ML17177A548
| ML17177A548 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/22/1992 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A546 | List: |
| References | |
| 50-237-92-14, 50-249-92-14, NUDOCS 9207280345 | |
| Download: ML17177A548 (19) | |
See also: IR 05000237/1992014
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REGION II I
Report Nos~
50-237/92014(DRP)~ 50-249/92014(DRP)
Docket Nos.
50-237; 50-249
Licensee:
Conunonwealth Edison Company
Opus West II I
1400 Opus Place
Downers Grove, IL 60515
License Nos. DPR-19; DPR-2S
Facility Name:
Dresden *Nuclear Station, Units 2 and 3 *
Inspection At:
Dresden Site, Morris, Illinois
Inspection Condu_cted:
May 29 through July 6, 1992
Inspectors:
W. Rogers
M. Peck
M. Miller
R. Zuffa, Illinois Department of Nuclear Safety
Approved By~* ~J.4.
7,~i#~.,
Brent Clay~, Chief,
- ~
Reac~or Projects Branch 1
Inspection Summary
Inspection from May 29 through July 6. 1992 {Reports No. 50-237/92014CDRPl:
50-249/92014CDRPll.
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Areas Inspected: A routine, unannounced safety inspection was cbnducted by.
the resident inspectors and an Illinois Department of Nuclear Safety
inspector .. The inspection included followup on previously identified items
and licensee event r~ports; review of operational saf~ty, monthly mairit~nance,
and surveillance activities; and event fol)owup.
Inspection modules us~d
during this inspection were:
61726, 62703, 71707, 92700, 92701,
9~702, and
93702.
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Results~ Of the six areas inspected, violations were identified in: two of
them (see sections 2.s & 5.a}.
The first violation, with multipl~ exa~ples,.
dealt with procedural and personnel performance inadequacies in establishing
and maintaining the prop~r level in the diesel generator day tanks.
The
second violation, also with multiple examples, dealt with maintenance
instruction and operational personnel performance inadequacies associated with
the replacement of an oil pump motor.
One non-cited violation was di~cussed
in section*2.k.
One open item associated with future licensee actions to
improve the performance of the reactor water cleanup system was
ide~tified.
9207280345 920722
ADOCK 05000237
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Plant Operations
Control room operators were professional and knowledgeable of-annunciator
alarms.
However, some instances of lack of attention to detail were observed
both inside and outside the control room. Also, weaknesses in the operator
training program as it relates to Technical Specifications were noted.
No
di scernabl e change in operator identification and* re solution of hou*sekeep'ing
.deficiencies was noted.
Maintenance/Syrvejllance
- The maintenance area provided two contrasting performance levels. The 2/3
diesel generator overhaul reflected well-coordinated and executed performance.
In contrast, .the high pressure coolant injection oil pump replacement did not~
No strengths or new weaknesses were identified iri the surveillance area. *
Safety Assessment and Quality Verific~tion
A continuation of' inadequacies in the corrective action system were
identified. These inadequacies dealt with untimely corrective action and
management's lack of knowledge of the overdue corrective actions .
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DETAILS
.1.
Persons Contacted
- C. Schroeder, Station Manager
- L. Gerner; Technical Superintendent *
- J. Kotowski, Production Superintendent
T. O'Conner, Assistant Superintendent, Maintenance
- J. Achterberg, Assistant Superintendent, Work Plarining .
G. Smith, Assistant Superintendent, Operations
- M. Strait, Technical Staff Supervisor
R. Radtke, Regulatory Assurance Supervisor
- E. Carrol, Regulatory Assurance
~D. Saccomando, Nuclear Licensing
- M.
Pape~ Quality Contr61.
- D. Karjala, Performance Improvement
- R. Flahive, Performance Assessment
- K. Vales, Nuclear Safety Administer
- R. Meadows, Maintenance Staff Supervisor
- B. Zank, Operating Engineer
- C. tollins, Site NED Engineer
- -* ----*.- -*.
- Denotes those attending the exit interview conducted on July 6~ *1992.
The i ns.pectors also talked with and interviewed several *other licensee
employees during the course of the inspection.
2.
Licens~e Action on Previouslv Id~ritified Ite~s*c~2701. 92702}
a.
(Open) Viol at ion (23.7 /9002*3-02(DRP)):
"Failure to fol J ow
procedures during m~intenance and operational evolutions." .In
response to the violation, the licensee conunitted to (1) provide
.additional procedural direction on when to monitor reactor cavity
water level, (2) add valves to the locked valve checklists,
- (3) upgrade radiation protection survey maps to include equipment
identification numbers, (4) evaluate the need for a reactor caviti
and dryer/separator pit level indication, and (5) reconfigure the
adjustment screws on the torus-to-reactor-building differential
transmitters for ease of access.
The inspector reviewed the corrective actions and de~ermined them
to have been sati~factorily accomplished with the following th~ee
exceptions:
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One valve and the operating notes for two other valves were
omitted from the locked val~e checklist.
The installation method for the reactor cavity level
indicator was not included in appropriate procedures.
The
licensee determined only one reactor cavity level indicator
3
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was needed since the shield blocks separating the dryer and
- separator pit areas are removed prior to raising reactor
vessel water level, allowing the dryer/separator areas and
the reactor vessel to function as one pool. A level .
indicator was fabricated and used 4uring the most current
Unit 3 refuel outage.
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A decision was made to replace the torus-to~r~actor-building
differential transmitters in lieu of reorienting them.
Two
of the four transmitters have been replaced with the last *
two scheduled for replacement at the next Unit 2. refueling
outage. *
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The licensee properly revised the locked valve checklistS prior to
the end of the inspection period. This violation remains open
until th~ other two corr.ective actions are.completed.
b.
(Closed) *Violation (50-237/91016-03(DRP)):
"Failure to report
- cracked reactor* vessel studs via the einergency not i fi cation
system." After issuance of this violation, the licensee conunitted
to substantive upgrades in the information available to onshift.
management for reportability determinatiOns.
However, a number of
the corrective actions were not performed or were ineffective* as
discussed in inspection report 237/92009(DRP); 249/92009(DRP}, and
will be tracked through that report. This item is c.losed.
c.
. (Closed) Unresolved Item (50-237/91022-04(DRP)):
~Improper
movement of control*rods to clear an annunciator alarm." As a
result of the licensee event evaluation, control rod movement
instructions were simplified and operators were retrained. The
inspector confirmed* completion of these corrective actions, and
determined the root cause of the event to be failure to follow
procedures coupled with confusing instructions. This event and
its root causes parallel previous enforcement actions (see
inspection report 237/91040 (DRP); 249/91044(DRP)) of this same
time frame.
Therefore, no enforcement action is warranted. This
. matter is closed.
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d.
(Closed) Violation (59-237/91022-IO(DRP)):
n1nadequate corrective
actions for operators failing t~ report an engineered safety *
feature (ESF) actuation. n .Corrective actions were inadequate to .
- preclude repetition of ESF reporting failures. The inadequacies
in the.corrective action system were discussed in inspection
report 237/92009(DRP)~ 249/92009(DRP}, and will be tracked through
that report. This item is closed.
e.
(Closed) Unresolved Item (50-237/91025-03(DRP)):
Rfailure of
operators to recognize entering a Technical Specification action
statement when torus water temperature exceeded 95°F (the
Technical Specification Limit).n This unresolved item was an
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- example of escalated enforcement violation 237/9103~-0l, and will
be tracked under that number.
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. f. -
- (Closed) Violation (50-237 /91027-0l(DRP)): *"failure to maintain a
monitor in attendance while the reactor building trackway inner
door was open as required by procedure.* Corrective actions
- included additional tailgate tr~ining*to all plant personnel and*
issuance of an operations department memorandum concerning
management expectations that personnel infrequently using the
trackway door key be questioned about the intended use of the- key
and their understanding of applicable administrative controls*,
.prior to being .issued the key. Licensee corrective action was *
considered adequate_ and this* i tern is closed.
g.
-(Open) Violation (50-237/91027-02(DRP)):
- failure to correctly.
translate: the reactor building trackway door seal modification
into appropriate procedures and instructions.* Prior to returning
the seal to a passive des-ign, operating instructions were pr.ovided
on how to operate the door seal. The licensee reviewed nu~erou~
past work requ~sts for applicability to the minor plant change *
program with one work request identified as appropriate to the
minor plant change program. Also, a task force was formed to
review the criteria for minor design changes.
The task force
reconunendations are to be completed by July 31, 1992, *with an -
implementation plan developed by September 25, 1992. This
- violation will remain op~n p~nding review ~f the task force's
reconunendations as well as the station's implementation plan
concerning those reconunendations.
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h.
(Closed) Violation (56-249/91022-02(DRP)): - *inadequate Technical
- Specification channel _check procedure." As corrective action to
the violation, the licensee revised the channel-check procedures
to include acceptance criteria and a definition for *channel
check." The torus wide range level transmitters were replaced and
operators were trained. The inspector confirmed completion of the
licerisee's corrective actions through record review~ This matter
is closed.
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i.
(Closed) Unresolved (50-249/91025-05(DRP)):
- underlyin~ cause of
a spilJ via a bank of hydraulic control unit drain valves." After
. further inspector review, this unresolved item was made an example
of escalated enforcement violation 249/91038-01, and will 'be *
tracked under that number.
j.
(Closed) Unresolved Item (50-249/91029-0l(DRP)):. "Potenti~l for
exceeding a welding hold poirit.* The inspector interviewed
welding supervisors and reviewed the specifics of the situation.
The inspector determined that personnel had an adequate
understanding of hold point concepts .. This matter is closed ..
k.
(Closed) Unresolved Item (50-249/91029-02(DRP)): "During the
inspection of the emergency_,diesel generator main _bearings, the
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bearings were removed from the crankcase without a written .
revision to the procedure." This was determined to be a violation
of 10 CFR 50, Appendix B, Crit~rion V, "Instructions, Procedures, _ *
and Drawings." However, the violation is*categorized at Severity
Level V and is not being cited because the criteria specified in* ..
Section V.A of the "General Statement of Policy and Procedures for
NRC Enforcement*A'ctions" (Enforcement Polley, 10 CFR-Part 2,.
- -Appendix C ( 1991)) were satisfied.
l.
(Closed) Unresolved (50~249/92005-05(DRP)): "Ramifications of a
missing junction box support bracket from a main steam isolation*
valve (MSIV) manifold-for over two years." The licensee
imniediately installed _the bracket and evaluated the operability of
the MSIV with the missing bracket. The analysis concluded that
- the valve was operable. The inspector reviewed the*analysi~ and.
agreed with the conclusion. The licensee conunitted to add support
brackets to the MSIV integrity checklist to assure proper
installation after maintenance. This matter ts closed.
m.
(Open) Unresolved Item (237/92005-06(DRP)).
"On Aprll 2, 1992,
the Unit 3 Reactor Operator observed only 5,600 gallons per minute
(GPM) total containment cooling service water. (CCSW) train flow.
The flow rate was considerably less .than the 7 ,000 gpm specified
in DOP 1500-02, "Torus Water Cooling Mod~ of Low Coolant lnjettion
. System* and the UFSAR values.* This issue was considered
unresolved pending inspector evaluation of the. licensee's low
pressure cool~nt injection system (LPCI) heat exchanger duty and
suppression pool temperature calculation, the 10 CFR 50.59 Safety
Evaluation for the 1988 heat exchanger tube ~odificati-0n, and the
original General Electric (GE) design calculation to support the
origin~l system design. _
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The original LPCI heat exchanger duty calculation could not be
retrieved by GE.
A new ca lcul at ion was performed and resulted in
a 9 percent reduction in the heat. removal capability fo~ the one
CCSW pump/one LPCI pump operation mode, referenced in the plant
process diagram.
No margin existed in the original one pump/one
pump mode. *Therefore, the 9 percent decrease in capability
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resulted in a post accident bulk torus temperature in exc~ss of
the 18d°F design acceptance criteria.
Although the documentation reviewed. was not conclusive, there wa:s
- .a strong indication that the. *May-Witt" decay heat input method
. was used in the original containment heat removal design at the* *
Dresden units.
GE based the operabiHty evaluation on a
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comparison of the normalized *May-Witt* decay heat input to a more
recent and realistic decay heat curve obtained from standard
ANS 5.1-1979 *Decay Heat Power in Light. Water Reactors."
In the
original analysis, the maximum peak suppression pool temperature
occurred at the 22,000 second point on the curve. At this point
the normalized *May-Witt" point was approximately 15% greater
magnitude- than the ANS 5.1 value. _The __ licensee_ concluded. that
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successful post accident ~itigation-would ensue b~c~use the more
realistic decay heat calculation methodology compensated for the 9
- percent decrease in heat remova 1 capability~
The inspector confirmed the accuracy of the new heat exchanger **
duty calculations. -However, reliance on the 15 percent difference
at the 22,000 *second point was considered a non-conservative
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- assumption versus integrating the heat input differences between .*
the two decay heat;methodology results~ Even though. the plant *
configuration* was outside of the:containment heat removal accident
analysis, .. the inspector concluded that an hvnediate safety concern
.di.d not exist~* This was .based upon additional available heat . *
transfer area and.the current and projected maximum ultimate heat
sink temperatures.' To resolve the issue, the licensee committed
to complete a containment h~at transfer analysis, us.ing the new
heat exchanger duties, by December. 1, 1992. This issue will
reinain unresolved, pending NRC review of this heat removal
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analysis and th_e 10 CFR 50.59 Safety Evaluation for the 1988 heat
exchanger tube material replacement.*
.(Closed) Unresolved Item (237 /91022-03(DRP)):
nPerformance of.
core spray pump surve 11 lance with suet ion source i so 1 ated." Upon
further review, the inspector ascertained that the applicable
Dresden Emergency Operating Procedure directed operators to line
up and operate only one core spray pump with suction from the
condensate storage tank {CST), provided the redundant operating~
.core spray _pump was taking suction from the torus. Therefore;. the.
safety signiflcance of aligning a core spray pump to the isolated
CST wa*s diminished;
The critical drawings in the control room
were properly revised to reflect the true position of the manual
valve to th~.CST and revision t~ the Dresden Operating.
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Surveillance, DOS 1400-04, was initiated. This matter.i~ closed.
(Open) Violation {237/92005-02e(D~P)): nFailure to follow
procedural steps of the 18 month undervoltage and emergency core
cooling integrated.fu~ctional test." The licensee's June 5, 1992,
response to this violation included a commitment to revise the
surveillance procedure by January 31, 1993. This date coincided*
. ~ith the next scheduled performance of the functional test *
. However; the licensee could use the surveillance procedure for
- post maintenance testiri~ prior to that date ~ithout revising it~
eontents. The inspectordistussed the matter with applicable
licensee personnel.* Subsequently, the licensee revised the*
commitment to state that the procedure would be revised before it
was used again.*
(Open) Violation {237/91035-02{DRP)):*ninadequate out-of-service
and operator turnover procedure." In the -violation response, the
licensee committed to revise the out-of-service procedure by June
1, 1992.
The inspector determined that this commitment was not
met. *Also the corrective action was not identified as being.
-overdue- in the=-Hcensee! s __ .i nterna l conuni-tmenLtr.ack.i ng, _systel'!I *.
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After the inspector informed the Jicensee, the procedure was
.* temporarily revised~* Further correct he actions to this violation
. will be reviewed in future inspection periods.
q~ *
(Open) Violation (237/91035-0l(DRP)): '*failure to follow
procedures causing a Technical .Spedfication to be exceeded.* One ..
- of the correcti.ve actions of the violation was to either combine
or revise two of the licensee's Technical Specification
interpretations by May 17, 1992. * The inspector determined the
- interpretations had been drafted. but had yet to.be*approved~
Also, the overdue conunitment*was not identified on the licensee's.
internal conunitmenttracking system as overdue. After the
inspector informedthe licensee of the situation, the
foterpretati oils were approved and .issued. Further corrective *
actions to this violation will be reviewed in future inspection
periods.
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(Clos~d) Unresolved Item (237/92010-0S(DRP)):
- ope~ability
.ramifications of degraded high pressure injection (HPCI) system
drain pot v*lve.n The inspector reviewed the licensee's
operability determination as discussed in LER 237/92015 and
considers the issue closed.
s.
(Closed.) Unresolved Item (237 /92010-03(DRP)):
"Ernergen.cy diesel
- generator (EOG) day tank level administrative control. n.
During a
revi~w of the center desk reactor operator's log book of April 2,
1992, the inspect~r noted that the shift engineer directed a non-
1 icensed. operator to clear the 2/3 EOG day tank level alarm by
draining the day tank.
The draining was terminated.prior to
clearing the alarm due to a plugged floor drain. The log entry
indicated that although the high level alarm was.not.clear, the ..
level was now below the surveillance specified level of 40 inches,
so the non-licensed operator refilled the tank to 40 inches.
Further inspection into the EOG day tank level maintenance
history, and the basis for the minimum level, *revealed the.
following:
In June 1991, due.to licensee concerns fro~ a recently
completed electrical inspection at Quad Cities, a fuel
consumption test, SP 91-6-70, was performed on all three
EDGs to determine the minimum required day tank level
necessary to support four ho1.1r operation of the EDGs. *The
Unit 2 and 3 EDGs test was performed at a load less than .the*
final safety analysis report (FSAR) established rated load
of 2600 .kW.
The test procedure specified a kW range of
between 2500 kW and 2600 kW.
As a result, the test results
were non-conservative for the Unit 2 and 3 EDGs.
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.DOS 6600-1 *oiesel Generator Surveillance Test" was revised
to establish minimum day tank levels based upon the fuel
consumption tests.
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On November 8, 1991, DOS 6600-1 acceptance criteria for the
EOG day tank level were changed through a temporary change
request '(TCR) to prevent the diesel generator daytankhi .
level alarms from being continuously displayed in the
control room. *A safety evaluation screening of the
procedure change concluded that a safety evaluation- need not
be done~ As a result of the change, the minimum required
level for the 2/3*EDG day tank was below that determined by
the June fuel consumption test.
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On April 28, 1992, DOS 6600-1 accept~nce criteria for the
EOG day tank levels was again changed through a iCR to abo.ve
the minimum level determined by the June 1991. fuel
consumption test.
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OAP 9-06, _*Temporary Changes to Procedure," sections 8.3 and
4, does not allow the intent of a procedure to be changed *
through a temporary change request but only through a
procedure revision.
.OAP 10,..2, *10 CFR 50.59 Review Screening and Safety
Evaluation,* form 10"."'2A steps 1 and. 7 directs the user to* .
perform a safety evaluation when a test/experiment procedure
was changed,. unless the change was purely editorial in
nature.
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OAP 7-14, *control and Criteria for Locked . .Equipment and .
Valves,* required final valve position for~ locked.valve be
independently verified by two individuals and documented in
the unit log book. This independent verification was not
performed on the 2/3 day.tank drain valve on April 2, 1992.
Licensee *management expectations were that the EOG wou 1 d be
.able to operate for four hours off the day tank as a *
condition of operability of EOG.
Thfs information was not
provided to the operating crews.
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The inspector identified thatthe 2/3 day tank was below the
minimum.specified to support the four hour run on May 5,
- 1992 .. That same day the licensee identified the unit 2 day *
tank below the four hour minimum.
No explanation of how the
tanks were so low could be ascertained. Both tanks were
- immediately fi 11 ed.
- , The operator rounds sheet for day tank level only required
- the 2/3 day tank be checked and did nqt required the 1 evel
be rec6rded.
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Subsequent discussions with the licensee's de~ig~
organization identified a one hour operation of the EOG as
the EOG coridition of operability. The engineering position.*
was reasonable based upon licensing document review and
discussions with cognizant Nuclear Reactor Regulation
personnel. Therefore, the EOG was not inoperable.when the
day tank level was below the four hour consumption level.
Froin this review the inspector cone 1 uded that a number. of ex amp 1 es *
of a 10 CFR 50, Appendix B, Criterion V violation had occurred.
These were:
Failure to provide an appropriate fuel consumption test
procedure ~n June 6, 1991, as it related tri tha acceptable
kW loading of the EDGs during the. test (237/92014-0la(DRP)}.
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Failure to follow OAP 9-06 when technical staff personnel.
altered the intent of DOS 6600-1 through TCR 91-320, on
November 8, 1991, and TCR 92-201, on April 28, 1992, for DOS
660~-l {237/92014-0lb(DRP)).
.. Failure to follow OAP 10:-02 when technical staff personnel.
failed to perform a safety evaluation on the effect of
changes TCR 91-320, on November 8, 1991, and TCR 92-201, on
April 28, 1992, on DOS 6600-1 (237/92014-0lc(DRP)).
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Failure to follow OAP 7-14 on April
2~ 1992, when.opetators
did not independently verify the position of the 2/3 EOG day
tank drain ~alve following manipulation of the valve
(237/92014-0ld(DRP)).
One violati.on and no deviations were iden.tified.
3.
Licerisee Event Reports Followup {92700)
The following licensee event reports were reviewed to ensure that
reportability requirements were met, and ~hat corrective actions, both
immediate and to prevent recurrence, were accomplished in accordance
~ith the:technical specifications:
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a.
(Closed) LER 237/91013, Potential Degradation of Secondary
Containment Involving Reactor Building Trackway Doors Due to
Personnel Error
b.
(Closed)
LER 249/92001, Primary Containment Isolation Valve
Closure Due to Shutdown Cooling System Spurious Isolation
c.
(Closed) LER 249/92002, Primary Containment Isolation Valve*
Closure Due to a Damaged Control Relay
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LERs 92001 and 02 were duplicates of the same event~ The licensee
originally attributed the first event to unknown reasons. The
inspector considered both events to be due to a damaged isolation
relay, probably caused by outage electrical cable pull activities~
d;
(Close~) LER 237/92004, Reactor Water Cl~anup System Primary
Containment Isolation *Valve Closu.re Due to Procedure Deficiency
e.
(Closed) LER 237/92014, Primary Containment Isolation Valve
Closure Due to Reactor Water Cleanup System. Isolation
f...
(Closed) LER 237/91019, Primary Containment Isolation Valve*
Closure Due to Reactor Water Cleanup System Isolation
g.
(Closed) LER 237/91033, Primary Containment Isolation Valve
Closure Due to Reactor Water Cleanup System Isolatitin
h.
(Closed) LER 237/91038, Primary Containm~nt Isolation Valve
Closure Due to Reactor Water Cleanup System Isolation
i.
(Closed)*LER 237/91004, Unit 2 Reactor Scram and Containment
Group I Isolation Due to Main Steam Line High Radiation Caused by
Resin Intrusion
LERs 91004~ 91019, 91033, 91038, 92004; and.92014 all dealt with
RWCU isolations due to design/equipment inadequacies of the*
demineralizers and the pressure/flow control valves ..
On June 11, 1992, the inspector met with the cognizant technical
personnel to review the status of design and repair initiatives on
the RWCU system. Corrective actions yet _to be acc_ompl ished .are:
Replacement of the 28 and 2C demineralizer post strainers
e
Repair of the 3C demineralizer underdrain
Inspection of the 2A, B, C, 3A and 38 underdrains
Replacement of the pressure control valve (1217) with an
18 stage drag valver
Replacement. of the flow control. valves,. 1219 and 1220.
Completi~n of these corrective action~ is consid~red an open it*m
(237(249)/92014~02(DRP)).
During the meeting, the licensee also discussed planned D2Rl3
inspections of the piping most susceptible to intergranular stress
corrosion cracking and potential piping replacements.
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(Open) LER 237/91034, Primary Containment Isolation .Valve Closure
due to Reactor Water Cleanup (RWCU) System Isolation
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On October 12, 1991, while in economic generation* control (EGC)
the unit 2 reactor operator observed the RWCU surge tank level low*
annunciator flashing *.. Due to pressure .. oscillations in the system *
the level indicator's -reference leg had filled causing an *
artificially low level indication *. The operator observed the
pressure oscillations and transferred the pressure control valve
to manual to compensate for pressure changes.
However, the
attempt was unsuccessful and the system isolated on high pressure
. closing the containment isolation valves.
Due to the previously *
identified design/equipment deficiencies in the pressure control
portion of RWCU; the operator must track pressure/flow changes
caused by EGC and compensate on occasion. * However, *the
pressure/flow recorder was malfunctioning.*
.. The lack of audible alarm upon receipt of the surge tank low level
alarm was due to original annunciator trigger design .. Jf, during
annunciator window testing, the *Annunc;iator Reset" pushbutton is
depressed to reset the fl ashing panel windows, without first
. depressing the "Acknowledge". pushbutton, the first annunciator
window to alarm in the panel following the test, would flash, but
would not give an audible alarm. This condition is only
.applicable to the Unit 2 RWCU/Rx Recirc panel.
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The licensee repaired *the pressure/flow recorder, and issued a
memorandum as part of operator required reading on December 17,
1991, discussing the annunciator anomaly.
The LER stated that
this annunciator anomaly would be resolved as ~art of the ongoing
_annunciator design change to _be completed at Unit* 2's next ref1Jel
outage. Additional corrective* actions associated withRWCU
pressure/flow ~ontrol were discussed as identified in the previous
sub-paragraph.
The inspector confirmed the pressure/flow recorder was repaired
and the annunciator memorandum issued. However, when control room
operators were interviewed on June 17, 1992, the majority of the
Qperators did not recall the annunciator anomaly. *Also, upon
conferring with the annunciator system. engineer as to whether the
anomaly would be rectified by the design change, .the engineer
indicated he was not aware of the anomaly or whether the design
change would remedy the problem.
The LER will remain open pending
further review of licensee corrective actions.
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(Closed) LER 237/91002, Reactor Head Stud Outside FSAR Allowables
for Toughness
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(Closed) LER 237/91032; Actuation of Group l Isola~ion Valves Due
to Personnel Error During Placement of Jumpers
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m.
(Closed) LER 237 /91036, Primary Containment Isolation Valve
Closure Due to Shutdown Cooling System Spurious ls9lation
No violatioris or deviations were identified in this are~.
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4.
Operational Safety Yerjficatjon CZlZOZl * *
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The inspectors reviewed the facility for conformance with the 1 icense ...
and with regulatory *requ.i rements.
a.
On a sainp ling basis,' the inspectors observed* contro 1 r,oom
activities for proper control.room staffing and coordination of
. pl ant activities. Operato.r adherence to procedures or Technical .
Specifitation and operator cognizance of plant parameters and
alarms was observed. Electrical power configuration was
.
confirmed. Various logs and surveillance records-were reviewed
for accuracy an~ completeness.
Observations included:
Control room operator log entries continued to' be of good.
quality.
- *
- Unit 2 operators fai)ed:to initiate a work request or
- *
otherwise document a malfunctioning RWCU indicator. The
inspector identified the condition on June 22nd and
concluded from discusstons with operations personnel that*
the condition had exi~ted ~ince June 19th .. Subsequ~ntly, ~
work request was initiated. *
On.May 26, 1992, the division B core spray differential
pressure transmitter failed calibratfon. This* transmitter
is identified in Techni~al Spe~ifications as part of the
core spray.system.
No explicit Limiting Condition for
Operation Action Statement exists for an inoperable
transmitter, only for an *inoperable core spray division.
The Shift Engineer did not declare the core spray division* .
inoperable since the division could inject water into the*.**
reactor ves~el. The inspector considered this decision non-.
conservative since the instrument was necessary to meet al.l .
the.Technical Specification requirements for core spray.
Before expiration of the Technical Specification Action -* *
Statement, the licensee completed an engineering evaluatirin
and concluded that the portions of the transmitter's range *
that had failed calibration were not necessary for the
instrument to complete its safety function; Based upon the
engineering eval Liat ion, the inspector. agree_d that the ...
transmitter was operable. However, the original Shift*
Engineer operability decision was reflective of inadequacies
in the operator training on Technical Specifications. This.
matter was discussed with the Assistant Superintendent of
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l
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..... -- '-*-" ._....,,..:_.......;::...*
- , b *~-c- -* *
Operations along with the recently issued Generic Letter on
operability.
b.
On a routine basis the inspectors toured .accessible areas of the
facility to assess worker adherence to radiation protection
controls and the site security plan, house~eeping or cleanliness,
and control of field activities in progress.
Observations included:
An unsecured portable stair was observed
- i.n each of the Unit 3 emergency core coo 1 i ng system ~orrier rooms.
Both of the portable stairs were located next to safety related
instrument panels. The licensee was informed of the condition and
the stairs were properly secured.
The inspector will.continue to
observe for similar instances of unsecured equipment during future
routine wa 1 kdowns and facility tours.
c..
Walkdowns 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
availabil.ity. Tagouts and jumper records were reviewed for
accuracy .where appropriate. The ESFs reviewed were: *
Unit 2
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Low .Pressure.Coolant Injection System
Unit 3
Low Pressure Coolant Injection System
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2/3 Standby Gas Treatment System .
Unit 2/3 Diesel Generator
Emergency Electrical Busses 23-1 and 34~1
No violations or deviations were identified in this area.
5.
Monthly Maintenance Observation C62703l
Station maintenance activities were observed to verify that they were
conducted in accordance with approved procedures and work packages,
regulatory or industry guidance, and in conformance with technical
specifications limiting conditions for operations. The inspector~ .
verified that approvals were obtained prior to work initiation, that
quality control -inspections occurred, that appropriate post-maintenance
functional tests or calibrations were performed, that maintenance
personnel were qualified, that parts and materials.used were properly
certified; and that proper radiological and fire prevention controls
were implemented.
The status of outstanding jobs was also reviewed to
ensure that appropriate priority was assigned to maintenance of safety-
rel ated. equipment which could affect system performance.
14
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The following ma~ntenance activities were observed and reviewed:
Unit 2
Troubleshooting of the 28 RWCU Pump
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- Replacement of IriitiaHzation Control for the Rod Worth Minimizer
Reactor Feed Pump (RFP} Seal Replaceme~t ~nd Installation of
Monitoring Equipment
HPCI Auxiliary Oil Pump Motor Replacement
Unit 3.
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Setpoint Change to the Secondary Undervoltage Relays on the 33-l .
. and 34-1 Electrical Busses
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- RFP Seal Replacement and Installation of Monitoring Equipment
Unit 2/3 EOG Five Year Inspection and Overhaul
Inspection and Preventive Maintenance of the 250V Battery Chargers
Inspe'ctor *observat ii:>ns were:
a.
During the HPC I auxiliary oil pump motor rep 1 acement severa 1
examples of poor work instructions and practices were noted:
Following motor replacement~ a rotational test indicat~d the
motor turning in the wrong direction. Since the motor was a
direct current shunt type either the armature or the field .
polarity should have been switched at the motor to reverse*
rotation. The procedure incorrectly instructed the worker
to switch the leads at the motor control center. The
armature and field shared a common wire leading to the motor
control center and switching the wires at the motor control
center resulted in burning out the new motor .. The failure
to provide appropriate instructions 1s considered an example
of a violation of 10 CFR Part 50, Appendix B, Criterion V,
{Violation 237/92014-03a(DRP.
Following the second motor replacement, the inspector observed the suction strainer to the auxiliary oil pump was being installed in what appeared to be the wrong orientation .. Quality control and the mechanic both assumed the orientation was correct; however, the flange was not punched marked and the work package contained no information on the orientation. The acting technical staff engine~r for the system was not aware of a specific orientation and
suggested the mechanic could look at the Unit 3 HPCI configuration. Techn iea l staff rev i e.wed the vendor manua 1 .and the work analyst contacted the vendor. They independently determined that the sucti<>n strainer was being installed in the wrong orientation. Guidance was added in the work package to correct the problem. 15
.~*.---..::.._.., __ ..._ ____ ..,...w..;.-....,...i.,.._ _____ ~-*~** ~-~..;... ..... g:;-;:=**=***:.o ... * ..... 1-*. =-* ..... * =-c=**.-.r=**-* -*** ...... _.,......_. ~-..:....~.~-*
_.., _____ ,...:,. * *
- An interview with the cognizant technical.staff engineer
revealed that he had observed the suction strainer being installed in*the wro~g orientation during the first motor change-out~ He informed the mechanic of the correct . orientation but no change to the wo.rk*package was made. Interviews with the mechanical work analyst and the mechanical foreman indicated that the normal practice for mechanics was to punch.mark flanges prior to disassembly. Based on this practice, the work analyst. di.d not consider * instructions were required to direct the mechanic to punch mark the flange or to indicate the orientation of the suction strainer. During inter.views, the Conunonwealth Production Training Center staff .stated that mechanics from both nuclear and fossil plants are trained at their facility. Due to the diversity of the classes, the module containing flange * marking teaches the methods that may be used to mark flanges and instructs the mechanics to m~rk flanges asdirec.ted in the work package. Training provided at Dresden provided no . further instructions regarding the need to mark flanges when -the work package did not provide guidance. Despite the belief by many station personne.l that mechanics marked all flanges prior to disassembly, this was not part of the .mechanic's formal training and, in this case, the marking of flanges prior to disassembly did not Qccur. The lack of instructions to match mark the flanges or provide sufficient orientation information for the flange is an example of failure to provide appropriat~ instructions and is a violation of 10 CFR Part 50, Appendix B, Criterion V~ (Violation 237/92014-0lb(DRP)). *
During the refilling of the HPCI oil reservoir, smoke was noted coming from the.tank. It was later determined that the HPCI oil heater had been left on while the tank was drained and as the added oil came in c6ntact with the heater, smoke resulted. The filling of the tank was halted and the heater was turned off.
An out-of-service (OOS) for draining the HPCI oil tank was completed prior to the first motor change -0ut. However, due to the time tonstraints of the job, operations perstinnel decided to perform the second draining of the oil tank rather than have maintenance workers perform the task. * Al though an OOS was hung for the _auxiliary oil pump, there was no OOS used specifically for the second oil tank draining. As a result, the oil heater and other items identified in the OOS for the first oil tank draining were* not checked prior to the second draining. Operations 16
failing to use an OOS prior to' draining the .ofl tank is an example of failure to provide adequate instructions and is a violation of 10 CFR Part 50, Appendix 8, Criterion V, (Vi-0lation 237/92014-03c(DRP)). b. Overhaul activities on the 2/3 diesel generator were well planned and executed reducing the time the licensee was in the Technical Specification Limiting Condition for Operation Action Statement.
- Each cylinder's power pack assembly had its own dedicated floor
space. The maintenance foreman maintained a log of the activities in progress .. These actions ultimately saved time in the engine disassembly process, and enabled maintenance, engineering and* vendor support personnel to perform necessary inventories and parts evaluations, and to correctly replace the worn parts~ . *Engineering and technical support was good. Vendor . representatives were ~res~nt during the overhaul activities. On numerous occasions the system engineer and technicai supporting staff were present at the job-site. Cleanliness of the diesel engine and the general engine room area was good during overhaul activities. Cre.ws kept their work .areas n~at and orderly. Maintenance persorinel wiped and cleaned ~il and other lubricating fluids from the engine and the floor staging areas prior to ending their shift. *
One violation and no deviations were identified. 6. . Monthly Surveillance Observation (61726) The inspectors bbserved required surveillance.testing and verified procedural adherence, test equipment calibration, technical specific~tion action statement adherence, and proper removal and restoration of affected components. The inspectors reviewed completed surveillance packages to ensure that results conformed with technical spe~ification and procedure requirements,*that there was independent.
- verification of the results, that proper signoffs occurred, and that any
test deficiencies were appropriately disposttioned.
The inspectors witnessed portions of the following test activities: Unit 2
DIS 2000-01, Drywell Floor Drain and Equipment Drain Flow. Calibration -
DOS 1400-05, Quarterly Core Spray System Pump Test
DOS 1600-01, Quarterly Valve Timing 17"
. ~:r. * .. ' ' Unit 3
DIS 0287-01, Auto Blowdown Perinissive LPCI and Core Spray Pumps Discharge Pressure Switches Test
DIS 1400.-04, ECCS Fill Alarm Pressure Switch Calibration
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DIS 1700-05, Main Steam Line Log Rad Monitor Calibration
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DOS 1500-03, Containment Cooling Servke Water Pump Test
DOS 2300~01, HPCI Motor Operated Valve Operability Verification
DOS 2300-03, HPCI Full Flow Surveillance
DOS 7500-02, Standby Gas Treatment System Operability.Run No violations or deviations were identified. 7. Event Followyp (93702) D~r~ng the inspectio~ period, ~everal*events otcurred, ~ome of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The. inspectors pursued the events onsite with the licensee and with NRC officials. *In each case, the inspectors reviewed the accuracy and timeliness of the licensee notification, the licensee's corrective actions and that activities were conducted within regulatory requirements. The specific events reviewed were: a. * June 4, 1992 - Unplanned .ESF actuation of the rea~tor water cleanup system*on Unit 3. The inlet and outlet containment isolation valves closed from a high pressure signal during fill and vent activities.
- *
b.
- .*June 14, 1992 - Two unplanned ESF actuations of the LPCI system on
Unit 3. The LPCI minimum flow valve closed once while cycling another LPCI valve, 388, and again when cycling LPCI valve 21A. * Valves 21A and 388 were being cycled as part of a routine.
surveillance test.
c. June 19, 1992 - Unplanned ESF actuation of the RWCU system on Unit 2~ The inlet and outlet containment isolation valves closed from a high pressure signal apparently due to a malfunctioning pressure control valve.
d. July 1, 1992 - The licensee declared an Alert due to annunciators on four control room panels being lost about three times in five seconds. The annunciators were momentarily lost again during troubleshooting efforts .. The cause of the event was a loose connection in a copper link within a fuse hrilder~ The Alert was terminated once the cause had been identified and corrected. No violati~ns or de~iations w*re identified. 18 .. '
. 8. Open Items Open item~ are matters which have been-discussed with th~ licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bath. An open item
- .disclosed during: the inspection is discussed in *Paragraph 3.
9. Violatio~s For Which A *Notice of .Violation* Will Not Be lssyed The NRC uses the Notice of Violation to formally document failure to meet a legally binding requirement. However, because the NRC wants to encourage and support licensee's initiatives for self-identification and correction of problems, the NRC will not issue a Noti~e of Violation if the require~ents set forth in 10 !FR Part 2, Appendix C (1991), Section V.A or Y.G.l are met. A vi.olation of .regulatory requirements identified
- during* the inspection for which a Notice of Violation will not be.issued
is discussed 1n Paragraph. 2.k. 10. Exit Interview The inspectors met with litensee representatives (denoted in paragraph 1) during the inspection period and at the conclusion of the inspection period on July 6,.1992. The inspectors summarized the scope and .results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be . considered proprietary in nature.
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