IR 05000249/1990016
| ML17202U756 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/18/1990 |
| From: | Phillips M, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202U755 | List: |
| References | |
| 50-249-90-16, NUDOCS 9007240033 | |
| Download: ML17202U756 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REG ION -II I Report N /90016(DRS)
Docket N License N DPR-25 Licensee:
Commonwt:a 1th Edi son Company _
Opus West III 1400 Opus Place Downers Grove, IL 60515 Facility Name:
Dresden Nuclear Power Station - Unit 3 Inspection At:
Morris, IL 60450 Inspection Conducted:
June 4-8, 11, and 13-14, 1990 lnspector~At~
Isa T. Yfr
~.pproyed By~-
.
- M:P:Pllips, Chief Operational Programs Section Inspection Summary 7 /!R/'lp Date 7/;~l"P Date Ins ection on June 4-8, 11, and 13-14, 1990 (Re ort No. 50-249/90016(DRS))
Areas Inspecte : Routine, announce inspection o icensee corrective actions initiated for the issues identified in its self-ii1itiated. Safety System Functional lnspt=ctiun (SSFI) and Safety System Functional Testing (SSFT) of the Emergency Di est: 1 Generator (EOG) syste The inspection was based on NRC Inspection Procedure 9272 Results:
Li censei: effort in conducting the SSFI and SSFT for the EOG system was good.* Based on this review and evaluation, the inspector determined the following:
- The licensee's initiatives to conduct the SSFI and the SSFT, and the positive actions taken by both the site and corporate staffs to promptly correct the deficiencies identified during this inspection were considered to be strengths within the CECo organization. Specifically: The EOG SSFI and SSFT scope was comprehensiv Evaluations and testing were conducted in a professional manne Many findings and -
subsequent hardware fixes were considered to be real diesel availability improvements..
- Prior to the completion of the inspection, the station promptly established ~lans and schedules to close out the remaining 31 EOG open items before the end of calendar year 199 Swift and decisive.station acticns to.improve procedural requirements*
were implemente For example, work orders were issued to conduct tests and perform repair * The DG3 air receiver check valve, the new DG2 receiver relief valve, and the DG3 air box oil filled pressure gauge were verified by the inspector to be installed in accordance with design requirement.
The lic~nsee's QA group did not followu~ its SSFI findings in as formal a manner as QA audit finding This difference created some interface difficulties between the QA group and the statio The difficulties related to the required depth* of engineeiing evaluations used to support iter.1 closure; and closure of.a11 item prior to corrective action implementatio In the later case 0-rings and element replacement within the jatket water thermostatic control valves was postponed subsequ~nt to th~ QA closeout of the issu The lack of formal finding control also resulted in so~e disagreement between QA and the station staff that was not brought to upper management's attention for resolution, such as in the case of technical and suitability evaluations required for replacing the viscous type lube oil vibration damper with a gear type dampe.
Station control in some cases was lax~ This is*being categorized as an Unresolved Ite The following specific deficiencies observed during the illspection could be attributed to personnel inattention: A Work Request was written to change a crankcase pressure gauge; instead, an air pressure gauge was installed ~t the air bo b:
An inadequate diesel start air system pressure* regulator adjustment procedure result~d in site personnel mishandling the equipment and making the diesel inoperabl Although a test of the as-installed diesel start air receiver relief valves did not meet acceptance criteria, the personnel performing the test signed it off as acceptable. *
- The licensee postponed the following scheduled maintenance activities without formal evaluation and justification: Changeout of 0-rings and elements within the jacket water thermostatic control valve Testing of diestl start air receiver relief valve ReplC1cemt!nt of the diesel start air system pressure regulator.
DETAILS Persons Contacted Commom"ea 1th Edi son Company (CE Co)
- R. Falbo, Regulatory Assurance Assistant
- R. Whalen, Assistant Technical Staff Supervisor
- M. Strait, Technical Staff Supervisor
- E. Steckhan, Senior QA Engineer
- K. Kociuba, NQP Superintendent
- S. K. Mehta, QA Engineer
- R. Geier, Master Mechanic
- R. Tate, Technical Staff Group Leader
- E. R. Zebas, Project Manager
- D. Van Petl, Assistant Stiperintendent - Maintenance
- E. D. Eenigenburg, Station Manager
- R. L. Williams, Regulatory Assurance Staff
~*J. Pietryga, Operations Engineer
- R. Stobert, OpercttiOliS E.ngineer K. E. *Yates, ONSG Adniinistrator J: Harrington, QA Inspector B. Vithl, Design Supervisor L. F. Gerner, Technical Superintendent E. R. Netzel, NQP Spt:cialist K. W. Peterman, Regulatory Assurance Supervisor R. Ralph, Regulatory ~\\ssurance Group Leader R. D. Speroff, Safety System Group Leader
.K. W. Uhlir, Principal Engine~r J. Rtvera, Technical Staff J. Brunner~ Engi~eering/TS Assessment Administrator W. Groszko, Design Support Group Engineer J. Silady, Nuclear Licensing Administrator U.S. Nuclear Regulatory Commission (U.S. NRC)
- D. E. Hills, Resident Inspector
- K. J. Knight; Intern
- R. Ewing, Intern
- Iridicates those attending the exit meeting at the site on June* 14, 199 Other licensee personnel were contacted as a matter of routine during the i11spectio.
Background..
The licensee 1 s QA Department conducted two detailed engi1H:~ring oriented Safety System Functional Inspections (SSFis):
Unit 3 Emergency Diesel Generator (EOG), conducted in 1987, with the final report issued on August 12, 198 **
Unit 2 High Pressure Coolant Injection, conducted in 1988~ with the final report issued on October 31,* 198 Subsequent to the completion of the above, the licensee re~ognized that their SSFis were mostly modification and maintenance overviews based on an assumption* that the original design and installation were adequate and acceptabl In view of the fact that SSFis performed by the NRC and other utilities identified shortcomings within the plant's ori"ginal design and installatio11 requirements, the_ licensee decided to supplement its EOG SSFI with a Safety System Functional Testing (SSFT) progra The purpose of this program was not to specifically address the original design issue, but to verify that modifications performed prior to its modification program upgrade (implemerited in 1987) were adequat This was done by demo~strating that the modifications had not degraded the functional
. requirements of the EO The licensee initiated the following steps in establishing and completing its SSFT for the EOG:
0
EOG functional requirements which had not been verified by normal
- operation or plant testing were identified in an Impell study dated May 28, 198 Various testing procedures were written for OG3 and OG2/3 and approved between April and June 198 Except for testing done for the diesel to run without cooling water under certain conditions, all EOG design functions that had not been verified within th~ routine surveil.lance and test program were included in th~ test procedur~s.
SSFTs for the EDGs wert:: completecl in June 1988, ctnd the results were presented to NRC Region III management on July 18, 198 The purpose of ihis inspecti6n was to evaluate the effectiveness of the corrective actions taken in response to the issues identified during the
$SFI and SSF The sysiem selected for this inspection was the ~SFI performed for the Unit 3 EO The NRC review of the SSFI report and the
.supporting SSFT reports of the Unit 3 EOG system concluded that the licensee's SSFI and SSFT scope was extensive; and they were conducted in a professional manne.
Review of Sample Selection The Unit 3 EOG SSFI identified twelve Category A issues which were considered to have effects on the functionability of the system, ten Category B issues which might not have direct effect on the functionability of the system but required corrective action nonetheless, and one open item that required followup revie The 23 issues were further broken down into 459 specific items for evaluation*and followup; among which, 428 items were closed by QA, and 31 items remained open at the ti~e of this inspectio The inspector selected the following items for his evaluation of the licensee's corrective actions:.
Closed Items No. A2. a OG governor oil was not periodically change *
No. A No. Al No. B2. a No. 8 DG jacket water *codling water system thermostatic control valv~ r~ceived no periodic maintenanc Questior.able practice to declare the DG operable immediately following the suryeillance te~t. even though failure of the turbocharger might occur if the DG Started in the 15 mi~ute to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> timeframe following shutdown from hot loaded condition Unauthorized installation of tubing connecting turbocharger exhaust to the crankcase drai Unauthorized in~tallation of crankcase pressure gauge and inoperable air box pressure gaug Nos. B6. d, e, i:illd f Modification deficiencies involving safety evaluations, reference to design documents, and post modification testin Nu. Bl Open Item No. A12 Questionable modification measures taken to replace the DG cooling water pump Lack of s1z1ng documentation for the thermal overload relays (TORs) for DG fuel oil transfer pump, vent fan, and circulating water pump motor Items Remaining Open Nu.. B No. Al No. 81 No. A3 No. Bl Unauthorized piping connection was found at DG2 cooling water hedt exchanger hea Air start receiv~r check valve arrangement did nbt
. satisfy design specification requirement Lack of modificatior1 control for replacing DG cooling water heat exchanger copper-nickel tubes with stainless steel tubes.*
DG relief valves were not inspected, cycled, or tested periodicall Lack of modification control for replacing DG3 lube oil viscous type vibration damper wi.th a gear type dampe.
Evaluation of Items (A2.a)
The Unit 3 DG governor oil was changed on April* 29, 1989, based on procedure DEP 6600-1, "DG Governor Oil Change, Flush and Compensation Adjustment, Revision 0, dated October 198 The CECo action was considered to be adequat (A2.b)
(All.b)
(82.a)
(B2.b)
(BG.d,e, and f)
Procedure DMP 600-9, "DG Five Year/8000-Hour Inspection,"
Revision 6, dated January 1989, required changeout of 0-rings and elements within the jacket water thermostatic control valve Records showed that DG2 was scheduled for these activities in February 198 Actions \\'1ere postponed to September 1990 without written justification. The licensee stated that their inspection of the sa~e items for DG3 during the May 1988 4nit 3 outage revealed no problems; therefore, there was no cause for DG2 reliability concern The inspector expressed concerns relative to whether or not visual inspection could be conducted to justify delay of required material replacement, and maintenance activities could be postponed without a written ev~luatio The inspector reviewed t~e Sargent and Lundy Engineers (.S&L)
report, "Evaluation of Emergency Diesel Generator Safety System Functional Inspection Con~erns, Dresden Nuclear Power Station -
Unit 3," dated Nuvember 23, 198 The specific operability assessmt:nt relative to possiblt::: failure of the turbocharger was included in the evaluatio The i11spector had no questions with the S&L assessmen The unauthorized ~odification was to reduce crankcase pressur The inspector observed thut the piping connection was removed..
The cause of high cra11kcase pressure was determined to be ~ue to plugging of the diesel exhaust screens by debris. A procedure, DMP 6600-4, "DG Annual and Biennial Mechanical Inspection,".
Revision 6, dated M~y 1988, included the diesel exhaust screen inspettio Records show~d that the inspection for DG 3 was *
performed on January 5, 1990; The CECo action was considered to be adt:quat The inspector observed that the crankcase pressure gauge had been remove The present program for determining positive crankcase p~essure was via periodic testing of the detector utilizing procedure.DIS 6600-4, "DG Crankcase Pressure Switch Calibration Check," Revision. 1, dated July 198 An oil filled air pressure gauge was installed at the DG3 air bo The gauge was in good physical condition, and record verification showed that the installed gauge was of the correct make and type as stated in the as-built databas However, Work Request (WR)
No. 077085 t~ correct the finding of an unathorized installation uf crankcase pressure gauge and inoperable air box pr~ssure gauge mentioned only the crankcase pr~ssure gauge. The installa-tion and QC inspection of.a new air pressure gauge was not addressed by the WR, although the work had been performe Workin~ outside the bounds of the work request is an Unresolved Item (249/90016-0lA).
The licensee issued Discrepancy Record report (DR) No.90-082 on June 11, 1990, to correct this proble These items concerned past Dresden modification process deficiencies.. The inspector reviewed the S&L operability assessment for Modification No. M12-3-72-16 regarding the
(BlO.b)
(Al2)
- .installation of vent valves on the DG closed cooling water*
pump S&L's assessment, dated November 17 through 23, 1987, addressed oll twelve concerns identified in the SSF The inspector had no *questions on the S&L evaluatio The inspector reviewed the S&L operability assessment for Modification No. M12-3-76-55 regarding the replacement of the DG cooling water pump The S&L assessment, dated November 16 through 23, 1989, addressed all fourteen concerns identified in the SSF The only S&L recommended action was to update the FSAR to reflect the installation of submersible cooling water pumps (Concern No. 7).
The inspector reviewed the up-to-date FSAR, Section 8, and observed that the corr:.ection had been mad There was a lack of documentation for the sizing of *the thermal overload relays (TORs) installed at specific motor ctintroller A generic concern was raised as to whether or not the TORs insto.lled for all the safety and*important to safety continuous duty motors were sized properly, and were designed in a uniform manne S&L evaluated the. three as-found TORs in Calculation No.* 8123-99-19-1, dated July 15, 1988, and concluded these TORs were acceptably size The S&L calculation was not r~viewed by CECo's QA group iri detail until the NRC inspection, and S&L revised its calculation on June 6, 1990, to provide additional clarification on design assumptions and the final justification The inspector reviewed the S&L calculatibn and had no adverse comment At present, the licensee's electrical/l&C group is in the final
. process of developing a standard TOR selection criteria,
. Exhibit H of procedure ENC-QE-59, for the continuous duty motors~ The criteria will be used by all the CECo contracted A-E The evaluation for all the continuous duty motors TORs installed in Dresderi is sche.duled for completion by October 31, 199 (B2.c)
The unauthorized piping connection found at the DG2 cooling wat~~ heat exchanger head was used to aid in draining the system when require The S&L evaluation found the as-built condition to be acceptable.* The.inspector had no adverse comment (Al)
Additional air start system receiver check valves were installed at DG3 and DG2/ The inspector observed the new check valve at DG3 and determined.that it was installed in accordance with the requirements of S&L drawing M-344, Sheet 4, Revision A, dated April 21, 198 The additional check valve had not yet been installed at DG2 of the completion of this inspectio (BlO.a)
The replacement of DG copper-nickel coo1ing water heat exchang~r tubes with stainless steel tubes had not yet been verified for material and fluid compatibility and proper installation as of the completion of this inspectio *
'
(A3)
The S&L eva.luatio11 concluded tha.t the DG lube oil filter, turboch~rger oil filter, and air start system receiver relief valves should be periodically teste As of the completion of this inspection, no t~st procedures had been written for the lube oil filter and turbocharger oil filter r~lief valve The air receiver relief valve test procedure was included in procedure DMP-6600-9, 11 DG Five Year/8000-Hour Inspection,"
Revision 0, dated January 198 Records showed that DG2 was scheduled for the test in February 198 However, the test was postponed to September 1990 by a plant management decision to imp~ove DG availabilit The inspector expressed concern relative to the postponement of the scheduled _test without any formal evaluatio (810.c)
Records showed that the QA group had commented on the station response on June 15, 1989. **They noted that-the replacement of the DG3 viscous type lube oil vibration damper with a gear type damper required technical a.nd suitability evaluations to ensure co~pliance with. the original design and material qualificatio The station responded to the QA comment on June 8, 1990, and concurred with the QA position that these evaluations were.
required, although they had not been comp*leted as of the end of ch i s i n s p e ct i on : NRC Walkdown Inspection During observation of the licensee's corrective actions associ~ted with DG2 and DG3, the inspector a.lso observed both DGs to be in excellent physical cbndition; there was an absence of oil leaks, loose tubing, or loo~e connection DG2 was painted in bright colors for easy system identification; for example, green for start air, orange for lube oil, yt::llow for fuel uil, and blue for tooling water.* DG3 was in the process of being painted the same as DG During the walkdown, the inspector identified the following concerns: Air* Pressure Regulator (APR)
(1)
APR Overpressure The-DG3 APR was observed showing 205 psi Procedure DOP 6600-r *
required the pressure setting to be within the 175 to 190 psig rang During a followup discussion~ the licensee stated that on JunE: 4, 1990 (the first day of the NRC inspection), the site staff performed a DG system walkdown, and found the DG2 APR reading to be 210 psi In an attempt to lower the air system pressure, the APR developed severe leaking, and the OG2 was declared inoperable at 7:34 p.m., and placing it in a seven day LCO. *The DG2/3 was started successfully in accoidance with Technical Specification requirement Subsequently, the leaking APR was replaceci, DG2 was tested and declared operable at 2:20 a..m. on June 5, 199 *
The leaking APR, was examined by the inspector and determined to be in proper working condition In discussions with the
licensee's staff, it was determined that the APR malfunction was caused by human erro The mechanics had failed to bleed down the APR back pressure prior to adjusting downward the APR pressure readin The use of a procedure to adjust the regulator that did not contain provision for bleeding off the batk pressure i~ an Unresolved Item (249/90016-018).
A procedure change was initiated -0n June 8, 1990, to incorporate APR
adjustment steps into procedures DOP 6600-01, and DOP 6600-04 for DG2, 3, and 2/3 for preparation of standby operatio A training memorandum, "Adjustment of DG Air Start APR," was forwarded to all of the licensed operators and high voltage operators. The DG3 APR was adjusted down to an acceptable pressure level on June 7, 199 (2)
APR Maintenance Site procedure DMP 6600-3, "DG Six Month Inspection/Mechnical Maintenance Department", Revision 2, dated January.22, 1988, required all APRs to be replaced every six month In reviewing the records the inspector determined that the APR for DG2 had not been replac~d since August 22, 1989, and therefore was overdue by more than three month This replacement had been deferred by plant management in an effort to not take DG2 out of service and enter an LC The inspector expressed concern relative to site management's change of s~heduled maintenance activities without any formal evaluatio (3)
Inter-Office Co~munication The insp~ctor noted that the above discussed AP~ problems were similar to those that were documented in the NRC SSFI conducted at the LaSall~ Station in July and August 198 That report had been issued in November 1989 (see Inspection Reports No. 50-373/89018; 50-374/89018).
In discussions with the site staff, the inspector was informed that Dresden had not received the NRC SSFI repo~t sent out t6 all the CECo plants by its Nuclear Licensing Departmen It ~as pre~umed that the report was lost in the mail distribution proces CECo stated that they would spot check distribution of other NRC inspection reports beginning in December 1989 to-ensure that they were properly distributed to the station personne Air Pressure Relief Valve.(APRV)
(1)
Paint on APRVs Two of the APRVs were found covered with pain The inspector expressed a concern that the paint could interfere with proper actuation of the relief mechanism's acti6n and movemen The licensee concurred with the inspector's concern._ The inspector followed up on the licensee's actions associated with WR No. D93416, wh.ich vfos issued un June 6, 1990, to replace one of the painted APRVs with a ne~ APR Prior to installation, the new APRV was to be tested with an acceptable setpoint pressure band of 274 to 277
psig (setpoint at 275 psig).
The inspector not~d that the test pressure range differed from site procedure DMP 6600~9, Revision 6, acceptance criteria of 270 to 275 psi The licensee investtgated this discrepancy, and determined that 274 to 277 psig was based on a generic site procedure DMP-0040-09, and was correct. A procedure change was initiated for DMP 6600-9 on-June 8, 199 (2)
Testing of Painted APRVs The licensee issued WRs No. D93425 and No. D93452 on June 7 and 8, 1990, to test, clean, and rebuild the removed DG2 APRV The APRVs failed the as-found test in two areas:
0 The first valve started weeping at 175 psig. This was contrary to the requirement thdt the valve should be*.
completely shut at 260 psig and belo Both valves fully lifted at 280 psig, which was above the upper acceptable range of 277 psi Despite tht:: above apparent deviations, both tests were signed*
off by the responsible CECo staff as acceptable on June 8, 199 Discussions with CECo mdnagement determined that they concurred with the irispector's concer Acceptarice of the test results when they were outside the bounds of the acceptance criteria is an Unres6lved Item (249/90016-lC).
- c. * Air Motor System Check Valve The.air motor piping and tubing system configuration was.verified by the inspector against S&L drawing M-173, Revision A No deficiencies were identifie.
Unresolved Items Unresolved items ~re matters about which more information is required in
- order to ascertain whether they are acceptable items, violations, or deviation Unresolved items disclosed during this inspection are discussed in Paragraphs 4, 5.a.(1), and 5.b.(2) of this repor.
Exit Interview The Region III inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 14, 1990 at the Dresden Nuclear Power Statio The inspector summarized the purpose, scope, and findings of the inspectio The licensee representatives acknowledg~d this informatio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspectio The licensee representatives did not identify any such documents/processes as proprietar