ML17177A323

Insp Repts 50-237/92-02 & 50-249/92-02 on 920113-0302. Violations Noted.Major Areas Inspected:Operational Safety, Monthly Maint & Surveillance,Training Effectiveness,Rept Review,Events Followup & Safety Assessment

ML17177A323
Person / Time
Site:	Dresden
Issue date:	03/11/1992
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17177A320	List: ML17177A319 ML17177A321 ML17177A323
References
50-237-92-02, 50-237-92-2, 50-249-92-02, 50-249-92-2, NUDOCS 9203240040
Download: ML17177A323 (20)

See also: IR 05000237/1992002

Text

• U. S. NUCLEAR REGULATORY COMMiSSION

REGION Ill

.

.

• • Report Nos.

50-237 /92002 (DRP); 50-249/92002 (DRP)

bocket Nos. 50-237; 50-249

license Nos.

DPR~l9; DPR-25

Licensee:

Corranonwealth Edison Company

.

.

Facility Name:

Dresden Nuclear Po~er Static~, Units 2 and 3

Inspection At: Dresden Site,.Morris, IL

Inspection Conducted: January 13 through March 2, 1992

Inspectors:.

W. Rogers

M. Peck

• M. Miller*

P. Lougheed

P *. ~escheske

K. Shembarger

D. Liao (Intern) .

.

• .

J~ Schapker

• .

..

.*.

• ' .

. R~ Zuffa, Site Resident Engineer *

.

Illinois .Depa~tment*of Nuclear Safety *

Approved By:

,.)_

.

~

B. L. Bur ess, Chief,

Projects: Section lB

Inspection Summary *

3/tt /? '1-

Date

In~pection from Janua~~ 13 through March 2. 1992 <Report Nos. *

50-237/92002CDRPl.: 50-249/92002CPRPllt

Areas Inspected: Routine unannounced safety inspection by the resident

inspectors, and.an Illinois Department of Nuclear Safety inspector ~f licensee

action on previously identified items; operational safety; monthly

• maintenance; monthly surveillanc~; training effectiveness; report review;

events followup; safety assessment and quality verification; concern followup;

• $YStem~tic evaluation program review; regional requests; and management

meetings.

-

• Results:

Two cited violations and one non-cited violation were id~ntified.

• One-of the cited violations, with two examples, dealt with ineffective

• corrective action (paragraph 5.a & 8.a). *The second cited violation dealt

• with not meeting a Technical Specification Limiting Condition for Operation

(~aragraph 8.c) .. The non-cited violation dealt with personnel not following .

procedures (paragraph 8.b).

Two unresolVed items were identified (paragraph

. a.d &: 9.a') ~--~ O!lf:!*open- item*-was-*tdentified (paragraph 2*.ey.

• • *

9203240040 92031~ ..

PDR*

ADOCK 05000237.

G

PDR

• *

Plant Op~rations Licensed operatcirs performed their control room dutie~

adeqOately with some limited improvement in log keeping.

Some long standing

equipment deficiencies continue to complicate manipulation of equipment.

Some

inattention to. detail occurred in the performance of field activities ..

Conservative mana~ement decisions were evident as they rel*ted to Unit 2 power

ascension. Housekeeping problems were observed within the Unit2 drywell

partially attributed to progr'arnrnatic ~eaknesses in the drywell closeout-:

process.

No other new programmatic weaknesses were identified.

-

.

.

.

.

.

.

. .

.

.

Maintenance/Surveillance Strict procedural adherence did not always occur i"n

the perfo~mance 6f maintenance activities resultirig in a non~cited violation ..

Some inattention to detail was noted in the performance of surveillance

activities and resulted in a violation of Technical Specifications. Also,

inadequate and defi~ient surveillance procedures contributed to o~erational

events.

.

.

.

.

.

.

Safety Asses~ment and Quality Verification Positive performan~e enhancements

were evident through the use of quality assurance*per~onnel irt reviewi~g Uhit

2 startup activiti~s and*impl~menting VQ training.* Conversely, inade~uate

corrective actions were apparent resulting ina violation and,_ a weak root

cause analysis to a maintenance event was noted .

2

.*. L.

Persons Contacted

Commonwealth Edison Company

DETAILS

1. • C~ Schroeder, ~tation Managei

L. Gerner, *Technical Superintendent

• J. Kotowski, Production Superintenderit . .

.

• _D. Van Pelt, Assistant Superintendent - Maintenance

J. Achterberg, Assistant Superintende~t - Work Planning

.G. Smith, Assistant Superintendent-Operations

• *

• R. Radtke, Regulatory Assurance Supervisor

M. Korchynsky, Operating Engineer*

B. Zank, Operat~ng Engineei

• R~. Stobert, Operating Engineer

T. Mohr~ Operating Engirieer

M. Strait, Technical Staff SupervisQr*

• D. Ambler, Radiation Protection.Manager

• K. Kociuba, Quality Assurance Superintendent

• Denotes tho~e attending the exit interview conducted*on.

February 28, 1992.

.

.

1. Denotes those attending the exit interview conducted on March 2, .1992.

The inspectors also talked with arid interview~d several other licen~e~

. employees, in~luding members of the technical and engineering staffs;.

reactor and auxiliary operators; shift engineers and foremen;

electrical, m~chariical, and instru~ent maintenance persorinel; and

contract securitj personnel.

.

.

2.

Previously Identified Inspection Items (92701 and 92702}

• a;

. (Closed) Violation (50237/91016-0l(DRP)):

Inadsquate 10 CFR 50.59

• .safety evaluation for a temporary alteration of the Unit 2 high

pressure coolant injection system.

The temporary alteration

provided direct interface between Class IE electrical equipment

and non~safety measuring and test equipment (M&TE). *The safety

evaluation failed to address the poteritial degradation -0f the

.

Class IE circuit from a fault in the M&TE~ The licensee p~ovided

~ letter (to NRC bocument Control Center from T. J. Kovach, on *

August 14, 1991) clarifying their commitment to c.onsider

Regulatory Guide L75 and IEEE 384 electrical separation

requirements, in the safety evaluation process. This matter is

b.

corisidered tlosed.

. (Closed) Violation *(50-:-237/91009-0l(DRP}):

Failure to- specify

standby liquid control (SLC) system post-modification test'

acceptance criteria verifying the net-positive suction head (NPSH)

design, and failure to perform a two~pump post-modificatiri~ flow

test of adequate duration to demonstrate satisfactory in-ser~ice

performance.

__ . __ -=

• -..--*-=--~

.....

_-:.~

=--

--=--

--*~ .. - -

._*_. -. -*:-,-

"!~-~*!.....;...~. --=-

• -

-* *--=-*-

."":..--~~ --*-

.*

_3

)

CECo retained the services of*a reciprocating pump consultant to *

p~tform an evaluation of the SLC pumps at the Dresden .and

.

Quad Cities stations. The consultant was unable to resolve NRC

qtie~tions regarding the adequacy of NPSH for single pump op~rati6n

• ... or the potential for two~pump interaction when the pumps were

• operating simultaneously. * The consultant recommended perfornii ng

.additional tests or system modifications to resolve the issue ..

The licensee performed a single pump test on February 11, 1991, at

Quad Cities Unit 1 *~d.the pump failed the acceptance criteria.

Subsequently, Dresden. personnel declared the SLC inopet~ble and -

entered*the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limiting conditton for operation (LCO).

To*

justifycontinued reactor operation, the Engineering Department

provided administrative restrictioris on storage tank level. and

temperature to ensure adeq~ate pump NPSH based on the Quad Cities

test results. A second testwas performed at Dresden Unit 2

verifying two pump capability on February 15, 1991, using the

newly established admini~trative restrictions ~s the acceptance

criteria. The t~st met the acceptance criteria of delivering

3,32i gallons of sodiuni pentaborat~ solution ~t 80 gallons per

minute.

The inspector verified the licensee's corrective a*ct ions were

completed. .ENC-QE.06.4, Modification Acceptance Testing

• .

Evaluation, was revised to establish adequate post-modification

• .testing. The licensee~~lso issued an Engineering. "Lessons

Learned" flyer communicating the. SLC testing problem to the

a~propriate personnel. This matter is corisidered clcised.

c*.

(Closed) Violation (23i/90023-08(DRP)):

Following the fuel bundle .. ,

mispositioningevents of January 10 and 12, 1989, licensee

corrective actions were insufficient to prevent repetition in that

stmilar events occurred on October 1 and 2, 1990.

Fuel bundle

mispositioning events did not occur during the Unit 3 refueling

activities conducted in 1991. Licensee action was consi~ered

adequate and this item is closed.

.

-

. .

d.

(Closed) Violation (237/91022-0l(DRS}):

On 'March 22; 1991, as

reactor power was increased during startup, the Unit 2 stea~

separator lifted from the seat on the.core shroud. This event was

• caused by the failure to tighten (and tq verify tight) the

~eparator hold down bolts during reactor assembly.

The licensee's

actions included review and revision of maintenance procedure~ and

practices regarding pre-job briefs, use of work packages, and

independent verification. All corrective actions were compl~ted

prior to the Unit 3 reactor assembly activities conducted in 1992 ..

This item. is closed.

e;

• (Closed) Confirmatory Action Letter (CAL-RIII-91-014):

On

October 22, 1991, the NRC issued CAL-R111-91-014 regarding the

• Octobet 18-19, 1991, Dresden Unit 3 fuel handling event in which

two fuel bundle bail handles were damaged in the spent fuel pool.

The ev.ent, l ic.ensee"-imnied*iate~act.ions, ~root* causes; and-" -

. 4

f.

consequences, ~ere discussed in NRC Inspection Re~ort

No. 249/91032(DRS).

The following summarizes licensee actions

requested in the CAL.

(1) . Assess damage and potential 1 oose parts.

.

.

.

.

(2)

Evaluate repairs and testing, movement of damaged fuel

bundles, and core redesigni

(3)

D~termine root cause and action plan, t6 include review and

evaluation of:* communication and controls associated with

fuel movement, training for fuel handling personnel, nor~al

and abnormal fuel handling procedures,* design and

performance. of fue 1 handling equipment, and corrective

(4)

actions from previous problems encountered during the Unit 2 *

• *. refue 1 outage. *

\\

Within thirty days of the conclusion of refuel activities,

submit a formal report to the NRC addressing actions~

CE Co 1 etter dated Qecember 6, 1991, from D. Ga 11 e to

A. Bert Davis, NRC~ constituted the licensee's response to the

• CAL .. All items in th~ CAL we~e adequately addressed by the

licensee,.including corrective actions to prevent recurrence.

• Fuel movement was subsequeritly resumed and core reload was

completed wit.hout further significant problems: *The CAL i.s

considered closed.

• *

Several actions were to be completed by the licensee prior to the

Unit *2 refuel outage (planried for September 1992) .. The following

will be .tracked as an Open Item, pending ~ompletion by. the

licensee and revi~w by the NRC (249/92002-0l(DRP)).

(1)

Additions and revisions to initial and continuing training

for fuel handling.personnel.

- .

• (2)

Installation of new refueling masts and g~~pples on Unit 2

and 3 refuel bridges.

(3). Review ~nd upgrada of normal fuel h~ndling procedures prior

to use~

(4)

Devel6pment of fuel handling abnormal procedures.

(Closed) Violation (249/91032.-0l(DRS)):

The licensee failed to

~dequately implement the station procedure for fuel movement

within the spent fuel pool, which resulted in ~amage to two fuel

bundle *bail handles.

Licensee corrective actions are discussed

with the closure of CAL-RIII-91-014 fissued following this.event).

The event, along with several other operatfonal events, resulted

in a Notic~ of Viol~tion (Notic~) and a Civil Penalty (CP) issued

on Janua~y 9; .1992;*c The' licensee response to the Notfce*,:-*date*d

5

February 7, 1992, was considered adequate with respect to ttie fUel

handling ~vent. The violatioh (and fart 11.E of the Notice) is

closed.

r

No violations or deviatiohs were identified in this area.

.

.

.

.

• 3.

Operational Safety Verificati~n (71707)

The inspectors reviewed the facility for conformance with th~ license

and regulatory requirements .. *

a.

On a sampling basis the inspe~tors observ~d control room

activities for proper control room staffing,* coordination of piant

activities; adherence to procedures or Technical Specifications; *

operator cognizance of plant parameters and alarms; electrical

power configuration; and th~ frequertcy of plant and control roo~.

visits by station managers.

Various logs and surveillance records

were teviewed for accuracy and completeness.

Significant observations were:

1)

2)

3)

. A limited improvement in ccintrol ~oom log quality was

observed.*

~wo emergency~perati~g ptocedures for Unit 2 c6ntained

temporary changes.

These changes were from 1991. and were .

• all owed by the licensee's temporary change process.

• However, the inspe~tor inquired as to the priority assigned

in translating the changes into procedure revisions.

No

definitive priority was evident.

The licehsee indicated

_that matters of this nature*were included in ongoing

initiatives to improve the procedure change process.:*

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.

'

• ..

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.

. .

.

The inspector observed startup activities of Unit 2 from a 2

1/2 month forced shutdown.

Control room activities were

performed adequately with strong operator performance

• .observed when ~lacing the reactor water cleanup system into

service.

The reactor water cleanup system exhibtted large

pressure fluctuations due to .design weaknesses within the

• * system.

b.

On a routirte basis the inspectors* tour~d accessible a~eas of the

facility to assess worker adherence to radiatioh control~ and the

site security plan, housekeeping or cleanliness, and control of

field activities in progress.

Significant observation~were:

• l)

During , a tour of the drywe 11 . the inspector noted the

• degraded Unit 3 drywe 11 *sea lt i te protective cab 1 e

• connections, identified during a previous drywell.

, inspection, we roe .ej th er- rep a i r-ed * or-* re pl aced"; ,

6

.:

c.

2)

The Unit 2 drywell close out health physics *pre-job briefing.*

~as conducted in a highly professional manner and in

accordance with prescribed procedure. Additionally, the

radiation protection survey was of good* quality and

..

appropriate to the work activity~

.

.

.

• 3)

On February 1, 1991, the inspector observed the performance

of the Unit 2 drywell close....::out.

The inspector noted the

follOwing material condition concerns* in the drywell:

o

A non-secured pipe next to the HPCI steam supply

. isolation valve.**

o

• Approximately 30 unsecured stainless steel

thermocouple tubes.

o

Approximately 20 cables, o.f varying size, coiled up *

and hanging at various locations in the drywell. Some.*

of the cables were iupported with duct tape.

.

.

o.* *.A piece of unsupported mirror insulation~

o

An unsupp.orted lighting switch, suspe-ndeq at the end

of a 30 foot conduit.

.

.

o

.. Several pieces of trash, inclu.ding several plastic

electrical connectors~

The* items identified, with thE:l exception of the trash, were*

~resent during previous power operation. A review of the

past drywell .closeout packages revealed the conditions had

not been documented; Analysis doctimenting acteptability of

the conditions, in regard to ECCS suction plugging or

seismic considerations, was not available for petiods of

reader operation.

DOS 1600-10, "Pre-Startup Drywell

Inspection Plan," did not delineate requirements for

.

documentation and resolution of material concerns. identified

during the closeout. . The licensee committed to add this

feature to the procedure p*ri or to the Unit 3 drywe 11 *

closeout.

Walk.downs of select engineered safety features {ESF) were

..

performed.

The ESFs were reviewed for proper valve and electrical

alignments.

Components, were inspected for leakage, lubrication, * *

abnormal corrosion, ventilation and cooling water supply

availability. Tagouts and jumper retards were reviewed for*

• accuracy wherf::l appropriate.

The ESFs .reviewed were:

Unit 2

.-

Selected-piping and components within the primary containment

7

4.

.

.

......

Standby gas treatment system

• 2/3 diesel generatrir:

Unit 3

A loop low pressure coolant injection system.

-

Selected piping and components within the primary crihtaininent

8 loop core spray system

No violatiOns or deviations were identified in this area.

Monthly Mainte~ance Obs~rvation (62703)

Station maintenan~e a~tivities affectin~ the.safety-related and .

.

important to safety systems and components.list~d below were obseived or

reviewed to ascertain.that they were conducted in accordance with.

approved *procedu_res, regulatory guides *and industry codes or standards,

and did not conflict *with Jechnical_Specifications.

Unit 2

Inspection and rebuilding of the standby gas treatment train 8 flow

. control valve operator

- * 28 Core Spray.minimum flow. valve controller repair

-

VOTES T~sting of Valve 2301~10 * .

.

-

Raychem Splici~g of EleGtromatic Relief Valve Solenoid 3C

- .. Pilot Assembly Re.pl_acement of Relief Valve 203~3A.

~ *Repair of Leaking Air Operated Valve 2301-31

. -

Repair Packing Leak on Valve 2301-10

Inspect Pinion Gear Setscrew* on Valve 2301-10

Replacement of Control Rod Drive R-10

• Repair Leaking Check Valve 2301-07 *

Unit 3

- *. 3A .Pumpback Air Compressor Overhaul

3A Reactor Recirculation Pump Motor Generator Reb~ild

38 H~/02 Monitor Repair

.

.

• .

. .

.

- . 38 Feedwater Line Containment* Penetration (X-1078) Replacement

-

VOTE~Testing of HPCI arid Isolation Condenser Valves

302 ~nd 303 Heat~r Nozzle R~pairs

HPCI Stop Valve Rebuild

-

Torus D/P.Controller Installation

Stator Cooling Panel Modification

MCC 39-2 and 39-3 Cable Installation* and Termination

...

Trouble Shooting.of Core Spray Min Flow Valve 3~1402-388

.* -

Vessel

He~d Stud Pr~paration and Installation

.

Sign~iicant observ~tions included:

a.*

While reviewing the- work package for valve 2-2301-10 the inspector

. noted that-the *post' ma-fntenance" veri-fication-tncluded* a*packtng -

8

,,-**

. .

.

.

.

.

. '

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leak th~ck of the valve.

Th~ leak check ~ad been accomplished ~nd

was signed off. However, the piping was*not pressurized when the*

leak* check was accomplished and no leak check was specified in the

post maintenance test requirements.: The* s iiuat ion was * i dent ifi ed

to the SCRE who modtfied the work packag~ to include a packing

leak check.when the system was pressurized.

b.

.While reviewing the VOTES work package for high pressure coolant

injectiOn valve 2-.2301-10 {test return valve to condensate stor.age

tank) the in~pector noted that the post maintenance verificatiori.

or testing did not include verification that th* valve thrust wa~

consistent with the thrust window provided by engineering.

The

inspector corifi rmed that the thrust was within the window but,* the*.

lack of a written veri fi cation of thrust acceptability was .a *

~eakness noted iri a recent inspection reporti 50~237/91036. *

.

.

No.violations or deviations were identified.

Monthl~ Surveillan~~ Observ~tion (61726)

.Surveillance testing required by Technical Specifications, the Safety

Analysis Report, maintenance acti~fties or modification actjvities ~ere

observed and/or reviewed. .Areas of con~ideration while performing

observations. were procedure adher*nce, calibratipn Of test* equipment,

identification of t~st deficiencies; and personnel qualification. Areas

of consideration while reviewing surveillance records were completeness, .

proper authorization/review signatures, test ~esults properly

.disprisitioned~ and independent verifi~ation documented.

The following

activiti~s we~e observed/reviewed:

Unit 2

-

DOS 300-02, CRD Stall Flow Test

-

DOS 300-01, Daily/Weekly CRD Exercise

DIS 700-3, SRM Rod Blpck Calibration Check

-

DIS 700-4, IRM ~ad Block/Scram Calibration Check *

-

DOS 6600-01, Diesel Generator Monthly Surveill~nce

• -

DOS 1600-01, Quarterly Valve Timing

-

DAP 11-21. Form C, Valve Stroke Timing of 2*301-10

DOS 2300-03~ HPCI Operability Verification

Unit 3

-

DOS 700-1, SRM Rod Block Functional Test

[2 Hrs]*

DOS 700~3, SRM Detector Position Rod Block Funct1onal Test

DES 6600-08, 2/3 Diesel Generator 18 Month Maintenance

.Surveillance Inspection

9.

'.

Significant observations included:

a.

• • DIS 1700-3. RBCCW Rad~ation Monitor Calibration

.

.

. On February 4, 1992, the inspector observed the calibration* of the

Unit 2-reactor building close cooling ~~ter radiatioh monitor per .

. Dresden Instrument Surveillance (DIS)

1700-3~ The calibration

required the connection of test equipment to the monitor drawer.

However, the procedure provided insufficient information for the

instrument mechanic (IM) to complete the task.

To complete the

task the IM sup~lemented the proced~re with t~o non-controlled

generic reference diagrams for the test equipment setup. *

Additional. protedural deficiencies had been iden~ified previously

by.the licensee on December 23, 1991, and a procedural inquiry

form was submitted~ Reliance on.the non-controlled generic

reference diagrams i_s conside.red a weakness. in the instrument .

mainten~nce department (IMO) surveillanc~ program.

A review of the IMB training records re~ealed the IM was hot

qualified to perform the radiation monitor calib~ation and the

appropriate administrative controls for using a non~qualified

individual were not implemented.

.

.

.

.

A similar situation had been identified by an* inspector during ..

. followup of a July 8, 1991, unplanned engineered safety features

att~ation. In that event the same IM performed a *calibration but

was not documented as a "qualified*indi~idual" on the job

• ssignment matrix.

To correct this July 8, 1991, probie~ the licensee issued IMO

Mem6randuin ~o. 8 on August 12, 1991.

The memorandum specified the

• following requirements when a non-qualified mechanic was assigned

• • a task:*

-

• *

• *

0

0

0

0

The ~upervisor and the e~ploy~e thoroughly review and

discuss the assigned task prior to perfor~an~e of the WQrk.

The supervisor document the critical task steps o.n

"Attach~ent A".

• The supervisor observes the performance of the c~itical task

steps.

-

Both the supervisor and the IM sign the "Attachment A".

.

.

.

.

The memorandum stated adherence to the policy was mandatory.

.

However, neither the IM or the supervisor completed the required*

documentation, *no critical steps were identified and the

. supervisor failed to observe any portion of the task performed for

the February 4, 1992,_ calibration.**

10

..:::..:*

-

The inspector reviewed the i~D time c~rds for November, 1991. A

• second example of a non-qualified mechanic, perfor~ing a

surveillance, without meeting the IMO Memorandum No. 8

.requirements, ~as identified. The failure to ~dequatelY implement

corrective actions from the.previous July 8, 1991, event is

considered ari example of a violation of 10 CFR 50; Appendix 8,

!riterion XVI (Violation 237/92002~02a(DRP)).

• b.

DES 6600_;08. DIG Ia Month EM Surveillance Inspection

.

.

-

.

Th~ overspeed calibration wa~ performed using ~ *

.

tachometer/transducer .connected to the governor~ Historically, a

dial type tacho~eter was used for deter~ining the overspeed trip

setpoint. This led to a setpoint slightly less than the.~endor

. recommendations~ Electrical maintenance incorporated the use of a

f~equency meter resulting in increased atcuracy .. Incorporation of

th~ frequency mete~ was GOnsidered a progressive and ptoactive

addition to the surveillance program.

c.

DOS 1600-01. Quarterly Valve Timing

During the revie* of DOS 1~00-01 the* inspector noted the stroke

time for valve 2301-14 appeared too s.hort.

The valve was stroking

at 7.6 seconds; approximat~ly three secrinds less than its

.baseline.

The inspector reviewed the results of the last four

strokes ~nd noted the valve was consisteritly st~oking at 7.6 *

seconds.

The .inspector identified the situation to the licensee's

inservice test personn*el.

The Hcensee. *stated the valve .would .be

rebaselined to 7d6 seconds.

• one example of a violation and no deviations ~ere identified.*

6.

Traini~~ Effectiveness (41400. 41701) .

• on February26, 1992, the inspector attended the Vision Through Quality

(VQ) Awareness training.*. VQ training combined discussion, videos and*

group workshops to demonstrate how involvement and *teamwork can be the

means of assuring quality .. The inspector.-0bserved a~tive pa~ticipation

by most individuals in the session: During the training, participants*

gained both a management and worker level perspective on the importance

of the program.

The class afforded participants the opportunity to ask

questions of the statibn manager and a union representative. The'

mandatory VQ training process was con*sidered a pro-active approach to

improving performance ~t the site.

No violations ~r deviations were identified.

7.

Repo~t Review

During the inspection period, the inspector reviewed the licensee's

Monthly Operating Report for January 1992.

Th~ inspector confirmed that

--

--~ ------- ~--~.

'11

• -

the information provided met the re~ui~ements of Technical Specification

.6.6.A.3 and Regulatory Guide 1.16.

• No violati.ons. or deviations were identified.*

8. *

Evehts Foll6~up (93702}

During the inspection period several events occurred, some bf which

required prompt notification of the NRC pursuant to 10 CFR 50.J2. The

inspectors pursued the events onsite with the licensee and/or NRC

officials.

In each.case, the inspectors.reviewed the accuracy ahd

timeliness of the licensee notifitat~on, the licensee's corrective*

actions and that activities were conducted within regulatory

requirements:

The specific events reviewed were:

a.

• Group II Isolatio~ - Unit 3

. b *.

. **.

.

. .

-~

.

. On January 15, 1992, a Unit 3 partial Group II isolation occurred

.when an electrician inadvertently disrupted the. neutral ground

circuit for ten_containm~nt isolation valves while performing DES

0200~39~ Main Steam.Isolation Valve flectri~al MaiDtenance. *The

procedure required the lifting of six control room field side

pane 1 wires to facilitate resistance and meggeri_ng checks of the

m~in steam isolation valve {MSIV} pilot solenoid coils. The

partial Group II isolation occurred.when the lead was lifted for

the JD MSIV ... The wiring drawings. revealed the neutral ground *

..

. circuit was designed on the panel side of the associated terminal_ ..

strip~ However, the circuit was actually installed on the field

si.de.

The cause of the isolation was a *discrepancy between plant

design and as-built configuration..

. A similar Unit 2 isolation occurred on December 8, 1990.

In this

event an electrician.also inadvertently disrupted the containment

isolation valve neutral ground circuit while performing the sam~

procedure.

The Unit 2 circuit was also tmprbperly installed on*:

the field side of the termin~l stri~ ih confli~t with design*

documentation.

Th~ corrective action from the December 1990 event included a

.review of the MSIV solenoid wiring configu~ation for both units

and a field verification of the protedure. A field verificati~n

of the ID MSIV circuit was performed but failed to identify the'

discrepancy.

The* failure to imp 1 ement adequate corrective action

from the previou~ event is considered *an ~xample of a violation of

10 CFR 50, Appendix B, Criteria XVI, Corrective Actions {Violation

249/92002-02b{DRP. . . Main Steam Line Plug Blown Out of Steam Line ~ Unit 3 . . . . . . On January 19, 1992, a main steam line p 1 ug was forced out of the. "C" s_tea111 line a.nd cam~_to_r_est.on top of the*,-shroud-head *while 12

the maintenance department wasre;issembling the vessel shroud and separator. When the pl~g exited the steam piping, a lanyard tied to the plug broke. The litensee stopped activities and informed appropriate members of ~anagement. An adequate course .of ~ction . was established.* A diver assisted the maintenance staff in removing the plugs an~ ccinfirming the shroud head area w~s free 6f any signs of da~age .. A*thoro~gh video scan of the annulus ~nd the shroud' head failed to identify any evidence of lanyard rope, . fittings, or other plug attachments that may ha.ve become detached. Following r~moval, each*of the. pl~gs were checked for all

• attachments.

No loose parts were identified. . . The licensee's investigation report, DVR 12-3-92-01~, identified* . procedural defici~ncy as th~ root cause for the ejected plugs. The report stated the controlling procedure used, bresden .

• Maintenance Procedure (DMP) 200-31, Revision 4, "Main Steam .Line

Pl~g Installation and Removal, 11 contained only g~neral ~uidance for the sequence of events to be used when removing the main steam line plugs .. This direction permitted operations to backfill the stearri line pushing the plug out of the steam line prior to v~nting the plug. The DVR also stated that a contributing factor for the main ste;lm line plug *ejection was the failure to depressuri2e the plug pri6r to the backfilling of the steam lines.

• *

. Through interviews.and p~ocedure*review the inspector determined: . . .. ' .

• '

. . . .** .

• .*

. o Maintenance perso.nneldi d .not de~ressuri ze the plug, per the procedure, ~fter supposedly ~enting the plug.

o Th~ v~nt line had been crimped during the maintenance activiti~s. However, had the main plug seal pl~g been. depressurized the pressure build up behind the plug.from the steam line backfilling operation, would hav~ been insufficient to eject the plug, even with the vent line blocked.

• *

o

• The written direction to backfill the steam lines by

operations was poorly stat~d and o~en to numerous interpretations. However, operations performed the*: -~~elution correctly on the day of the event. Therefore, the inspector determined failure to follow the

• procedure was the main cause leading to the ~ut of sequence of

activities and to the ejection of the main steam line ~lug .. lhis cone 1 us ion is not :consistent with the licensee's i nvesti gat ion .. report analysis.** . .

• The safety signfricance of the event was minimal, due to the plant

. conditions at the time of the event (vessel cavity was flooded, the shroud head in place and secured ~nd irradiated fuel protected . from direct projectiles). Appropriate . corrective actions were

• .

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taken at the time of the event and subsequent to the ev,ent in order to prevent reoccurrence. These corrective actions tncl~ded . counse 11 i ng of the maintenance personnel involved. D~~ to the isol~ted nature of. this event, li~ense& corrective actions and minimal safety significance, the event is ~ons~dered to be a Se~erity Level V non-cit~d violation' rif 10 CFR 50, Appendix B, Criterion V. ,

• * *

c. Intermediat& Range Monitor 11 Inoperable - Unit 2 * - . . . - - On February 3, 1992, while Unit 2 was in Refuel Mode, a Nuclear Qualities Program (NQP) Inspector identified a disconnected high .voltage power supply cable th intermediat~ range monitor (IRM) 17. Two days previous on February 1, 1992, DIS 700-4, IRM Rod Block/Scram Calibration Test, was performed cin all the IRM monitor~~ *The surveillance included rem~val of the high voltage supply cable from the detector drawer to facilitate annunci~tor circuitry diagnostics and reconnecting the cable prior to . *

• returning the applicable monitor to service. During the

restor*tion.activities* the instrument mechanit (IM) failed to* properly reconnect the high voltage cable. The prbcedure did not require independent or second party verification for cable reconnection. Therefbre, none was performed.

• .*

. . -.

. The main causes of the event were ~ersonnel error and procedural . . inadequacy. The personnel error was the IM failing to 'properly reconnect the high voltage cable,following completiori bf the surveillance. The sur~eillance procedure was deficient because it did not contain an independent verification for reconnecting the high voltage cable.

In response to NUREG.0737, Item I.C.6, the licensee committed to implement independent verification fo~ surveillance testing f6llowing staffing of the shjft control room engineer (SCRE) position. (letter to D. G. Eisenhllt, NRC~ _from A~ S. Abel; CECo, . December 15, 1980). The SCRE positioh was subse~uently manned in 1981. IE Information Notice 84-51, Independent Verification,.

. clarified the NUREG 0737 Item by including the guidance of Section . 5.2.6, Equipment Control, of the American Nuclear Society draft . revision to ANSI Standard Nl8.7-1972 (ANS 3.2). The clarificati~n *

• included surveillante testing, as in the ca~e of the.IRM

,calibration, within to the scope of activities requirin~ independen~ verification.

• *

The_literisee initiated the following corrective actions: . . . . o A review was conducted identifying 18 additional procedures l~cking apprri~riate verifications dealing with: potential undetected failures to reconnect .a cable or a lifted lead. . :." .::- ~ - -* - -~:-::. -:- _:_~ - - .. 14

.*

.o The maintenance staff verified proper reconnections were made on affected equipment ~rior to Unit 2 startup . . Following discussions with the residant staff concerning.the . NUREG 0737 Item, the procedures identifted were changed to require independent veri.fication. Origina*lly, the licensee .considered second verificatitin (not independent verifitation) adequate .. * *

. '

• .

"

. . . . . o The licensee C:ommittedto complete a similar review for Unit* 3 prior tri startup.

o

• Work performed by the IM during the *previous two weeks was*

reviewed. No .additional problems were identified.

o A walkdown of the auxiliary electric equipment room panels

• nd preamplifier racks to ensor~*prop~r equipment

connections was completed prior to Unit 2 startup. o The IM was interviewed by station managenient and counseled on the importance of *self~checking.

• From February 2,

1992~ until IRM 17's high *voltage cable was connected on February 3, *1992, the licensee was in violation of the* IRM Technical Specification. On February 2, .1992, * 1RM 15, another detector in IRM 17's reactor protection system (RPS)

channel, had been "by-passed". Technical Specifications (TS).* require~ minimum of 3 of 4 IRMs operable in each RPS channel. The by-passed IRM, tog~ther with the disconnected IRM, resulted in _.* only 2 of the 4 IRMs operable in RPS channel "B", and is a violation of TS (Violation 237/92002-03(DRP))~

• The safety significance of.the event was mitigated by the

availability of the, source range monitors to scram the reactor:* Also~ the inoperable IRM would be self disclosing during ~ea~tor * startup when the detector rem~ined down scale in contrast to.the* other operable .IRM monitors. d.

• Isolation Co~denser Inoperable - Unit 2 *

' On February 11, 1992, the Unit 2 isolation condenser steam

• isolation valve, 2-1301-1~ was identified without electrical powet

at shift turnover by the shift control room engineer. Operations personnel subsequently fotind the break~r operating handle locked .. in the off position. The motor operated valve (MOV) was without* electrical po~er for approximately three hours rendering the containment isolation aspectof the valve inoperable. Earlier in the day VOTES diagnostic testing was performed on the Unit 3's isolation condenser steam isolation valve, 3-1301-1. .Prior to connecting :the diagnostic equipment t.he main and alternate * breakers were racked out and an electrician's lock.was placed - -- - ---- - . - -~-__; --- - ' -

' .

. . -* - *. 15

through the handles. The operator ~ho perfor~ed*the evolut~ori . inadvertently racked out the Unit 2 breaker. The breaker position was not under the control of the station out-of~service program at the time.* This issue is considered unresolv~d pendihg review tif . the l_icensee's equipment control system (Unresolved_ Item 50- 237/92002-04(DRP)). . .. . :e. Contamination of Unit 3 Reactor Building On February 16, 1992, a demineral ized water (DI) spill occurred. resulting in contaminatjon of the north west end of the reactor building. The spill occurred after opening of the refuel. floor DI station as part of an Out of Service (OOS) in preparation for a Unit 3 local leak rate test. The DI station, the high point in. the reattor building, was o~en to provide a system vent path after _the reactor building DI supply was isolated. A hose extending _eight*feet into the dryer-separator pit was*attached to the

station. After the station was open a solid stream of water emanated from the hose. Operations personnel monitored the flow for approximately ten minutes without observing any flow decrease. The operators left the refuel floor. Subsequently secOrity personnel reported water running down the Unit 3 elevator. The DI hose was found outside the dryer-separator pit arid wedged in the refueling bridge trolley tracks. The floor drains were plugged and the water backed out onto the fourth floor. The OOS boundary failed to include a DI crosstia valve between Units. Thi~ event will*be followed up in.a subsequent inspection.

One ~iolation, an e~ample.of ~nether violation, and a rion~cited violation were identified. No deviations were identified. ~9. Safety Assessment and Quality Verification (40500} a. On Janu~ry .21; 1992, the Nuclear Engineer:ing Department {NED) informed plant personnel the Unit 2/3 diesel generator service water (DGSW) pump h~d .inadequate internal flood ~rotection. ,Specific~lly, the conduits which entered the transfer switch on .. * Panel 223-109 were not sealed. This condition had existed since the installation of the panel on November, 1986, under modification Ml2-2/3-84-62. The vulnerability of the transfer switch to internal flood was identified as a ~e~ult of walkdowns perfo~med in response to generic letter 89-15 on servi~e water. * Following re~iew of the walkdown data, NED questioned the qualification of the conduits and performed a review of the flood

• protection licensing bases.

In anticipation of a negative outcome, ~lectrical mairitenance personnel sealed the questionable conduits on January 19, 1992. However, on January 22, 1992, the licensee identified the caulking material used was not qualified for safety related applications. Operations personnel subsequently declared the DGS.W ~url]p, and. :the assoc-iated emergency -

• - *.. _.

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'

diesel generator, inoperable because of the:lack o( flood protection. . .. .

• .

. .

• .

ENC~QE-40.1, E~aluation and Review 6f Potential Design Concerns for Impact on Plant Operability~ describes the. acti~ns that must be taken when* a des,ign or equipment concern is identified that may potentially impact operability. The procedure was established as* a mechanism for documenting, transmitting and tracking operability * reviews for the engineering organization. The procedure applied

• to operability concerns identified by either CECo or external

sources related to safety~related designs or equipment referred* to NED for evaluation. The procedural intent was to ensure the necessary actions were expeditiously taken to resolve concerns and confirm op~rability even when personnel believed a system f~ operably but hav,e concerns rel.ated to it.

NED ~ersonnel pursued the DGSW electrical conduit in~ernal fl~od protectioh concern to resolution. However, the management cont~ol mechanism, ENC-QE~40~li wa~ not utilized~ As a result, the .on~

shift ope rat it1g authority was unaware of the flood protection venerability until after action was taken to seal the conduits. This issue is considered tinresolved pending a review of the NED operability evaluation prbcess, the modificatiori safety evaluation, and the work packages which utilized the non-safety- related sealant material in a safety-related applic*ation. (Uriresolved Item 237/92002~0S(DRP)). . . . . . . .* . . b. On February 6, 1992, Unit 2 was restarted.following a *3 1/2 month for<;:ed outage. Prior to restart the 1,i censee formulated an error free startup plari~ The plan includ~d a documentation review and physic~l verification of complet~d out of services, cleared temporary alterations, degraded equipment, and valve alignment by Nuclear Quality Programs (NQP). As a result, NQP idehtified two* sighificant conditions adverse to quality. The first, discussed. in Section 8.c, was the inoperable IRM 17 .. The second was the failure to remove lead shielding from the Unit 2 west hydraulic control unit bank* .. The addition of shie.lding was analyzed and ~pproved for u~e only during th~ Refuel and Shutdown modes . . However, an engineering evaluation performed subsequent to the discovery-concluded that the shielding did not adversely affect the operability of th~ hyd~aulic control unit during operation. c. Following Unit 2 restart, other than the IRM17 prbblem and wrong unit manipulation of an isolation .condenser valve~s electrical breakers, the following operational r~lated events occurred: o * . ~he ope~ations erew.was un~ble to latch the 202 feedwater * heater level control solenoid due to an imprbperly positioned sensing line isolation valve. . -----. -=-* - -:_ *- - **- . 17

. ' o The seal water injection for all three reactor feed pumps (RFP) was isolated potentiall)' resulting in seal damage .. '. . .. . . o Decrease in condenser vacuu~ occurred as a result of the mis-manipulation.of a valve asso~iated with the ~land seal drain.

Fro~ these eventi station manageme~t te~rignized the need to .evaluate petsonnel performance aspects of the_ events.for any* commonality and. halted power ascension until the preliminary event investigations where complete.* Also, plant management made a conservative decision not to increase power above 50% until all .- three RFPs where available.* The pump seals .apparently failed as a result of an inadvertent isolation of the seal water.inje~tion* flow. Once. the pumps were repaired ~nd the event investigations completed power ascension continued. . . . d.

• Inspectors review~d the -Onsite Nucle~~ Safety Report 92~01, a

routine safety group report, and noted that the st~tion had adopted recommend~d changes to the annunciator response procedure following a loss of gland seal condenser exhau.st by establishing a mechanism for monitoring turbine lube oil for moist~re intrusion with an upper operating limit. Followi~g a loss of gland seal * exhaust, moisture accumulatio.n had gone unnoticed for several

• hours resulting in significant water accumulatiori in excess of

vendor recommended limits.

No viol*tions or de~iations were iden~ified. 10. Concern Followup *CAMS.No. RIII-92-A-0006) A concern was raised at the Dr.esden* N~clear Power Station, Unit 3 th~t from December l, 1989, through January 3, 1990, a contractor supervisor* had used an interpretation of the contract, and intimidated d~ta analysts to ~omplete packages in-~ 24~hour period.** Consequently, a complete review of prio~ data for all of the exams was not possible and the supervisor was informed of this fact. During one particular* "ptoduction" day, a total of 99 examinatio~s were performed. * The NRC inspector reviewed all the UT data reports which totaled'l26 for . the outage. All of the UT-e~aminations were performed manually, no automatic UT exams were performed. *Manual exams require little or no data analysis as the examiner performs and records the data during th~ examination process~ Of the 126 examinations, only twelve required analysis. These were analyzed as root geometry or beam redirection. No defects were recorded. All other UT reports had no reportable indications and therefore, needed no analysis. The licensee supplies the non-dest~uctive examination contractor with previous UT data to help in the analysis of indications. However, t~is is not a requirement of the UT procedures, Code, or contract .. The 18

.

review of previous UT data analyses is not*a requirement of the contract with the licensee. NRC inspector review of the licensee's contract with General Electric, th~ tontractor, for this outage found *that General fl~ctric wa~ required to submit completed copies-of the "Manual U.T. Reports: By the end of the next work day following the day in which the * examination was performed." This requirement was.not restrictive and did not present a safety issue.

The NRC inspectoi concluded that the contractor supervisor directed the UT inspectcirs.to c~mpl~te the UT data sheets within a reasonable time period, which sh6uld not have created a*hardship on the UT inspectors~ The NRC inspector c6uld n6t substantiate that 99 examinations were

• performed during one production day.

No violations* or deviations were identified. 11. Systematic Eva 1 uati on Program (SE.Pl Items* (92701} . . . . . . (Open) ~ystematfc E~aluation ~rogram Topi~ VI~4, "Leakage C~nditions under Which*the Remote Manual Isolation Valves on low Pressure Coolant* Injection (LPCI) and Core Spray Syst_ems Should be Isolated are Incorporated Into the Emergency Procedures". Thi~ item was reviewed and closed ih a previous inspe(tion report .. Subsequently, a region based

• inspector reopened the matter in inspectio_n report 237/91032; 249/91035.

Further NRC review is necessary to close this item. *The SEP discussed the need for closure of manual v~lves on both the suction ahd discharge . lines of the. LPCI and core spray penetrations. Cloiure of isolatiort

valves in the suction line~ has been incorporated into appropriate procedures and was the basis for the original closure of this topic. However, additional review as to how the discharge val~e closures were ~ddre~sed remains to be reviewed .. *

No viol.ations or deviati~ns were identified. 12. R~qion~l Requests In response to a regional management request the inspectors evalu~ted the l~censee's response to the General Electri.c service information letter 475. Special testirig was performed to dete~mine the diffe~ential ~re~sure corresponding to 300% steam flow for the high pressure coolant injection system high steam flow isolation setpoint. These setpoints were found to be 90 inches and 75 inches of water for Uni ts 2 and* 3 respectively. Presently Technical Specification 3~2.1 for Units 2 and 3 show a setpoint of 150 inches of water. A revision of the high pressure coolant injection high steam flow isolation instrumentatiori trip level . setting has been proposed. *This change was a result of the revision of the calculation method used to determine the steam flow set point. No violations or deviations were id~ntified. 19

13. Mana~ement Meetings C30702l On February13, 1992, NRC Regional Management met with CECo Corporate and Stati.on Management at* the Dresden Training Center. The purpose of* the meeting was to update NRC personnel on the licensee's short-term.and 1 ong-term corrective actions to, improve *performance at the Dresden Station. Discussion centered upon the Dresden .Performance Improvement Act1on Plan and resources availability. Also onFebruary 13, 1992, a technical meeting on recent maintenance problems was h~ld at th~ Dresden Training Center with representatives. from NRR. and Reg iOn II I. 14. Open Items.* . Open items are matters which: have been discussed with the licensee;. will be further reviewed by the inspedor; and involved some actions on -the part of the NRC, licenseet o~ both. An open item disclosed during *

• the inspection is ~iscussed in paragraph 2~e. *

15. Unresolved Items * Unresolved items are matters wh~ch require more information in order to ascertai~ whether they are acceptable itemsi disclosed during the inspection are discu~sed in paragraphs 8.d and 9.a.

16. Violations For Which A "Notice of Violation" Will Not ~e Issued . The NRC uses the Notice of Violation as a standard method for formalizing the existence of a violation of a legaliy binding requirement. However, because the NRC wants to encourage and support * li~ensee's ihitiatives for self-identification and correction of problems, the NRC will not generally issue a Notice of Violatioh for a violation that ~eets the requirements set forth ih 10 CFR 2, Appendix C, Section V.A. These tests are: 1) the* violation was identified by the. licensee; 2) the violation wo~1d be categorized as Severity Level IV or V; 3) the .violation will be corrected,.,including meas.ures to pr.event recurrence, with a reasonable time period; and 4) it was not.a violation that could reasonably be expected to have been prevented by the

Licensee's correCtive action for a previOus violation. A violation of regulatory requirements identified during the inspection for which a

• .Notice of. Violation will not be issued is discussed in paragraph 8.b.

17. Exit Interview .. '* The inspectors met with licensee representatives (denoted in paragraph * 1) during the inspection period and at the conclusion-of th~ inspection period on February 28, 1992 and March 2, 1992._ The inspectors summarized the scope .and results of the jnspection and discussed the . likely content of this inspection report. The licensee acknowledged the information and did indic.ate that some of the information disclosed during the inspection could be considered proprietary in nature*. The information that could be considered proprietary, is not contained in this .,report. * * .. __ - c ~-.

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