCI 11 in the form blank where applicable Technical Specification sections were to.be entere A second.MMP w~s generated and the precautions on another Attach~ent B, dated November 24, 1985, stated:
11Assure other loop is operable.
Plant conditions were essentially the same when both Attachment B forms were generated (reactor shutdown and defueled) implying that there was no need for LPCI or core spray system On the Attachment B dated November 14, 1985, no Technical Specifica-tion section was listed on the form ~nd it appeared that the pre-caution entered was incorrec On the Attachment B dated November 24, 1985, the precaution to 11assure othe.r loop operable 11 did not appear to be correct as LPCI or CS were not required in this mode.
. 2.4.10.3 Modification Ml2-3-83-16 (Main Steam Line ~adiation Monitor Replace-ment):
Technical Specification references were not correct. The correct reference was Table 3.1.1 while the Attachment B form referenced Technical Specification Section 3.70.
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2.4.11 2. 4.1.4.1.4.12 2.4.13 2.4.1.4.1 A review of OAP 15-1, 011Work Requests, 11 identified two discrepancies (Deficiency 2.4-10):
The work request procedure did not adequately addr~~s revisions of work requests for work that was in progress, specifically the flow-path for review by management, the conduct of 10 CFR 50.59 safety reviews, the review by QA/QC personnel, specification of minor or major work scope changes, etc. It appeared that numerou~ procedures were violated because the pr6cedures were inadequat The work request procedure referenced the Total Job Management (TJM)
manual which referenced work request forms that were out of dat The work request procedure specified filling out sections of the work request in accordance with.the TJ M12-3-84-14 and M12-2-84-14 (CCSW Pump Room Cooler Piping Modifica-tions) contained many examples where the as-built condition was not in accordance with the work package or design requirement For examples of documentation inadequacies se~ Section Only after the installation of the modification was completed were change documents issued which identified some of the installation incon-sisten~ies with design re~uirements. Concerns that were identified with the Unit 3 modification were also found to still exist with the Unit 2 modification accomplished during a previous outage (Observation 2.4-2).
Dresden craft personnel ~lso failed to follow the work instructions of M12-3-84-14 in that work was accomplished which replaced piping and components shown on the drawings.as outside the scope of the modification (Deficiency 2.4-11).
M12-3-85-17 (Removal and Installation of Interferenc~s Associated
~ith the Replacement of Recirculation Piping):
Drawings 181 and 190 were reviewed and walkdowns accomplished which resulted in identifi-cation of the following discrepancies (Deficiency 2.4-12).
I Drawing 181:
Chicago Bridge and Iron Company (CB&I) procedure IRR-1 stated that drawings shall include 11as was 11 control dimensions that would be used to assure proper reinstall at ion of the remova 1 inter-ferenc However, the as found setting of a spring hanger on piece 118 11 was not documented nor were there any instructions for post-installation load settin Drawing 181:
CB&I procedure IRR-1 stated that if a deviation from a drawing was required, a drawing revision or engineering change notice was mandator However, the drawing did not show an existing pipe support on the vertical run of piping attached to both pipes, which was disassembled during pipe remova Consequently, there was no record of its preremoval condition nor instructions for installa-tio Also, the removal of this hanger was a violation of paragraph 6.1 of the CB&I QC manua.4.13.3 Drawing 181:
Similar to the above, the drawing did not indicate that the pipe support on the horizontal run of piping attached to all three pipes was to be disassembled to effect pipe removal or instal-latio However, the hanger wa~ disassembled with no record of its
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- I*
predisassembled condition or instructions for installatio Also, the disassembly of this hanger was a violation of paragraph 6.1 of the CB&I QC manua *
2.4.13.4 Drawing 190:. Similar to the above, the drawing showed three clamp type suppo.rts but only the two that were to be modified were detaile The drawing did not specify the third hanger for disassembl However, the third hanger was disassembled during pipe removal without any record of its preremoval condition or instructions for installation. Also, the removal of the third hanger was a violation of* paragraph 6.1 of the CB&I QC manua *
2.4.14 During plant walkdowns of modifications and review of procedures, discrepanties were identified with regard to cleanliness and foreign material exclusion practices (Deficiency 2.4-13).
2~4.1 M12~3-84-14 (CCSW Pump Room C6riler Piping Modifi~ations) did not coritain a QC holdpoint for verification 6f internal cleanliness pribr to closure of the pipin This same concern was also noted regarding the same modification performed on Unit 2..
2.4.. 14.2 M12-3-84-27 (Replacement of Solenoid Operated Valves 3-1601-SOA and 3-1601-508) did not contain a QC holdpoint for verific~tion of internal cleanliness for the replacement valves an.d associated air lines. This same concern was also noted on the same modification accomplished on Unit.4.14.3. Work Request 46639 (Replace Packing in 3A CCSW Pump) did not contain a QC holdpoint.for verification of cleanliness prior to closure. It was also noticed by the ihspectfon team that while the upper half of the pump casing was removed, many i nterna.l. pump components were spread out on the floor with no action taken.to prevent entry of foreign materials. At the ti~e -0f the inspection, the pump was unattended and not being worked o.4.14.4 Check valves 3-1601-33A, B, C,.0, E, and F (drywell vent to torus)
were completely disassembled for maintenance with no provisions to prevent entry of foreign material At the time of the inspec-tion, the valves were unattended and not being ~orked b The inspection team did not review the work request to determine whether cleanliness requirements and or precautions were specifie *
2.5 Installation and tonstructfon Controls This portion of the SSOMI entailed an inspection of the installation and hard-ware of 33 work packages.. The 33 were reviewed to varying degrees of detai 1 against design and procedural requirements and commitment Concerns were identified with the installation of 27 work packages and are.discussed below.
. Table I identifies the modifications inspected and those with identified concern..5..5. The modification i.nstallatfons were inspected to their applicable drawing requirement Numerous i nstance.s were i dent ifi ed that deviated from those requirements (Deficiency 2.5-1).
M12-3-83-30 (CS Suction Valve Control Switch Replacement):
Wiring changes had been made for the valve motor operator circuits in two motor control center The changes included landing a spare conduc-
. tor from an existing cab.le which had been signed as completed by Station El~ctric~l Maintenance Department (EM).
A visual inspec-tion by the SSOMI team revealed that the conductor from the wrong cab 1 e h'ad. been 1 anded i.n both motor contro 1 center M12-3-83-40 (IEB 79-01 Instrumentatio.n Replacement)~ A number of deviations from drawing requirements were identified.with the sample of hardWare installed per this modification..
Safety-related cables were found bundled with nonsafety-related cables inside panels 2203-73A and 2203-73 Note 2 on drawings 12E7860 Rev. E and 12E7861 Rev. E required the nonsafety wiring to be in conduit or to maintain.6 inches of.separation from
safety-related wirin Note 5 on drawing 12E2103A Rev..E required that the cable pulling tension be monitored for all Class lE cables. * SSC had
.not monitored the pulling tension of any of the Class 1E cables installed per this modification.
.Conduit segregation code stickers were not installed every.15
.feet as required by drawing 12E2103A Rev. Conduit suppo.rts were installed further from conduit bends than the 42 inches maximum specified* by drawing 12E2103B Rev. Conduits did not form a continuous path to plant ground as required by drawing 12E2103A Rev. *
2.5. M12-3-83-38 (lEB 79-01 Instrumentation Replacement):
One required weld on instrument rack OR-2203-8 had not been mad The weld was specified on drawing M-3622 sheet2 Rev. 0 and had been inspected and accepted by the contractor's Q ln addition, a restraint channel member for this instrument rack did not conform to its drawing configuration as shown on drawing M.,.3622 sheet 2 Rev. These deviations were subsequently documented by the contractor on Nonconf ormance Report (NCR) 09 *
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- 2. M12-3-85-26 (RPR Electrical Interferences):
A portion of the work performed by Commonwealth Electric Company (CE), under subcontract with CB&l was inspecte CE work package 3159-24 required the de-termination and subsequent re-termination of the motor operator for LPCI inboard isolation valvi 3-1501-22 During de-termination and inspection of the field cables, CE noted a jumper wire crimped with a field cable conductor under one lug and documented the condi-tion in accordance with their procedure The A-E's response was to remove the jumper and terminal lug and install a hew lug on the field cable conducto CECo would install a ~ualified jumper during their EQ updating on the motor operator while the operator was remove However, the inspection team found that the field cable conductor had not been repaired and the original jumper was still lugged to it and reinstalled (Deficiency 2.5.2).
In addition, a new jumper had been installed by station E CE subsequently documented this finding on NCR No. 3159-018 for correctio. M12-3-84-9 (Core Spray Isolation Valve Anti-hammering):
Wiring changes made in the motor control centers and the valve motor operator~ were inspected by the tea A severe bend radius was noted on all three motor power leads in motor -0perated valve 3-1402-25 See Section 2.5.4, below, for a discussion of cable splice deficiencie The leads we're straightened and the severe bends removed by CECo prior to reinstalling the cover on the motor operato During the team's inspection of motor operated valve 3-1402~258 it was noted that the cable tag incorrectly identified control cable 32825 as cable 33825 (Observation 2.5-1}.
2. Discrepanctes involving inadequate cable spli~es were noted with several modification packages (Deficiency 2.5-3).
Most splices were performed using the manufacturer's splicing instructions and most receiv_ed QC hold point inspection For example:
2.5. M12-3-84-27 and 28 (Replacement of Solenoid Operated Valves 3-1601-50A and 3-1601-508):
Splites were made to the ~nvironmentally qualified solenoids for the tbrus to reactor building vacuum breaker valve Three of the four splices (two per valve) had damage to the splice sleeve, with one sleeve exposing bare ~rinductors. The splices for one of the solenoids were found to be severely bent and may have contributed to the insulation damag The sleeve on two of the splices extended over the braided jacket on the solenoid wire The manufacturer's splicing instructions stated to "remove all...
braided jacketing material from the splice area.
2:5.4.. 2 M12-3~83~40 (IEB 79-01 Instrumentation Replacement):
Splices were made at the environmentally qualified conduit seals for instruments DPT~3-2352, PT-3*2389A, and PT-3-2389 All the qualified sleeves were found to be 3 inches or less in length while the required length was 6 inche The sleeves were too short and did not capture the outer jackets of either the field c.ables or the conduit seal cables although a 1 inch minimum -Overlap was require The splices were to include 1-to 1~-inch inner sleeves and the splices were required to be.offset from each othe Because of the outer sleeve lengths actually used and their configuration, the splices were apparently
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2.5. not offset. In addition, several of the splices were *found with
.kinked wires, damaged wire i nsul at ion, and exposed and damaged conductor M12-3-84-49 and 50 (East and West LPCI Room Cooler Motor Replacement):
The braided jacket on several motor leads extended under the splice insulation which was prohibited by the MMP instructions in the modification packag MMP instructions for splicing the motor leads to field cables stated that the glass braiding should be removed from the motor leads since Raychem heat shrinkable tubing 11will not positively seal over a braided material.
Raychem instructions for the motor splice installation specified that 11all nonqualified or braided jacketing materials should be removed from the splice area.
In addition, the instructions stated that.Raychem products were designed to seal to smooth, non..;woven surface Despite the MMP and Raychem instructions, the motor splices were found with the Raychem heat shrinkable material installed over the glass braided motor lead jacke When informed of this, plant p~rsonnel cut -0ne splice open a~d found that the braided material extended only up to approximately 1 inch from the primary material used to seal the bolted connection and the pl~nt staff stated that this was acceptabl However, Raychem instructions required the removal of the braided jatket from the splice area, and the MMP did
. hot a 11 ow the braiding to be 1 eft in.pl ace in any cas Part 5 of the MMP was s.i gned off as construct ion complete and was accepted by QC and Q This installation appeared to violate the MMP require-ments.and the Raychem instruction.5. M12-3~84-9 (CS Valve Anti-hammering):
A severe bend radius was noted on all three motor power leads in motor operated valve 3-1402-25 One of the leads was bent on the heat shrinkable tubing while the other two leads were bent at the splice to motor lead interfac. Modification M12-3-84-8 (HGA Relay Replacement):
The use of handwritten notes to document wiring changes (see section 2.2.4, above) resulted in a number of instances where the installation did not match the latest revision to wiring diagrams since wiring was performed in accordance with handwritten notes instead of the dia-grams themselves. For example:
2.5. The SSOMI team identified an incorrect connection during inspection of this modificatio Terminal point AT2 was supposed to be con-nected directly to point MM75 according to the construction test requirement Instead, point AT2 was connected to MM2 and a jumper was connected between points MM2 and MM7 Modification M12-3-83-27 required the removal of the jumper between points MM2 and MM75. When this modification was completed and the jumper removed, the LPCI/CS relays would not have functioned properly (Deficiency 2.5-4).
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4,
..
The construction test, which included wiring verificatibn, was signed off as correct even though the connection w~s incorrec This indicates that the installed wiring was improperly verified during the performante bf the construction tes.5. Step EM5 in the modification package traveler required.that the door relay markings be updated to reflect correct relay installa-tion Two examples were found where this step was not performed correctly even though it.was signed off.by plant personnel.. Relay 1530-129 was not added to the door marker in cabinet 903.:.32 and relay 1530-105 was also not added to the list on the door in cabinet 903-3 Controlled drawings should be used to document relay loca-tions rather than the current practice of using uncontrolled sketches on cabinet doors to document relay installations (Observation 2.5-2).
Z. Modifications M12-3-84-49 and M12~3-84-50 (West ~nd East LPCI Room Cooler Motor Replacement).
The following discrepancies were identi-fied (Deficiency 2.5-5):
2.5. MMPs for these modifications specified that Raychem WSCF-N shrink tubing sho~ld be used to cover broken glass braiding on the motor lead The inspection team noted that Raychem shrink tubing was not installed on several of the leads which had broken glass braiding even tho-ugh the MMPs required this installatio The Westinghouse Equipment Qualific~tion program did not discuss the u~e of WSCF tubing material tb repair motor leads. lhe reprirt discussed how the motor leads were qualified with the glass-braided jacket and described how Scotch 33+, 88 ~nd 130C adhesive tapes were acceptable for insulating cable splicings to the lead No concur-rente appears to have been received from We~tinghou~e to use the WCSF material for lead splicing or motor lead jacket repair I
.
2.5. During a walkdown of M12-3-84-50 (East LPCI Room Cooler Motor Replacement) it was found that one of the pulley belts had fallen off and the second belt was loos The construction package was com-pleted and signed off and accepted even though these discrepancies were note In addition, the MMP work traveler required r~placement of the ori gi na l flexible conduit to the motor, however another 1-i nch flex1ble conduit was drawn out from stores to be used as a replace-ment, but the new conduit was not used and the old conduit was left in plac. Modification package M12-3-83-36 (IEB 79-01 Instrumentation Replace-ment):. A yellow, adhesive-backed note was found attached to the front of the p~ckage to provide a reminder to station personnel that the 110 11 rings on _level transmitter LT1526 needed to be replace Dresden staff indicated.that the core spray system transmitter needed new 110 11 rings because the electrical cover had been remove After a review cif the modification package, it appeared that this conditi~n was not documented elsewhere in the packag Since 110 11-rings are required to be replated on EQ transmitters during each maintenance to maintain EQ status, which wbuld include proper documenta~ion, con-cerns should be raised by Dresden regarding other EQ transmitters for which proper documentation may not exist (Observation 2. 5-3).
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...
2. M12-3-84~27 and M12-3~84~28 (Replacement of Solenoid Operated Valves 3-1601~50A and 3-1601-50B on Unit 3).
These modifications, performed by the EM Department, involved removal and replacement (with environ-mentally qualified valves) of the so.lenoid operated air operator valves for the torus to reactor building vacuum breaker valves 3-1601-20A and 20 Discrepancies were identified that involved improper hardware installation as follows (Deficiency 2.5-6):
2.5. The station traveler required verification that the stilenoid was mounted in a vertical positio This item had been signed off as ~omplete, but valves ~ere installed with the solenoids in a horizontal positio.5. The installation schematic in the ~odification package for*~onnett ing the operating air lines was erroneous a~d would cause the valve to cycle opposite to the intended position The valves and operat-ing lines had been installed as shown on the schemati.5. The Westec Environmental Qualification Checklist listed a different catalog number than the installed valves and the serial numbers listed were switched i.n relation to the QA material tags in the modification package.5. The air supply tubi.ng on valve 3-1601-50B was severely bent and kinke. Work.Requests 39291 and 39292 {Replace Operator Mounting Bolts,
.Install Anti-rotation Bars, Alter Operating Times and Inspect Seats on Valves 3-1601-20A and 3-1601-20B).
This work activity was being performed by the Station Mechanical Maintenance department.on the torus to reactor building vacuum breaker valves (the valves actuated by the solenoid operated valves replaced by modifications Ml2-::3-84-27 and 28).
This work had been completed in the field except for the changing of the valve operation time The following discrepancies and concerns were noted by the inspection team (Deficiency 2.5-7):
2.5. The work requests and a vendor recommendation letter specified that the new bolts be stake It was not physically practicable to stake the bolt threads and there was no indication in the documentation that this was not possible, not required or not performe.5. The Station Mechanical Maintenance Department was not aware that the EM Department was replacing the solenoid operated actuating valves (3-1601-50A and SOB) during the outag Part of the work instruction involved changing the valve stroke times by adding orifices which would not work on the new valves and would not comply with vendor requirements for changing stroke times. In addition, these work requests indicated that 1/4-inch NPT exhaust port valves were instal-led although, the original Pratt design detail schematic indicated that the Versa valves in this position had 1/2-inch NPT exhaust ports.
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,,
.
2.5. Some of the operator and bonnet mounting bolts were reinstalled with lock washers and some without.
2.5. Work request instructions speci~ied SAE grade 8 bolts (carbon steel)
and then specified stock numbers for ASTM A193 grade 8 bolts (stain-less steel).
The work request weld map required ASTM A193 grade 8 bolts. Actually installed and apparently adequate per the vendor were the SAE grade 8 bolt *
2.5. The work requests for these valves and previous work requests for.
the same valve design provided instructions to apply silicone grease to the valve seat CECo had received a Confirmatory Action.Letter from Re~ion III on April 13, 1983, regarding greasing of Valve seats to allow valves to pass leak test.s.10 To obtain more information regarding the concern of continued* use of silicone grease on valve sealing surface,. the inspection team reviewed additional completed work requests, discussed the use of grea.se on valve seats with the valve manufacturer's engineering department and reviewed CECo actions addressing the concerns of the 1983 Confirmatory Action.Lette Completed work requests indicated that application of a film of silicone grease was used on valve bonnet gaskets (WR 29776) and containment hatch seals (WR ~1299) as we11 as on valve seat The 1984 Pratt field*trip report indicated that valve maintenance should
.include thorough seat cleaning and light lubrication with a silicone based grease to "prevent aging of seat material."
In the same Pratt report, the engineers stated that seat damage could have resulted from debris coating the seat "especially since they are coated with a lubricant.
Other published Pratt manuals and instructions did not specify greasing of seating surface Although the use.of.. a film of silicone grease may be technically justified for prevention of pre-mature aging of rubber seals, the inspectors have several tbncerns with the practices currently in.place at Dresde~. The use of grease on sealJ subject to local leak rate testing (LLRT) such *as valve seats, bonnet joints and hatch seals has the easy potential for use as a means tb pass leak test As the long term sealing effective-ness of this.lubricant is unknown the results of the leak tests may not indicate future tightness and readiness to perform as required during accident conditions (Observation 2.5-4).
M12-3-84-14 (CCSW Pump Room Cooler Piping Modifications).
This modification, being performed by the Station.Mechanical Maintenance Department, involved pip1ng modifications to install four-way reversing valves and pressure gauges to the CCSW pump room coolers to facilitate backflushing and head remova Although the fi,eld work for this modification was partially completed and not final inspected, the inspection team had a number of concerns with this activity *cunresol ved ltem 2. 5-1).
The following discre~ancies were identified during the inspection of piping that had been welded or had completed flanged joints:
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2.5.10.1 A 300-psi flanged joint shown at data point 225 on the design drawing had not been installed.
2. 5. 10. 2 Ten di mens ions shown on the design drawing exce*eded the.three inch tolerance specified by Sargent & Lundy in the Section XI Repair Program details. Out of tolerance amounts varied from 1-1/4 inches to 2 feet 4 inche.5.10.3 In two locations piping shown on the draw.ings as "existing" had been replaced with new piping, i.e., the modification boundary had been expande.5.10.4 The piping configuration between data points 155 and 165 was revised to eliminate an elbow shown on the design drawin.5.. 10.5 Fiber gaskets were installed in all flanged joint S&L spet:ification K-2202, applicable to this piping, required Flexitallic type gaskets.
. 2.S.10.15 The design drawings specified and crafts had installed 150-psi
.reversing valves and adjacent flange Specification K-2202 requires installation of 300-psi valve~ and flange. 5.10. 7 The P&ID for thi*s system, W*360, indicated that flow elements and temperature i ndi ca tors were installed in t_he 1 i nes between the pumps and the cooler These devices were not r.efletted on the piping drawings and were not installed in the fi.l *
2.5.10.8 The line and cooler designator letters were in error on both piping drawings..Drawings show 11C 11 desi*gnated piping and valves being instaned to 11A 11 and 118 11 designated coolers and 118 11 designated piping and valves installed to "C" and 110 11 de'signated cooler.5.10.9 There was no documentation in the modification package indicating the
. source and pedigree of the eight 300~psi flanges that had been installe *
.2. 5.10.10 The piping drawings did not specify any specific orientation of the
.reversing valves for normal or -backflush flowpath *
2.5.10.11 The visual weld inspection test (during system operation) included in the modification package specified the inspection of welds at the cooler flanges, the four way valve flanges and the pressure gages,
.but did not addres~ inspe~tion of other new in-line pip1ng wel~ This test also stated only to record defects on the test form; there was no reference to ctiscrepancy.reports or other appropriate deficiency r~porting system At the time of the NRC SSOMI inspection, the work pack~ge did not reflect documentation of the above changes nor was an FCR issued to obtain engineering approval prior to completion of wor Subsequently, FCR DM-38 was issued.to doc.ument a number of changes made on this modification.
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..
.
2.5.11 M12-2-84-14 (CCSW Pump Room Cooler Piping Modifications, Unit 2):
Numerous Unit 2 discrepancies were noted which resembled Unit 3 ~iscre pancies (Deficiency 2.5-8).
For example:
2.S.11.1 Contrary to specification requirements, fiber gaskets were installed in all flanged joints instead of Flexitallic type gasket Also, 150-ps i flanges were i nstal 1 ed at a 11 1 ocat ions where 300-ps i flanges were specified on the piping drawin Three configuration dimensions did not match the as-built dimensions shown on the piping drawing with variances of 4 inches, 3-1/2 inches, and 4-1/2 inche The a:s-buiit drawings designated piping and valve designator 118 11 to coolers 11C 11 and 110 11 and 11C 11 piping to coolers 11A 11 and 118 11 *
2.5.11.2 The visual observation test included in *the modification package documentation did not specify the purpose of the test or any accept-ance criteria. It did indicate that some welds and some joints (but not all) were being inspected for defect The test record sheet had been signed off by QC with the comment 11 no leaks.
It was not clear whether QC understood the inspection requirement or the acceptance criteria at the time -0f inspection (Unresolved Item 2.5-2).
2.5.12 M:-12-3.;.85-50 (Installation of Diesel Generator Cooling Water Pump Suttion Pressure Gage) added a pipe, valve and gage off the 8-inch pump suction lin Several discrepancies were noted upon inspection of the installation (Deficiency 2.5-9):
2.5.12.1 Sargent and Lundy Specification K-2202 required that fittings be rated for 3000-ps Contrary to this, the sketches accompanying the package specified that the sockolet be rated at 150-ps The individual who installe.d the fitting ignored the sketch requirement and actually i nsta 11 ed the proper 3000-ps i rated fittings. Nowhere in the modification package wa:s this exception noted or otherwise
.identified nor was the MMP revised as required by station procedure OAP 5-.5.12.2 The station traveler (Step 3) and a sketch inclu~ed in the package both specified that the gage root valve should be a 1/2-inch, 2000-psi bronze valv Step 3 of the traveler was signed off as conforming to this requiremen A second sketch in the package referred ~o this valve as a 200-psi valv Contrary to these requirements, the Quality Assurance Material.tag issued with the valve indicated that the installed valve actually had a 150-psi rating and was constructed of bras Nowhere in the modification package was this exception noted or otherwise i dent i fi ed nor was* the MMP revised as requ.i red by station procedure OAP 5-.5.12.3 The two sketches i.ncluded in the package required that the sockolet and reducers be manufactured to ASTM A-106 grade B, which was a specification for piping, and not fitting The fittings that were installed were per ASTM A-10 Nowhere in the modification package was this exception noted or otherwise identified nor was the*MMP revised as required by station procedure OAP 5- *
2.5.12.4 P&ID M-355 showed the.diesel generator pump suction piping, including this instrument tap, up to and including the root valveJ as being safety-related, but there was nothing in _the package *indicating that the piping was seismically designe When this issue ~as discussed with the project engineer, he stated that since it was safety-related it was also seismi In light of this, there was no mention of seismic acceptability in the modification package nor were there any guidelines or limitations as to the dimerisi.ons (length) or weight of the components involved in th_e pressure tap installation. There was also no mention of required supports for the instrument lin.5.12.5 The SNED modifitation l~tter stated that the piping and valves shall meet the requirements of Sargent and Lundy Spec. K-2202, design Table 110.
Table 110 11 of K-2202 required that the isolation valve be of a rising stem desig Contrary to this, the installed valve was of a non-rising stein desig ~5.12.6 The sockolet referenced on the sketches was identified only by the size of the socket weld fitting (1/2-inch) but was welded to an 8-inch pip The Quality.Assurance Material tag issued with the fitting stated that the beveled end was sized to fit 2~- to 2-inch di~meter pip There was no notation in the package indicating that the fitting was modified to fit the 8 inch pipe or that, if ~odifiedJ appropriate inspections were performed prior to installatio. 5.13 Mi2-2/3-85-34 (Reactor Building Hose Penetration) bored two hole.s in the reactor building common wall between units 2 and 3 and installed penetrations to be used fo.r routing miscellaneous services from one unit to another on a temporary basi A review of the work package and an examination of the installatibris i~entified the following discrepancies (Deficiency 2.5.;.10):
2.5.13.1 Step 2 of the station traveler stated that the penetrations should be located per Sketch 1 in the package and was signed off as com-pleted with no exception Contrary tc;> this, the SSOMI found the verticai centerline of the penetrations to be 9 inches from the face of column 44-N and the horizontal centerline of the lower penetration 7 inches from the floor versus 14 inches and 3 feet, respectively, as specified on Sketch.5.13.2 Step 5 of the station traveler required that any severed reinforcing bars (rebars) be reported to the technical staff. This step was signed off but there was no indication in the documentation whether or not any rebar had been cu.5.13.3 Step Q of the traveler required that the installed piping be grouted in the wall and ~acked (internally) with ceramic fiber. This was in agreement with Sketch In contradiction to this, the statement of
"work performed 11 on th_e associated work request stated that ceramic fiber was installed around the pipe (between the pipe and the wall)
and covered with Vimasc In addition, there was no notation on the work request indicating that any grout was used in conjunction with the installatio The inspection team noted that at least -0n the exterior surface, grouting was never accomplished.
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I
,f, 2.5.13.4 The modification.package instructions di.d not specify the sizes of the pipe-to-flange welds; however, they were specified on the weld inspection record to be 3/8 inch fillet These weld inspection records were completed and accepte Contrary to this documenta-tion, the inspection team discovered two welds that were signifi-cantly ~hdersized, humbered 2A and 28, which measured approximately 1/8 inch per le *
2.5.13.5 The detail on Sketch 1 indicated that a slip-on flange was to be bo 1 ted to the wa 1 Contrary to this, 1/2-i nch thick stee 1 pl ates were used in place of the specified flange No revised MMP was issued or approved as required by OAP 5-.5.13.6 The work package indicated that the penetration was of an approved design; however, no specific document was referericed nor could the project engineer provide documehted evidence that any approval existed or that any standard designs for penetration assemblies existe.5.13.7 A structural analysis performed by Sargent and Lundy was cited as the bases for structural acceptability as referenced in S&L letter dated September 3, 198 Certain details of the final instal~ation differed significantly from several assumptions of the S&L analysis which tould invalidate the analysi These included an increase in the size of the core boring from 4 inthes to 5 inches, the location of the penetrations with respect to column 44-N and floor (noted above), the questionable ext~nt of rebar cutting, and the omission bf grout between the pipe and the wal.5.14 For M12-3-85-17 (Removal and Installation of Interferences Associated With the Replacement of Recirculation Piping) the inspection team examined seven pipe snubber inst~llations that had been removed as interferences, reinstalled and final QC inspected by the contractor (CB&I) and the licensee 1s independent inspection agent (United States testing). Discrepancies were noted on five of the sev~n installations, as shown below, including loose body housing to end cap joints, broken end cap to ihdicator tube screws, missing spacers, an undersized weld, spherical bearing out of position and an as built orientation not in accordance with the original design (Deficiency 2.5-ll).
2.5.14.1 Drawing 502:
The snubber body contacted pipe insulatio The snubber/insulation interference will be increased at operating temperatures due to thermal growt.5.14.2 Drawing 503:
The pipe end attachment did not have an extra spacer as required by the drawin.5.14.3 Drawing 537:
The pipe attachment point, as-installed and as 5hown on the CB&I as-found drawing, Was offset 3 inches from design drawing requirement.5.14.4 Drawing 589:
Two end cap to indicator set screws were sheared off which allowed the indicator tube to rotate on the end ca The welds joihing piece 8 to structural steel were undersized by approximately 1/8 inc *
- 2.5.14:5 Drawing 591:
The indi'cator tube rotated on the end cap, spacers were not included on the lower connection and the lower spherical bearing had slipped out of the lu.5.15 As a result of tha above observations the licensee took the following corrective actio Impell engineers reinspected all 24 snubbers worked during the RPR modification work and found additional similar deficiencie As a result of their evaluations, lmpell revised their Tolerance Specification to provide direction for proper spacer installation and issued specific FCRs and ECNs as appropriat CB&I and U.S. Testing issued nonconformance reports for all identi-fied discrepancies and for the failure to identify them on the original inspectio Ten additional new snubber related welds were reinspected for proper size with no deficiencies note Fire Suppression *System Installations/Modifications Extensive additions and modifications to Units 2 and 3 fire protec-tion systems were being performed tb comply with 10 CFR ~O Appendix R and commitments to the NR Although not safety-related systems they are "important to safety" and de$ignated "reliability related" by the license This work was being performed by Azco:-Hennes Inc. (Azco)
under the direction of CECo Station Constructio Professional Loss Control (PLC), Inc. was providing S&L with on site consulting ser-vices regarding system design and design change The work was governed by S&L Specification K-4072 and Nation Fire Protection Association (NFPA) Standards 13 aMd 1 Azco site procedures were reviewed and, although general, should hav.e provided adequate control and direction for the scope of work involve During an inspection team system walkdown during the hydrostatic test of the Unit 2 reactor feed pump room sprinkler system, several hanger deficiencies were note These deficiencies included loose hanger rod locknuts on five hangers, one hanger with no locknut and one hanger that had not been completely made up (all fasteners loose).
These items were corrected on the spot by the contracto These obvious deficiencies were identified even though the system had a prehydrowalkdown the day before the test by a team consisting of the Azco, S&L and PLC personnel. Several dimensional deficiencies had been identified during that wal kdown that actually delayed the hydr PLC representatives had performed system walkdowns prior to the hydro to verify that as-built conditions would meet design and code requirements for hydraulic calculations, sprinkler obstructions, et A review of six written reports from PLC to'CECo design (SNED) sum-marizing walkdown findings revealed that PLC engineers had identified several installation deficiencie These deficienci~s included the installation of the wrong temperature rated sprinkler heads, riser nipples installed that were not shown on drawings, improper i nsta Ha-t ion of elbows that elevated the piping system 6 inches instead of lowering it 6 inches as intended by a design change, pipe lengths out of tolerance and numerous instances of the use of bushings contrary to the NFPA 13 Cod There was no objective evidence that the
problems noted by PLC were formally documented as quality problems or that any specific actions were taken by CECo, S&L or the contractor
- 42 -
to take 1 ong term corrective action or to eva 1 uate the overa 11 quality program for effectiveness. There was no evidence of CECo QA/QC awareness of the PLC observation The inspection team walked ~own accessible portions of the.Unit 3 pump room sprinkler system per S&L drawing F-362 and identified several cohcerns as noted below (Unresolved Item 2.5~3):
2.5.15.l The dimension from the cross main tee to the sprinkler near hanger 48 was specified as 5 feet 9 inches,.but was found to be 6 feet 1 inch (2 inch tolerance allowed).
2. 5.15. 2 A.pipe cap symbol was sh-own on FCR 4606, Sheet 5 near hanger 63 but the installed piping had a continuous run at that poin.5.15.3 The dimension to the drain valve on FCR 4606, Sheet 5 was specified as 2 feet 6_ inches, but the actual dimension w~s one foot 9 inches (3 inch tolerance allowed).
2.5.15.4 The dimension specified as 6 feet 7 inches on FCR 4606, Sheet 5 was actually found to be 6 feet 11 inches (3 inch tolerance allowed).
2.5.15.5. Hanger *56 was loose and not taking any loa.5.16 2.5.17 M12-3-83-57 (Main Steam Piping Lug Installation) installed lugs ~n a vertical run of main steam piping to prevent a support from sliding down the pip Drawing M-777 which detailed the installation, stated that full (100%) contact was required between the lugs and the support Cl amp, which would be achieved by grinding if require The inspection team_hoticed no evidence of grinding -0n the lug~ and approximately 50% contact (Deficiency 2~5-12).
Ml2-l-2-3-84-32 (Install Isolation Valves on Primary and Secondary Fuel Lines, Bleed Valves on Filter and Valve on Crankca_se on the Security Diesel) was not a.safety-related modification but was considered as 11 important to safety 11 and was designated as reliability-related by Dresde The NRC SSOMI team reviewed the work package aMd backgrourid because of the postponement of DOS 6600-4, 118us Undervoltage and ECCS Integrated Functional Test for Unit 3 Diesel Generator, 11 (which was caused in part by the unavailability of the Security Diesel).
The Security Diesel was inoperable during the initial review of the work package on July 12, 1986 and had been inoperable for week On June 25, 1986, the maintenance department had been verbally notified by the Technical Support Staff that problems existed with the Security Diesel modification and th~t unauthori~ed parts should be remove No discrepancy report or other documentation was i.ssued describing what those deficiencies were and subsequently corrective action was not take On July 12, 1986, a discrepancy report (DR) was written agaihst the Security Diesel entitled "Procedure Violatio*ri in MOD M12-2/3 - 84-32 11 (DR No. 86-0079).
Numerous discrepancies were.noted by the SSOMI team in an examination of field work and documehtation for the Security Diesel modification (Unresolved Item 2.5-4).
For example:
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2.5.17.1 The statio.n traveler fisted S&L K-2202 as the design spetificatfon, however, the components specified in the traveler or procured were not in accordance with the S&L specificatio In addition, the components installed were not as specified in the traveler in some case Gate valves were installed in lieu of globe valves as required by S&L speci fi cation K-220 S&L specification K-.2202 required carbon steel components, whereas two stainless steel valves were installe S&L specification K-2202 required 3000-psi fittings and 600-psi valve The work package did not specify pressure ratings for fittings on the flex hose None of the valves installed had a 600-psi *pressure ratin Item 3 of the station traveler required~ 300-psi, schedule 80, 1/2-i nch threaded carbon steel valv Actua 11 y i nsta 11 ed was an 800-psi 3/4-inch socket valv The schedule of the valve was
.not determined by the inspection tea Item 2 of the *station traveler required 300-psi, carbon steel bleed valves of no partftular size. Actually installed were 1/4-inch, 40:00-psi, stainless stee.l valve Item 1 of the stati~n traveler required a 300~psi, carbon steel threaded.isolation valve (using design table 11G11).
Actual installed was a 1~i~ch, 800~psi gate ~alve with threaded end Table 11G11 required a Goo~psi, globe valve with s.ocket welded end.5~17.2 A note on WR 035149 indicated that a Fire Hazard Review was not required because no welding was required..However, welding was accomplished during the modificatio.5.17.3 The 11work performed 11 section of WR 035149 includedonly a partial listing of materials use Omitted were pipe and fittings that were installe *
2. 6 Maintenance Contro 1 s and Pr'act i c~s During the conduct of this inspection, observed maintenance practices were evaluated as well as housekeeping and general condition of the plant and equipmen Several areas of concern were identified (Observation 2.6-1).
2. M12-3-84-8 (HGA Relay Replacement):
Maintenance and housekeeping discrepancies identified with this modification include the followin,g:
2.6. Terminal block MM was found to be cracked in cabinet 903-33, Part The block terminated wires to LPCI and CS system safety-related equipmen. 6.1. 2 Safety-related fuses for the LPCI and CS relays were found on the floor of cabinet 903-3 In addition, out of service tags were fouhd on the floor of the cabinet and were not attached to the fuse b 1 ocks where the lfuses were ori gi na lly i nsta 11 e Two of the fuses were securely tied to out of service tags while the remainder were laying on the floo It appeared that at least *14 fuses were remove However, only six of these were found on the floor and attached to the Out of Service tag.6. A 1/2-inch (approximately) diameter cable was found irl the auxiliary re 1 ay cabinet 903-33, Part Another similar cab 1 e was found in the adjacent cabine No out of service tag, jumper tag, temporary modification tag or other identification was found on the cabl.6. Trays in cabinet 903-32, and othe.r similar cabinets inspected, did not have covers rep 1 aced.after i nsta 11 i ng wire Trays had wires installed laying outside the tray wall and were overloaded with cable.6..6..6,2 Paper combustibles were found in the 903-32 cabinet..Approximately six to eight sheets of paper were found in the bottom of the cabinet and could increase combustible loading beyond the point where fire suppress ion systems could protect the equipmen A taped wire connection was found in 903-33 cabinet which appeared to be a butt splice to affect a conductor repai No records were pro-duced documenting the splic Removal of the tape on the splice by plant personnel showed that the splice was insulated but that the metal mat~rial from the splice was protruding through the insulatio Since no documentation could be found, it could not be determined whether the insulating tape was qualifie Control Room Annunciators During witnessing of tests it was noted that about 50 control room tile type annunciators had one light bulb burned ou This was indicated by the annunciator tile glowing diml Control room personnel indicated that this was not a problem as the annunciators had two bulbs and they were tested regularl The inspection team considers waiting for the second bulb in a two-bulb system to burn out before taking action impruden It appeared that due to the widespread nature of the problem and discussions with control room
- 45 -
2. *
,,.
operators, this was co'nsidered standard practice for Dresde The Operations Superintendent was questioned in the control room and in the process of checking three annunciators, one bad annunciator socket was discovere A work request was written to investigate the faulty socket. However, in the process of checking the annunciators three annunciator tiles were removed at the same ti.m This was contrary to station procedures which allow only one annunciator tile to be removed at one time since they were interchangeabl Control Room Conduct During witnessing of tests, the inspection team n6ted that a hard hat was knocked.off the top of panel 903-24 hitting valve control handle No valves were repositfoned by *the hard hat, although the potential to inadvertently operate plant equipment ~xisted since several hard hats were noted on top of panels iii such a.manner that they could be knocked on top of equipment switche On a separate occasion, it was noted that a cup of coffee was knocked off the top of panel 903-56 spilling on top of controls for the coritaihment atmospheric monitor-ing system; however, the panel was s,ubsequently inspected (by control rooin operators) and.was not damaged. * Stricter controls iii the area of operating panels are needed to prevent equipment damage or inadvertent operation of equipment.
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2.7 lest Procedure Control Test procedures applicable to modification packages were reviewe These included procedures to functionally test the modifications, instrumentation and operation surveillances, RPR special procedure tests and CECo Operational Analysis Department (OAD) construction test Procedures were eval~ated to assure that systems would properly function after modification, that functiona1 as well as system.integrity tests were performed and that interactions with other systems during normal operations and event conditions were considere The review also included the control and processing of temporary changes to procedure. Several test procedures contained errors or omissions even though the tests had been reviewed and approved (Defici~ncy 2.7-1).
2.7. M12-3-83~29 (LPCI Suction Valve Control Switches):
TCR 86-6-384 incorporated steps into Dresden Instrumentation Surveillance (DIS)
1500-5 Rev. 5, 11 LPCI/CCSW System Logic Test,
to functionally test the modificatio The equipment lo~ation for step 222C on Attachm~ilt C of the change was incorrect in that it indicated a local relay panel instead of the control room pa~e *
2. 7. M12-3-83-30 (CS Suction Valve Control Switches):
TCR 86-5-315 incorporated steps into DIS 1400-5 Rev. 6, 11 CS System Logic Test, 11 to functionally test the modificatio The change did not include steps to return the control switches to the AUTO position to continue the surveillance tes In addition, an action listed for verification in step 94b (valve closes) could not occu The valve was already closed when step 94b was accbmplishe. 7.1. 3 M12-3-84-9 (CS Isolation Valve Anti-hammering):
The functional test written for the modification contained an error in that step S refetenced valve 258 instead of 25 This was discussed with the licensee and the reference was subsequently changed by the cognizant modification staff engineer before the test was per-forme.7. DIS 1400-5, 11Core Spray System Logic Test," contained several errors in referencing equipment but was stil1 conducted without appropriate change documents to correct the procedur For example:
Step 8 referred to relay 140-1268 instead of 1430-126 Step 138 referred to relay 903-33 instead of 903-Step.17 referred to the annunciator for core spray system II instead of system Step 17 referred to valves 2499-38 and 48 instead of 2499-18 and 2.7.L5 The following RPR special procedures (SPs) were found to have incorrect references.:
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f
Test Procedure No.
SP 86-1-11 SP 86-1-12 SP 86-1-13
.
Step.N..1 Correct Reference 6.1.2...1..7. Appendix 10.2 of SP 86-1-9 iisted lifted lead The.applicable procedure steps discussed both lifting the leads and landing jumper The removal steps only discussed rel~nding the lifted leads without discussing removal of the jumper.7. M12-3-86~38 (IEB 79-01 lnstrumentation Replacement):
Uninitialled pen and ink changes were made to numerous trip points for HPCI steam line flow isolation calibration data sheets, DIS 2300-1, Rev. 7, page 9 of A few of the changes to the trip points were initialled and some were no Special Procedure 86-5-74 also.had changes to safety related trip points that were not initialle. Several of the RPR special procedure tests.did not include steps to verify the test or to document the equipment verifications on the applicable test appendiCes (Deficiency 2. 7-2).
These are listed belo Test Procedure N SP 86-1-6 SP 86-1-8 SP 86-1-11 SP 86-1-12 SP 86-1"'.'13 Appendix 1.8 1.7, 1.8 Comments Last four trarismitters on Appendix Temporary Change No. 332 wr.itten to include this step Step 3.£ verifies test but does nnt require documentation on Appendix 1 Step 3.3 verifies test but does not require documentation oh Appendix 1. Several modification related test procedures and special test procedures were reviewed to determine content and control processe General examples of inadequate procedural control include (Deficiency 2.7-3):
2.7. In each of the procedures reviewed, there.was no documented acknow-ledgement or other indication that test prerequisites were satisfac-torily me Often, significant worksteps such..as valve lineups, connection and removal of differential pressure cells and gauges, optional or contingency steps, starting and securing of pumps, et had no verification signature space.7. In several jnstances, signature ~p~ces for steps were annotated as being not applicable (NIA) without an accompanying initial as required by Dresden administrative procedure,.
2.7. Frequently, individuais witnessed events in the field and informed control room personnel of field conditions as required by the test procedure The test engineer in the control room then initialed the appropriate step as being completed without making a notation that the activity.was actually performed by another individua.7. Temporary procedure changes did not make reference to the revision of the procedure to which they applie.7. The affected steps of a procedure that were changed as a result of a temporary change were generally not annotated to invoke the chang Thus, it was not clear whether signoffs indicated acceptance of activities required before or after the chang.7. There was no formal mechanism for granting permission by the shift supervisor or other control room personnel to perform~ tes.7.3.)
Many tests lacked a signoff for test compl~tion and verification of test acceptabilit. OAP 5-1, "Plant Modification Program, 11 paragraph B.22 indicated that, if a modification package was not complete, the Operating Engineer may authorize equipment operation after an Incomplete Modification Review Checklist, OAP Form 5-lC was complete A Form 5-lC was initfated to allow fuel load prior to completion and closeout of RPR modific~tion package M12-3~85-1.. Attached to the checkl.ist were extensive punchlists defining incomp.lete construction activities; however no mention was made concerning incomplete prereq~isite testing, testing discrepancies, tesiing deviations, outstanding testing evaluations of test failures and their
. general impac Discussions with the CECo project engineer who had sigried many of the signature spaces on the form, elicited.the information that ~uch incomplete testing activities and evaluations did exist (Unresolved Item 2.7-1).
Procedure DTS 1600-1, "Local Leak Rate Testing (LLRT) of Primary Containment Isolation Valves, 11 had no specific valve lineup included in the procedure or for QC verification of proper lineup prior to performance of test Valve positioning and associated prerequ.isites for LLRT was left to the discretion of the test enginee The test engineer that performed the test for the containment purge valve, 3-1601-21, stated that there was generally no QC coverage for leak
- rate testihg (Unresolved Item 2.7-2).
A review of DOS 6600-3, "Bus Undervoltage and ECCS Integrated Functional Test*for 2/3 Diesel Generator (Unit -3 Test Only),
11 and DOS 6600-4, "Bus Undervoltage and ECCS Integrated Functional Test for Unit 3 Diesel Generator, 11 *indentified incorrect references to Unit 3 Technical Specification Two of the three references in the test procedures referred to the wrong sections.in the Technical Specification Procedure Section H.1 should have referenced Technical Specifications Section 4.2, Table 4.2.1 rather than ~ection 4.2.1; and procedure Section H.3 should have referenced Section 4.9.D.4, Diesel Generator Operability rather than 4.9.A.4, Station
- 49 -
.
Batterie This was corrected with a Station Procedure Temporary Change Request.after.discussions between the inspection team and licensee personne Dresden personnel indicated that the Technical Specifications were recently revised which may have been the reason for incorrect reference Plant personnel were asked to produce documentation to
- Show that the proper tests were conducted to comply with the appro-priate Technical Specification *references during previous under-voltage tests (Unresolved Item 2.7-3).
- 2. Special Procedure 86-1-9, "Reactor Recirculation System Preoperational Test:"
TCR 86-7-46 was issued to Sectio.n 6.3.6.D which changed the
- . method of testing a recirculation loop temperature detect.o The original procedure required a functional test of the temperature detector to be performed.by removing the detector from the detector we 11 and heating it with a heat gun while observing temperature indication on the plant compute The TCR allowed the use of a signal injector at the detector terminal b.ox which would result in a test only or the wiring from the output of the thermocouple to the plant compute This appeared to change the intent of Section 6.3.6.0 and was contrary to the requirements of OAP 9.2, which allowed a TCR to be used only if.it did not change the intent of a procedur This also appeared to violate Dresden Unit 3 Technical Specifications, section 6.20 regarding temporary changes to proce-dure Utility staff indicatedthat the original intent of the procedure was only to verify the wiring and not the thermocouple so it was allowable to use the TCR (Unresolved Item 2.7-4}.
2. Several general concerns. were identified with the issuance of temporary changes to test procedure The changes were documented on TCRs for current testing even though recommended for permanent incorporation into the procedur Although the procedure number was prominently recorded on the TCR, the revision number of the procedure was not rec.orde In addition, the incorporation of TCRs into the test procedures was inconsisten Generally, TCRs were appended to the front of the procedure without making the changes to the steps in the 2. procedure itsel When the tests were conducted, the original steps were signed as being performed and there was no indication that the steps as changed by the TCR were performe In those cases where the changes were incorporated with the procedure, there was no correla-tion bac.k to the TC This was further complicated when there were several TCRs written against a procedure which included nondiscript change request SUlllillaries such as "See attached sheets," where the attached sheets were not.numbered or identified by their TCR numbe Discrepancies were identified by the SSOMI team b.etween the Technical Specifications and the FSAR ~nd operational surveillance tests in the listing of primary containment isolation valves (Deficiency 2.7-4).
Technical Specification Table 3.7.1, Primary Containment holatfon, lists. individually 69 valves in the 5 pri:mary containment isolation valVe groups and 47 other valves required for isolatio The 69 v~lves in the isolation groups were required to operate on an auto-matic safety initiation signal and maximum operating times were specified for them in the tabl FSAR Table 7.7.2.1, Primary
... 50 -
2.7.10
.
Containment Isolation'Systein Valve Groups, identified the function and number of valves by function for the five isolation group Correlating the two tables produced discrepancies in both the number and types of valves listed in the FSAR tabl The specific discre-pancies are identified on Table I The Technital Spe~ifitation table was also c~mpared to the listing of valves in surveillance test procedures DOS 1600-1, 11Quarterly Valve Timing, 11 and DOS 1600-18, 11Cold Shutdown Valve Testing.
These two surveillance tests identified on their checklists which valves were part of the primary containment isolation system, and the checklists provided for those valves maximum closing time acceptance criteria consisteht with Technical Specification Table 3.7.1. -However, DOS 1600-1 did not identify valves A0-1599-61 and A0-1599-62 (torus transfer isolation) as part of the primary containment system, although they were listed on Technical Specification Table 3.7.1 in isolation group 2 as torus to condenser drain valve In addition, only 59 valves were identified between the two DOSs as primary containment isolation valves; ten valves less than listed on the Technical Specifi~ation tabl A similar* item, containment isolation valves listed in the Dresden Unit 3 FSAR but not in *the Technical Specification, was discussed in IE Information Notice 86-38, 11 Deficient Operator Actions Following Dual Function Valve Failures.
This was the result of an unusual event that occurred at the site in February 198 M12-3-84-27 and M12-3-84-28 (Replacement of Solenoid Operated Valves 3-1601-50A and 3-1601-508 on Unit 3):
The operational test detailed in the work package did not specify or refer to verification.of proper stroke times as required by ASME Section XI for In-Service Testing of power operated valves (Deficiency 2.7-5).
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2.8 Test.Conduct and Documentation The SSOMI team witnessed the conduct of tests performed to verify modifications and reviewed completed test documentatio Tests were observed to determine whether procedures were fo 11 owed and if the tests were performed adequatel Documentation was also reviewed to determirie whether it truely reflected the test as performe Discrepaneies and concerns were identified fo both area. A review of DIS 1400-5, "Core Spray System Logic Test, 11 and DIS 1500-5, 11 LPCI/CCSW Logic Test, 11 identified concerns in test conduct and deviations from test procedure Specific examples of these deficiencies are as follows (Deficiency 2.8-1):
2.8. A caution card was not installed during the retesting of steps 69 through 92 of the procedure as required by the test procedur Caution Card III-53-86 was installed May 31, 1986, for the per.for-mance of the 11A 11 Core Spray System Logic test The c;:aution card was removed May 31, 1986, and the retest of the steps was conducted on June 5, 198.8~ The Shift Supervi6or 1s signature was not obtained on June 5, 1986, to document that Operations had been notified and concurred with performing a portion of the tes.8..During the initial testing of Steps 69 through 92, a relay (1430-127A)
failure occurre No written evaluation was conducted to determine if testing could continue and no entrywas made in the test procedure to document that a discrepancy report was wd tte.8. A retest conducted :on steps 69 through 92 had no written evaluation of the relay failure to doc.umelit that only those steps of the proce-dure should be reteste No documentation existed to verify that the Shift Supervisor had been notified that a retest was to be conducte.8. Step 114 failed due tb relay 1430-107A contacts 7 and 8 not functioning properl No discrepancy repo~t was written ahd ho entry was made in the test procedure regarding why the problem occurre.8. Steps 113 through 116 were retest~d via TCR 86-6-366J however, signoffs were hbt made to indicate that steps 113 through 116 were reteste.8. TCRs 86-5-315 and 86-6-366 did not specifically identify the procedure sections to be changed and.only referenced the TCR attachment See Section 2.7, abov.8. While performing Step 159 of DIS 1500-5, relay 1530-133 (BU) failed to actuate, apparently caused by a wiring error. It was also found that the wiring d.iagram for the relay was incorrect and a OCR was submitte No discrepancy report was written on the event and no entry was made in the test procedure to document the occurranc *
(.
2..
Modification M12~3-83~37 (IEB 79~01 Instrumentation Replacement):
Documentation for instrument calibrations and calibration checks previously performed were reviewed and conduct of calibration checks were witnesse The SSOMI team identifi~d a concern regarding the method of recording the calibration checks (Observation 2.8-1).
2.8. A calibration check of core spray flow transmitters FT-3-1464 A and B had been performed but not documented in the modification package~
The original station traveler prepared on January 6, 1986, specified a hydrostatic test at 250 psi This test was satisfactorily conducted on January 24, 1986, followed by an instrument calibratio However, a new MMP and station traveler were prepared on June 6, 1986, to hydrostatically test the flow transmitters to 400 psi Dresden staff indicated that they decided to do a calibration check of the transmitters as the original calibration was done after the 250 psig hydrostatic test but prior to the 400 psig hydrostatic tes Although no procedure change was instituted to conduct the calibra-tion check, the calibration check was conducted using the calibration procedure; however, the calibration check and calibration data were not recorded in the modification packag Dresden staff indicated that a red 11tick 11 mark had.been placed by the original calibration data on the data sheet if the calibration point had the same value as during the initial calibratio.8. Calibration checks were witnessed by the SSOMI team on the analog trip system for the core spray master trip units and slave trip units which coritrol the cycling of core spray valves 1402-38A and 1402-388.
The calibration check was not recorded in the modification packag Tick 11 marks were again used as discussed above to *indicate points that had not changed on the original calibration checklists, and no other documentation of the calibration checks was mad. Procedure SP-86-l-6 (Core Spray Preoperational Test):
The object of thi.s test was to functionally prove that the core spray piping and components affected by the RPR modification package were restored and that the system was operabl Satisfactory performance of this test was a prerequisite for fuel loa The 11Test Objectives 11 section of the procedure specifically stated that an objective of the procedur~
was to verify proper i ndi catian of the core spray header dif'ferenti al pressure instrumentatio During the originai installation of the header differential pressure transmitters, the nomenclature for the instruments was transpose Instrument dPI 3-1467A was installed on the 118 11 core spray line and dPI 3-14678 was installed on the 11A 11 core spray lin However, the test procedure referred the 11A 11 instrument to the 11A 11 core spray line and the 118 11 instrument to the 118 11 core spray lin During the performance of the test, at the first instance where a reading from one of these instrum~nts was required (zero-flow condition)J the test engineer noticed the error and, assuming that it was a typographical error, made a pen-and-ink correction without any apparent further investigation of the matte Throughout the remainder of the test no other corrections were made, thus calling to question whether or not the instrumentation was indeed i~stalled and indi~ating properl *
If the test proced~re.had b~en followed as written, the test would have failed and the ihstrument nomenclature error noted as the cause of failure (Observation 2.8-2).
- 2. Procedure SP-86-1-8 (Low Pressure Coolant Injection (LPCI)
Preoperational Test):
The object of this te~t was to functionally prove that the LPCI piping and components affected by the RPR modifica-tion package were restored and.the system was operabl Satisfactory performance of this test was a prerequisite for fuel loa Inadequate test conduct and documentation of test deviations or failures were noted as follows (Deficiency 2.8-2):
2.8. Step 4.7 established a requirement that reactor water temperature should not exceed 150 deg-F, yet there was no requirement in the procedure to monitor or record reactor water temperatur.8. Step 6.1.2.b - Valves M0*1501-22A and 228 were shown with double entries for their respective test data. If st~ps were reperformed and more than one set 6f signatures or data was entered on a test proc~dure or data sheet, the reasons fbr these actions must be clearly annotated on the procedure or data shee.8. Steps 6.2.6 and 6.3.6 - The data for LPCI pump discharge pressure did not meet the acceptance criter.i In the margin of the test procedure was written the note 11 see evaluatio *No evaluation existed at the time of the S~OMI (approximate1y 6 weeks after the test was performed).
This was contrary to the requirements of CECo QAM Section 11, which required analysis and evaluatio Fuel loading was accomplished without the required evaluation being p~rforme.8. Steps 6.2.7, 6.2.~.b and 6.3.8.b of the procedure originally required LPCI flowrates to be recorded using computer poiht 35 The proce-dure was later changed by TCR 86-5-332, which allowed the use of computer points 354 or 34 Since the TCR was issued as an attach-ment to the original procedure rather than a direct change to the procedure, step verification signatures actually indicated that computer point 354 was used to obtain the flowrat The following concerns were noted:
Step 6.2.7 had been annotated to indicate that flow recorder 3-1540-7 was used to obtain the fl owrate, which. was not authorized by the procedur Steps fi.2.8.b, 6.3.7 and 6.3.B.b were signed off, which indicated that computer point 354 was use The inspettion team discovered that computer points 354 and 347 were not calibrated and thus could not be used during the tes Due to the slow scan rate of the ~omputer and the short pe~iod of time in which to obtain data, the data point(s) read zero during the tes Because of this, it was appareht that signoffs for steps 6.2.8.b, 6.3.7 and 6.3.8.b could not have used data
- 54 -
'l'
from computer'point'354 (as signed) or computer point 347 (as all o~d by the TCR) but, instead, f.1 ow rate data was obtained from some other source not mentioned in the test procedure.
2.8. Appendix 10.7 - The calibration date (May 21, 1985) for LPCI flow transmitters FT-3~1551-A and B was incorrec These transmitters were replaced in February 1986 and subsequently calibrated. *Although the instruments were properly calibrated for this test, procedures appeared to be ineffective for updating calibration and equipment records in.a timely fashio.8. No entries were made to Apendices 10.l or 10.4, "Test Exception Disposition Report," and "Test AnalysisReport, 11 respectivel. 8. 5 Procedure SP-86-5-92 (LPCI Flow Rate Test with two Minimum Fl ow Valves Open):
Because of irregularities related to LPCI test SP-86~1-8 (See section 2.8.4 above), the licensee stated that part of the evalµation would be based on ariother test, SP-86-5-9 sp~a6-5-92 was deve)oped in res.ponse to IE Bulletin 86-01 and was designed to prove that.a 2.. LPCI flow of 14,500 GPM could be obtained with a pump discharge pressure of 125 psi At 14,500 GPM, the discharge press.ures of the three operating LPCI pumps were in excess of 155 psi No discre-pancy report was issued as a result of this, contrary to the require-ments of CECo QAM Section ll (Deficiency 2.8-3).
In addition, the test was deficient in other areas including a lack of provisions on the data sheets for identifying the person responsi-ble for conducting the test or for reto.rding the date or period during which the test was performed, a failure to retard the actual LPCI fl owrate, and a fai 1 ure to identify the instruments from which data was to be obtained (e.g., flowrate, _pump discharge pressure, and pump motor current).
- Procedure SP-86-1-10 (Reactor Water Cleanup (RWCU) Preoperational Test):
During performance of Step 6.1.2.b.2 which required verifying operation of several* RWCU valves, the computer point position indica-tion for valve M0-1201-2 failed to functio The comment "see evaluation" was written in the margin of the procedure, but at the time of the SSOMI inspection no ~uch evaluation had been performed nor were there any remarks included in Appendix 10.3, "Test Exception Disposition Report.
This problem was not resolved prior to perform-ing the steps of.Section 6.2 of which completion of Section 6.1.2 was a prerequisite (Deficiency 2.8-4).
Dresden Maintenance Procedure (DMP) 200-30, 11Units 2/3 6 11 Safety Valve Overhaul and Test Protedure 11 was invoked to test main steam safety valves associated with Unit 2 at Quad Cities Nuclear site, using the facilities available at Dresde Consolidated safety valve, serial number 7155 ~as tested on November 6, 1985, with an acceptable lift pressure of 1262 psi Upon review of the test procedure and test results, the inspection team had the following concerns (Unresolved Item 2.8-1):
- 55 -
2.8. Section 3 of the test 'procedure required the valve body to be warmed up 11to normal operating temperature, approximately 200 deg-F, 11 prior to testin The test procedure did not include a requirement for 2.8... monitoring the spring temperature which should have been at the
.
normal_9perating temperature of approximately 200 deg-F. The tempera-ture of the body.and seat of 200 deg-F was much lower than the expected operational temperature of approximately 500 deg-The differences between the test temperatures and the normal operating temperatures will affect the point at which the safety valves will lift and should be evaluated. *
The test procedure did not require reseat pressures to be recorded since the.boiler used at the test facility had insuffic.ient capacity to achieve meaningful reseat pressure valu.e Also, the instruments used during the lift tests.calibrated per DIS 5700-1 recorded only ihitial values and failed to record final values, after test comple-tio.
.
Observation of DIS 1500-5, "LPCI/CCSW Logic Test, 11 resulted in concerns regarding test conduct and deviation from test procedure * During the performance of steps 67 and 68 of the test, the techni Ci an was to place a test switch to the "AC" position from the 110ff
position and to obtain a relay actuation ti.m The technician completed this action but inadvertently missed the actuati.on time of the rela The technician then placed *the test switch in. the 11 BC
position, a position not called for in the test procedur He then placed the switch in the uAC" position and obtained the relay time.
The technician did not obtain permission from the senior level technician who was supervising.the test to deviate *from the test p.rocedure, did not do.cume.nt the occurrence in the test procedure.,
and did not evaluate the effects of the change in test conditions (Deficiency 2.8-5).
No discrepancy report was written on.the inci-den *
Modification packages M12-3-84*103 and 104 (Valve Operator Motor Replacement):
The functional tests for these modification packages were witnessed by the inspection tea Testing involved cycling of the recirculation system pump discharge valves from the control roo During the testing and the subsequent review of the modification packages after testing was completed, one discrepancy was identi-fied regarding test requirements (Deficiency 2.8-6).
The valves were cycled from the control room while indication was observed on the control panels. This was in accordance with the modification functional test procedure The work packages, however, contained a SNED recommendation that the acceptance triteria for testing the modifications include checking the valves for hammering in the open and closed directfons during manual and automatic.opera-tio The functional tests did.not provide for the recommended acceptance criteria. Utility staff stated that the valves had additional testing under Special Test Procedure SP-86":-1-Upon checking the special test procedure, it was found that it also did not contain the recommended acceptance criteri New functional tests were subsequently written and.performe The new procedures stationed a man at the valves to verify proper operatio *- 56 -
- 2.8.10
,,.
The team observed the ~erformance of DOS 6600~4, 11Bus Undervoltage and ECCS Integrated Functional Test for Unit 3 Diesel Generator.
Inadequacies were noted in th~ areas of test conduct and preparation of TCRs (Deficiency 2.8-7).
- Conduct of DOS 6600-4 was ftnallypostponed because of the unavail-ability of the security diese Transferring the security gate.house load from the safety-related bus to its own diesel generator was a prerequisite of the tes However~ this could not be accomplished since the security diesel was out of service because of an improperly accomplished modificatio The modification performed on the security diesel is discussed in Section 2.5, abov The following concerns were noted durf ng test performance:
2.8.10~1 Procedural steps ~.l and F.2 a, b, c, and d, whi~h started the actual testing, were signed off as being completed prior to completing prerequisite signoff.8.10.2 Miscellaneous notes were written' in the border of the master copy of the test procedure indicating location Of ~~uipment listed in the procedural step This appeared to be necessary as the procedure in several cases did not specify where the breakers or switches were or at what location the step was to be conducte.8.10.3 Pages 26, 27, 28, and 29 contained changes to the procedure that were made without a TC A change notice was processed after the inspection.team asked if there was a TCR to support the chang.8.10.4 The test procedure did not specify the position that switches should be returned to after the switches were operated during the tes.8.10.5 Step C.7 of the test prerequisites was incorrect for the plant configuratio Step C. 7 stated 11Transfer the gatehous*e loads to the Security Diesel when testing Unit 3 onl Since this will be adead bus transfer, ensure that the security computer is deenergized during the transfer.
The security computer has an uninterruptable power supply and therefore did not need to be de-energized to transfer loads or conduct the tes This step of the procedure was not corrected to reflect the correct information and true configura-tio.8.10.6 The breakers for the reactor cleanup recirculation pump 3B arid reactor shutdown cooling pump 3B were found in the test remote position although their entries in the Caution Card Checklist (lines 28 ~rnd 32 on page 17) were signed by the Shift Foreman as being in the test local positio.2.8.11 Observation of the performance of DOS 6600-3, 11 Bus Undervoltage and ECCS
~ntegrated Functional Test for 2/3 Diesel Generator (Unit -3 Test Only),
11 was conducte Inadequacies were noted in the areas of test conduct and preparation of TCR It was also noted during the testing that the test procedure.method of determining sequential timing was in co~flict with FSAR requirement Additional steps and checkpoints were temporarily added to DOS 6600~3 via TCR 86-7-421 to functionally test modification Ml2-3-84-118 (Drywell Cooler Trip
- 57 -
w*
Bypass);. The fo 11 ~~i ng c 0oni:erns were noted.during survei 11 ante of test performance (Deficiency 2.8-8):
2.8,11.1 The test was not adequate in specifying the location of personnel and specific indicators for starting and stopping stopwatches to time speC:ific event An attempt to correct this was made by passing out what amounted to an unapproved addendum to the procedure which specified who was located where and what plant indicator would be used to start and stop timing during the tes. 8.11. 2 Step C. 9 of the prerequisites was signed off prior to test personnel leaving the control roo Step C.9 stated, 11 Establish communications between the control room and the second floor.of the Reactor Buildin.8.11.3 The checklist verification in step F.9 of the test procedure required that the lineup of the core spray and LPCI valves be veri-fie No valve identifications and lineup was provided in the test procedure to perform this verificatio *
2.8.11.4 The timing required in step F.22 was missed as no one was assigned to ti me i The test was stopped at step F. 26.and conditions were reset to prest~p F.20 conditions to repeat steps in order to get the time for the step that was misse This was done without a procedure by looking through the steps and~etermining what breakers/switches/pumps needed to be operated.
. 2. 8.11. 5 Step F. 31 of the procedure required that the 2/3 diesel generator be unloaded and shut down ih accordance with Dresden Operating Procedure (DOP) 6600- Instead the operators ran the diesel genera-tor for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per vendor instructions at loads of 2000 to 2800 K This requirement was not covered by the DO Dresden operations personnel indicated that DOPs sometimes did not provide adequate information on how to operate equipmen.8.11.6 Steps F.14 a, b, and~ Of the test procedure required recording the time that annunciator 114 KV Bus 33-1 Voltage Degraded 11 alarms and when the second level uhdervoltage trips occur (approximately 5 minutes).
The procedure times the annunciator alarm and the second level undervoltage trips from the same starting poin Step :F.14 and Section E.4 of the procedure also specified that the time peried for the load trips should be less th~n or equal to 5 minute The test results produced a time for alarm i~itiation of 6.8 seconds and a time for the second level trip of 4 minutes, 47 second However, FSAR section 8.2.3-3 describes a different timing sequence for these event The FSAR stated that the annunciator should alarm and a 5-minute timer should be initiated if a degraded voltage condition has persisted *tor 7 second After 5 minutes have passed
.the di.ese.l generator is started and the second leve 1 undervo 1 tage trips occu Therefore, the FSAR required that the timing for the 5 minute period start after the 7-second timer had timed out and initiated the 11 4KV Bus 33-1 Voltage Degraded 11 alar The FSAR also stated that the time should be greater t.han or equal to 5 minutes.
- 58 -
,,
2.8.12 Other concerns raised ~nd o6servations made during the surveillance of DOS 6600-3 and DOS 6600-4 include (Observation 2.8-3):
2.8.12.1 Steps F.33 and f.34 required the re-energization of equipment as necessary after test completio No specific references were provided to plant operation~ procedur~s or equipment to specific~lly determine the plant status after completion 6f this step and place it back in its normal conditio.8.12.2 The Bus Undervoltage Breaker Lineup Checklists in the procedures did not provide equipment numbers for any of the device Equipment numbers were* not provided in any part of the procedures to specifi-cally relate a c-0mponent functi-0n to a ~pecific piece of equip~en.8.12.3 The Die~el Auto-Start and Loading Checklists contained a note that stated the lineup is 11 *** one of several which may be used...
11 *
No specific plant lineups were required for these tests and no references were.provided for other possible lineups for use by test personne.8.12.4 There were no plant announcements during the test to alert personnel that ECCS buses ~ould b~ energized and de~energized, ECCS pumps started and stopped or other equipment operate.8.13 2.8.14 2.8.15 A review of the Contro1 Room Jumper log was conducted as a part of the operations portlon of the inspectio The majority of temporary jumpers were in place for approximately 2 years with some jumpers in place for up to 6 year The length of time that the jumpers were being maintained was not in accordance with the intent of the plant modifications procedure, -OAP 5-This procedure required that permanent plant changes be accomplished with a plant modification packag~ {Unresolved Item 2.8-2).
Modification M12~3-83-36 (IEB 79-01 Instrumentati6n Replacement):
The inspection team attempted to witness the performance of DIS 1600-3 on the torus to reactor building vacuum breaker valve However, during a pretest operability check both valves failed to perform as require Valve 3-1601~20A would not fully ope The alarm indicated that it was not fully close Valve 3:1601-208 fully opened but did not contact the li~it switch ta indicate open position in the control roo The alarm indicated not fully close Two work requests were written to correct the prpb]ems with both valve These were work request 55707 for valve 20A and work request 55708 for valve.20 Procedure SP-86-1-9 (Reactor Recirculation System Preoperation Test):
The purpose of this test was to determine whether any gross abnormalities existed.in the piping, valves or pumps while operating the recirculation system at minimum flo With the recirculation pump running to provide minimum flow, vibration readings were required to be taken; however, the specific instrument required, or type of instrument, was not specified in the procedur The points o.n the reactor recirculation pumps and motors where vibration readi-ngs would be taken were inadequately defined, consequently
- 59 -
2.8.16 2.8.17 comparisons of current' vi
brati on readings with previous readings or acceptance criteria may be meaningless (Observation 2.8-4).
Procedure DTS 1600-1 11 Local Leak Rate Testing of Primary Containment lsolation Valves:
The inspection team witnessed a portion of this generic testing procedure which involved testing the containment purge valve, 3~1601-21. The test was a pne~matic pressure drop test which used the service air system to achieve test pressur Several unsuccessful attempts were made by the test engineer to pressur.i ze the system and eventually the test was aborte A discrepancy report was not issued to document the reason for the test failure (Observation 2~8-5).
Preparation for conduct of the hydro test included venting the system from only three poirit Since the sprinkler system consisted of 47 sprinkler heads mounted on 16-to 20-inch high risers, a considerable amount of air would have been trapped in the syste Azco procedure AZ-9RR, "Sprinkler System Testing, 11 stated that the system should be vente.d to eliminate trapped air while the system was being fille Steps were not taken duri.ng the hydro to ensure that each 1 i ne was vented prior to going up in pressur This practice could be a personnel. safety concern as well as yielding questionable test results (Deficiency 2.8-9).
- 60 -
2.9 Quality Assurance/QualitY Cont'ro1 Program Activities ln the course of examining the various outage modification and testing activi-ties at Dresden, specific aspects of the site QA/QC program we~e also reviewe.... Interviews were held with two QC inspectors, the QC Supervisor and two QA.specialists concerning their experience, training, knowledge Of procedures, and their responsibilities and activities on sit In general, the personnel interviewed appeared to be quaiified, know-ledgeable and conscientiou Items of concern noted by the inter-viewers were that QC personnel seldom wrote discrepancy reports involving installation deficiencies and.that selection of QA surveil-1 ance projects appeared to be haphazard and with i nsuffi Ci ent focus * *
on field work (Observation 2.9~1).
The SSOMI team rev1ewed 49 QA surveillances performed in 198 Of these, only 10 were hardware oriented and 5 related to turbine modification Of the remainder, 11 surveillances were shop inspec-tions, 13 were a review of documents only, and 10 were for area walkthrough Only two open items were identified; poor housekeep.ing and a discharged fire extinguishe It appeared that more ~mphasis needed to be placed on hardware and work activities since more than 2 findings in 49 surveill~nces would be expected based on the field observations.made by the SSOMI tea *
A review of QA surveillance thecklists also indicated~ lack of emphasis on field observation For example, the Work Activities-Mechanical Maintenance checklist had 14 items, none* of which addressed hardware or work observation (Observation 2.9-2).
DRs are written to document nonconforming materials, parts or component The SSOMI reviewed 96 DRs written in.1985 on Units 2 and Of those reviewed, 34 involved out of calibration or lost instru-ments and approximately 20 involved bypassed hold points or work accomplished out of sequenc Only five were written for probl~ms identified by QC during actual work observatio The only trending of DRs was performed quarterly by the Technical Staff Supervisor and was presented at management on-site review meetings, which were held 6 months or more after the end of the quarte In addition, the *
reports did not require spetific action or closeout, and few adverse trends had been identified during the last five quarterly reports which was not con~istent with SSOMI findings (Observation 2.9-3).
Based on the concerns identified regarding modified fire protection piping systems, the inspection team examined other related documenta-tion. A review of Azco records for work performed prior to July *15, 1986, revealed that for five systems which had been hydrotested, the 11final 11 inspection reports.had not yet been comp 1 eted and signed off by Azco Q In addition, the signoff on the work traveler for certifying that the system had been installed as required by the drawings had not been signed off for two system Documentation
- 61 -
2. *
should have existed' wh.ich' fodicated that systems had been installed and inspected to design requirements prior to testing (Ob~ervation
.2. 9-4).
On one system (drawing M-363) the CECo QA/QC hold point for the hydro performed June 3, 1986 had not been signed as of July 10, 198 The inspection team al so examined CECo QA audit and survei 11 ance *
activities related to Azco wh1ch included 2 audits (October 1985 and March 1986) and 15 survei 11 ances (November 1985 through May 1986).
The first audit identified a problem with weld inspection qualifica-tion which precipitated a long term "over inspection" of weldin However, the remaining findings, open items and surveillance activi-ties were pr.iniarily related to documentation and procedures, rather than to hardwar Surveillance activities related to field work we.re limited to witnessing two hydrostatic tests and minor welding control proce$ses (Observation 2.9~5).
- 62 -
2.10 Qualification and T 0rainin'g of Personnel In general, the qualification and training of personnel to c6nduct the work and perform the training was adequat However, a lack of training or discipline was apparent in the review and implementation of procedures, and in the advance planning of inspection activiti~ QC inspectors being used for electrical i.nspections were primarily.experienced in the mechanical inspection are ANSI 45.2.6 allows nondiscipline certification of inspectors assuming that they perform visual inspection work, e.g., point to point wiring check If the inspectors are required to make judgments to determine the adequacy of a technical procedure nr installation, then ~ppropriate training must be provided (Observation 2.10-1).
In at least one case, the QC inspector who inspected the splices in modificati~n M12-3-84-49 had done so without fi~st receiving the Raychem splice trainin.11 Cor-rective Actions Dresden staff were generally responsive.with regard to correcting apparent deficiencies identified by the inspection tea Frequent comments by utility staff on deficiencies were to the effect that the modification packages did not have final QA review or final sign off signatures, and that most items would have been caught during testing or in the final review process. lhe team considered it to be questionable whether a final review would have identified problems that many of the same personnel missed during the initial review and approval or during in-process work or inspection.1 NRC Region II I performed a 1 i mi ted inspect ion of Unit 2 modifi cations whith were similar to the*modificati6ns for which installation deficiencies had been discovered by the SSOMI on Unit Region III examined nine modifications in detail and two tn part. The results indicated that similar inst~llation deficiencies existed on eight modifications, two modifications were acceptable based on a cursory review (not a complete inspection) and one modification was accept-able based on a more complete revie Based on these findings by the Region In fo 11 owup team, it was apparent that many i nsta 11 at ion deficiencies were not being discovered by final* engineering, QA or QC reviews, or by the Dresden testing progra It was also noted throughout the inspection that insufficient emphasis was placed by.plant personnel on documentation of deficien-cies, identification of appropriate correttive action, generation of procedures to correct deficiencies to prevent their recurrence, or*
the performance of closeout inspections and tests to verify accept-ability. Without an adequate corrective act ion process, management may be unaware of generic problems and adverse trends in the quality of work, 2.1 On July 2, 1986, a meeting was held in the NRC Regfon Iii offices which.CECo summarized short term and long term improvements to.their modification program, not only for the Dresden facility but for all operating nuclear plants managed by CEC CECo's proposed corrective action was prompted by the extensive number of concerns reported by the SSOMI team and by CECO's own Interdisciplinary Review Team (IRT).
The IRt not only ~ub~tantiated most of the SSOMI findings but discovered additional areas of concer The basic conclusions of the IRT were the following:
2,11.2.1 Improper changes to design
- FCR process.difficult to follow
- FCR rout i ng/approva 1 varies from stat ion to stat ion
. 2.11.2.2 Inadequate procedures/instructions
- Level of detail not consistent between stations
- Lack of in~tallation.acceptance ~riteria
- Instructiohs n6t properly transmitted to worker
- Poor coordination of instructions on multi-departmental modifications
- 64 -
2.11.2.3 Improper installation *
Installation groups not involved in design phase
- Design packages not always timely
- Design p~ckages do n~t iontain all requirements
- Specifications typically prepared only for contractors 2.11.2.4 Inadequate QC/QA involvement
- No formalized in-process or final inspection program
- Personnel latk experience although qualified
- Emphasis on paperwork instead of field conditions 2.11.2.5 Inadequate testing
- Construction testing typically not done for electrical maintenance modifications
- Acceptance criteria not always defined
- Operating s*urvei 11 ances used in pl ace of modification tests 2.11.2.6 Miscellaneous
- Specific responsibilities not clearly defined
- Workers have not been taught the expectation of "meticulous attention to detail
2.1.CEC0 1s corrective actions, in response to findings identified during the SSOMI installation and test inspection, i.ncluded the following:
2.11.3.1 Short Term Actions Final field verifications Wiring diagram verification during jumper place~ent/lifted leads Control bf sequential ~lectrical modifications Define testing as three phases
- Construction test
- Modification test
- Equipment operability test Definition of 11modification
- Clarify FCR instruction Review Dresden modification group organization
- 65.;.
Implementation Method QP 3-51 revision Cond of OPS directive DPG Ltr 6-6-86 QP 3-51 revision QP 3-51 revision
.QP 3-2 revision Dresden management
2.11. Long Term Recommend~tit>ns' (Subject to Management Review/Approval}:
- Revise QP 3-51 to ensure.more consistent implementation
- Devel-0p standard QC inspection program with checklists
- Develop standard installation procedures to limit 11craft capabiliti1
- Enhance CECo QC training/qualification
- Develop standard design/installation specifications
- Computerize/cross reference drawings to FCR 1s, ECN 1s, et Improve accountability of installer via field verifications
- Provide training on detailed responsibilities
- Periodically evaluate modification program i~plementation
- Standardize SNED*design package format
- Improve control over commitment progress The short and long term co~rective actions listed above appear to be acceptable, assuming that implementation of the programmatic changes is timely and that the new program is followed by.Dresden personne *
TABLE I SUMMARY OF INSPECTION CONCERNS BY WORK PACKAGE Inadequate Inadequate Inadequate Inadequate Number Descri~tion Disci~line Work Package Test Procedure Installation Testing M12-3-81-12 125 VDC Main Bus/Reserve Electrical No
Bus Separation M12-3-83-16 Main Steam Line Rad Monitor Electrical Yes
M12-3-83-23 Alternate Power Source for Electri ca 1 No No
No Inboard Isolation Condenser Valves M12-3-83'-29 LPCI Valve Switch Replacement
.Electrical Yes Yes No Yes""*
M12-3-83-30 CS Valve Switch Replacement Electrical Yes Yes**
Yes
M12-3-83-36 IEB 79-01 Instrumentation I&C Yes No
Replacement M12-3-83-37 IEB 79-01 Instrumentation I&C Yes Yes
Yes Replacement M12-3-83-38 IEB 79-01 Instrumentation I&C Yes Yes No
Replacement M12-3-83-39 IEB 79-01 Instrumentation I&C Yes
No
Replacement M12-3-83-40 IEB 79-01 Instrumentation I&C Yes
Yes
Replacement M12-3-83-57 Main Steam Piping Lug Mechanical No
Yes
Ins ta llati on-67-
- TABLE I (Continued)
SUMMARY OF INSPECTION CONCERNS BY WORK PACKAGE
'
Inadequate Inadequate Inadequate Inadequate Number Descri~tion Disci~line Work Package Test Procedure Ins ta 11 at ion Testing M12-3-84-5 Blume Criteria Supports Mechanical Yes
No
M12-3-84-8 HGA Relay Replacement Electrical Yes Yes Yes Yes Ml2-3-84-9 CS Valve Anti-hammering Electrical Yes Yes Yes
Ml2-2-84-14 CCSW Pump Room Cooler Mechanical Yes Yes Yes Yes Piping Modification (Unit 2)
Ml2-3-84-14 CCSW Pump Room Cooler Mechanical Yes Yes Yes
r-Piping Modification (Unit 3)
M12-2-84-27 Replacement of Solenoid Mechanical Yes Yes Yes Yes Operated Valves 2-1601-50A (Unit 2)
M12-2-84-28 Replacement of Solenoid Mechanical Yes Yes Yes Yes Operated Valves 2-1601-50B (Unit 2)
Ml2-3-84-27 Replacement of Solenoid Mechanical Yes Yes Yes
Operated Valves 3-1601-50A (Unit 3)
Ml2-3-84-28 Replacement of Solenoid Mechanical Yes Yes Yes
Operated Valves 3-1601-50B (Unit 3)
Ml2-3-84-32 Security Diesel Generator Mechanical Yes Yes Yes
Ml2-3-84-38 IEB 79-01 Seismic Restraints I&C Yes
Yes
-68-
- .
TABLE I (Continued)
..
SUMMARY OF INSPECTION CONCERNS BY WORK PACKAGE Inadequate Inadequate Inadequate Inadequate Number Descri~tion Disci~line Work Package Test Procedure Installation Testing Ml2-3-84-42 HPCI Pipe Whip Restraints Mechanical Yes Yes Yes Yes M12-3-84-49 West LPCI Room Cooler Motor Electrical Yes
Yes
Replacement Ml2-3-84-50 East LPCI Room Cooler Motor Electrical Yes
Yes
Replacement M12-3-84-78 Fire Protection System Mechanical Yes No Yes
(Unit 3)
Ml2-3-84-103 MOV Motor Replacement Electrical No Yes
Yes Ml2-3-84-104 MOV Motor Replacement Electrical No Yes No Yes Ml2-2-84-107 Fire Protection System Mechanical Yes No Yes Yes (Unit 2)
Ml2-3-84-118 Drywell Cooler Trip Bypass Electrical
No**
No**
"M12-3-85-17 Removal and Replacement of Mechanical Yes
Yes
Interferences for Recircula-tion Pipe Replacement Ml2-3-85-26 RPR Electrical Interferences Electrical Yes Yes Yes
Ml2-2/3-85-34 Reactor Building Hose Mechanical Yes
Yes
Penetration-69-
TABLE I (Continued)
t, SUMMARY OF INSPECTION CONCERNS BY WORK PACKAGE Inadequate Inadequate Inadequate Inadequate Number Descri~tion Disci~line Work Package Test Procedure Installation Testing M12-3-85-50 Installation of Diesel Mechanical Yes
Yes
Generator Cooling Water Pump Suction Pressure Gage Ml2-3-85-54 Solenoid Valve EQ Conduit Seal Electrical No
No
WR 29776 Greasing Valve Bonnet Gaskets Mechanical Yes
WR 39288 Miscellaneous Work on Valve Mechanical Yes
Yes
3-1601-60 WR 39293 Miscellaneous Work on Valve Mechanical Yes
Yes
3-1601-22 WR 39294 Miscellaneous Work on Valve Mechanical Yes
Yes
3-1601-56 WR 39291 Miscellaneous Work on Valve Mechanical Yes Yes Yes
3-1601-20A WR 39292 Miscellaneous Work on Valve Mechanical Yes Yes Yes
3-1601-20B WR 31299 Greasing Containment Hatch Mechanical Yes
Seals-70-
TABLE I (Continued)
SUMMARY OF INSPECTION CONCERNS BY WORK PACKAGE Number WR 46639 NOTES:
Description Replace Packing Sleeves in ECCSW Pump 3A
- - Not reviewed or witnessed Inadequate Inadequate Discipline Work Package Test Procedure Mechanical Yes
- - Functional testing performed by or incorporated into existing surveillance test procedure..
Inadequate Inadequate Installation Testing
\\.f'-
- I TABLE II DISCREPANCIES IN LISTING OF PRIMARY CONTAINMENT ISOLATION VALVES Isolation Number of Valves Number of Valves Va 1 ve Funtti o GrouE Listed in FSAR#
Listed in T.S.*
Isolation condenser
None
vent to main steam Drywel 1 air sampling
10
Cleanup deminerali:Zer
3
3
Drywell/torus inert
Function not listed
Torus to condenser
Function not listed
drain Drywell pneumatic
Function not listed
supply HPCI torus suGtion
Function not listed
Notes:
- FSAR Table 7.. 7. 2: 1, Primary Containment isolation System Valve Groups
- Technical Specification Table 3. 7.1, Primary Containment Isolation
- 72 -
- BACKGROUND 3.1 Meetings and Contacts The foll owing 11$ t identifies 1 i censee representatives and NRC personne 1 in attendance at the exit meeting h.el d July 16, 1986, and key indi vi dua 1 s contacted during the inspectio. Exit Meeting CECo:
J. Achterberg R. Flessner E. Armstrong G. Frankovitch
.D. Booth M. Jeisy D. Brown N. Ka Ti Vi anaki s 0. Farrar 0. Scott NRC ~nd Con§ultants:
R.. Compton R. Jacobstein A. Ounl ap J. Konkl in M. Good R; Lloyd 3. CECo Coordinators and Contacts J. Achterberg J. Doyle E. Armstrong R. Dyer J. Brunner R. Flessner T. Ciesla G. Frankovich R. Doebler s. Jerz
- 73 - D. v.
L. Sebby G. Smi.th R. Stols M. Strait**
J. Wojanarowski J. Wujciga L McGregor S. _Stein M. Sulouff Knudtson 0. Scott O'Neil G. Smith Rhee R. Stols Ringo M..Strait
. Rockovski
I
- '
t,i...,
- I 3.2 _Design and Vendor Insp~ct1oh Reports 3. Design Report:
Safety Systems Outage Modifications Inspection (Design) 50-249/86009 dated May 29, 198. Vendor Reports:
Vendor ComEonent/Service ReEort, N Date Rosemont pressure transmitters 99900271/8501 04/19/85 Nutherm In power supplies 99900779/8501 07/01/85 Control Products Agastat relays 99901045/8601 08/21/86 Cor Gonax Cor penetrations 99900323/8601
.07/28/86 Westinghouse Cor motors 99900294/8604 05/30/86 Limitorque Co.r valve operators 99900100/8601 02/28/86 Union Pump ECCS pumps 99900248/8601 06/13/86 Amerace relay /8601
- Report to be issued presently.
- 74 -
..
3.3 References The following documents are referred to directly in the repor Number OAP 2..-7 OAP 2-8 OAP S-1 OAP 7-4 OAP 9-1
.OAP 9-2 OAP 12-12 OAP 13.:.12 OAP 15-1 DIS 1400-5 DIS 1500-5 DIS 1600-3 DMP 200-30 DOS 1600-1 DOS 1600-18 DOS 6600-3 DOS 6600-4 DOS 6900-6 DOS 6900-7 DTS 020-3 DTS 1600-1
.ECTP-1 QP 3-2 QP 3-51 QP 6--:52 K*2202 SP-86-1.,.6 SP-86-1-8 SP-86-1-9 SP-86-1-10 SP-86-5-92 Title Control bf Drawings to be Reproduced and Logged to Modifications Oeviation Reporting Plant Modification Program Control of Jumpers of Lifted leads Station Procedures Procedure Preparation Installation and Control of Temporary Shielding Control -0f Safeguatds Information Work Requests CS System Logic Test LPCI/CCSW System logic Test Torus to Reactor Building Trip Unit Calibration Units 2/3 6 11 Safety Valve Overhaul and Test Procedure Quarterly Valve Tim.ing Cold Shutdown Valve Testing
. Bus Undervoltage ahd ECCS Intergrated Funttion Test for Unit 21~ Di.esel Generator (Unit-3 Test Only)
Bus Undervoltab~ and ECCS Intergrated Function Test for Unit 3 Diesel Generator 125 Volt Stat ion. Battery Capacity +est 125 Volt DC Ground Detection-Unit 3 Temporary Installation of lead Blankets local.Leak Rate Testing of Pr.imary Containment Isolation Valves *
Elettrical Motor Installation Test Design Change Control Design Control for Operations - P1ant Modifications Procedure for Station Construction Department Design Document Control
Sargent and Lundy Specification Core Spray Preoperation Test low Pressure Coolant Injection Preoperational Test Reactor Recirculation Syste.m Preoperational Te.st Reactor Water CleanupPreoperational Test LPCI Flow Rate Test with Two Minimum Flow Valves Open
... 75 -
"
- .
'"'
3:4 Documents Reviewed
- ,
The types of documents listed below were reviewed by the SSOMI team to the extent necessary to satisfy inspection objective Reference to specific procedures and drawings are contained within the body of the repor.
Final Safety.Analysis Report Tethnical Specifications Quality Assurance Manual Quality.Equipment List Administrative Procedures Work Requests Modification Procedures Final Design Packages Construction Packages 10. Operating Instructions 1 Operating Procedures 1 Installation Procedures 1 Speci~l Te~t Procedures 1 Surveill~nce Test Procedures 1 Calibration Procedures 1 Modification Drawings 1 As-Built Drawings 1 Welding Proc~dures 19.. Personnel Qualification Records i
2 Material Traceability Records 2 Surveillances 2 Audits
- 76 -
- ~*
,I... ~
_. G°LOSSARY A-E architect engineer ANSI Ameritan National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AZCO Azco-Hennes, Inc..
CAL Confirmatory Action Letter CB&I Chicago Bridge and Iron Company CCSW containment cooling service water CE Commonwealth.Electric Company CECo Commonwealth Edison Company CS core spray OAP Dresden Administrative Procedu~e OCR design change r~quest DIS Dresden Instrumentation Surveillance DMP Dresden Maintenance.Procedure DOP Dresden Operating Procedure DOS Dresden Operations Surveillance DOSR Dresden onsite review DR deficiency report DTS Dresden Technical Surveillance ECCS
- emergency core.cooling system ECN engineeting change notice ECTP Electrical Construction Test Procedure EM Station Electrical Maintenance Department EQ environmental qualification FCR fi~ld change r~quest FSAR Final Safety Analysis Report GPM gallons per minute GSA General Services Adini ni st rat ion HPCI high p~essure coolant injection IEB NRC Office of Inspection and Enforcement Bulletin IEEE Institute for Electrical and Electronic Engineers I~R Interference Removal and Replacement IRT CECo Interdisciplinary Review Team ISA Instrumentation Society.of America LPCI low pressure coolant injection LLRT 1oca1 leak rate testing LOCA loss of coolant accident MM Station Me~hanical Maintenance Department MMP Maintenance/Modification Procedure NCR nonconf ormance report NFPA National Fire Protection Association NPT Nati ona 1 Pi p*e Thread OAD CECo Operational Analysis Department P&ID piping and instrument drawing PLC Professional Loss Control, Incorporated psi pounds per square inch psig pounds per square, gauge PWHP pipe whip QA quality as~urance QAM Quality Assurance Manual QC quality contro 1
- 77 -
QP RPR RRS RWCU SAE S&L SNED SSC SSOMI TCR
. TJM TS WR G'C6s<SARY :.(Continued)
quality procedure recirculation pipe replacement reqOired response spectra reactor water cleanup Society of Automotive Engineers Sargentand Lundy Engineers CECo Station Nuclear Engineering Department CECo Sub Station Construction Department Safety Systems Outage Modifications Inspection Station Temporary Proc.edure Change Request Total Job Manual technical Specifications work request - 78 -