ML17174A744
| ML17174A744 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/05/1991 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17174A745 | List: |
| References | |
| 50-237-91-10, 50-249-91-09, 50-249-91-9, NUDOCS 9106120057 | |
| Download: ML17174A744 (11) | |
See also: IR 05000237/1991010
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Repo~t Nos.
50-237/91-0lO(DRP); 50-249/91009(DRP)
Docket Nos.
50-237; 50-249
License Nos.
Licensee:
Commonwea 1th Edi son Company
Opus West II I
1400 Opus Place
- Downers Grove, IL
60515
Facility Naine:
Dresden Nuclear Power Station, Units 2 and 3
Inspection At:
Dresden Site, Morris, IL
Inspection Conducted: April 2 through May 16, 1991
Inspectors:
D.
Hills
Approved
M.
Peck
R. Lerch
S. Burgess
R. Zuffa, Site Resident Engineer
Illinois Department of Nuclear Safety
By~~ef
Projects Section 18
Inspection Summary
Date 1
'
Ins ection from A ril 2 throu
(Re ort Nos. 50-237/91010(DRP);
50-249 91009 DRP
Areas Inspected: Routine unannounced safety inspection by the resident
inspectors, regional inspectors and an Illinois Department of Nuclear Safety
inspector of licensee action on previously identified items; licensee event
. reports; operational safety;- monthly maintenance; monthly surveillance;
engirieered*safety features walkdown; training effectiveness; events; safety
assessment and quality verification; and systematic evaluation program items
and report review.
Results:* Two non-cited violations were identified.
One involved the use of
non- licensed operators to perform direct reactivity_ changes (parag.raph 4.e)
and the other involved the control of design input assumptions to the diesel
generator service water calculation (pa~agraph 2).
Two unresolved items w~re
identified, one involved the calibration requirements of primary and secondary
containment tsolation damper fail-safe pressure switches (paragraph 7), the
other dealt with reactor. shroud head bolts not fully tightened (paragraph 9) .
9106120057 910605
ADOCK 05000010
Q
Plant Operations
This 'area. remains under close scrutiny due ~o the negative trend in operationa 1
practices as delineated in recent inspection reports and as illustrated by
the utilization of non-licensed operators to perform direct reactivity
changes. However, identification of the Unit 2 power/flo~ anomaly and the
quick reaction during the reactor recirculation pump run-up/over power
event indicated good operator response to off normal conditions.
Maintenance/Surveillance
This area remained on a declining trend in regard to wor~ practices. This was
exhibited by the failur~*to properly install -the Unit 2 reactor steam separator
assembly.
Radiological Protection
~erformanc~ in this area remained good.
No problem~ were noted during the
inspection.
This SALP functional area was not addressed in this inspection period.*
Security
Performance in this area remained good.
No problems were noted during the
inspection.
Safety Assessment and Quality Verification
Performance in this area continued to improve.
This was evident by the
coo~dination and review of NRC concerns identified at the Quad Cities
facility.
Engineering and Technical Support *
This area remains under close scrutiny due to the mixed trend delineated in past
- reports. This was evident by the utilization of non-conservative assumptions
utilized in the diesel .generator cooling water calculations *
2
.
.
1.
DETAILS
Persons Contacted
Commonwealth Edison Company
- E. Eenigenburg, Station Manager_
-*L. Gerner, Technical Superintendent
J. Kotowski, .Production Superintendent
E. Mantel, Setvices Director
- D~ Van Pelt, Assistant Superintendent - Maintenance
J. Achterberg, Assistant Superintendent - Work Planning
- G. Smith, Assistant Superintendent-Operations *
- K. Peterman, Regulatory Assurance Supervisor
M. Korchynsky, Operating Engineer
B. Zank, Operating Engineer
J. Williams, Operating Engineer
R. Stobert, Operating Engineer
T. Mohr, Operating Engineer
M*. Strait, Technical Staff Supervisor
L.* Johnson, Q.C. Supefvisor
J. Mayer, Station Security Administrator
D. Morey, Chemistry Services Supervisor
D. Saccomando, Health Physics Services Supervisor
K. Kociuba, Qua 1 ity Assurance Superintendent
- D. Lowenstein, Regulatory Assurance Analyst
.
- R. Ra.dtke, Compliance Engineering, NuClear Licensing
- R. Wahlen, Technical Staff
- R. Janecek, Sr. Participant - Offsite Review
- K. Yaks, ONS Administrator
- B. Viehl, Nuclear Enginee~ing Department, Supervisor
- Denotes those attending the exit interview conducted on May 16, 1991.
The inspectors also talked with and interviewed several additional
- licensee employees, including members of the technical and engineering
staffs, reactor and auxiliary operators, shift engineers and foremen,
electrical, mechanical and instrument maintenance personnel, and contract
security personrie 1.
2.
Previously Identified Inspection Items (92701 and 92702)
(Closed) Unresolved Item (50-237/91003-02):
The licensee ha~ resporid~d
to NRC concerns regarding the appropriateness of design input
-
parameters/assumptions uti*lized in the Stone and Webster Diesel Generator
Cooling Water (DGCW) Requirements Calculation (18662-M(CI)-10 .
- .
Re~ision 0).
Examples of assumption discrepancies included:
1100 gpm design Diesel Generator (D/G) water jacket side flow was
assumed.
This input was non-conservative and inconsistent with the
1080 gpm value required by the vendor manual reference.
3
The calculation assumed 2500 Kw for the continuous D/G output rating
and *2750 Kw for the two hour overload condition. This input was
.
non-conservative and inconsistent with the Final Safety Analysis
Report (FSAR) ratings of 2600 Kw for continiJousoutput and 2860 Kw
for the ove~load condition.
The assumed design cooling manifold temperature alarm location used
. in the calculation was not consistent with plant drawing M517.
The
calculation incorrectly positioned the alarm on the heat exchanger
inlet while the drawing indicated the alarm te~perature switch to be
on the outlet.
The calculation was revised following NRC identification of the .
discrepancies.
The revised calculation resulted in an increase. of the*
minimum flow requirement .from 830 gpm to 840 gpm.
When compared to the
850 gpm available flow established during testing, the use of *corrected
input assumptions reduced 'the analytical flow margin 50%.
To correct the
programmatic deficiencies of inadequate review of design deficiencies, the
licensee issued Engineering and to~struction (ENC)-QE-81, Revision 0, "Rev1ew
of Assumptions and Judgements For Architect Engineered Supplied Design
Evaluations".
ENC-QE-81 was to ensure the applicable regulatory
requirements were addressed for design evaluations and an adequate review
.of associated assumptions was performed.
Failure to adequately control
design input assumptions used by contract architect/engineers is
considered a violation of {50-237/91010-0l{DRP)) 10 CFR 50, Appendix B,
Criterion III, "Design Control".
However, as this was considered to be
-an isolated occurrence of minimum safety significance, and the
appropriate corrective actions were completed, a Notice of Violation is
not being issued 'in accordance with 10 CFR -2, Appendix C, Section V~A.
- The inspector has no furthei concerns in this area.
{Open)
Open Item (50-237/89019-04):
Verify installation of river level
indication and alarm in the control room for Systematic Evaluation
Program (SEP) Topic II-3.B.l/4.1~4. This item is to remain open until
the mo~ification has been completed .. Current expected completion date is
- September 1991.
Orie non-cited violation and no deviations were identified in this. area.
3.
Licensee Event Reports Followup (90712 and 92700)
Through direct observations, discussions with licensee personnel, and
review of records, the following event reports were reviewed to determine
that reportability requirements were fulfilled, immediate corrective
action was accomplished, and corrective action to prevent recurrence had
been accomplished in accordance with Technical Specifications.
a.
(Closed) LER 237/91001:
Partial Group I Isolation Due to Shorting
of 18 Main Steam Isolation Valve (MSIV) Position Indicating Light
Socket.
b.
(Closed) LER 237/91003:
Omission of Liquid Radwaste Discharge
Composite Analysis Due to Management Deficiency. -
c.
(Closed) LER 237/91006:
Unplanned Primary Containment Group V *
4
'
i
.*
Isolation Due to Unknown Causes.
d.
(Closed) LER 237/91007:
Violation of Core Thermal Power Limits Due
to Unplanned 28 ReaC:tor Recirculation Pump Speed<Increase.
In additi~n,.the inspecto~ reviewed the licensee's Deviatio~ re~orts
(DVRs) generated during the inspection period. This was done in an
effort to monitor the conditions related to plant or pers.onnel
- performance, potential trends, etc.
DVRs were also reviewed for
initiation and disposition as required by .the applicable procedures and
the Quality Assurance (QA) manua 1.
No violations or deviations were identified.
4.
Operational Safety Verification (71707)
The inspectors daily and randomly verified during back shift and on
weekends, that the facility was being operated in conformance with the
licenses and regulatory requirements and that the licensee's management
control system was effectively carrying out its responsibilities for safe
operation. This was done on a sampling basis through routine direct
observation of activities and equipment, tours~ interviews and
discussions with licensee personne 1, verification of safety system status
and limiting conditions for operation action requirem~nts (LCOs),
corrective action, and review of facility_retords.
On a sampling basis the inspectors daily verified proper control room
staffing and access~ operator behavior, a~d coordination of p1ant
activities with ongoing control room operations; verified operator
adherence with the latest revisions of procedures fo~ ongoing activities;
verified operation as required by Technical Specifications (TS);
including compliance with LCO~, with.emphasis on engineer~d.safety
features (ESF) and ESF electrical alignment and valve positions; .
monitored instrumentation recorder trace channels for abnormalities;
.verified status of variou~ lit annunciators fo~ operator understanding,
off-normal condition, and corrective actions being taken; examined
nuclear instrumentation and other protection channels for proper
operability; reviewed radiation and stack monitors for abnorma*l
conditions; verified that onsite and offsite power was avajlable as
required; observed the frequency of plant/control room visits by the
station manager, superintendents, assistant superintendents, and othe~
managers; *and observed the Safety Parameter Display System for
~o~p=e=rao-i-1 *
During tours of accessible areas of the plant, the inspectors made note
of general plant/equipment conditions, including control of -activities in
progress (maintenance/surveillance), observation of shift turnovers,
general safety items, etc. The specific areas observed were:
a.
Engineered Safety Features (ESF) Systems
. Accessible portions of ESF systems and components were inspected to
verify:
valv~ position for proper flow path_; proper alignment of
5
b.
power supply breakers or fuses {if visible) for proper actuation on
an initiating signal; proper removal of power from components if
required by TS or FSAR; and the operability of support systems
essential to system actuation or performance through observation of
instrumentation and/or proper valve alignment.
The inspectors also *
visually inspected components for leakage, proper lubrication,
cooling water supply, etc.
Radiation Protection Controls
The inspectors verified that workers were following health physics
procedures for dosimetry, protective clothing, frisking, posting*,
etc.i and randomly examined radiation protection instrumentation 'for
use, operability, and calibration.
c.
Securit.y .
Each week during routine activities ortours, the inspector
monitored the li~ensee's security program to ensure that observed
actions were being implemented according to their approved security
plan.
The inspector noted that persons within the protected area
- displayed proper photo-identification badges and those individuals
requiring escorts were properly escorted~ The inspector also
verified that checked vital areas were locked and alarmed *
d.
Housekeeping and Plant Cleanliness.
The inspectors monitored the status of housekeeping and plant
cleanliness for fire protection, protection of safety-related
equipment from intrusion of foreign matter and general protection of .
equipment from hazards.
e.
Reactivity Control By Non-Licensed Individuals
The licensee identified the inappropriate practice of utilizing non-
licensed operators to perform local manual operation of the reactor
recirculation (RR) pump scoop tube positioner. The change in the
position of the scoop tube resulted in a direct change of reactor
reactivity. This evolution was performed on the 2A RR pump by a
. non-licensed operator on June 29 and 30, 1990~ The problem was
attributed to a failure of the corporate 11censing organization to
identify local scoop tube manipulations as a direct reactivity
control during the review of the Title 10, Code of Federal
Regulations, Part 55, March 1987 revision.
To correct the
deficiency, Dresden Operating Procedure {DOP) 202-12, "Recirculation
Pump Motor Generator Set Scoop Tube Operation", was revised to.
restrict local RR pumpscoop tube manipulation only by licensed *
operators.
The practice was in violation {50-237/91010-02(DRP)) of
10 CFR 50.54(i) and 10 CFR 55.13, which requires the licensee to not
permit manipulation of the controls of the facility by anyone who is
not a licensed operator or licensed operator trainee.
However, as
this violation was considered*an isolated occurrence and
corresponded to the criteria for the exercise of discretion
delineated in 10 CFR 2, Appendix C, S~ction V.G.1, a Notice of
Violation is not being issued.
The inspectors considered licensee
identification of this issue to represent good coordination and
- review of NRC concer.ns at the Quad Cities facility.
The inspectqrs also monitored various records, including tagouts,
jumpers, shiftly logs and surveillance, daily orders, maintenance items,
various chemistry and radiological sampling and analysis, third party
review results, overtime records, QA and/or Quality Control (QC) audit
results, and_postings required per 10 CFR 19.11.
One non~cited violation and no deviations were identified in this area.
5.
Monthly Maintenance Observation (62703)
Station maintenance activities affecting the safety-related systems and
components listed below were observed/reviewed to ascertain that they
were conducted in accordance with approved procedures, regulatory guides,
and industry codes or standards and in conformance with Technical
Specifications.
The following items were considered during this review:
the Limiting
Conditions for Operation were met while components or systems were
removed from service; approvals were obtained prior to initiating the
work; activities were accomplished using approved procedures and were
inspected as applicable; _functional testing and/or calibrations were
performed prior to returning components or systems to service; quality
control records were maintained; activities were accomplished by
qualified personnel; parts and materials used were properly certified;
radiological and, fire prevention controls were implemented.
Wo~k
requests were reviewed to determine status of outstanding jobs and to
assure that priority is assigned to safety-related equipment maintenance
which may affect system performance.
The inspectors-monitored the licensee's work in progress and verified
that it was being performed in accordance with proper procedures, and
approved work packages, that applicable drawing updates *were made and/or
planned, and that operator training was conducted in a reasonable period
- of time.
The following maintenance activities were observed and reviewed.:
Unit 2
2C Electromatic Relief Valve Repla~ement
Control Rod Drive Overhauls
Unit 3
30 Condensate Booster Pump Motor Overhaul
Turbine Building Sample Panel Hangers & Tube Installation
No violations or deviations were identified in this area.
7
...
6~
Monthly Surveillance Observation (61726) *
The inspectors observed surveillance testing required by Technical
Specifications during the inspection period and. verified that testing was
performed in accordance with adequate procedures, ~hat test
instrumentation was calibrated; that LCOs Were met, that removal and
restoration of the affected components were accompli~hed, that results
conformed with .Technical Specifi*cations and procedure requirements and
were reviewed by personnel*other than the individual directing the test,
and. that any* deficiencies identif.ied during the testing were properly
reviewed and resolved by appropriate management personnel.
Th_e
in~pectors witnessed port"ions of the following test activities:
Unit 2
~
High Pressure Coolant Injection (HPCI) System Cold Fast Start Testing
Rod Worth Minimizer Checkout
Post-LOCA Containment. -H2/02 Monitor Calibration
Unit 3
ReactQt Wide~Range Pressure Instrumentation Calibration
LPCI System Flow Instrumentation Calibration
No violations or deviations were identified in this area *
7.
ESF Walkdown (71710)
A review of the reactor building ventilation isolation damper
.
surveillance procedure, Dresden Technical Surveillance (DTS) 1600-29,
Revision 01; plant drawings M-269, Revision H; M-529, Revision K; M~25,
- Revision BN; and M-356, Revision AU, indicated several discrepancies *.
Plant drawings M-269 and M-529 identified the reactor building
ventilation isolation dampers, including the fail-safe closure mechanism
and the air reservoir accumulator, as safety~related. However, plant
drawings M-25 and M-356, associated with containment ventilation
isolation dampers, excluded the air reservoir from the safety-related
boundary. *In addition, the safety-related pressure switches associated
with the isolation d~mper fail-safe closure mechanism did not appear to
be incorporated into the station calibration program.
Some of the
similar pressure switches on the primary containment isolation dampers
also did not appear td be periodically calibrated. This issue is
considered an unresolved item (237/91010-03(D~P)) pending further
review of the calibration requirements for the pressure switches.
No violatioris or deviations w~re identified in this area.
8. * Training Effectiveness (41400, 41701)
The effectiveness of training programs for licensed and non-licensed
personnel was reviewed by the inspectors during the witnessing of the
licensee's performance of routine surveillance, maintenance, and
8
operational activities and during the review of *the licensee's response
to ~vents Which occurred during.the inspection period. Personnel -appeared
to be knowl~d_geable of the tasks being performed.
No viol~tions or deviations were identified. '
.
9.
Events (93702)
On April 11, 1991, Dresden Unit 2 exceeded 102% of rated core thermal
power for approximately 5 seconds .. The transient occurred due to ~
malfunctioning deviation meter during resetting of the 28 reactor
recirculation (RR) pump motor-generator (M/G) set scoop tube lockout.*
.
The magnitude of the over power event was limited by the prompt action of
the reactor operator who locked-out the scoop tube at the back panel.
On
April 15, 1991~ a se~ond Unit 2 reactor.overpowe~ event occurred as a
result *of a level transient following the startup of the standby reactor
Reactor power exceeded 102 percent for a 20 second
duration with a 105 percent peak core thermal power.
The second event
occurred while the RR pump scoop tube was locked out for repair.of the
flow controller deviatfon meter. *The standby RFP was started following a
seal failure on one of the two operating pumps;
Lifting of the Shroud Head and Steam S~parator Assembly
On March 22 ~ 1991, Dresden Unit 2 experie*nced an unexpected anomaly in
electrical output as cooling water flow through the reactor core was
- * i ncrea.sed.
As coolant flow through the reactor core increased from 72 to
75 million pounds per hour, the plant's electrical output increased by 2
megawatts instead of the anticipated 30 megawatt increase. Also, reactor
co.olant temperature in the annulus region increased about 2 degrees
Fahrenheit at the same time the core flow/electrical output anomaly
occurred.
Because the power/flow anomalies were similar to a Vermont
Yankee event associated with the steam separator lifting from the seat on
the core shroud in the reactor, the licensee commenced a Unit 2 shutdown
on March 24, 1991, to inspect the reactor internals.
An investigation
'team comprised of CECo ~orporate and plant individuals was formed to
review this ev~nt, along with other recent maintenance-related problems
during the Unit 2 refuel outage.
On March 27, 1991, regional NRC
specialists arrived on site. to review the event and licensee actions.
On March 27, 1991, the steam dryer was removed to facilitate inspection
of the shroud head bolts. With assistance from General Electric Company
(GE), a detailed inspecti9n plan was initiated and* implemented, with
emphasis placed on verifying if the shroud head bolts were latched and
tightened. Troubleshooting and corrective .action was performed under
Visual inspections 6n seven accessible shroud head bolts with
an underwater camera indicated that the bolts were *latched, but not
- tightened. Subsequently, all 48 bolts were verified latched, but not
tightened. Based on an evaluation performed by GE, the_ loose shroud head
bolts would allow the shroud head and steam separator to lift at high
core flow conditions.* The GE analysis for the Vermont Yankee event
concluded that no significant changes in plant safety margins occurred
during operation with the -separator assembly lifted. The causal factors
for the bolts not being fully tightened is an unresolved item
(249/91009-04(DRP)).
g
10. Safety Assessment and Quality Verification (35502 and 40500)
Dres~en Station Technical Support Engineers partiGipate~ in the-daily
Quad Cities NRC Electrical Distribution Safety Funetional Inspection
(EDSFI) debriefings~ - As a result issues raised at the Quad Cities
facility were also evaluated for applicability at Dresden. This included*
the seismic qualification issue of the D/G fuel oil transfer and air
start systems.
When the seismic analysis for the Dresden fuel* oil
transfer system could not be retrieved, the licensee commissioned a
Seismic Qualified Utility Group walkdown by Stevenson and Associates to
address -system operability concerns. Additionally, licensee. identification
of the inappropriate- use of non-licensed operators to perform reactivity
manipulations, as delineated in paragraph 4.e., resulted from the
coordination of NRC concerns raised at the Quad Cities plant.
-~o vi6lations or deviations were identified in this area.
11. Systematic Eva iuation Program Items (92701)
11Saf.ety Evaluation Report Related to the Full-term Operating
License for Dresden Nuclear Power Station,
11 Table 2.1, identified 22 SEP
Integrated Plant.Safety Assessment Report (IPSAR) topic resolutions to be
confirmed by the NRC Region _III office *. -
The expected completidn date for Item 2 for Topic II-3.b.l/4.l.4 is
detailed as Open Item 50-237/89019-04 in p~ragraph 2 of this report.
In
addition to Item 2, the following four items remain to be verified as
closed by the licensee and confirmed by the NRC:
Item 6 - .Topic VI-4/4.18.6
Item 13 - Topic III-2/2.2.2 (Supp. 1)
Item 14 - Topic III-4.A/4.5.3 and 2.2.2 (Supp. 1)
Item_ 16 - Topic VI-4/4.18.2; Topic VI-6/4.19
Each of these items were in some stage of verification review by the
licensee.
No violations or deviations were identified.
12.
Report Review (90173)
During the inspectiori period, the inspector reviewed the licensee's_
Monthly Operating Report for February 1991.
The inspector confirmed that
the information provided met the requirements of Technical Specification -6.6.A.3 and Regulatory Guide 1.16. The inspector also reviewed the
Dresden Nuclear Power Station Monthly Plant Status Report for March 1991._
No violations or deviations were_ identified .
10
13.
Violations For Which A "Notice of Violation" Will Not Be Issued
The NRC uses the Notice of Violation as a standard method for formalizing
the existence of a violation of a _legally binding requirement.
However,
because the NRC wants to encourage and support licensee's initiatives for
self-identificatiori and correctioh* of problems, the NRC will not generally
issue a Notice of .Violation for a violation that meets the requirements
set forth in 10 CFR 2, Appendix C,Section V.A.
Violations of regulatory
- requirements fdentified during the inspection for whi~h a Notice of
Violation will not be issued are discussed in paragraphs 2 and 4;e.
14. Unresolved Items
15.
Unresolved items are m~tters about which more info~mation is required
in order to ascertain whether they are *acceptable items, items of
Tionco~pliance, or deviations.
The two unresolved items disclosed
during this inspection are discussed in paragraphs 7 and 9.
Exit Interview
The inspectors met with licensee representatives (denoted in paragraph ,1)
during the inspection period and at the conclusion of the inspection
period on May 16, 1991.
The inspectors summarized the scope and results
of the inspection and di~cussed the likely content of this inspection
report.
The licensee acknowledged the information a~d did not indicate
that any of the information disclosed during the inspection could be
considered proprietary in nature.
- *
11