ML17179A493

Insp Repts 50-237/92-23 & 50-249/92-23 on 920801-0915. Violations Noted.Major Areas Inspected:Followup of Previous Items & Lers,Operational Safety,Monthly Maint & Surveillance Activities,Events Followup & SALP Topic Followup

ML17179A493
Person / Time
Site:	Dresden
Issue date:	10/02/1992
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179A491	List: ML17179A490 ML17179A492 ML17179A493
References
50-237-92-23, 50-249-92-23, NUDOCS 9210130083
Download: ML17179A493 (20)

See also: IR 05000237/1992023

Text

U.S .. NUCLEAR REGULATORY COMMISSION.

REGION III

. Report Nos.

50-237/92023(DRP); 50-249/92023(DRP)

Docket No~. 50-237;50-24g

Licensee: -

Commonwea 1th Edi son Company

Opus West II I

1400 Opus Place

Downers Grove, IL 60515

License Nos. DPR-19; OP.R-25

F~cil~ty Name:

Dresden Nuclear Station, Units 2 and 3

~

Inspection At:

Dresden Site, Morris, Illinois

Inspection Conducted:

August 1 through September 15, 1992

• Inspectors: * _W. Rogers.*

M. Peck

A. Bongiovanni

P. Lougheed *

R. Zuffa, Illinois Departm~nt of Nutleai Safety

Approved. By: .

Ins*pecfion Summary

Reactor Projects Section 18

'I (J lz 19 :i

Date 1

Inspection from August 1 through September 15, 1992 <Reoort Nos.

50-237/92023(DRP); 50-249/92023(DRP)) .. *

• Areas Inspected: A routine, unannounced safety inspection was conducted by *

the resident inspectors and an Illinois Department of.Nuclear Safety

inspector.* The inspection included followup-on previously identified items

and licensee event reports; review of operational safety, monthly maintenance

a~tivities; monthly surveillance activities; events follo~ up; Systematic

Evaluation Program topic follow up; and train~ng effectiveness.

In~pection

modules used during this ins~ection were:. 41400, 41701, 61726, 62703, 71707,

92700, 92701; and 92702.

Results:

Of the eight areas inspected, no violations were identified in six;

. In the remaining 'areas, eight violations were identified regarding adequacy of

equipment control procedures, implementation of established equipment control

procedures and response to ~larms, test intervals for instrument surv@illance, .

. performance of T/S chemistry surveillance and declaring equipment inoperable

when instrument surveillance render equipment non-functional.

Five of these

. ~iolations met the criteria for being non-cited.

9210130083 921005

.

PDR

ADOCK 050002:i7--- - --~----- *.

G

PDR

Plant Operations

Weaknesses in the licensee's equipment control-procedures were evident.

The

operators handled. emergency situations well.

Maintenance/Surveillance

'

.

Observed ~aintenance and surveillance activities were well performed.

However, some eq~ipment failures during the inspection period were indicative

of past poorly performed maintenance. *Also, the interface between chemistry

and operations is weak re~arding assurance that technical*specification (T/S) *

required suryeillances are accomplished.

Safety Assessment and Quality Verification

1 Missed commitments continue to be i dent i ffed.

2

l

DETAILS

1 .. *

Persons Contacted

C. Schroeder, Station Manager

• S. Berg, . Techn i ca 1 Superintendent

.

~J. Kotowskii Production Superinte~dent

• T. O'Conner, Assistant Superintendent, Maintenance

J. Achterberg, .Assistant Superintendent, Work Planning

G. Smith, Assistant Superintendent, Operations

• M. Strait, Technical Staff Supervisor

.

• R. Radtke, Regulatory Assurance Supervisor

• K. Tupman~ Shift Engineer

• R. Stobert, Operating Engineer

• D. Ambler, Health *Physics Supervisor

• R. Aker, Chemistry Services Superv1sor

• T. Ga 11 aher, Nuclear Qua 1 i ty Program s*uperi ntendent

• Denotes those attending the exit interview conducted on

September 15, 1992.

• The irispettors also talked with and interviewed seve~al other licensee

employees during the course of the inspection.

2.

. Liceniee Action on Previously Identified Items (92701. 92702)

a.

{Closed) Unresolved' Item {237/92020-03{DRP)):

Review of.

administrative controls concerning use of human out-of-services

and review of the licensee's commitment to American Nation

Standa~d ANSI 18.7-1972 in regard to control of out-of-services.

After reviewing the applicable administrative and regulatory

documents the inspector concluded that use of the human

out-of-services process was not addressed in the'licensee's

administrative controls program.

The licensee was committed to

ANSI NlB.7-1972 of which section 5.1.5, "Equipment Control'.*

• Procedures," required procedures to be provided for the control of

the equipment, as necessary., to maintain reactor and personnel

. safety and to avoid un~uthorized operation of equipment.

Thes~

procedures were required to incorporate control measures, such as

• 1ocking or.taggin~ equipment to secure it in a controlled status ..

The licensee committed to incorporate the necessary attributes for

use of human out-of-services into the administrative control

• system by December 31, 1992 .. In the interim, the licensee

committed to implement a policy restricting the u~e of human.

• out-of-services to either emergency conditions or with the

concurrenc~ of the Assistant Superintendent of Operations.

Though identified by the NRC, this violation of 10 CFR Part 50,

Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"

• was of minor safety significan~e and would have been categorized

3

as Severity Level V. * The corrective actions taken, as discussed

above, were adequate to prevent recurrence.-

Also, no violation in

the last two years dealt with the human hold out-of-service

process.

Therefore~ in accordance with the provisions of 10 CFR

Part 2, Appendix C,Section VII.B.l, a Notice of Violation will

not be hsued were met.

This item is considered clos*ed.

b.

(Closed) Unresolved Item (249/92020-04(0RP)):

Spilling 500

• gallons of diesel oil irito the Unit 3 emergency diesel g~nerator

(EOG) toom. lhrough independent inspection _and review of the

records the inspector ascertained the information below.

On July 14, 1992, non-licen~ed operato~s attempted to resolve an

problem with the ~nit 3 EOG day tank level *indicator.

On day

shift the day tank hi/lo alarm annunciated.

Non-licensed

operators were dispatched.and they determined th~ alarm was due to.

a high level condition in the tank.

The tank was drained to the *

• oil separator to clear the alarm.

The non-licensed operators,*

though- both were involved in the drain down, signed off the

restoration and independent verification of the final drain valve

positions. * Later on the same shift, the system was tagged out-of-

service and the indicator was replaced.

Whil~ op~rators were

returning the indicator to s~rvice tin swing ~hift, the hi/lo alarm

recurred.

Once again the tank was drained to clear the alarm.

This tfme the drain valve used was not closed, although the*

operator stated he did close the valv~; * Later du~ing swing shift

the alarm recurred when enough oil ~rained from the tank to r~ach

the lo level alarm setpoiilt. Operators did not respond to the

alarm .. The oil clogged the drain line to the separator and began

backing up into the EOG room and the turbine* building.

The oil sp~ll was observed duririg performance of operator rounds

on the graveyard shift. At that time, the valve was closed and

the spill was terminated.*. In response to the spilled oil, an

Unusual Event was declared. Over the rest of graveyard Shift and

into the next day shift, preparations were made to remove the oil.

Eventually, most of the oil was cleaned up and the Unusual Event

terminated.

However, during a graveyard shift inspection, the .

inspector found a oil slick that had been missed.

Upon the

operating crew being informed, that oil was also cleaned up.

Licensee troubleshooting and investigation determined that the.day

tank was routinely draining through a malfunctioning check valve

to the seven day tank.

When the low level switch activated the

transfer pump filled the day tank to the high level cutoff. This

pr6cess had been occ~rring for numerous weeks.

The routine

alarming of the hi/lo annunciator -had desensitized operators to

respon~ing to the ~larm.

The inspector determined that:

4

...

Disposition of a previous EOSFI item led the licensee to

raise the level in the day tank possibly contributing to the

siphoning effect in the.day tank back to the seven ~ay tank.

• The drain v~lve left open met the locked valve criteria as

stated in OAP 2-27 but was not tn the locked valve program.

• Personnel error by a. non-1 i censed operator* caused the dr.a in

valve to be left open~ *

Non-licensed personnel on day shift failed to implement the

independent verification process when manipulating the drain

• valves on the day tank.

Operators failed to properly respond to the hi/lo tank alarm

ori swing shift increasing the duration and extent of the

diesel oil.spill.

Licensee corrective action to this event included:

Disciplining the rion-licensed operator who left the drain

valve open.

Discussing this event with all operators in Cycle 7 of the

licensed operator training~

• Caution carding the sight glas~ ihdicator valves explaining

how they function.

Submitting an action item request.to engineering to resolve

• the original EOSFI concern by December 31, 1992.

• *

Changing the alarm response to the day tank alarm by

December 31, 1992.

Evaluating, walking down, and revising the complete locked

valve program by December 31,- 1993.

There will be.

appropriate milestones to allow ~valuation of all valves

which are non-accessible at power.

Dresden Alarm Notification 903-8 G-7, "U3 Diesel Generator Day

Tank Level Hi/Lo," Operator action B.l.state~ "Direct an operator

to check Day Tank Level Sight Glass~ LG. 3-5241-13 in the Diesel

Generator Room." *

Dresden Administrative Procedure 7-14, "Control and Criteria for *

Locked Equipment ~nd Valves," A.2.a(S} requires manual .vent ~nd

drain valves that could greatly degrade a system's operability be

specified as ~ locked valve and have a physical restraint on the

operation of the valve.

5

Dresden Administrative Procedure 7-27, "!~dependent Verification,"*

• B.l.b requires independent verifications be performed "apart in *

. time" from the initial activity or status review.

Section

B.3.a{l) requires all manual valves in *afety-related systems be

independently verified whenever manipulated ..

. The failure of operato~s to implement established procedures and

the valve oniissions in the locked valve checklist are cons.idered a

violation (237/92023-0l(DRP)) of 10 CFR Part 50, Appendix B,

Criterion V,

~Instructions~ Procedures and Drawirigs."

However,

the corrective actions stated above adequately address the

violation; therefore, no response to this violation is required.

This item is considered closed.

c"~

(Closed) Unresolved Item (237/92020-06(DRP)):

Performance of an

instrument surveillance rendering a diviston of low pressure

coolant injection (LPCI) inoperable while the swing EOG was *

inoperable. *

The licensee informed the resident staff that on June 24, 1992,

operators permitted instrument maintenance technicians to perform

the T/S required 2/3 co~e height ~ontainment. spray interlock ..

surveillance test. Each division for both units was tested in

succession.

Performance of this test rendered that applicable

division of LPCI inoperable for less than a minute at a time.

At

the time the surveillances were performed the swing EOG was

inoperable for overhaul.

Prior to rendering the EOG inoperable, management determined that

certain surveillance-were nof allowed by T/S to be performed due

to a new interpretation of their motherhood (3.0.B) T/S~ Because

of the riew interpretation, Operating Order 19-92 was issued to the

shift crews discussing the change; the applicable surveillances

were removed from the plari~in~ schedule; and the instrument

mechanic foreman's turno.ver instruct ions were changed, directing

the surveillance not to be performed .. The f6reman overlooked the

instructions and dir~cted performance of the 2/3 core height

containment spray interlock survei"l lance test, the senior reactor

operator thought the surveillances had* been omitted from the

planning schedule, and the Operating Order did not discuss

particular surveillances.

Had the controls for the new T/S 3.0.B interpretation been*

properly carried out the violation of T/S 3.9.8:2.c would not.have:

• occurred.

T /S 3. 9. B .. 2. c al lows . an EOG to be rendered inoperable

only if all low pressure core cooling and containment cooling

• subsystems are operable .. If the condition is ~ot met, an orderly

• shutdown is to ini~iated. Therefore, T/S 3.9.B.2.c was violated

when an orderly shutdown was not initiated.

The main causal~factors of this violation _were:

6

Personnel error on the part of the instrument mechanic

for~man to direct performance of the surveillance. *

Poor shift turnover communications as*to a change in the way

operations would be conducted.

A lOngstanding practice by management to not declare

equipment inoperable when performing surveillance testing.

Corrective .actions to this viol~tion were:

As stated in LER 237/92019 section E

Completion of a matrix identifying which surveillances-

. render T/S equipment *inoperable by January 1, 1993

Requiring crew members to signify acknowledgement and

understanding of the content of memoranda from management,.

such as operating orders

• This violation was licensee identified, would have been

categorized as a Severity Level IV or V, reported within the

applicable time constraints, ~dequately corrected as discussed

above, and isolated. Therefore, a Notice of Violation will not be

issued because the requirements set forth in 10 CFR Part 2,

Appendix C,Section V.II.B.2 were met.

This item *is closed.

d.

{Closed) Unresolved Item {237/92005-07{DRP)): *Failure to perform

source and intermediate range survei11 ance testing .. at the required

T/S intervals. The corrective actions were:

Revising the specific surveillance procedures to indicate

the correct surveillance frequency

Revising the computerized scheduling system to include the

testing requirements

Tailgating the event with station personnel

Establishing a T/S pro~ed~r~ cross-reference by

December 18, 1992

This T/S violation was licensee identified, would have been

categorized as a Severity Level IV or V, reported within the

applicabl~ time constraints, adequately corrected as discussed

above, and isolated. Therefore, a Notice of Violation will not be

issued because the requirements set forth in 10 CFR Part 2,

Appendix C,Section V.II.B.2 wer~ met.

This item is closed.

7

• --- --.-

e.

{Closed) Unresolved Item {249/92020-05{DRP)):

Failure to perform

a chemistry surveillance withifl T/S time con~traints. On July 24,

1992, the licensee distovered that a required T/S twelve~hour

analysis ~for the inoperable Unit 3 service water {SW) effluent *

• monitor had not been completed on July 23".

The analysis was

.

s~tisfactorily completed at 8:33 a.m~

The major causal facto~ of

the_event was personnel error, in that the chemist neglected to

complete the analysis as directed during the shift turnover ..

Contributory causal factors were:

Failure of shift supervision to track the.sample on the

.limited-conditions-of-operations boar_d in the control room.

No effective mechanism for the operations depar,tment to

ensure that T/S-required non-routine ~amples *or arialyses

• were completed by th.e chemistry staff within-the time

constraints of T/S limiting condition of operation.

The T/S requirements were not ~learly understood by the

chemistry personnel involved.

The licensee documented corrective action to the missed grab

~ample in LER 249/92018.

However, the corrective action did not

sufficiently address the contributory causal factors.

Failure to

perform the T/S required grab sample is a violation {249/92023~

02{DRP))~ *The unresolved item is considered closed.

f.

{Closed) Violation {237/91624-0l{DRP)):

Inadequate performance of

surveillance activities rendering four steam line high radiation

channels inoperable simultan~ously. The licensee committed to

revise the applicabl~ surveillance procedures,. DIS. 1700-01 and

1700-05, to.include independent verification of all calculations

and data transfers_, conduct a supervisory review .of the

surveillance activities on two compariion ch*nnels before

proceeding to the last two channels, and tailgate the event with.*

instrument maintenance personnel.

The inspector confirmed proper

completion _of the~e corrective actions through record review.

This item is cl-0sed.

g.

{Closed) Unresol~ed Item {237/91032-0J{DRS)~ 249/91035-0J{DRS)):

By letter dated June 1, 1992, the licensee proposed revisions to

bring the .airlock door T/S into conformance with the requirements

of 10 CFR Part 50, Appendix J. Though identified by the NRC, this

T/S violation was of minor s~fety significanc~ and would have been

categorized as Severity Level V.

The corrective actions t-aken

- were adequate to correct the situation.

The licensee's T/S

improvement process will prevent recurrence. This violation was

isolated. Therefore, in accordance with the provisions of 10 CFR

Part 2, Appendix C,

Sec~ion VII.8.1, a Notice of Violation will

not be issued were met.

This item is considered closed.

8

h.

{Closed} Violation {249/92009-04{DRP: Inadequat~ flood protection of EOG cooling water pumps. After issuance of the inspection report.the licensee identified a waterproof seal in the power cable of the pumps which was o~igirial *to the pump design. Subsequent testing confirmed its waterproof properties. Therefore, no violation existed and the.matter is closed. i. {Closed} Unresolved Item {249/92002-0S(DRP}}: Design of EOG cooling water pumps for protection from flood. *As discussed in paragraph 2;h, adequate protection existed and w~s part of the design of the pumps. This item is closed. j.- (Open} Open Item (237/91025-0l(DRP}}: Performance of an

• integrated relay contact review.

T,he licensee expanded the scope of-the re~iew to include a total of seventeen systems. Presently, the licensee's goal is to revise all applicable drawings by - December 31, 1992, and to revise applicable surveillance

procedures before their use during the upcoming Unit 2 refueling outage. This matter remains open pending completion of the licensee's corrective actions. k. (Open} Open Item (237/89019-04(DRP}}: Installation of River Level IndicatiOn and Alarm in *the Main Control Room. Modification 12~0-90-17(A&B), which install~ the river.level indication, was partially complete at the end of. the inspectio~ period. The level indicator was installed, but it had not been tested and was not connected to the control room computer displays. The licensee estimated .completion of the modification within two months. This item remains open pending modification completion. * * l. (Open} Violation (237/90023-02(DRP}): Failure to follow . procedures~ The ~nly outstanding action on thi~ violation is to replace the Unit 2 reactor building-to-torus differential pressure transmitters during the upcoming refueling outage. This item will remain_ open until the last action is completed. -~* (Open) Unresolved Item (237/92020-07(DRP))~ The licensee identified fiv~ instances when four non-licensed operators apparently falsified rounds documentation. In addition, the licensee identified eight other non~licensed operators who. performed 20 other rounds* faster than management expect*tions. The inspector attended a continuing non-licensed operator training class in which managem~nt strongly reinforced the importance of accurat~ rounds documentation and proper data recording. This* issue will conttnue to be .considered unresolved pendi~g further regulatory evaluation of the apparent rounds falsificati~n issue. n. (Open} Open *Item (237/90027~14(DRP)): Inspection of systematic evaluation program (SEP) topic resolutions .. The in~pettors reviewed an SEP item d~ring this inspection period as discussed in paragraph 8. This item will remain open pending licensee

confirmation of topic closures and inspector verification. 9

. o. (Open) Violation (2~9/91035~0l(DRP)}: The inspector noted that three corrective actions, for either the violation or its associated LER~ were not complete at the time of th~ inspection. These were:

Establishing a computerized data base of post maintenance testing (PMT) requirements . . .

Training work analysts, operations, maintenance, and technical staff personnel on PMT requ1rements

Completing a Dresden Admini~trative Procedure (dAP) f~rmal izing PMT. requirements Inspector observations were:.

. A multi-discipline, inultiple tier, task force was established to review all work packages for the Unit 3 outage t6 ensure that PMT requirements were prriperly imposed and implemented. This task-force completed its review, identifying two cases where PMTs were not properly imposed .. However, NRC Inspection Report 50-237/92013(DRP); 50-249/92013(DRP) identified thre~ additional examples where PMT requirements were not included in the work packages. This inspection report also identified other concerns regarding the work package pre~aration ~nd implementation process, including other PMT concerns ..

M~ny of the LER commitment dates w~re revised, one beyond the LER commitment date. The changing of commitment dates in the nuclear tracking system was a problem identified by

• the vulnerability assess~ent team (VAT), as well as previous

NRC inspection reports.

Color coded P&ID's showing *the primary containment boundary were being maintained and revised. This was considered good continuing corrective action by the licensee.

The technical staff ISl/IST group was continuing its revi~w of a 11 work. packages to ensure that lOca 1. leak rate testing PMT*requirements were properly incorporated.* This was also good continuing corrective action. This matter remains open pending completion of .the licensee*s corrective actions. ' ' p. (Open) Operr Item (237/91039-02(DRP)): SALP improvement items. The inspector confirmed the completion of some of the corrective actions from the last SALP r~port response docum~nted in a letter dated November 1, 1991. The completed actions were is~uance of work analyst guidelines, revision to procedure ENC 40.1 and the* evaluation of the technical staff's current experience level. Another action reviewed was the issuance of a technical 10 __ . ..._ __ _

q. requirements document for quality calculations. The document was still in draft and had yet to be issued. This matter remains open pending further inspector review and licensee issuance of the technical requirements document~ (Open) Unfesolved item (237/92010-04(DRP)): Adequacy of is~lation condenser five year functional test. The licensee's nuclear fuel services group reviewed the test data of the most.current

performance.of this test and concluded the isolation condenser transferred the _necessary heat load. However, choke flow conditions occ~rred during the test. The licensee indicated further review and followup of the choke flow situation would be perf6rmed at the next test sometime in the fall of 1992. The next test had not yet been run by the end of the inspection period.

• This matter remains unresolved pending further followup by the

licensee and subsequent review by the resident staff. No other violations or deviations were identified. 3. Licensee Event Reports Followup (92700) The following licensee event reports were reviewed to ensure that reportability requirements were met, and that c6rrective actions, both immediate and to prevent recurrence, were accomplished .in accordance with 'the T/S: a. (Closed) LER 249/91002, Violation of Primary Containment Post Accident Monitor Surveillance Interval Due to Management * Deficiency b. The licensee c9rrective actions, as documented in the LER, were appropriate to the circumstarice. These corrective actions included revising the administrative procedure controlling surveillance activities, OAP 11-l, to require department head concurrence when a surveillance exceeded the scheduled date. Since the OAP was revised, no other surveillances have been missed due to implementatiori o~ the established program. This T/S violation was licensee identified, would have been categorized as a Severity Level IV or V, reported within the applicable time constraints, adequately corrected as discussed above, and isolated. Therefore, a Notice of Violation will ~ot .be issued because the requirements set forth in 10 CFR Part 2, Appendix C, Section V.II.B.2 were met. This item is closed. (Closed) LER 249/91009, Failure.to Perform Post Maintenance Local Leak Rate Testing (LLRT) Due to Management Deficiency This matter and its cdrrective actions were reviewed in paragraph 2.j. To avoid duplicate tracking, this item is closed. 11

c. (Clo~ed) LER 237/92010, Source Range Monitor Calibration Test Frequency l/S Requirements not Met Due to Management Deficiency This matter and its applicable corrective actidns were reviewed in paragraph 2.d~ To avoid duplicate trackihg, this item is closed. d, (Closed) LER 237/92016, Unchallenged Primary Containment Boundary Due to Management Deficiency

The inspector reviewed the safety evaluation report for installation of the continuous air monitoring system, and discussed the system isolation provisions with the local leak rate test engineer and the System engineer. The inspector considered the licensee's actions on this matter to be conserv~tive. e .... (Closed) LER 249/91007, Type Band C Containment Local Leak Rate Testing Limit Exceeded Due to HPCI Turbine Exhaust .Check Valve The inspector confirmed that the total Type * B and C leakage wa*s within allriwable limit~ prior to Unit 3 startup, including leakage through the high pressure coolant injection (HPCI) system turbine* exhaust valve. The inspector determined that the HPCI valve had been replaced, and the licensee was investi~ating potential modifications to prevent furth~r failures. Also, the *inspector noted that the overall leak rate program for ~ll containment . penetrations had improved since the. previous outage.

. . ' f. (Open) LER 237/92027, Failure to Sample Reactor Water Due to Tech Spec Misinterpretation

Durin~ the Unit 2 startup on Augus~ 6, 1992, the licensee determined that a four hour reactor water sample required by T/S * had not been performed. T/S 4.6.C.2 ~tates that, during startups and at steaming*rates below 100,000*pound per hour, a sample of reactor coo 1 ant sha 11 be taken every four hours and analyzed for * conductivity and chloride content.. Startup activities were terminated until a sample was obtained. Discussions with.the licens-ee indicated that the chemistry technicians obtained iniorrect informatiori that the steam flow was greater 100,000 pounds per hour; therefore, the chemist .felt that the T/S sampling was no longer required .. This information was conveyed to the shift control. room engineer (SCRE) who erroneously confirmed the ~teaming rate data: Based on this, the chemist believed that the T/S was met and terminated the sampling. The root cause of the event was personnel error, in that, the SCRE and the chemist misinterpreted the steam flow indication and the* T/S requirement. Although this event and the one described in paragraph 2.e involved different personnel, several similarities existed which contributed to the root causes of bdth events: Shift supervision did rtot track the T/S sample on the limited-condition-of- operations board in the *control room, as requited by plant 12

g. procedures. No effective mechanism existed for operations to - ensure that non-routine T/S samples or analyses were completed by the chemistry staff on* time. And the T/S requirements were not clearly understood by the chemistry personnel. The.licensee documented corrective actions to the missed sample in LER 237/92027. However, the corrective actions did not sufficiently address the contributory causal. factors described above. Failure to perform the T/S required sample is considered a violation (249/92023-03(DRP)). (Open) LER 249/92018, Sample Not Analyzed Within Required Time

• Period Due to Personnel Error

Additional aspects of this ~atter were discussed in paragraph l.p. The LER did not ~ddress: ~he misinterpretation or misunderstanding of the T/S requirement; the inadequate or non- existent check/balance between shifts; the working around problems (namely, the monitor status was considered irrelevant since

• samples were taken each shift); the extensive time the ~onitor had.

been inoperable causing ~outine taking of the sample; and the lack of mechanism between the control room and chemistry that T/S surveillance (non-routine) are completed: h. (Closed) LER 237/91014, Primary Containment IsolatiOnValve

• Closure due to Reactor;Water Cleanup system Isolation

i. (Closed) LER 237 /92011, High Pressure Coo.l ant Injection Surveillance exceeded due to Turbine Oil Leakage ** j. (Closed) LER 249/92013, Pressure Suppressiori System Torus Vacuum Relief Valve, 3-1601-20A, Actuation Due to Los~* of Control Power. k. (Closed) LER 249/92006, Emergency Diesel 'enerator Rotor Mounting Bolts Loose

l. (Closed) .LER 237/92003 ~nd Revision 1, Flood Protection for Emergency" Diesel Generator Cooling Water Pumps m.

• (Closed) LER 237/92026, Drywell Equipment Drain Sump Pumping

Interval Exceeded due to Isolation Valve Operability Concerns n. (Closed) LER 237/92023, Reactor Recirculation Valve 2-220-45 - Closure and Loss of Outboard MSIV Indication Due to Blown Fuse

• No other viol.ations o-r deviations were identified in this area.

4. Operational Safety Verification (71707) The inspectors reviewed the facility for conformance with the ltcense and with regulatory requirements. - 13

a. On a sampling basis the inspectors observed control room activities for proper control room staffing and coordination. of plant activities. Operator adherence to procedures and T/S and operator cognizance of plant parameters and alarms was observed. Electrical power configuration was confirmed. Various logs and

• surveillance records were reviewed for accuracy and completeness.

Observations included:

Many of the shift engineer (SE) logs duplicated information previously presented on the unit logs and the SE failed to log the operability e~aluatio~ for the degraded penetration {X-125) discussed in Section 7. However, improvements in the log~ were noted towards the end of the inspection period, with a narr~tive format used.

The on-shift crew handled the August 16th Unusual Event well. Clear management direction was provided .and directions were properly executed.

b. On a routine basis the inspectors* toure~ accessible areas of the facility to assess worker adherence to radiation protection controls and the site security plan, housekeeping or cleanliness, and control of field activities in progress. * c. Observations included:

• * *

On September 3, 1992, the inspector noticed that a rear access panel. (door) to an equip~ent circuit breaker cubicle on Motor Control Center (MCC) 29~1 was slightly ajar.

• Inside the open access panel was a bag of respirator

filtration c~nisters. The SE ~as notified and the canisters* were removed. Subsequently JJ*other MCCs were inspected and

• ininor, old debris was observed and removed from five of

them.

• On August 17, 1992, a manual locked LPCI valve, .2~1501-128,

was in- the correct position but was not properly locked.* The sit~ation was reported to the shift engineer and the

• valve was immediately locked.

A deviation report, 12-2-:92- 161, was initiated. The inspector will follow the licensee's review of this matter through their internal corrective action system. Walkdowns of select engineered safety features (ESFs) were performed. The ESFs were reviewed for proper valve and electrical alignment~. Components were inspected for 'leakage, lubrication~ abnormal corro~ion, ventilation and cooling water supply availability~ Tagouts and jumper records were reviewed for accuracy where appropriate. The ESFs reviewed were: 14

" Unit 2: Unit 3: Common: High Pressure Coolant Injection Containment Cooling Water System Unit 2/3 Standby Gas Treatment System No violations or deviations were identified in this area~ 5.. Monthly Maintenance Observation {62703) 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 T/S limiting conditions for operations. * The inspectors verified that approva 1 s 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 material.s 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 wa~ assigned to maintenance of safety-related equipment which

• 1

could affect system performance. The following maintenance activities were observed and reviewed: Unit 2

Trou_ble* Shooting of lPCI Minimum Flow Pressure Transmitter

• .

Replacement of the Short 8ruihes cin the 28 Reactor* Recirculation Motor Generator Set

Rebuild of the 2A Reactor Recirculation Pump Seal .

Standby Liquid Control Temperature Hi/Low Annunciator Trouble Sho.oting .

• Inboard Main Steam Isolation Valve, 202-lD, Lim~t Switch

Replacement Unit 3

.38 Stator Cooling Heat Exchanger Cleaning and Head Crack Welding

HPCI Aux Oil Pump Trouble Shooting

Reactor Recirculation Pump Scoop Tube Mechanical/Electrical Limit . Switch Adjustment

Common

Constructiori Testing of Main Control Room Panel 901-2.

Standby Gas. Treatment System (S8GT) Flow Control Valve, 2/3-75lOA, Trouble Shooting and Repair Inspect~r observations were: 15

On August 4, 1992, at approximately 1836 hours, the instrument maintenance department, in conjunction with the operations department, was performing Dresden instrument surveillance (DIS) 7500-1, Standby Gas Treatment (SBGT) System Auto-Actuation Test.* While performing step 18 of the procedure -- which required.manually lowering the SBGT flow to 3500 cubic feet per ~inut~ -- valve 2/3-7510A, SBGT flow control valve, went to the fully closed position. * Investigation revealed that the * valve control linkage on the position actuating mechanism had rotated beyond its normal travel, forcing the valve to .the full closed position. It was not known, at the time of repair, how the linkage had been placed in a position which precipitated.the val~~ failure. However, it was determined that SBGT would have per.formed its intended function even with the valve fully closed. This matter will remain open (237/92023- 04(DRP)) pending further investigati~n of the failure. ~o violations or deviations were identified~ 6.* Monthly Surveillance Observation (61726) The inspectors observed required surveillance testing and v~rified procedural adherence, test equipment calibration, T/S action statement adherence, and proper removal and restoration of affected components. The inspectors reviewed completed surveillance packages to ensure that results conformed with T/S and procedure requirements, th~t -there was independent verification of the results, that proper signoffs occurred; and that any test deficiencies were appropriatel~ dispositioned.

The inspectors witnessed portions of the following test activities: Unit 2

• DOS 400-02, Rod Worth Minimizer Pre-startup Surveillance

DIS 2400-01, Post LOCA Containment H2 and 02 Functional Calibration

DOP 0040-M3, Lock Valve Check List Accessible During Operation

DOS 6600-1, Diesel. Generator Surveillance Test

DOS 250-03, MSIV Fail Safe Closure Test.

DOS 1600-18, Cold Shutdown Valve Testing

DIS 5600-03, Generator Load Rejection Control Valve.Fast Acting Solenoid Valve Calibration

DOS 1500-06, LPCI System Pump Operability Test with Torus Available

• DOS 1400-01, Core Spray System Pump Test with Torus Available

DOS 1500~08, Discharge of Containment Cooling Service Water from Conta~inated HPCI Heat Exchangers duting Core Pump Operation Unit 3

DIS 250-02, Main Steam Line Low Pre~sure Isolation Switch Calibration

• *

DIS 500-07, Turbine 1st Stage Pressure 45% Sciam Bypass 16

DIS 1700-03, Reactor Building Closed Cooling Water Radiation Monitor Calibration

DIS 7500-01, Standby Gas Treatment System Auto Initiation Surveillance*

DOS 1500-02, Containment Cooling Service Water In Service Quarterly Pump Test

DOS 1500-06, LPCI System Pump Operability T~st with Torus Available .

DOS 1500-10, Quarterly LPCI System Pump Operability Test with Torus Available for the In-Service Test (IST) Program On August 16, 1992, the LPCI minimum flow valve could not be repositioned due to a failed flow transmitter. The terminal side transmitter was found to be filled with water. After corrosion was removed from the terminal connections, the transmitter was successfully bench calibrated.- -Water was found to have entered the transmitter.via the flex conduit and-junction box located on the instrument rack above the tr~nsmitter. Water may h~ve entered the junction box during the

• recent disassembly and cleaning of the 28 LPCI heat *exch~nger. The

licensee inspected the flex conduits of several other non-safety transmitters which were also fed from the bottom of the junction box and

• no additional water inttusion was found.

A core spray and a LPCI safety-~elated pressure switch were inspected on September 10, 1992, and evidence of past.water intrusion was noted. The licen~ee planned to inspect several additiOnal safety related transmitters fed from the * electrical junction box in the future. This issue will be followed up. in a subsequent inspection ~eport;

No violations or deviations were identified. 7. Events Followup (93702) Durin~ the inspection period, several events occurred, some 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 nspectors reviewed the acuracy and timelin~ss of the licensee notification, the licensee's corrective a_ctions and that activities* were conducted within regulatory requirements. The specific events ~eviewed were:

a. An Unusual Event was declared on August 16, 1992, for two disparate reasons: an inoperable LPCI subsystem while HPCI and an

• EOG were out of service on Unit 2, and a loss of telephone

communications affecting both units. A control room operator observed the Unit 2 Division 2 LPCI minimum flow valve out of position. *when the valve could not be repositioned, LPCI was declared inoperable. * At that time, the 2/3 EOG was out of service to troubleshoot premature automatic shutdown of _the EDG during low loads and HPCI was tiut of service due to a malfunctioning auxiliary oil pump .. With LPCI, HPCI, and an EOG inoperable, multiple T/S sections required the unit to be placed in hot 17

shutdown within 12 hours and cold shutdown within another 12 hours. The licensee*declared an Unusual Event and started a shutdown. At 'the same time, the telephones, both commercial and ENS, were malfunctionin~ such that another Unusual Ev~nt . activation criteria was required~ Both Unusual Events were terminated on August 17, 1992, following replacement of the flow .transmitter and restoration of telephone service. b. On August 21,. 1992, the station was notified th~t ~ Uni~ 2. containment purge penetration (X-125) was not installed as originally analyzed at initial licensing. The structural analysis

• of the bellows was based on a tied single bellows, while the

actual* installed was an untied tandem bellows.* A problem , identification form was routed to the SE. The SE concluded *the penetration was oper'able based on engineering judgment and the results of the last integrated leak rate test. Although the immediate operability conclusion was sound, the SE failed to log the rationale for continued operability. On Aug~st 28, 1992, the engineering organization completed their operability evaluation on penetration X-125 and determined that.

. inal. safety an~lysis report (FSAR) stress limits in.the existing configura lOn. s were approximately twice the ~ield strength of the pipe and in excess of the 831;1 code limits. However, the stress limits met operability *1 i mi ts as defined in Commonwealth Ed iso*n Company's * pipe system criteri'a. This criteria was based ori an NRC.letter dated Septe~ber 27, 1991, f~om Leonard N. Olshan to* Thomas J. Kozack. The licensee planned to reduc~ the penetration* stresses design to within FSAR allowable during subsequent refueling outages on both units. - c. On Augusi 25, 1992 the licensee informed the resident staff of a .large number of elec.trical cables. that may be thermally. overloaded. The licensee's initial judgment were the cables were operable after completing an operability determination. *However, further analysis were to be performed. NRC regional electrical specialists we~e assigned to follow the licensee's efforts on this . matter. This matter is considered unresolved (237/92023-05(DRS)) pending NRC review of the licensee's. final analys.is. No violations or deviations were identified~. 8. Systematic Evaluation Program Items (92701) NUREG i403, "Safety Evaluatiori Repo~t Rel~ted to the Full-term Operating License for*oresden Nuclear Power Station," Table 2.1, identified 22 SEP integrated plant safety assessment report topic resol~tirins to be * confirmed by the NRC Region III office.

The fo 11 owing .item in that report was reviewed by the inspectors: 18

Topic VI-4/4.18:6, Leakage Conditions under which the Remote Manual Isolation Valves on LPCI and Core Spray Systems should be Isolated Ar~ Incorporated intri Emergency Procedures . . The inspector discussed with the licensee the concern that the closure package only ad.dressed the discharge lines {from the pumps to the reactor vessel) and not the suction lines, while the SEP document discussed both. The licensee stated that closure of both* suction and discharge valves had bee~ incorporate~ into appropriate emergency procedures, and provided information as to how this had been accomplished. The licensee conunitted to reviewing the closure paperwork and either verifying that documentation existed on both discharge and suction lines, or providing the necessary documentation. No violations or devi~tions were identified. 9. Training Effecti~eness (41400 and 41701) The effecti~eness of training programs for licensed and non-licensed personnel was reviewed by the .inspectors during the witnessing of the licensee's performance of routine surveillance, maintenance, and operational activities. Weaknesses were evident in operator knowledge of chemistry l/S. A review of the licensed operator training program with respect to chemistry T/S were poor with operators only required to read the T/S~ * The training for chemistry technicians was good. 10. Open Items Open items are matters which have been discussed with the licen~ee, , .

• . which will be reviewed further by the inspector, and which involve some

action on the part of the NRC or lice~see or both. One item disclosed during the inspection was discussed in Paragraph 5. 11. Unresolved Items Unresol~ed itenis are matters about which more info~mation is required in order to ascertain whether they are acceptable items, violatirins, or deviations~ * An unresolved item disclosed during the inspection was discussed in Paragraph 7.c. *

12: Violations For Which A "Notice of Violation" Will Not Be Issued The NRC uses the Notice of Violation to formally documerit failure to meet a legally binding requirement .. However, because the NRC wants to enco~rage and support licen~ee's initiatives for self-identification and correction of problems, the NRC will not issue a Notice of Violation if .the requirements set forth in 10 CFR Part 2, Appendix C, Section .VII.B.l or VII.B.2 are met. Violations of regulatory requirements identified during the inspection for which a Notice of Violation will not be issued

• are discussed in Paragraphs 2.a, 2.c, 2.d, 2.g, and 3.a. *

19

13. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) during the inspection period and at the conclusion of the inspection period on September 15, 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 disc]osed during the inspection could be considered proprietary in nature . . 20 - -- ---.--.* }}