ML17179A580

Insp Repts 50-237/92-26 & 50-249/92-26 on 920916-1109. Deviation Noted.Major Areas Inspected:Followup on Lers, Review of Operational Safety,Review of Maint Activities & Scram Evaluation

ML17179A580
Person / Time
Site:	Dresden
Issue date:	11/17/1992
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179A577	List: ML17179A576 ML17179A578 ML17179A580
References
50-237-92-26, 50-249-92-26, NUDOCS 9211240044
Download: ML17179A580 (19)

See also: IR 05000237/1992026

Text

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u~s. NUCLEA~ REGULATORY COMMI~~ION

REGION Ill

Report Nos.

50-:-237/92026{DRP); 50-249/92026{DRP)

Docket Nos.

50-237; 50-249

License Nos. DPR-19; DPR-25

'Licensee:

Commonwealth Edison Company

Opus ~est III

1400 Opus Pl ace. r

Downers Grove, IL 60515

Fa~ility N~me: Dresden Nuclear Station, Units 2 and 3

Irispection At:* Dresden Site, Morris, Illinois

Inspection Conducted:

September 16 through Novembe~ 9, 1992

Inspectors:

Approved By:

W .. Rogers

• .M. Peck

A. M. Stone

P. Lougheed

A. Markley

R. Zuffa, Illinois Department of Nuclear Sa~ety

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0;.1 7 0*./ */

i/ t'/t/'/;.h, ,/-. * /f-t*l{VJ*v,)

'Patrick L. Hilai'ld, Chief

Reactor Projects Section 18

Inspection Summary

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Date

Inspection from September 16 through November 9, 1992 (Reports No.

so~237/92026CDRP); 50-249/92026(DRP)).;

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

the resident inspectors and an Illinois Department of Nuclear Safety

• inspector .. The inspection included foll~wu~ on previously identified items;

followup on licensee event reports; followup on System~tic Evaluation Program

items; review of operational safety; review.of maintenance activities; review

of surveillance .activities; events followup; performance of regional requests;

concern review; and scram evaluation.

Inspection modules used duiing this.*

inspection were:

61726, 62703, 71707, 92700, 92701, and 93702.

Results:

In the* ten areas inspected, no violations were identifi.ed.

Qne

deviation was identified {Paragraph 9). Three unresolved it~ms were

identified {Paragraphs 4, 6 & 7), as were two open items {Pa'ragraphs 3 & 8}'.

9211240044 921118

PDR

ADOCK 05000237

.G

PDR

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Executive Summary

Plant Operations

Operator response to the Unit 3 scram w~s generally good.

Routine operations,

• inchiding log-keeping, were performed satisfactorily.

• Maintenance/Syrveill~nce

Maintenance and surveillance activities generally were performed

satisfactorily. However, an ESF actuation was caused by personnel error

during surveillance activities.

Engineering ~nd Technical .Support

A weakness ~as noted in communicating important informatidn from erigineering

to operations regarding the performance of some motor operated valves.

The

technical content of the safety.evaluation for filling ~nd ventirig the

isolation condenser was weak.

Also, some weaknesses were noted in the

technical rigor of the review of the isolation condenser steaming anomaly.

Safety Assessment and Quality Verification

Clear i~prbve~ents were noted in short outage shutd~wn risk management.

The

post scram review process significantly improved.

However, root cause

analysis and establishment of corrective actions to a recent LER were poor.

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DETAILS

Person~ Contacted

1. • C.

Sc~roeder, Station Manager

• S. Berg, Technical Superintendent

_ #*J. Kotowski, Production Superintendent

• T. O'Conner. Assistant Superintendent, Maintenance

J .. Achterberg, Assistant Superint~ndent, Wotk Planning

G. Smith, Assistant Superintendent, Operations

• M. Strait, Technical Staff Supervisor

• R. Radtke, Regulatory Assurance Supervisor

1. • E. Carroll, Regulatory Assurance Coordinator

• Denotes those attending the October 30, 1992, exit interview.

1. Denotes those attending th~ Nove~ber 9, 1992, ~xit interview.-

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The inspectors also talked with and interviewed other licensee employees

during fhe course of the inspection.

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2.

Licensee Action on Previously Identffied Items (92701. 92702)

a.

(Closed) Unresolved Item (249/90016-0l(DRS)):

Poor maintenance

and testing practices while rebuilding ind testing diesel

generator to~ponents~

D~screpancy Report 90-082 was w~itten and

dispositioned. _The poor practices were rectified and protedure

changes were initiated to provide more craft flexibility when_

working on diesel generator components.

Subsequent inspection

observations and issuance of violation 237/92005-04 encompassed

similar poor testing practices. This matte~ is consider~d closed.

b.

(Closed) Open Item (237/90027~14(DRP)): Inspection of Systematic

_ Ev~luation Pr6gram (SEP) tripic resolution.

Only one SEP item

remained to be cltised under this open item (Topic Vl-4/4.18.6).

Based upon the review performed this inspection period, as

discussed in paragraph 4~ the open item will be closed with

followup being tracked as an unresolved item.

c~ _

(Open) Violation 237/91016-02(DRP)):

The licensee failed to

establish adequate periodic calibration requirements for safety-

related instruments.

The licensee developed an instrument.

setpoint control program and identified instruments to be

incorporated into a data base through plant walkdowns and design

document reviews.

The data base was under review to ensure that

instruments required for safety system actuations were covered by

a ro~tine calibration surveillance.

The license~ .completed a

review of the existing master equipment list, compared it against

instrument maintenance surveillance procedures, and identified two

-~eviations. The licensee also completed a review of technical

specifications (TS) and-identified nineteen compliance functions

for which an error analysis had not been performed.

The

• inspectors will

c:_ontJr:iu"~ t_o J~Hf>_W __ th~,. ~orr_ect i ve actions ..

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d~

(Clos~d) Uriresolved Item (237/91026-01; 249/91027-0l(DRS)):

Acceptability of extending ~mergency diesel generator preventative

• .* maintenance frequency from every six months to every .refue 1 i ng.

In response to inspector concerns, the licensee technically

.

justified extending the diesel generator pr~ventative m~intenance

• frequency; *elevated the authorization to change preventative

maintenance frequencies; and established technical evaluation

requitements*for rescheduled, canceled, or changed preventative .

maintenance tasks. The inspector confirmed the licensee actions

and was satisfied with the techhical evaluation.

. e..

(Open) Violation (237/91027-02(DRP)):

Rail car door seal modified*.

without using the design change protess.

In a June 1, 1992,

letter, the licensee committed to review crite.ria for minor design

changes.

The task force established to perform the review.was to

make recommendations by July 31, 1992, and Dresden station was to

develop an implementation plan by September 25, 1992. * On July 30,.

1992, the task force recommended continued use of the exempt

f .- .

change process until August 31, 1992,*while a nuclear operations

directive (NOD) was being prepar~d and issued. Dresden's

implementation plan, in respons~ to th~ recommendations, was to

iss~e ~ppropriate station procedure~ to .implement the 'NOD, Once it*

was issued.

The NOD was issued on October 16, 1992.

At the same

time; revisions were made to the quality assurarice manual to

include the definition of exempt change, which was "those changes

that require minimal engineering effort and have low potential to

significant1y reduce the margin of nuclear safety~" This item

. will remain open pending is~uance of the station procedure and

inspector *review of the procedure and its implementation.

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(Open) Violation (237/91035-0l(DRP)):

Failure of operations

personnel to adhere to administrative procedures.

In response to

the violation, the licensee committed to upgrade log-keepi.ng,

improve the -shift tu~nover proce~s, revise procedure~ associated

with high torus temperature, prbvide additional operator *

communications training, emphasize operator alarm response and

administrative c'ontrols compliance and submit a TS request on

torus high temperature. Also, in the general response to the

violation, additional corrective actions incltided implementation

of a rapid communications system of significant events to station .

personnel, establishment of an operations improvement team,

establishment of management overviews of operating crews,

establishment of a procedures manager position, focused and

frequent senior management plant presence~ and development of a

master recurring equipment problems database.

The.inspector confirmed completion of the specific violation

corrective actions except for the TS submittal. Discussi-0n ~ith

licensee personnel indicated that the TS chang~ will be submitted

before the end of 1992.

The inspector confirmed completion of two

of the general response items: the rapid communications system

a~d the Procedures Manager~position~~ Ho~e~~r, f9r the last three

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months, the documentation assoC:iated with the operating crew

management overview program was not complete for the Assistant

Superintendent for Operations, Operating Engineers, Fuel Handling

Supervisor, Shift Engineers and Shift Control Roqm Engineers.

Through interview with a number of the individuals involved two

• root qlUses emerged:

Failure to document overviews and time.

constraints due to. other tasks which reduced the number of

observations. The inspector diScussed the situation with the

Assistant Superintendent of Operations who committed to revamp the

program by December 20, 1992.

The revamped effort will be.

r~viewed. in a future inspection period.

The remaining corrective

actions were not reviewed during this report period .. This

~iolation remains open pending further review.

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(Open) Violatibn (249/91035-0l(DRP)):

Lack of containment

integrity foi an 6perating cycle due to an inadequate post~

maintenance test.* The inspector confirmed OAP 15-10 "Post

Maintenance Verification/Testing," Revision 0, was issued

• September 30, 1992. This completed one of the three remaining

items necessary to close the violation. The other two items

(training and completion of the post-maintenance testing

• computerized data base) will be *reviewed in future reports.

h. *

(Closed) Violation (237/91035-02(DRP)):

Inadequate procedures for

• turnovers and establishment of out-of-service boundaries~ The

licensee committed to revise the affected procedures or policies,

The inspector confirmed the corrective actions were performed.*

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(Closed) Violation (237/91035-03(DRP)):

Failure to follow

• procedures wh i1 e performing scram ti me testing.

The 1 i censee

~ommitted to establishing a control rod task force, issuing a

strengthened policy on Heightened Level of Awareness Briefings,

providing additional reactivity and admiriistrative controls

training. The inspector confirmed the ~ctions were performed.

(Closed) Violation (249/91038-0l(DRP)):

Improper draining of

hydraulic control units. Licensee corrective actions included

management counseling of individuals, strengthening of the policy

on procedure compliance and revision of procedures on how to drain

hydraulic cont~ol units.

The inspector confirmed these actions

were performed. . *

k. * **(Closed) Open Item (237/91039-0l(DRP)): Corrective actions to

sto~ leakage through the reactor recirculation sample valves.

The

licensee performed engineering reviews.determining no design *

modification was warranted .. This matter is considered closed.

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(Closed) Violation (237/92002-02a(DRP)):: Previous corrective

actions failed to preclude tepetition of a non-qualified

instrument mechanic (IM) from performing a surveillance without

direct supervision.

The licensee committed to add a "Job

Assignment Matrix*Checkoff"Block" to .. th~ s_up~!'\\'i~or~s daily

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turnover sh~et to ensure and document the supervisor's

qualificatiori review before assigning jobs to the IMs.

The

. inspector confirmed proper completion of these corrective actions.

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{Closed) Violation {23i/92002-02b{DRP)):. Corrective actions taken

following a previous unplanned Group lI Isolation failed to

preclude repetition of a second Group II Isol~tion. Both

isolations *occurred when an electrician inadvertently d1srupted

the neutral ground circuit for the isolation valves while *

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perfo.rmi ng a megger and resistance check of the main ste~m lfoe

isolatiori valv~ pilot solenoids.

Both isolations were caused by

discrepancies between the_pl.ant design control doc~ments and the

as-built configuration.

The licensee committed to revise the*

applicable procedure to include a precautionary statement

emphasizing that the field side of the AC terminal blocks in the

main control room panels shall have no more thari one.lead per

terminal.

The inspector confirmed the proper completion of these

corrective actions.

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{Closed) Violation {237/92602-0~{DRP)): A failure to ~aintain a

minimum of three operable intermediate ~ange monitors in each

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re~ctor protection trip channel while in refuel mode~ In addition

to the corrective actions discussed in Inspection Report

n1 /92002, the licensee committed to revise .OAP 9-2. "Procedure. and

Revision Processing" to require independent verification .. The

inspector confirmed proper completion of these corrective actions.

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{Open) Llnre~olved Item (237/92020~0l(DRP)): Licensee's practice

of not performing as-found testing on the standby gas treatment

system charco~l adsorber~ appeared to be inconsistent with ANS

Standard 18.7-1972.

The Office of Nuclear Reactor Regulation

(NRR) has been requested to evaluate the licensee's commitment to

ANSI Nl8.7 with regard to charcoal adsorber bypass testing. This

m~tter remains open pe~ding response from NRR.

(Closed} Open Item (237/92023-04(DRP: Failure of the A train standby gas treatment flow control valve to the closed position. Mairitenance records of all previous work performed on the flow control valve we~e researched. None of the documentation provided evidence that previous maintenance resulted in the incorrect orientation of the valve's. position indication mechanism. No violations or deviations were identified. 3. * Licensee Event Report~ Followup (92700) T~e following licensee event reports (LERs} were reviewed to ensure thai' re~ortability requirements were met, and that corrective actibns, both immediate and to prevent recurrence, were accomplished in accordance with the technical specifications: - " 6

a. (Closed) LER 2j7/83062, Revision 1, Inoperable HPCI System Due to -Failed Motor Gear Unit Signal Connecter.

. . . b ... -*(Closed) LER 237/9100~, Revision 1, Orderly Unit Sh~tdown Due to . Leakage Through Primary Containment Isolation Valves AO 2-220-44 and AO 2-220-45. * c. d. e. f. g. h. i. j. (Closed) LER 237/~1008, E~ceeding Core Thermal Power limits oue to 2A Reactor Feed Seal Failure. (Closed) LER 237/91015, Revision 1, Orderly Unit Shutdown Due to

• • Leakage Through Primary Containment Isolation Valves.AO 2-220-44

and AO 2,..220..:45. (Closed) LER 237/91020, Reactor Buiiding Ventilation Isolation and Autom~tic SBGT Initiati-0n due to Radiation Monitor Power ~upply Failure. Thei'solatiOn was the result of a failed reactor .buildirig ventilation and fuel pool area radiation monitor power supply. The licensee committed to present a modification request to the station modification review committee (SMRC) to evaluate replacement of the radiation monitors with state-of-th~~art monitors. *On May 4, 1992, the SMRC concruded the modification would not be scheduled during the next refuelirig outages for either unit, due to cost considerations. * (Closed) LER 237/91023, Revisions 0 and 1, 2A ReCirculation Pump. Discharge Motor-Operated Valve Failure to Close due* to Torq~e Switch Setting Problem.

(Closed) LER 249/92003, Unexpected Partial Group II Containment Isolation During Surveilla~ce Te~ting due to Personnel Error. Vi-0lation 237/92002-02b was issued regarding the events associated with this LER. . See paragraph 2. m. for further information. (Closed) LER 237/92005, Violation of Technical Specificati6n Limit for Intermediate Range Monitor Operability due to Personriel Error. Violation 237/92002-03 was issued regarding the events associated with this LER. See paragraph 2.n. for.further information.

(Closed) LER 237/92007, HPCI Declar~d Inoperable due to Turriing Gear Failure. (Closed) LER 237/92010, Revision 1, SRM Calibration Test Frequency Technical Specification Requirements Not Met Due to Management Defi ci*ency. This LER discussed a further example of a non-cited yiolation identified in inspection report 237(249)/91025 paragraph . 2.b. Specifit corrective actions were taken to prdperly revise the surveillance scheduling system. Programmatic corrective

actions are being performed under the licensee's integrated . electrical contact review program. The implementation of this program is being followed under open item 237/91025-01.-

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.. k. . (Closed) LER 237/92018, Primary system Isolation Valve Closures* Due to Reactor Water Cleanup System Isolations~ l. (Open) LER 237 /92019, Contafnment Spray Interlock Momentarily Inoperable Due to Surveillance Testing With 2/3 Diesel Generattir Inoperable. The*e~ent described in this LER was the subject of a non-cited* violation discussed in Ins~ection Report 237/92023; * 249/92023 paragraph 2.c. In addition t~ the corrective actions discussed in that repoft, two corrective actions from the body of the LER were still being implemented:

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. * .* By February 26, 1993, changing Operatfog Ord.er 19....:92 into a p~ocedure, and. ehhancing its guidance to include ~urveillance procedures affected.

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Initially,-and annually thereafteri training o~erators on this event and the ensuing policy change .. the LER remains-open pending li~~nsee tompletion of these activitie~.

. . m. {Clo~ed) LER 237/92021, A~tomatic Isolation of Reacto~ ~uilding Ventilatirin due to Radiation Monitor Trip Relay Failure. One long* term corrective aCt ion remained outstanding. In the corrective actions section of the LER, the licensee stated all energized safety-related CR 120A relays WOllld be replaced during the next two t~fuel outages rin Units 2 and 3. Completion of the relay replacements is an open item (237/92026....:0I(DRP)). n. (Closed) LER 237/92027, Failure to Sample Reactor Water Due to Technical Specification Misinterpretation. This event became the . subject of violation 237/92023-03. To elimi~ate duplicity of

tracking, corrective actions will be reviewed under the violation ..

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.{Open) LER 237/92028, Initiated Unit Shutdown Due to Inoperable 2/3 Diesel .Generator and Auto Closure of LPCI Minimum Flow Valve. During instrument rack inspections, further water intrusion into transmitters w~s observed.* This reinforced the licensee's root cause determination that water intrusion occurred during heat exchanger maintenance~ .Howeve~,-the corrective action specified in section "E" of the LER did not address the root cause of how the water got there, only its results. S~ecifically, all the. corrective actions focused on identifying. the instruments affected . by the water and repafring or replacing those instruments.

• The~efore, the corrective action documented ~as inadequate. * The .

LER will remain open pending adequate correc:tive action by the * licensee.

p. (Closed) LER 249/91005, Isolation Valve Closure Due to Reactor Water Cleanup System Isolation 8

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. q. r. s.' .* t. (Closed} LER 249/91009, R~vision 1, Failure to Perform Post- Maintenance Local Leak Rate Test Due to Management Deficiency . This revision changed the conunitment dates for two action items (Item 6 and 12) from January 1, 1992, to September 30, 1992 . . Revision 0 was .closed based on the remaining items being tracked under. violation 249/91035-01. Changing the .commitment dates does not affect that closure. Therefore, revision 1 is also closed. (Closed} LER ~49/91010, Revision 0 and l~ Bus 38 Undervoltage . Relay Actuation Due to Inadvertent Shorting of Relay Terminals. (Closed} LER 249/91012, Partial Primary Containmel'!t Group II Isolation During Maintenance Repairs Due to Per~onnel Error . .. (Closed} LER 249/92010, Engine~red Safety Feature Actuatio*n due to Reactor Protection System Motor Generator Set Dri~e Motor Breaker Failure.

No violations or deviations were identified in this irea. ,Systematic Evaluation Program Items (92701) NUREG 1403, "Safety Evaluation Program Report Relate~ to the Full-term Operating License for Dresden Nuclea~ Power Statioh," Table 2.1, identified 22 SEP integrated plant safety assessment report topic resolutions_to be confirmed by the NRC Region III office. _The following * i tern in that report was reviewed by the inspectors: .*

Topic VI-4/4.18.6, Leakag~ Conditions urider which the Remote

• Manual Isolation Valves on LPCI and Core Spray Systems Should be*

Isolated Are Incorporated into Emergency Procedures* . . . The licensee provided a copy of the em~rgency operating procedure which addressed, in general terms, the manual isolation of the LPCI and core spray valves. The licensee-considered this procedure to be*sufficient to meet the procedu~al requirement of the SEP item. The inspector attempted.to confirm the control room operators' ability to close the-. ten LPCI and tore spray valves listed in the SEP following an accident. The control room operators showed the inspector how eight of the valv~s could.be closed in post accident conditions and were knowl~dgeable of why and when they might need to be closed. However, the operators .. stat~d that valves 2(3}-1501-22A and B, the LPCI injection valves, could . not be manually isolated due to an electri~al interlock. The te~hnical s_taff tentatively confirmed the existence of the interlock on the. electrical drawings. The inspector concluded that the pre~ent system configuration, while not meeting the SEP conunitment; did not present an immediate safety concern. Further confirmation and review of the interlock's effect on the SEP conunitment is necessary. This matter is considered unresolved (237(249}/92026-02(DRP}} pending further review . 9

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No. viblations or deviations were identified; however, one unresolved item was identifi~d. Operational Safety Verificatiori C71707l .The inspectors reviewed the facility for conJormance with the license and with regulatory requirements. a. On a sampling basis the inspectors observed c~ntrol room activities for proper control room staffing and coordination of plant activities. -Operator adherence to procedures or TS and . operator cognizance of plant par~meters and alarms was observed. Electrical power configuration was confirmed. Various logs and . survei 11 ance records were reviewed for accuracy and completeness. * -Observations included:

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Although they were properly taken, not all of the 4-hour . chemistry sample results were logged by the unit operators during Unit 3 startup in mid-October. The shift control * room engineer relied on chemistry personnel to insure the samples and analysis were completed per TS requirements. *

On October 20,*1992, during Vnit 3 startup, with the reactor . coolant pressure at 191 psig (1317 kilopascals) operations ~erso~nel ob~erved 365°F (185°C}* on the tube side ~nd 210°F (99°C} on the shell side of the isolation condenser (IC). Approximately 2 inches (5.8 cm} of shell side water had boiled off. Operations personnel declared the IC inoperable* and closed the containment isolation valves (CIVs). Health phjsics persohnel stirveyed the parking lot and identified no contamination. The startup continued.to 2% power while an evaluation of the anomaly was performed.

Following review and completion of a safety evaluation by technical. staff personnel, a Tygon tube was installed at the l6cal leak rate test (LLRT) taps between the inboard and outboard CIVs on the IC return line. The tube was run ~everal floors up to the. IC shell and used as a tube side_ level indicator. -The IC was then filled and vented to a

• level above. the top of the tubes.. After the fill and vent

operation, the IC was pressurized and returned to service. No additional temperature anomalies were noted. The anomaly was caused (at least .in part} by a poor return-to-service for the IC prior to restart. The inspectors observed: * -* Reactor powe~ was increased to place the Unit in a * more stable condition once the decision not to shutdown was reached. This minimized the potential for a reactivity excursion.

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Operations personnel conservatively chose not to enter * * the "run" mode with the inoperable IC. .

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A pr6cedure wa~ not required t6 fill and vent the IC.*

Engineering principles ~ere not fully utilized to understand the d~graded condition. *

A dedicated control room operator was not designated to monitor IC pressure and temperature while the Tygon tube was attached and the llRT taps were open.

The safety evalu~tion, although not requi~ed,. fa~led to document key aspects of the evolution including:

The removal of po~er to the closed IC CIVs

• ,(1301-1, -2, and -4); -

The pressure and temperature rating of the Tygon tube;

The precautions taken to preclude a reactivity excursion when returning the IC to ~ervice from * cold water carry over into the reactor vessel if the IC tube~ were overfilling; and

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The use of a dedicated operator stationed at the manual llRT test valve within radio contact of

• the main control ro6m .

On a routine basi~ the inspectors toured accessibl~ 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 iri progress.

c. Walkdowns of select engineered safety features (ESF) were perfrirmed. *The ESFs were reviewed for p~oper valve and electrical * alignmerits~ Components were inspected f6r leakage, lubrication, abnormal corrosi~n, ventilation and cooling water sOpply availability. Tagouts and jumper records were revi.ewed for acctiracy where appropriate. The ESFs reviewed were: * Unit 2

.High Pressure Coolant Injection System

4:1 Kv Electrical Distribution System

Standby liquid Control System

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Containment Cooling Water System. Unit 3

Standby liquid Control System No violations* or devt-ations-,wer.e i.d~ntif~.e~. * 11

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-Monthly Maintenance Observation (62703) Stat ion maintenance. act i vit i e_s were observed to verify that they were ~onducted in ~ccordance with approved procedures and work packages~ * regulatory or-industry guidance, and in conformance with TS limiting' conditions for operations. - The inspectors verified that approvals were obtained prior to work ~nitiation, that quality control inspe~tion~ occurred, that appropriate post~maintenance funttional tests or - calibrations were performed, that maintenance personnel were qualified, that parts ~nd materials used were properly certified; and that proper radiological arid fire pre~ention cbntrols were impl~mented. _The stat~s of outstanding jobs was also reviewed to ensure that appropriate priority was assigned to maintenance of safety-related equipment which could affect system performance. The following maintenance activities were observed and reviewed: Unit 2

_Repair of the Outboard Hydrogen Monitor Containment Isolation Valve - -* 2C ccsw Pump Overhaul

Inspection of Safety-Related Equip~ent for Water Intrusion Instrument Rack 2202-19A - -

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West Corner Room LPCI Sump Cleaning

2C Containment Co~ling Service Water Pump Rebuild

LPRM Detector Plateaus Confirmation

2B Reactor Feed P~mp Seal Replacement Unit 3

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Common HPCI Signal Converter Trouble Shooting/Repair 3B CCSW Flow Indicator Trouble Shooting/Repair Standby Liquid Control Boron Tank Temperature Co~troller Troubleshooting Standby Liquid Control Temperature Switch Replacement 3A Condensate/Condensate Booster Pump Motor Replacement 3B Condensate/Condensate Booster Pump Motor Replacement -

2/3 Diesel Drivert Fire Pump toolant System Repair

2/3 B Service Wat~r Strainer Inspection/Rebuild - Observations included: a. On September 2°6, 1992, the inspector observed the testing of the 2C containment cooling service water (CCSW) pump following_ completion of maintenance to replace the pump's impeller . 12

7.

b. While reviewing the CCSW piping and instrument diagram, P&ID M-29, Sheet 2; *the inspector noticed two 2Y2-inch (6.35 cm}. diameter lines downstream from the CCSW discharge header, running up to and co~necting with the service water system supply cooling {SSWS} water header. The .CCSW discharge header to the SWSS header served

• as a back up means of supplying the .heat sink to the contrql room

air handling unit's refrigeration condensing unit. Isolating the CCSW supply header to the SWSS header was an air-operated . . . isolation valve, XCV-2/3 5741-48A,* which failed open upon loss cif either instrument air, or electric power. The licensee isolated one CCSW supply to the SWSS header; through a manual valve, and . concluded that the other line was operable through engineering* . judgment. This decision will be confirmed through testing of the systems in ~id-November.

The inspector *sked the licensee whethe~ this divergent CCSW supply was ever considered under design bases acCi den_t {OBA) _ conditions. Since the CCSW supply line isolation valve failed open on loss 6f instrument air, which would occur du~ing a loss of coolant accident with a los~ of offsite power, this open flow path from the CCSW system could potentially dive~t flo~ from the tbntainment cooling heat exchanger~ At the end rif the inspection period, licensee erigineering personnel were reviewing plant modification {M-12-2/3.,.82-1} documents, which originally installed

the. CCSW line to the control room

11 8-" air *hand.ling unit, to determine whether OBA conditions were considered in the modifi~ation. This item will remain unresolved {237(249)/92026- 03{DRP}} until the documents and* test results have been re~iewed .* by both the licensee and the inspector. During the Unit_3 forced outage, planning and scheduling provided a daily safety assessment of shutdown risk. ** This assessment was based on the status of the reactor coolant system inventory, fuel pool cooling, AC and DC power distribution; containment, . reactivity control, decay removal capability, and offsite power* availability~ The shutdown risk assessment was discussed at each "Plan of_ the Day" meeting while the Unit was shutdown and emphasis was placed on the identification of those scheduled activities.

• ~hich cbntributed t~ shutdown risk. Additionally; a status.sheet

was incorporated into the daily outage schedule .* No vi-0lation~ or deviations were identified; however, one*unresolved item was identified. Monthly Surveillance Observation (61726) . . The inspectors observed required surveillance testing a*nd .verified procedural adherence, test equipment calibration, TS action statement

• adherence, and proper remo~al and restoration of affected components.

The inspectQ.rs *reviewed completed surveillance packages to ensure that results. conformed *with --rs and proced.ur~ r_~qui rements, that there was 13

independent verification of the results, that proper signoffs occurred, and that any test deficiencie~.were appropriately dispositiohed. - . . . The inspectors witnessed portions of the following test activities: Unit 2 .

DOS 2300-3 High Pressure Coolant lnjeition System Verificatioh

DOS 1400-02 Core Spray Valve Operability Check

. DOS 1600-1 Quarterly Valve Timing

DOS 1500-06 Ltiw Pressure Coolant lnjecti6n System Pump Operability Test with Torus Available

DOS 1500-02 Quarterly Containment Cooling Service Water Pump Test for Inservice Test Program . *

DOS 1500-8 Distharge of CCSW from containment LPCI Heat Exchanger During Pump Operability Test

DOS 1400-03 Emergency Core Cooling System. Fill System ~- DIS 3900-1 Service Water Fluid Sample Radiation Monitor Calibration and Functional Test . Unit 3

DTS 8236 Full Core Calibration

.OADMP-lAS Calibration of ~he Instant~neous and.Timed Overcurre~t Protective Relays for the 38 Condensate and Condensate/Booster Pump Motor . *

DOP 1300-10 Standby Operationof the Isolation Condenser

• *

DOS 1400-01 Core Spray System Pump Test With Torus Available

. DOS 1400-02 Core Spray System Valve Operability Veri fi cation

• DOS'l500-02 CCSW In Service Quarterly Pump Test

.

DOS l500-06 LPCI System Pump Operability Test with Torus Available

• * * .DOS 1500-10 Quarterly LPCI System Pump Operability Test with Tort.is

Available for the In-Service Test (IST) Program

DOS 2300-03 HPC I System Operability Verification '. .

• *

DIS 2400-03 Post LOCA Containment Hydrogen/Oxygen Eighteen Month

Calibration and Surveillance Inspector observations were: On O~tober 5, 1~92, while reviewing the Unit 3 high pressure coolant injection (HPCI) system operability verification, the HPCI system tripped with the "HPCI Signal Converter Failu~e" annunciator in alarm .. HPCI was subsequently declared inoperable and the system engineer was notified and asked to evaluate the problem. After a review of the HPCI logic drawings, the inspector accompanied the HPCI system engineer to* the HPCI turbine supervisory instrument (TSI) cabinet in order to observe the trouble-shooting effort. lhe electrical schematics indicated that the power monitor circuits for the motor gear unit were wired in a similar fashion, i.e., with the activating alarm wired acrtiss the closed coritacts*of-botb p_ower monitor circuit .cards. The purpose of the power monitoring circuit car~H *were -'to tr.ac_k_~~l_tage on the 1 inear 14

-*

.. * 8. . - ---- variable differential transformer (LVDT) which ensured that HPCI flow controller demand and HPCI turbine control valve position for that flow .demand were in agreement with each other. Should a Circuit of the LVDT open or short~ the respective power monitor circuit card would de-energize and iriitiate an alarm*. in the main control room .. . . .. . During review of the"as-wired" configuration of the power monitor cards inside the TSI cabinet, the 27X card, which monitors power on the positive winding of the LVDT, was found to be wired differently from the 27Y power monitor card. Subsequent licensee revi~w confirmed the incorrect Unit 3 wiring; the Unit 2 circuit cards were then confifmed to

• be wired correctly. The licensee concluded that the 27X power monitor
• circuit board had become defective and that the alarm function of the

circuit board had been incorrectly wired at some point in time. The iafety significance of the incorrect wiring was that, if the positive output of the LVDT failed with HPCI in sta~dby, the control room operator would not hive indication of the failure. HPCI would have initiated, but the. auto-flow control capabilities of HPCI would not have . been functional. This item will remain unresolved (237/92026-04(DRP}) *

• until the inspector reviews the licensee's event report ( LER) corrective

actions and performs additional wiring configuration observations to - determine whether this was an isolated condition. No violaticins or deviations were identified; however, bne unresolved .item was identified. Events Followup (93702) * During the inspection peri ad,* several events occurred, some of which required prompt notificatio~ of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the ~vents onsite with the litensee and with NRC officials. In each case, the inspectors reviewed the accuracy ~nd timeliness of the licensee notification, the licensee's corrective actions and confirmed that activities were conducted within regulatory requirements. The specific events reviewed were: a. On September 28, 1992, the Unit 2 hydrogen monitor drywell outboard sample valve, 2-8501-58, was found to be leaking _. 74.28 scfh (35 seem) following the performance of a local leak rate test (LLRT). The valve was declared inoperable and the .inboard valve was isolated. When this leakage was summed to the total type B and C leakage, the total exceeded 85% of the 0.6L. TS limit. Previously, the licensee had committed to maintain an administrative limit of less than 85% of 0.6L. for the remaind~r of the Unit 2 operating cycle as part of a one-time schedular * exemption fo~the 2 year test interval for type B arid C testing requtred by 10 CFR Part 50, Appendix J, Sections II.D.2(a) and .JIJ.D,3. The valve was repaired and returned to service. Subs-eqliently,.0,LER,Z,37_/92031 was submitted to the NRC discussing all the licensee cofrecfiVEf'act-i ans .. _ _This matter will be pursued during fo 11 owup to this L_ER.

• *

15

. b. On October 14, 1992, the Unit 3 outboard main steam* line drain line valve, ~03~220-2, unexpectedly ~losed during shutdown~ The closure occurred while electrical maintenance department persrinnel * were installing jumpers on the four main steam line isolation

valve {MSIV) test relays for performance -0f the MSIV fail-safe clo~ure test. The drain valve closure resulted from a blown fuse a~tuating the auto closing circuit. Th~ outboard MSIV AC pilot - solenoids were als.o deenergized by the blown fuse. The* surveillance was performed with the MSIV control switches in the "normal-after-opened" position, which* resulted in the jumpers placed tn parallel with an energized circuit. The fuse blew.as a result of a momentarily open circuit caused by movement of the terminal wire while the jumper was installed~ *This event will be followed up. in a ~ubsequent inspe~tion report. c. On October IS, 1992, the 2/3 diesel generator auto-started when a* operator closed the auxiliary relay compartment on Bus 33-1 . actuating*th~ bus's undervoltage relays. A Group II and a Group III isolation, and standby gas treatment system {SGTS) auto-* start signals were also generated due to the momentary loss of powe~*during the transfer. This event will be followed up in a subsequent inspection report.

d. On October 24, 1992, an inadvertent reactor buildirig isolation and SGTS initiation occurred when an instrument mechanic inadvertently. tripped the_ reactor building effluent radiation monitor while performing a calibration of the spent fuel pool radiation monitor.

• lhis event will .be followed u~ in a subsequent inspection report.

e. On July 1, 1992, the annunciator system t6 Unit 2 failed. During this inspection period, the licensee disc~ssed with the inspector

• -the design changes to preclude repetition of this event.* Future

corrective actions includ~:

Eiiminating saddle type fuse holders . Permaneritly eliminating the single fuse in the annunciator

• common return circuitry.

Separating fuse holders on the annunciator circuitry into positive and negative blocks. Revising the electrical installation standards to include . fuse links for all applications. Revising the work analysts guide and the fuse control procedure {OAP 11-27) to always require the use of manufactured links.

Possible* fus.i.ng of each annunciator branch circuit . 16

• • -
• -

- - Completion -Of licensee initiatives to.reduce the loss of annunciators due,to_ele-ct-rical grounding or shorting is an open ttem (237/9~026.:...05(DRP}j~ ; ** _ No violations or deviations were identified.

• 9.

Regional Requests . ' In a June 25, 1992, *submittal related to motor-operated va.lve (MOV) concerns,_ the 1 icensee committed to perform a daily wal kdown of the accessible outboard_pipirig of the isa]ation condens~r (IC) system. The purpose of the walkdown was to minimize the probabil-ity of a challenge to deficient IC isolation valves by the early detection of leaks in the accessible pipe sections which were also susceptible to intergranular str~ss-corrosion cracking. During the inspection period, regional management requested that the inspection staff confirm performance of _ these walkdowns. The inspectors verified that oper~tors were inspe~ting the IC system daily. However, operations personnel were unaware of e_ither the reason for the daily walkdowns or the IC MOV deficiencies. - - . In submittals dated September*l2, 1990, March 11~ and 21, 1991, and September 5, 1991, the licensee responded to Generic Letter (GL) 89-10, Supplefuent 3, "Consideration of the Results of NRC Sponsored Test and - Motor Operated Valves" concerns. In the submittals, the licensee indicated that a number of reactor water cleanup, HPCI, and IC MOVs had been determined-to ~e defitient. In an April 16, 1992~ Jetter, the NRC indicated that all of the identified MOVs needed modification to provid~ --confidence that they would be capable of performing their design-basis' function. In response to the GL Supplement, the ]icensee prepared~ pl ant speci fie safety assessment ver.i fying the generic safety assessment * .performed by the NRC and the BWR Owners Group, was applicable to -

• Dresden.

Item 3 of the site specific safety assessment, "Conduct of Training," stated that plant operator training would be augmented to_ . address the MOV concerns, including discussions ~egarding the potential for incomplete closure of the subject MOVs.* However, this training was not* performed. The failure to pefform the augmented training is a deviation (237/92026-06(DRP)). Following identification to the licensee, the licensee initiated a condition adverse to quality record and routed training summary sheets to operations personnel. No viol,ations were identified; however, one deviation was found . -10. Concerns a~ (Closed) AMS No. RIII.:...90-A-0104: A concern was-raised regarding an individual who was terminated after raising concerns during an .ai-low-as-reasonably-achievabl~ meeting. After review of the circumstances, .th~ ~~ncern was not substantiated. This . ; conclusion was prov-ided in a *letter_ t_o the licensee dated September 10, 1992. . 17

b. (Closed) AMS No. RIII-9t-A-0092: A concern was raised regarding

• potential falsification of signatures on work requests. This

concern was investigated by the -Region III Office of Investigations .. Theit investigation did not conclude that any wrongdoing occurred .. A synopsis of their conclusions was provided to the licensee pn September 29, 1992.

c. (Closed) AMS No. RIII-92-A-0071: A concern was raised regarding the signatures that appeared on some weld records. The investigation into this concern dfd not identify any NRC requirements which had _been violated; therefore, this concern was rtot substantiated.

No.violations or deviations were ~dentified. 11. Scram Follo~up On October 13, 1992, Unit 3 automatically scrammed from 97% power due to a ~eactor protection syste~ (RPS) initiation signal of low reactor water level. A failed condensate/booster pump motor caused low .reactor feedwater pump suctidn ~ressure tripping the operating feedwater pumps. During the ensuing water level transient the RPS actuation setpoint was reached. Also, a Group II and Ill containment isolation.and SGTS initiation occuried due to the-low reactor ~ater level. The inspectors reviewed: the li~enseets post ~cram report, operating logs, and alarm printers~ All engineered safety features functioned properly, including the RPS. One intermedi_ate range monitor could not* be inserted into the core following the scram .. A leaking IC valve in the drywell shorted out the monitor's drive* circuitry. The balance-of-* plant feedwater level control system locked Up due to a dirty elect~ical contact *nd less than optimum response characteristics in the

• .instrumentation. Operators generally responded wel.1,- although the-*

restart of one .reactor feedwater pump was performed w~thout all . precautions being chec_ked. The post scram review was well performed with complete, accurate documentation. The initiating equipment failure, the condensate/booster motor, was due to a combination of leaking oil and paint* chips causing a sigriificant decrease in winding cooling .. Eventually the motor windings shorted out from the reduced cooling .. No violatioris or deviations were identified. 12. Man~gement Meetings

On September 25, 1992, Mr. A. Bert Davis and staff from NRC, RegiOn III, met with Mr. Cordell Reed and staff from CECo; at Commonwealth Edison Headquarters, Downers Grove, IL. The meeting was .to d"fscuss * fi ndi n,gs. of a recent 1 y comp 1 eted vulnerability assessment and license~~bfrective -actions. _The licensee's 18

presentation involved systems requiring futu~e coordinated review, specific issues needing resolution, technical staff resource changes, and material condition priorities.* At the conclusion of the meeting, the licensee provided positive results to select performance indicators.

On October 15, 1992, .Mr. Charles E; Norelius and staff from NRC, Re~ion Ill, met with Mr. Kenneth Grae~ser, General Manager, BWRs, and staff from CECo, at the Dresden St~tion. The meeting was to discuss radiation protection issues identified in the SALP report and the. Dresden . Station Hea 1th Physics ~erformance goa 1 s.

13. Open Items Open items are matters whfch have been di~cuss~d with. the licensee, which will be reviewed ,further by the inspector,. and.*which involve some action on the part of the NRC or licens~e or both. Two items disclosed during the inspection are discussed in Paragraph 3 ~nd 8. 14. Unresolved Items Unresolved items are matters ab6ut which more information is required in order to ascertain whether they are acceptable items, violations,* or .. deviations. Unresolved items disclosed.during the inspection are* discussed in Paragraphs 4, 6 and 7 .

• 15.*

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 October 30, 1992, and on November 9, 1992. The inspectors* summarized the scope and results of the inspection and discussed the likely content of this inspection report .. The licensee acknowledg~d the information and did not indicate that any of the information disclos~d during the inspection could be considered proprietary in nature.

19 }}