ML17179A676

Insp Repts 50-237/92-32 & 50-249/92-32 on 921110-1215. Violations Noted.Major Areas Inspected:Lers,Review of Operational Safety,Monthly Maint Activities,Monthly Surveillance Activities

ML17179A676
Person / Time
Site:	Dresden
Issue date:	12/31/1992
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179A674	List: ML17179A673 ML17179A675 ML17179A676
References
50-237-92-32, 50-249-92-32, NUDOCS 9301120020
Download: ML17179A676 (26)

See also: IR 05000237/1992032

Text

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U.S. NUCLEAR REGULATORY COMMISSION

• .REGION III*

Report Nos.

50-237/92032(DRP); 50-249/92032(DRP)-

. Docket Nos.

50-:23 7; 50-249

~icensee:

Conunonwealth Edison Company

Opus West III

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1400 Opus Place

Downers Grove, IL 60515_

Ucense Nos. DPR-19; DPR-25

Fad .l i ty Name:.. Dresden Nuclear Station, Uni ts 2 and 3

Inspection At:

Dresden Site, Morris,

Illinoi~

Inspection Conducted:

November 10 through-December 15, 1992

Inspectors: - W. Rogers

M. Peck

A.M. Stone

P. Lougheed .

R._ Zuffa, Illinois Departm~nt of Nuclear Safety

Approved By: @;J2/JiJ * .. * .. * .*

.. *. 1.J-/!t/1J.."

Patrick L. Hiland, Chief *

Date

Reactor _Projects _Section lB

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Inspection' Summary

Ins~ection from Nov~~ber 10 through December 15. 1992 CRepcirt No.

50-237192032 <DRPl: 50-249/92032 CORP)).

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

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the resident inspectors and an Illiriois Dep~rtment of N~clear Saf~ty

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inspector. The inspection included follow tip rin p~eviously identified items

and license~ event reports; review of operational safety, monthly maintenance

activities; monthly surveillance activities; even1;s follow up; and Dresden

management act-ion plan (DMAP) review of reactor water cleanup system (RWCU)

initiatives. Inspection modules used during this inspection were:

61726, *.

• 62703, 71707, 92700, 92701, 92702, and 93702.

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Results: Of-the seven areas in'specte~, two cUed and t~o non-cited violations

were identified *. The violations concerned the failure to correct a condition

adverse to quality and the failure of_ corrective a~tions to p*revious

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Conditions adverse to quality to ~revent returrence of those sa~e coriditi~ns

adverse to quality. The violations are dhcussed in paragraphs 4 and 5.

The

non-cited violations concer-ned a licensee-identified undocumerited design

modificati~n (discussed *1n paragraph 2.o) and a licensee-identified technic~l

. _specification violation (discussed in paragraph 3~s). - Four unresolved items -

- and three op~n items were also identified. -

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9301120020 921231

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PDR

ADOCK- 05000237

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EXECUTIVE SUMMARY **

• Plant Operations

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Operator cognizance of plant parameters and alarms w~sgood. Appropriate

decorum was mainta.ined in the control. room. Written turnovers were accurate .

. but. omissions in' log-.keeping were evident. Weaknesses were noted in senior

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.. -reactor _operator knowledge of Tec,hnical Specif,1cat1on requirement~. x I11creased

errors fo maintaining accurate equipment* status were observed.

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.Radiation Protection

Improvements were noted in maintaining contaminated boundaries and postings.

However, mechanical maintenance personnel occasionally did not follow

established radiological ~ontrols~ a repetition of earliet occtirrences.

Maintenance/Surveillance

A violation was noted: *testing of equipment until the acceptance criteria was

met without repair or technical evaluation of the malfunction. Work control

initiatives have yet to improve implementation of ~aintenance activities.

Safety Assessment and.Quality Verifitation

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Management oversight and direction was lacking in completing the safety...: *

related contact testing program and the reactor water cleanup system

improvements.

Licensee event report content was poor on a number of

occasions.

Inadeq~ate corrective actions-to a~ internal audit were apparent._

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DETAILS*

Persons Contacted

Commonwealth Edison Comoany ct~Col

• c~ Schroeder, Station Manager * . * *. * .

• R; Flahiv.e, Technical. ,Sup~dnten'dent **:l-

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.. J. Kotow.ski, Production Superintendent

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• T. O'Conner, Assistant Superintendent,.,Maintenance

J .. Achterberg, Assistant *superintendent, Work Planning.

• G. Smith, *Asshtant Superintendent, Operations

• M. Strait, Technical Staff .Supervisor.

• R. Radtke, Regul~tory Assurance Supervisor

• D. Ambler, Health Physics Supervisor

• D. Karjala,. Performance Improvement Director*

• *P. Barnes, Compliance Supervisor

• E. Carroll, Regulatory Assurance

• S. Eldrid~e, BWR Engineeri~~

.*J. Kish, Onsite Quality Verifi~ation

• W. Morgan, Statiori Partn~r

• D. Saccomando, Compljance Engineer

U. s. Nuclear Regulatorv Commission*

• P. Hiland, Chief, Section 18

. *Denotes those attending the exit *interview on December 15, 1992.

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Th~ inspectors also talked with and interviewed several other licens~e

employees during the course of the inspecti~n.

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. Licensee Action on Previtiusly Identified Items (92701. 92702)

• a.

(Open). Open Item (237/88022-0l(D~P); 249/88023-Ql(DRP.)):

Licensee

initiative to incorporate human fa~to~s into maintenance

procedures.

Human factors concerns are incorporated into*

• procedures as they are revised~ This matter remai~s ripen pending

upgrade of all maintenance procedures by a.targeted conipl~tion

date of June 1993.

b.

(Closed) Op.en Item (237/89019-04(DRP)}:. * Install at ion of a river

water level indicator. The licensee initiated a modification to

provide river water level indication via a computer po.int t_o

displ~y screens in the control room *. The modification was

installed but has been malfunctioning in the post-modificati~n

test mode since August. The inspector reviewed the work request

and the modification package and determined that no documentation

existed:as t~ the na~ure of the ~ost-modification testing

deficiencies. This matter is cortsidered an unresolved item

. (237 /92032:..0l(DRP)) until the inspector can pursue why test

deficiencies were not generated in association with this

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modtftcation. The previous open item is closed, with successful

completion of the post-modific~tion test being constdered part of

the unresol ve~ item. *

(Closed) Violation (237/249-91004-0l(DRS)):

Lack of surveillance

. testing for 1 i near therma 1 . detectors. i nsta 11 ed hl fire zones

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• * l.1.1.1- and 1. 1.2 .1. . The licensee issued a new procedure, Of ps:

4183-07 *unear Thermal Dete~tor SembAnnual Surveillance,* _and:

incorporated the surve11 lance 'i rito the licensee's *surve11 lance ..

tracking system.

The inspector confirmed .completion of these

corre~tive acti~ns and this matter is considered closed. * *

(Closed) Unresolved Item (237/249-91004-:02(DRS)): Reportability

of fire protection system pump fa i1 ures. . The inspector d iScussed

whether* *such fa i 1 ures . are re qui red to be reported under *.

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10 CFR 50.72 and 10 CFR 50.73 with the Nuclear Reactor Regulation

.(NRR) Project Manager and it was determined that these fai 1 ures

were not reportable. ThiS matter is considered closed.

(Open) Violation (237/91016-02(DRP)): lnadequacies in the s~ope

of the calibration program.

The licensee's corrective action

involved the completion of a setpoint calibration program.

The

program entailed plant walkdowns to validate new instrument data

sheets, inclusion of the data sheet information into a

computerized database, and development of calculations for .

instrtime~t strings. To date, the* licensee has completed all

necessary walkdowns.

The computerized data sheet information will

be available to station personnel in January 1993. Caleulations

for reactor protection and. emergency core cooling should complete

by December 31, 1992. The licensee projected completion of

calculations for all other technical specification (TS) parameters

• by December 31, 1993, with a definitive. schedule being _provided in

January 1993. After completing the TS parameters, other items

such as Regulatory Guide *1.97, emergency op.erating procedures, arid

non-safety related items will be addressed *. This matter remains *

open pending the licensee's completion. of this program.*

(Open) Open Item *(237/91025-0l(DRP)): *_integrated electrical

contact review and testing *. The licensee's program encompassed a

review of safety-related electrical circuits to determine *whether*

all contacts were being tested, revisJon of appli~able

surveillance procedures, and enhanc*emerit of the e]ectrical ' *. . .*

drawings .with additional nomenclature.

The program *was targeted

for completion at the onset of the Unit 2 refueli_ng outage.*

.However, due to lack of management oversight, licensee resources

did not support the targeted completion date. Instead the

licensee intended to complete only .the surveillance tests for the

emergency diesel generators (EDGs) and low pressure coolant

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injection*(LPCI) system duri~g the refueling outage, along with

all the drawing revisions. A revised schedule will be provided to

the NRC in docketed correspondence within a few weeks of this.

• report. *

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(Closed) Violation (237 /91027-02(DRP)): Unauthorized railcar door

modification~ This item remained open pending review of the

exempt change process and issuance of a station specific * .

procedure. The inspector discussed the process with the cognizant.

technical staff individu.al and reviewed. the corporate. engineering

procedure.

No problems were identified with _implementation of the

exempt change process *. The station procedure was in onsite review

at tbe end of the *inspection~

Thh\\1t~m/ls -closed. .

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(Open)* Open Item (237 /91039-02(DRP)):

SALP initiatives .. ,;*In*;

response to the 1991.SALP report, the licensee indicated *that. a**

number of corrective act1ons would be performed.

One of thes.e .

actfons involved issuance of standards for quality calculations to

• Architect/Eng1neering firms.

The inspector confirmed 1ssuanceof.

technical information document, TID-DS-03, accomplishing this ..

corrective action. This item will remain open pending completion

of the in~pector's review into the other ~orrective actions.

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(Open). Unresolved Item (2j7/92005-06(DRP)): 'Containment cooling

service water (CCSW) design concerns~ On December 1, 1992,

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General Electric (GE) completed a new Dresden containment heat

removal analysis using a corrected heat exchanger duty and the

ANSl/ANS-5.1- model.

The analysis-concluded post-accident peak

suppression pool temperatures and pressure were in excessof

previOus design results.

GE also determined that a number of

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.. other site's containment heat remova 1 . heat exchanger duties were

in*correct. This i"nformation was forwarded to regional management

for disposition. The Dresden specifi~ case wil1 be: the subject of

a future special inspection report.

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(Open) Open Item (237/92010-0l(DRP)): Corrective actions to-an

inadequate safety evaluation on the drywell sampling system.

Two

corrective actions were involved.

One was to rebaseline the

Dresden licensing basis by December 31, 1993.

The inspectors

reviewed the sched_ule ass.ociated with the rebasel ining effort and

determined it to be on schedule. .The second corrective action was_ *

to perform a containment air sampling system engineering.

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• .evaluation. The licensee completed the evaluation. and submitted a

request to NRR, requesting approval of opening of all twenty-two

sample valves simultaneo~sly. NRR authorized the o~ening of one

sample valve at a time. The licensee is revising the sampling

prQcedure, DRP 1350~07, to use one sainple point at a time* *. This

ite~ will remain open until the licensee completes the rebaseline:

• effor~ _and* .issues procedure DRP 1350-07.

(Open) Unresolved Item (237/92010-04(DRP)):

lsol~tion condenser

• (IC) test adequacy. During this inspection period the licensee

performed the 5 year heat removal capacity test on Unit 3. After

reviewing the test results, the inspector determined that the .

choke* flow phenomenon should not be a factor in a*post~SCJ".am

situation. However, given the error associated with the test

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procedure, questions still remain on the adequacy of the procedure

(See section* 6.a. of this report for further discussion).

. (Open) Unre~olved Item (237/92010-06(DRP)):. Weaknesses in* the

parts classification process.

.This item was originally opened to

. address ~roblems with the* cla~,ification of the.Unit 2.SPING.

Since the item was opened; however, other parts problems have

occurred; specifically, the *Unit 2 ,high pressure cool~nt injection

(HPCI) auxiliary oil pump motor, the Unit 2 CCSW pump impeller and

the Unit 2 CCSW pump bearings. All of .these items had concerns

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reg~rding the parts procurement process, as discussed 1~ paragraph

• 2.n and below. Therefore, this item will remain open.

(1)

(2)

• Follow up on the SPING classific~tion: Three issues were

identified which required further evaluation: **

The SPING was not oli the master equipment list (MEL) because:

it did not have a component identification number.* The

personnel responsible for the MEL recognized .that there were

deficiencies in MEL, and have begun a systematic update.

The non-safety-related SPING parts~ that were upgraded at

Dre~den based on previous inspector questi-0ns, were also

approved* for use in the Quad Cities and Zion SPINGs. The

licensee did not have any method to notify these stations

of the parts di screp_anci es found at _Dresden. *

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The licerisee did not have a definite b~sis as to what

• equipment comprised the environmental moriitoring e~uipment *

discussed in the Quality Assurance Manua 1. The MEL upgrade

personnel believed that only equipment used to monito*r

• effl uelits were* required to be .. regulatory-related.- ...

Follow ~p on ccsw*pump impeller: On-September 9, 19~2,

mainteriance*was performed on the Unit 2 CCSW pump, because

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of high vibr~tions. -As part of _this_ mai.ntenance effort, the~ *

bronze. impeller was replaced with a stainless steel .

impeller, which.was approved via.a part technical

evaluation, 02-90-06-522-00, based on a facsimile from the

pump manufacturer, Ingersoll-Rand, which stated that the

hydraulics on the stainless steel impeller was equivalent to

the original .bronze. impeller. Because the .manufacturer

accepted Part 21 responsibility, the licensee did not pursue

whether the impeller actually met the manufacturer's claims. *

After the stainless steel impel le~ was installed,-*

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dimensi-onal differences were identified, which affected pump

performance.

The impeller was replaced with a spare bronze

impeller. Further inspection is needed regarding the

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licensee's process for handling material _changes by the

original manufacturer.

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During the same CCSW pump maintenance, the.pump bearings

were changed from a shielded bearing to a.sealed one.

Following identtfitation of the change in bearing types

. during installation, a parts ev-.luation (D2-03-1088-00) was

performed which deten:nined the sealed bearing was

acceptable. Further inspection is ne.cessary.* regarding the

• Hcensee's conunercial grade-dedication process and . *

substitution of~partS~:not approved by -~he original .

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manufacturer.

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(Open) Open Item (237 /92014-02(DRP)):

Licensee initiatives to

. improve perfonilance and reduce engineered safety features * .

a_ctuations associated with the RWCU system.

Following addi~ional

LERs (237/92017; 249/92005, 249/92014, 249/92016), the corporate*.

engineering group performed an evaluation on t_he RWCU system and *

recommended expansion of the corrective actions in some respects *

and delaying some modifications. During the upcoming Unit 2 -.

refueling outage, pressure control valve 1217 and flow control

valve 1219 will be repl*ced.

Afte~ completion of these * *

~edifications, the operating data will be re~iewed and the

licensee will decide whether further design changes are necessary .

. Also during the refueling outage, seven check valves.and fout

relief valves will be inspected and repaired, if necessary.

The

licensee's engineering evaluation reconunended that a detailed*

engi:neering. controls evaluation be performed. This evaluation was

completed on.December 10, 1992, and. corrective actions will be .

established by February 1, 199~.

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Minimal progress has been made*toward correcting demineralizer

. underdrain problems.

Th~ li~ensee lo~t cognizance on the need.tti .*

decide what type of wire mesh to install in the underdrains. This

caused demi nera 1 i zer 3C to be taken out-of-.servi ce and 1 eft out

. for many months~ Also, ~o other underdrain.has been inspected ..

The licensee has developed an extensive schedule for completing

• the undetdrains and other system improvements.

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• .Post-stainer corrective _action implementation was much better with

only-the 28 post~stainer left for replacement.

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• This matter remains operi pending completion of 1 icensee corrective

actions and is* expanded to include review of_ the inspection and

repair of the relief and check valves, licensee corrective action

• * implementation, and 1 icensee determination whether further RWCU

system modifications are necessary.

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(Closed) Vi.elation (237/92014-03(DRP)): .HPCI aux<<>ii"pump motor

improper maintenance.

The inspector verified all corrective

actions were either in place (in the case.of the continuing*

training) or completed *. -During this review~ the inspector noted

that differences between the original motor and the replacement

motor contributed to the maintenance problems.

The in~pector wa~

unable to locate the *suitabiHty for application" (Dresden

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administrative procedure (OAP) 15-:06, Checklist C) which was

supposed to be used when a replacement part was not identical to

the one being replaced. Although-a parts evaluation (02-92-03-

. 0780-:00) was performed to address shorteni11g the shaft length, it

did not address the differences in motor.amperage, field ohms or *

• . number. *and. arrangement .of leads~ Inspector concerns . regarding

• • this parts evaluation will be tracked urider unresolved item *

237/92010~06 *. Th~ vi~lation is c~n~idered closed~ **

(Closed) UnresolVed Item (237/92026-04(DRP)):

Undocumented

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alteration of a powe_r. monitor c.ircuit card in the HPCI tu.rbine

supervisory instrumentation. Neither the system engineer or the

inspector'could ascertain exactly when the circuit-was* altered,.

• but it appeared'to:have been prior to 1982. It was determiiied *

that* the po~er monitor circuit alteration, which entailed-

. bypassing the failed circuit card~ .was a design change which was

• . not properly reviewed or administratively controlled.

The failed power monitor circuit card was promptly replaced, and a

licensee event report (LER 249/92019) was written detailing both

inunedia.te and lQng term corrective actions.

Followi_ng additional.

inspections of wiring configurations and reviewing the LER

corrective actions, the inspector concluded the matter was *

isolated and the LER corrective actions were adequate~

• The impropei~iring wa~ a-violati~n of 10 CFR Pa~t 50; Appendix: B,

Criterion 111, "Design Coritrol." Although the viol~tlon is. *

categorized as Severity Level IV, because the criteria specified

in Section Vll.B.2 of 10 CFR Part 2, Appendix C were satisfied,

the violation-is not being cit~d.

(Open) Open,ltem (249/92010-:.02{DRP)):

Installation of additional

clean demineralized water sources for. the. secondary side of the

IC.

The licensee. was in the process of providing a diesel powered.*

pump and motor operated valves for the Un;t 2 IC~ Unit 2

installation will be completed by the end of D2Rl3 (the upcoming

refueling outage) an.d the Unit 3 installation by the end of D3Rl3

• (scheduled to begin January 1994). *This itein will remafo open * *

pendh1g modification completion.*

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(Closed) Violation (249/92013-0l(DRP)):

lnade~uate post-

maintenance testing. The inspector reviewed the ~evtsed wotk

analyst guidelines, the training records for the symposiums, and

the assistant supervisor of maintenance's documentation oil his

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review. Additionally, the inspector discussed.the status of-the

post-maintenance testing upgrade program with the responsible work*.

analyst. : The only item still remaining tQ be completed is the

comp~terized data base; however, that is currently being followed *

unde~ the response to violation 249/91035-:0l(DRS). * To avoid.*

dupli~ation, this item is closed.

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(Open) Violation (249/92023-02(DRP)): Failure to perform a TS

required service water grab sample. The inspector verified that

the appropriate procedures were revised as comitted in the

licensee's response.*-* A_s discussed below,. a supplemental response

addressing the surveillance tracking and.communication weaknesses

wn l be submitted by mid January 1993_.

s.

(Open)- Viol at ion. (249/92023-03(DRP)):

~-Failure .to perform a TS

requ; red reactor water sample. The appropri a_ie procedures were

revised and a TS interpretation was issued to aid operations:and.

chemical personnel, as*specified in the licensee's response to the

violation. Discussions with the chemistry supervisor indicated

that a fonilal mechanism to track TS surveillances and to enhance

communication.between the operations and.chemistry staff was under

develop~ent .. A supplemental response addressing this issue will

be submitted in mid January 1993. Other initiatives such as,

chemistry staff attendance to the operations shift briefings and

• plan of the day meetings have been implemented to improve

communications.

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. (Open) Unresolved Item (237 /92026-03(DRP)):

Adequacy of*

containment tooling service watet destgn as a result ~f system

crosstie to the c9ntrol room ~VAC system. Significant information

regarding this item is provided in Section 6.b of this.report.

Further inspection is necessary to ascertain the design.change

• process associated with tieing these two systems.

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One non-cited violation and one unresolved item were 1dentifi~d.

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Licensee Event Reports Followup (92700)

The*following.LERs were reviewed to ensure that.reportability

• .requirements were met, and that correcti.ve actions, both immediate and

to prevent recurrence, ~ere accomplished in ac~ordance with the TS:

a.

(Closed) LER 237/83062, Revi~ion 2, High Pressure Coolant

Injection Motor Gear Unit Failure

b.

(Closed) LER 237/91011, Unit 2 Reactor Scram Following Turbine

Trip Due to Main Turbine- Thrust Bearing Wear Detector Malfunction

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(Closed) LER .237 /91018, Reactor Scram on Intermediate Range * .

. Monitor (IRM) *High-High Due to. System Noise.

Long term corrective .

actions to the IRM problem are being followed under open item.

137/92021~02(DRS).

d.

(Closed) LER 237 /91024, Reactor Scrim Due to Spurious Low.*

Steamline*Pressure Pulse When Turbine Stop Valves Close

e.

(Closed) LER 237 /91025, SRM/IRM Functional Test Technical

• specification Requirements Not Met Due to Procedural Deficiencies.

• The licensee completed all procedure changes to assure proper

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testing of the SRMs and IRMs~ This LER became the subject of a

non-cited violation, identified in inspection report 237/249-91025 *

paragraph 2.b. Programmatic corrective actions are being.

• perforined under the 1i censee' s integrated e lectri ca 1 *contract

• revi.ew program and are being followed un~er open item 237/91025...:01

(See section 2.f. of thh report).*

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(Closed)* lER 237 /91026, Unanticipated\\Valve Closures .~During *

. 125 Vdc Ground Checking Due to Procedure Deficiency . , ..

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(Closed) LER 237/91027, Inadvertent Closure of Core Spray Minimum.

Flow Valve 2-1402-38A Due lo Procedural Deficiency. The root* *

cause of the event was determined to be an inadequate *procedure.

The procedure.was. revised;. however, the .inspector noted th.at no*

temporary procedure chang~ was initiated during ttie revision

period. Discussion-with the licensee indicated no problems were*

encountered during this period. The oversight of immediate

corrective actions_was not safety significant.

(Open) LER 237/91028, Violation of Technical Specification Limit

on Torus Water Bulk Temperature Due to Personnel Error.

The

• inspector confirmed the completion of-all but one corrective

.action discussed in the LER.

The outstanding corrective action

was to revise a procedure indicating when LPCI water samples*were

required. The procedure stated in the LER was not revised1

• instead other chemistry department procedures were revised _

supposedly accomplishing the same task. The licensee stated the

LER would be revised in the future discussing exactly which

procedures were revised. The LER remains open pending. revision

and inspection. review of the appli.cable procedures. This LER.*was

the subject of a previous violation, 237/91035-0l(DRP).

.

.

.

.

.

.

.

(Open) LER 237/91029, The inspector determined that only two

corrective actions were not completed. These.were:

• :

Submittal of a TS change to eliminate 'the high steaml ine

radiation trip_s ~ The insp*ector ascertained that the TS

• . submittal will .be made by March 31, 1993 *

. *

.Evaluation. of methods to stop propagation of errors between

channels -

A review of the licensee's tracking system

revealed that the evaluation to stop error propagation was ..

. only for the radiation channels~

.

.

..

After further discussion with licensee management, the inspector

ascertained that division testing will be attempted with the

implementation of new TS in late 1993. The licensee's. initiative

to accomplish divisional testing is considered an open item.*

(237 /92032-02(DRP)). This LER remains open* pending submittal *of

the TS amendment. .

10

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(Closed) LER 237/91037, Reactor Scram on Spurious Intermediate

Range Monitor (IRM) High-High Signals *Due to Electromagnetic

Interference. Long.term corrective actions to the IRM noise

problem 1s being fol lowed under open item 237 /92021-02(DRS) ..

.

.

k..

• cc1 osed) LER 237 /92002, Spurious Closure of. the 2-003-2A Main

Steam Isolation Valve (MSIV) due to Failure of DC Pi.lot Solenoid.

The MSIV closure followed a.moment~ry interruption of AC power

during a power transfer, due to an undetected DC solenoid failure.

The LER stated a visual inspection of the DC coil externals *and

leads did not indicate any heat related problems.

However, the *

inspector observed discoloring on the coil leads ind~cating a

potential heat related failure. Therefore, the inspector

considered the licensee's analysis to be of pbor quality. *

.

.

.

.

Sihce the MSIV DC pilot solenoid lights only pr6vide indicat~on of

available voltage to the coil, the coil's opeh circuit was n6t

detectable. The. licensee evaluated changes to the MSIV circuitry

to provide detection and concluded no circuit ~hanges were

required at th.is time, due to monetary limitations. The circuit

design is considered an open item (237/92032-03(DRP)) pending

inspector review of the desjgn b~sis of the solenoid lights_. *

1.

. (Closed) lER 237/92008, ~nanticipated LPCI Minimum ~low_.Valve

.

Cloiure due to Spurioui Master ltip Unit Spike during Calibration.:

The licensee received ~vendor failure ahalysis of the;master trip

unit. The analysis determined that some wear in the selection

-

switch shaft -Occurred, allowing misalignment of the inside and

• • .outside selector dials. A supplemental LER will be submitted-by

January 1993 and will discuss the failure mode analysis on the

master trip unit and its ramifications to the engineered safety

features actuation. *The root cause determination .wil 1. be

evaluated ~uring review of this. supplemental response ..

. m.

(Closed) LER 237/92015~ Unanticipated Val~e Movement D~ring *

125 Vdc Ground Checking Due to Management Deficiency. * The root

cause o.f this event was management defiCiency, iil that: corrective*

actions to prevent recurrence as stated in a.previous. LER were.not

completed. This is considered another example of violation

(237/~49-92009-05b) ~ince the failure to. ensure adequate and *

. timely corrective actions occurred within the same period. **As al 1

corrective actions have been completed, this item is closed ...

n.

(Closed) LER 237/92017, Unplanned Reactor W~ter Cleanup Isolation. **

See section 2.m. for further information.

• O.

• cc1osed) LER 237/92022, Unplanned Loss of Control Room

Annunciators Due to Loose .. Power Supply Fuse.

Long term corrective

actions to the annunciator problem are being followed under open

item 237/92026-06(DRP}.

11

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(Closed) LER 237/92025, Isolation Condenser Vent ValJe 2-1301-17

and 2-1301..:20 Closure Due to Unknown Causes ..

(Open) LER ~37/92030, Missin~ Piping Supports on Contai~ment

Atmospheric Sampling System .. The inspector met with the cognizant

engineering personnel involvedin discovering and evaluating the .

.. missing supports *. Although the LER gave an event date of.

-September 18, 1992, "this was .the date .when station personra.el.were

informed of the problem by corporate enginee*ring personnel.

Contract personnel had actually identified the missing support in

June 1992. Through a number qf.walkdowns to analyze the as-found

condition and subsequent stress calculations, the contractor, * *

under corporate engineering overview, determined-the configuration

• to be report ab 1 e. * However, .. a number * of . de 1 ays *occurred before

that conclusion*was reached, including: a poor *screening decision

as to the importance of the missing supports, lack of funds to *

c*omplete the project- under .which the configuration was initially* *

observed, rel~ase of the contract supervisor in~harge of the

project, and poor conununication between the contractor and

cognizant licensee ind1vfduals. These delays were reflective of a

weak process in resolving nonconforming c*onditions identified by

contractors and lack of own~rship of said projects by CECo.

.

personnel.** This LER remains outstandjng pendjng technical review

of the licensee's stress calculations.

(Closed) LER 237 /92031, Failure of *the Outboard Drywell Air Sample

Valve 2-8501-58 During its 24 Month Local Leak Rate Testing

Surveillance Due to Improper Valve Seating. This was a .voluntary

. LER.describing a local leak rate test (LLRT) failure which*.

resulted in the allowable administrative leakage limit being *

exceeded. This administrative limit was established based on a

schedular exemption granted by the NRC. The licensee determined

that the va 1 ve failure caused the tot a 1 maximum pathway 1 eakage to

reach 435.64 scfh. The licensee immediately complied with the TS

limiting condition of operation by closing the inboard isolation

valve and taking it out-of-service. The outboard valve was ..

repaired and tested, *and the system was *re~urned to service.

_ The inspector reviewed past LL.RT records. Valve 2-8501-5a had no

history of previous failures during the last three integrated leak

rate tests (covering a period of approximately 10 years). The *

inboard valve, during that same time period, had one failure.

Based on that record, the inspector concluded that this valve was

~ot a repetitive failure._ This item i~ closed.*

.a

(Closed) LER 237/92036, Technical Spe~ificaiio~ 3.9.B.2 Violati~n;

Failure to Run Unit 2 and 3 Diesel Generators With 2/3 Diesel *

Generator Inoperable Due to Personnel. Error. *On October 26, 1992,

with both* Units; 2 *and 3 at power, the swing. (2/3) .EOG was rendered

inoperable to perform a special diagnostic* surveillance of the*

EOG.

The operating engineer (OE), a senior reactor operator (SRO)

license holder, provided instructions to the shift indicating that

12

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the redundant EDGs on. Units 2 and 3 did not require testing to

confirm operability. Although the instructions were in conflict

with TS, they were approved by another OE.

Subsequently, the

shift engineer and-shift control room engineer (SCRE) implemented

the night orders withoutconsideration for the TS requirements

• associated with the redundant EDGs.

The LER corrective *actions included counseling the OE pr1ginating

the .instructions, revising the TS and informing the operating *

crews of the TS change.

The inspector reviewed these corrective

actions and considered them lacking as to corrective actions

associated with the other SRO license holders involved. The

ins.pector discussed this matter with operations management who

• indicated counseling sessions had been held with all SROs

associated. with the event but was omitted from .the LER.

These .

additional corrective actions, coupled with the new, clearer TS,

are considered adequate. This matter was identified initially by

the lkensee and a condition adverse to quality report was issued.

Also~ the two redundant EDGs were successfully tested a few hours

later. *This is a violation of TS 3.9.B.2. *However, the violation

will *not be cited because it meets the requirements for a .

non-cited violation under 10 CFR Part 2, Appendix C, Section

VII.B.2.

.

. Two other items were identified from the inspector's review:

Th_e new TS, issued on October 19, 1992, provided no

direction to assure operability of redundant EDGs when a *

diesel is taken out of service for pre-planned preventative

maintenance or testing. This matter was identified to the

NRR project manager for resolution.

.

When an EOG is rendered inoperable, two outside power lines

are r~quired to be in~servite to meet.the TS limitfrig

.

condition for operation (LCO).

However, the licensee.did

not document that.these lines were operable or confirm that -

they were in service. This matter was discussed with the

assistant superintendent of operations (ASO).

.

.

t.

(Closed) LER 249/91014, Standby Liquid Control Relief Valve

Failure. *During this inspection period, the licensee reviewed and

expa~ded the LER corrective actions to apply to both units and

• assigned dates as to w~en the actions would be accomplished.

The

licensee conunitted to*revise preventative maintenance pr.ocedures,

• * .DMS-1100-01 and DMP-1100-02, and incorporate, into the operator

• lesson plans, a discussion of boron intrusion effects on the

. relief valve by January 1993. Additionally, the licensee

conunitted to revise 'procedures DOS-1100-01 and oos-1100~04 by.

March 1993 and to replace the packing in the valves du~ing the

next refueling outages on both units. Completion of these actions

is considered an open item (239/249-92032-04(DRP)).

13

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(Closed) LER 249/91015, Revisions 0 and 1, Unplanned Autom~tic

Initiation of the Standby Gas Treatment System (SGTS) during-

Reactor Protection .system Electrical Bus Transfer and Failure of

SGTS to *Start during a Preplanned Testing Sequence. While

v.

w.

• _ reviewing the SGTS logic the inspector i~entified two i_mportant

• aspects of the control logic: -

_

• _

• -

Through certain ~ontrol switch manipulations, -it was

possible to- align the SGTS logic circuitry s'uch that a train

could be electrically ~locked-out* of an auto initiation.

The lock-out of one train can occur dur1ng surveillance -

testing and has been previously observed. The safety

significance of the lock-but was considered minimal as one

train of SGTS would.be performing its intended safety *

f unct i ofl when the 1 ockout occurr_ed.

. .

.

.

. .

When performing Dresden Operating Procedure (DOP) 7500-L -

• standby Gas Treatment System Operation,* both trains could

_be rendered inoperable. One train would be in_ service and

• the second train would automatically start from an accident

signal. With both trains of the SGTS running, the flow to .

. each train would be approximately 50 percent of -normal full

flow, or about 2000 scfm, due to the air flow transmitter in

the conunon SGTS discharge piping which regulates flow to-

only 400() scfm.

The *2000 scfm at the .suction of each SGTS

fan would be insufficient (2800scfm required) to actuate

the flow switch starting the respective SB~T's heater._

Under these conditions~ both SGTS trains would ru~ without

- an energized* heating element, .creating higher humidity

across the charcoal adsorption filter. Higher humidity:

would significantly jmpair filter efficiency.

-

The inspector determined the* procedures ~stabl ishi-ng these switch

corifigurations have been in place sirice ~pproximately September -

1974. The.licensee was in the process of revising the procedure -

at the end of the irispection period~ This matter is considered an~-

unresolved item (237/249-92032-05(DRP)), pendirig further review of

_ -the SGTS design basis.

(Closed) LER 249/92005, Unplanned Reactor Water Cleanup -Isolation.

See .section 2.m for further information.

.

..

.

.

.

-

• .

.

.

(Open) LER 249/92008, Containment Cooling Service Water Pump Vault

Door Leakage due to Worn Latch Packing.

The licensee.committed to

_ rep l *ace *the 1 atch mechanisms and the -door sea 1 * every -other

.refueling outage as part of a preventative maintenance program.

Also, a maintenance surveillance procedure would be written to

- perform the activity.* The LER did , not indicate. when the

corrective actions would be completed~ The inspector confirmed

the procedure was completed December 8, 1992.

The failure to _

include a completion date in the LER was considered a weakness.

14

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The LER remains open pending confirmation that the procedure.was

• incorporated into the preventative maintenance scheduling program.

(Closed) LER 249/92014, Reactor Water Cl_eanup System Isolation

During Fill and Vent Due to Pressure Control Problems. See section

2~m for further informati9n.

(.Closed) LER 249/92016, Unplanned:,Reactor Water Cleanup Isolation.

See section 2. m *for further fof orniat ion *

. (Closed) LER 249/92019,.HPCI-System Declared Inoperable Due to

Signal Converter Failure. See section 2~0 for further

information.

(Open) LER 249l92020,. Unplanned Closure of Main Steam Line Drain

Valve 3-0220-2 Caused by Blown Fuse Due to Procedure Deficiency~

The correct_ive action section of* the* LER did not provide a date as

to*when the deficient proc.edure.would be revised. This is.

considered a weakness.

The licensee s~bsequently indicated the

procedure would be revised in January. _1993.

The LER remains

outstanding pending issuance of the procedure revision.

bb. * (Open) LER 249/92021, Reactor Scram Due to 38 Condensate/.

• Condensate Bo9ster P4mp Motor Failure and Subsequent Event.

The

LER had numerous omissions .. iricludirig missing corrective action .

compl~tion dates,* correctiv~ actions associated with t~o operator.

errors, actions to resolve voltage.spikes when starting a reactor

feedwater pump and corrective actions dealing with .communfcation

• _weaknesses betwe~n the OE and cognizant maintenance personnel as

• to the material condition of the pump motor prior to its failu.re ..

This LER remains open pending revision of the LERr

One non-cited violation, one uriresolved item, arid three op~n items were

identified.

4.

Operational Safety Verification (71707)

.

.

.

• The insp_e~t~rs reviewed the facility for conformance with the 1 icense .

and with regulatory requirements.

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 or Technical

Specifications and operator cognizance of plant parameter_s and .

alarms was observed. Electrical power configuration .was

.* *

confirmed .. Various logs and surveillance records were review~d

foraccuracy and completeness.

..

Observations included:

.. 15

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On November 2-7, 1992, during- the second shift,* an engineered

safety feature (ESF) actuation occurred when the A-train of

. the SGTS automatically started. Notification to the NRC was

• * made in a ti me l y manner.

However, the event was not

documented in the center desk log. The inspector discussed

this with shift management and a log revision was made. *

. .

- .

. .

.

.

.

• .

On December 6, *'-l992., :~everal * survei 11 ances were ,per.formed to

. fulfill .the post maintenance testing requirement fQr. the 3A

LPCI system return to service. The Unit 3 NSO logs .for the

appropriate shifts did not $tate the surveillances in *

progress nor clearly state the problems encou_ntered.

The -

inspector discussed the concern with the operator and .

clarify~ng statements were added to the log.

.

.

Operators were cognizant of p l'ant parameter~ and al arins.

.

Throughout most of the inspection period, a high_ temperature

was observed on the 2A reactor recirculation pump seal that

required additional monitoring by operators. Operators

conscientiously monitored field performance and provided

accurate information on the degradation of the seal.

Subsequently, on D~cember 9, the licensee shut down Unit 2

• for a forced outage to determine the cause of* the seal

degradation and to replace the sea 1.

'.

'

Appropriate decor.um was maintained within -the control room .

Verbal conununications within.the control room were clear

with some instances of informality. Written turnovers were

complete and accurate. * Face-to~face turnovers did not

always include joint panel walkdowns.

Log entries of November 30, 1992, for-Unit 3 indicated that

. containment isolation valve~ 3-1601-55, was stroked timed

. *per DOS 1600-01, *Quarterly IST Valve _Stroking.* The valve

• *failed the *5 second acceptance criteria by 0.02 seconds and

• was declared inoperable*.

However, the valve was

successfully restroked twice and the OE declared ;t

-Operable. A work request designated for unit outage was

initiated on the valve and a condition adverse to quality

report written. The inspector discussed* the adequacy of

these corrective-actions with the ASO who instructed the

valve be placed on a weekly stroking period. The failure of

operators to adequately d_ispositfon the test deficiency is

considered a violation (249/92032-06(DRP)) of 10 CFR

Part 50, Appendix B, Criterion XVI, *corrective Actions* in.

that the deficient valve was restroked until it passed the*

• acceptanc~ criteria without the malfunction being corre.cted.

b.

On a routine basis the inspectors toured accessible areas of the

• facility to assess worker adherence to radiation protection.

controls and *the site security pla~, housekeeping or cleanliness~

16

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and control of field a~tivities in progress. Observations

included:

• ..

. Appropriate .contaminated boundaries w~re established. or

immediately identified to health physics by wor.kers> *

Radiation postings were appropriate. *

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• On November 9,-1992, .bolts .were .found to be missing *from ..

• seismic cable. tray s~pports associated with the reactor.

,vessel level instrumentation. system (RVLIS) cabling i11-the

. Unit .3 reactor building. * The *licensee was* infonned and on *

• November 13, 1992, engineerfog provided a written evaluation

of. the nonconforming condition. The evaluation concluded the *

cable tray and support system met the final .safety analysis.

report (FSAR} limits without the bolt installed. **Therefore,

no operability concerns existed with regi}rds to the* trays.~.

Walkdowns of selected ESFs were performed.

The ESFs were reviewed

• for proper valve and electrical alignments. * Components were *

inspected for leakage, lubrication, abnonnal corrosion,

ventilation and cooling water supply availability. Tagouts and

jumper records were reviewed for accuracy where appropriate .. The

ESFs reviewed were:

. Unit 2

. Unit 2/3 :standby Gas Treatment system

Unit.3

.

• *

High Pressure Coolant Injection

• *

Low Pressure Coolant Injection

Core Spray

One violation wa~ identified.

Monthly Maintenance Observation C62703l *

.

.

.

Station maintenance activities were observed to verify that they were

conducted in accordance .with approved procedures and work packages, * .

regulatory or industry guidance, and in conformance with TS LCOs. The

inspectors verified that approvals wer, obtained prior to work

initiation, that quality control*inspections occurred, that. appropriate

post..;maintenance functional tests or calibrations were perfonned, that

maintenance personnel were*qua11fied, that*parts and materials. used were

• properly certified; and that proper radiological and fire prevention

controls were implemented.

The status of outstanding jobs was also

reviewed to ensure ihat appropriate priority was* assigned to maintenance

• of safely-related equipment which could affect system performance~ The

following maintenance activities were observed and reviewed:

.

.

17

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Unit 2 .

. *

Troubleshoot and Repair Oxygen Analyzer

Refuel Environmental Qualification surveillance on Bus 24-1

Breaker

.

.

Replacement of Matn Steamline Flow Indicator

.

Overhaul of *2-3704, Shutdown Cooling RBCCW Flow Control Valve

B Off-Gas Recombiner Room Ventilation Exhaust Fan Replacement

• .-

..

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Unit 3

.

Repair of Reactor. Building Vent Recorder

Repair of*. Reactor Building Radiation Monitor

Repair ofDivision II* Torus Temperature Recorder

• Repair of Service Water Radiation Monitor

.

A Stator Coolt.ng Water Pump Motor Replacement

A LPCI Discharge Checkvalve Rebuild

. B* Reactor 'Feedwater Pump Seal Repair_ * **

• *

Reactor Building Sump Pump Repack

.

.

• * Overhaul of Degraded Voltage Relay for Bus 33-1

Common

2/3B Service Water Strainer Rebuild

Inspector observations .were:*

a.

On December 1, 1992, ~hile touring the Unit 3 west LPCI c~rner*

room, the inspector observed two mechanical maintenance personnel *

exiting the torus afte.r performing work on the Unit 3. sump pump .. *

The .two individuals failed to perform a whole body frisk- prior to

donning their street clothes.

OAP 12-13, *Personal External

Contamination Surveys,* section F.6. states that a whole body*

survey is required to be performed prior to donning personal

clothing if an entire set *of protective clothing was worn~

• Failure to perform a whole body survey is contrary to DAP 12-13. *

On Qecember 1, 1992, while observing mainten~nce on the 38 reactor

.. feedwater pump, the inspector observed _a maintenance individual

remove. both the rubber. and inner cotton gloves to perform a

..

. delicate m~nipulation. * The area was posted as a contaminated* area

• under radiation work permit (RWP) 20259.

Review of the RP survey

in effect indtcated that the work area was clean since the process .

1 ine had not been broken_. * However, the RWP required cotton liners

and rubber gloves during_maintenance activities *. OAP 12-25,

• Radiation Work Permit Program,* section E.6. *states that

protective actions and special instructions; as .specified by the

RWP, are to be implemented in the course of performing each. job.

Section F.2.e.(3) states that it 1s the responsibility of the

individual to sign the RWP a~knowledgement form indicating that

the RWP has been read and understood. and will be complied with .

. Removal of radiation protection clothing was contrary to the* RWP

• requirements *

18.

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The license~ promptly investi~ated the two incidents ~nd discussed

the inappropriate actions with the individuals involved.

In '

addition, tha licensee identified that the individual involved* on

the feedwater -pump job had.signed*onto the general RWP and not the

specific RWP for this job.

Further ,review indicated that on May 9, 1992,- .a radiation*

-.

.

occurrence report (ROR) was written to document the failure to

-follow RWPs by two mechanical maintenance individuals.

In the

ROR, protective clothing w~s*worn-improperly; including removal of

. a rubber glove while adjusting an indicator. * The .corrective

actions consisted of disciplinary actions for the individuals.

Discussion with the onsite quality verification supervisor

indicated that a September 1992 audit (#12-92-09) identified a::

corrective action request regarding failure to frisk prior to

donning clothes. , The corrective action consisted of training on

RP practices which was completed on October 1, 1992 during

departmental tailgate~.

10 CFR P~rt 50, Appendix 8, Criteria XVI, states, in part, that

measures shall be established to assure that conditions adverse to

quality such as nonconformances are promptly identified and

corrected~ .Failure to implement effective corrective actions to *

prevent recur*rence of the failure to * fo l1 ow the RP procedures by

mechanical maintenance personnel is contrary to Criteria XVI and

is considered a yiolation (237/249-92032-07(DRP)).

b.

-On December 1, 1992, the 3A and lD LPCI pu~ps were run~irig th the*

torus cooling mode of operation in support of a HPCI routine

surveillance. After the LPCI pumps were secured, the operator

'observed the low pressure annunciator did not clear.

Investigation revealed the 3A LPCI discharge check valve was not

fully seated.which r~sulting in the low pressure condition~

Investigation under the corrective work request (14474) indicated

the viton seal was torn preventing one disk of the dual check

valve from fully seating. The valve was a 12 inch dual disk check:

valve manufactured by C&S Valve and was installed in late 1991. A

similar valve *was installed in the 38 LPCI pump system *. * The 3A

. *

valve* was replaced with a similar valve of a different lot number.

-The new seal was inspected by the vendor and technical staff prior

to installation.

Preliminary root cause.determination indicated the seal adhesive

was ineffective. The-vendor ~as.nrit cognizant of any si~ilar *

problems with the seals. The licensee has initiated a 10 CFR *

Part 21 review and is continuing the root cause* investigation;

The 1 icensee intends to inspect the 38 LPCL dhcharge check valve

in the near future. *

Following repair of .the valve, DOS 1500-10, *Quarterly LPCI System

Pump Operability Test with Tor~s Available for the Inservice Test

19

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(IST) Program,* was specified as a post-maintenance test to prove

the proper functioning of the 3A LPCI pump discharge check valve.

Several discrepancies and concerns were noted with the post-

maintenance testing~

Specifically~

Several: steps were marked as *Not Applicable (NA)*; however,

no int~ia*ls or explanation as to why the steps were marked

• were provided *. The purpose of the test was to verify the

operability of the check valve; however, the steps to

document the opening of the c.heck valve were marked *NA.* *

The test was considered satisfactory for proving check valve

operability; however, the acceptance criteria to verify the

• . valve opened was marked . *NA.*

Sections of the test were performed out of *ord.er. Actions .

were taken without procedural steps or documented direction.

The procedure specifically directed the operator to test the *

• .B pump (including starting* the pump and verifying no back

leakage through the A discharge chec*k valve) proceeded by

the A pump operability section (including starting the

A pump, se_curing the B pump and verifying the discharge

check valve opens). Discussion with the operator indicated

that the A LPCI pump operability section was performed first

and po.rtions of. the B LPCI pump section were performed last.

While the reasoning behind this decision* was logical, the

• procedure, as written, did not support this evolution *. By

performing the sections out of order, no steps were provided *

to secure the pumps *. Discussion with the operator ind.icated

that the A pump was secured after startirig the B pump and

the B pump was secured using the procedural step to secure

the A pump.

Had the A pump not been secured while the B *

• pump was running it would not have been.possible to verify

that the A discharge theck val~e closed properly as the step

• to secure the A pump was not provided in the B pump

.operability section~

-

The.method for performing the test in the above .man~er was

, not documented in the procedure or* in the operator .1 ogs.

Altho~gh the above discrepancies in the test otcurred~ the _

inspector considered that operability of the check valve was . *

demonstrated, based upon the operators statement. *Therefore, the

safety significance of this example was minimal *. However~ 'this is

considered an unresolved. item (249/92032~0S(DRP)) pending further

review of the use and conduct of partial surveillances.for post-

m~tntenance testin~.

One violation ~nd on~ unresolved item ~ere identified.

20 .

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6.

• Monthly Surveillance Observation C61726l

.

.

.

.

.

-

The* inspectors observed required survei 11 ance testing and verified.*

procedural adhe~ence, _test equipment cal ibrati_on, TS action statement

adherence, and proper remova 1 and restoration of affected components. _

The inspectors reviewed completed surveillance packages to ensure that *

results conformed with TS and p,rocedure requirements, that *there. was

independent verification of.the'.results,>t~at,proper signoffs occurred~

and that any test ~eficfencies were appropriately dis~ositioned. The

inspectors witnessed- portions of the following t~st activities: *

Unit

• * **

• • *

• * *

2

DOS 500-8

Main Steam Line ls~lation Valves Not Full Open Scram

DOS 500-3

APRM Rod Block and Scram Functional Test

DOS 6600-1 Diesel Generator Surveillance Tests

DOS 300-1

Daily/Weekly Control Rod Drive Exercjse .

DOS i700-l Main Steam Line Radiation Monitor Scram and Isolation * *

Functional Test

.

• ..

DOS 6600-8 Quarterly Diesel* Generator.Cooling Water Pump Test for

the In-Service Test Program * .

.

DOS 1600-9 Monthly Suppression Ch.amber to Drywell *vac_uum Breaker_

Full Stroke Exercise Test *

DOS 1600-11 Monthly Nitrogen Makeup Valve Operability Checks

DOS 250-1

10% Closure Test of Main Steam Isolation Valves

DOS

250,...02 Full Closure Testing and Timing of the Main Steam

lsolatitin Valves

DOS 2300-01 HPCI *System Valve Operability Test

• * *

DOS 2300-03 HPCI System OperabilUy Verification*

.

• DIS 1300-04 Isolation Condenser Radiation Monitor Calibration and

Surveillance

.

.

DIS 1600-03 Torus to Reactor Building Vacuum Relief V~lve Trip

Unit Calibration

..

SP 92-11-133 Special Test of Pump Performance Of the Containment

Cooling_Service Water (CCSW) Pumps

un*i t 3

• *

DOS 1700-1 Main Steam Line. Radiation Monitor Scram and Isolation *

Functional Test

• .

- .

-DOS 6600:-8 Quarterly Diesel Generator Cooling'Water _Pump Test* for

the In-Servite Test Program

- DOS 1600-11 Monthly Nitrogen Makeup Valve Operability Checks

_

• *

DOS 1600-9 Monthly Suppression Chainber to *Drywell Vacuuin Breaker. *

Full Stroke Exercise*Test

DOS 2300-03 -HPCI System Pump Test

.

DOS 1500-10 Quarterly LPCI System Pump Operability Test With Torus .

.

Available for the In-Service Test Program

.

• DOS 1500-06 LPCI System Pump Operability Test With Torus Available

DOS 300-1 * Daily/Weekly Control Rod-Drive Exercise

21

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DOS 6600-8 Quarterly Die.sel Generator Cooling .Water Pump Test for

the In-Service Test Program

.

. *

DOS 1600-11 Monthly Nttrogen Makeup Valv.e Operability Checks

DIS .1700-15 Refuel floor Radiation_Mbnitor Calibration and

Functional Test

• Inspec.tor observations .were:

. .

.

.

.

.

~.

On November 14, 1992, the licensee performed the *1c five year heat

removal .capability test for- Unit 3, per DOS 1300.,.0l.. The pretest

high-level-of-awareness briefing was excellent. Contingencies for

potential test anomalies, including a failure in the deficient IC

1sol at ion valve- (3-MOV-1301...;03), were discussed and staged.*

Radiation protection support was also good.

Precautionary steps

were taken in anticipation of the hi~h radiation fields expected

b.

on th* IC floor.

The test acceptance criteria specified in the FSAR required

verification of the heat removal duty.

The test procedure

verified the duty by comparing the calculated primary side power

output differences before and after initiation of the IC.

The

primary side power calculat10n used inputs from the average power

range monitors (APRMs) and the feedwater fl ow venturi es. ** Test

data indicated. approximately 20% random variance in the

.

• • instantaneously calculated duty_ due to random §!rror of the input

parameters. *However, the procedure acceptance criteria and * .

calculation failed to*consider the instrument error *. A previous

unresolved item (237/92010-04(DRP)) was identified concerning the

adequacy to th.e IC heat removal test procedure.

The instrument.

error aspect of the p~ocedure will be incor~orated into this

previous uriresolved item, which will .remain open~

On November 18, 1992, the licensee performed a. specia*l .test of the

Unit 2 CCSW pumps in order to determine their oper.abilj,ty -~nder

conditions* requiring divergent fl ow from the contai niiient*>c-oo 1 i ng

heat exchangers, through the pti~p's respective room cooler.~s well

as through the control room B afr handling unit's (AHU) *

refrigerator_condensing unit. The inspector confirmed that the

test was performed in accordance wtth proper procedures ahd that

applicable TS LCOs were* entered.

The special te~t originated from the inspector's concerns during a

routine walkdown -of the CCSW System on September 26, 1992, as to

whether the* 1 oss of lPC I heat exchanger fl ow due to these .

.

divergent paths were appropriately considered. The results of the

test indicated that both the 28 and the 2C CCSW pumps did not meet

. their ts requirements when* tested. in the* *as-fo~nd* system

condition. Subsequent to the as-found test condition, divergent

CCSW fl ow adjustments. were made to both the room coo 1 er and the. *

control room B AHU such that the 28 and 2~ CCSW pumps were able to

22

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meet the TS required discharge fl ow and. pressure. . However, the

.divergent flow path from the CCSW system to the B*eontrol room AHU

. has since been isolated to ensure the TS operability of the CCSW

• system. This matter will be the subject of a future special

. inspection report .*

.

'

.

.

No. violati.ons or deviations were identified.

7.

Eventi Followyp C93702l

During 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 inspectors reviewed the accuracy and . *

.. timeliness of the licensee notifi~ation, the licensee's correctiv~

actions and t'hat activities were-conducted.within regulatory *

requireme*nts.

The specHic ~vents reviewed were:

a.

On November 7, Unit 3 was shutdown due to a 40 scfm nitrogen leak

in the drywell pneumatic control system. A main. steam 1 ine*

isolation.valve instrument block valve was identified as the

leakage source and the. valve was repaired prior to startup *.

During the forced outage, four control rod drive accumulators were

replaced and a reactor recirculation pump ventilation duct was

repaired. Restart began on November 9, 1992, and the main

generator was synchronized to the grid on November 10, 1992;

b.

On November 24, the licensee informed NRC site. and regional

personnel that a control rod mispositioning.event occurred on

September 18, _1992.

This ma_tter will be the subject of a future

special inspection report.

c.

On November 26, the licensee informed the inspectors that a .

• reactor protection system instrumentation problem identified.at

the Monticello Power Station could exist at Dresden.

The problem

dealt.with the slow bias reactor scram and associated theoretical ;,.

instrumentation errors *. The licensee determined that the analyzed

.120 percent power upper limit could be exceeded by one-half

percent if all instrument error were in the nonconservative

direction. The licens*ee reduced the n.ominal power gain filttors by_

. one percent, providing the necessary conservative power margin.*

. The licensee also initi~ted a condition adverse to quality report

to.document corrective actions.

d.

On November 27, the RWCU pump room gate was found unlocked.-

This* *

is a high radiation area *. A condition adverse to quality report

was written by the operating crew.

The investigation and

determination of the root cause as to why the gate was unlocked

will be pursued in the next inspection report. *.

e.

On November 27~ the A train of the SGTS automatically started due

.to operator error. Prior to this event, an instrument *mechanic

23

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was performing DIS 1700-'15 which generated'a start signal to the B

train. When the B train automatically started, the operator

inappropriately placed the A train SGTS start sw;tch in the * ...

primary position *. Thb actfon was not stated in the procedure.

Since the automatic start signal was not.reset, the A train also

• started. After realizing the error and discussion with the SCRE, *

the operator secured the A train. The licerisee's investigation *

and corrective actions:*will :be.,rev*iewed*:with"*the;:LER.

• *

-~ **.

On November 29, Unit 3 operators found a containment spray vent

valve locked-open instead of locked-closed *. A condition adverse

to quality report was written *. The companion vent valve was .

closed and the system was operable~ The inspector* will follow *

licensee's investigation and corrective action fn a subsequent*

inspection report.

On ~ovember 29, APRM. channel 3 and 4 were past their surveillance .

criti~al date a~sociated with DIS 700-06. A condition adverse to*

~uality report was written. The inspectors wi)l follow licensee's

• inve~tigation and corrective action in a subsequent report.

On December 1,- electrical maintenance_personnel were unable to

• obtain starting battery specific gravity readings on either the*

• unit 1 or unit 2/3 diesel driven fire pumps due to low

temperatures. Both fire pumps were declared inoperable ~nd the

.station entered a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> administrattve LCO for loss of all fire

.

suppression. Operations personnel restored the local temperatures * *

to within operating parameters by the use of portable heaters by

6:12 a.m.

The low temperatures occurred when the plant's heating

boiler was removed from service to repair a tube leak i~ the '

. condensate return unit *. The boiler was returned to service on the

afternoon of December. 1

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Later that day the Unit 2/3 fire pump engine overheated due *to a. .

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procedure to address action to be taken by operating crews when

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heating boilers or sections of heating systems within the facility

.

s~~!:n .~~\\:~e~e~!c~0 t~.~~!~r: .. m~~P~!!~:.~~~=~~atory . ,

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A. number of equipment status. or out-of-service (OOS) problerns.

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switch was off although it had an OOS card attach_ed

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on* November 13, the OOS card for.the 2A hydrogen/oxygen

analyzer sample pump electrical breaker was *attached to the

28 samp 1 e pump breaker~

'*

.

• *

On December 4, a portion of the Untt 2 .fuel pool cooling

piping was overpressurized during a hydrostat.ic t~st of a

• shotdown cooling heat exchanger~

On December 5, the 28 off gas recombiner exhaust fan* was

disassembled without the fan motor taken OOS.

These* matters are c.onsidered an unresolved item {237 /249-92032- *

09{DRP)) pending inspector re~iew into the ~ausal factors

surrounding these events.

• No violatfons or deviations were. identified; however, one unresolved

.item ~as identified. *

8.

• Review of Dresden Management Action Plan Actfons Associated With the

Reactor Water Cleanup Svstem

The inspector reviewed DMAP TS-06 associated with improving the

performance of the RWCU system.

The inspector noted:

• • ..

.

.

.

~

.

.

.

.

.

• The steps had been revised excluding demineralizer 38 and 3A

.

inspections even though these inspections were convnitted to be

performed in correspondence to the N~C.

Step 7 associatedwith*inspection and repair.of demineralizer 3C

was annotated 100% complete although needed repairs were not made.

to demineralizer 3C.

Step 8, repair of demineralizer underd~ain 28, was annotated for-*

completion during D2Rl3, however, the work request.was not .on the

outage schedule and, per.conversation.with the system ~ngineer~

wi 11 be performea after D2R13.

• *

. The DMAP *steps did not include implementation. of a recent

corporate engineering s~udy on the RWCU system or an ongoing.study

of.the RWCU controls *systems.

• When the inspe~tor inquired, th~ responsible supervisor could not

explain.why the DMAP*had been revised. Further inspection determined

• these actions were taken by the *system engineer, who has since left the

licensee's employ.

Subsequently~ the licens~e determined the true

status of the DMAP and provided that status-to the inspector *.

.

.

.

No violations or deviations were identified.

25

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9.

Open Items

Open items are matters which have been discussed with the licensee;

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

action on the part of the NRC or.licensee or both~ Three i terns

'~~r

. disclosed during the *inspection are d.iscussed in paragraph 3.

• .* -'l'**

10. *Unresolved Items

UnresolYed items are matters about which more information is requh*ed in

order to ascertain whether they are acceptable items, violations, or

de~iations. Unresolved items ~isclosed during the inspection are

discuss~d in paragraph 2, 3, .5, ~nd 7.

11. . Violations For Which A nNotice of Violation* Wi.11 Not Be_ Issued

. The NRC uses the Notice of Violation to .formally. document *failure to

meet a legally binding requirement. However, because the NRC wants to

encourage and support licensee's initiatives for self-identification and

correction of problems, the NRC will not issue a Notice of Violation if

the req~irements set forth in 10 CFR Part 2, Appendix C, Section v11~s~1 *

or Vll.B.2 are met. Violations of regulatory requirements identified*

during the inspection for which a Notice of Violatiori will not be issued

are discussed in paragraphs 2 and j,

12. * Exit Interview *

. The inspectors ~et with licensee representatives (denoted in

• .paragraph 1) during the inspection period and at th~ conclusi~n of the*

inspection.period on December 15, 1992.

The inspectors summarized the

scope and results of the inspection and discussed the likely content -0f

this inspection report. The licensee acknowledged the information and

did not indicate that any of the information disclosed during the

inspection could be considered proprietary: in nature.

26

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