ML17179A925
| ML17179A925 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/25/1993 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17179A923 | List: |
| References | |
| 50-237-93-12, 50-249-93-12, NUDOCS 9306080184 | |
| Download: ML17179A925 (17) | |
See also: IR 05000237/1993012
Text
U.S. NUCLEAR REGULATORY COMMISSION
. REGION II I
Report Nos. 50-237/93012(DRP); 50-249/93012(DRP)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
Opus West III
1400 Opus Place - Suite 300
Downers Grove, IL
60515
Facility Name:
Dresden Nuclear Power Station, Units 2 and 3
Ir.specticn At:
Morris, IL
Inspection Conducted:
March 16 through May 5, 1993
Inspectors:
Approved By:
Inspection Summary
M. Peck
A. M. Stone
C. Gill
D. Hills
D. Liao
C. Zelig
R. Zuffa, .Illinois/9epartment
/OcJ_ /JLrd_
P. L. Hiland, Chief
Reactor Projects Section lB
Inspection from March 16 through May 5, 1993
(Report Nos. 50-237/93012(DRP); 50-249/93012(DRP))
Date
Areas Inspected: Routine, unannounced inspection by resident inspectors,
regional inspectors, and an Illinois Department of Nuclear Safety inspector.
The inspection included followup of licensee action on previous inspection
findings; temporary instructions; summary of operations; operational safety
verification and engineered safety feature (ESF) system walkdown; maintenance
and surveillance observations; engineering and technical support observations;
safety assessment and quality verification; licensee event reports (LERs);
refueling activities, report review, and management meetings.
Results:
Of the ten areas inspected, no violations were identified in eight
areas.
One violation concerning an inadequate work instruction was identified
in paragraph 5.b.
An additional example of a previous violation, 237/93011-
01, concerning the failure to follow out-of-service procedures, was identified
in paragraph 5.b. A non-cited violation concerning the failure to adequately
maintain critical drawings control was identified in paragraph 6.
An
unresolved item associated with inspector concerns related to the fire
protection system was described in paragraph 6.
9306080184 930526
ADOCK 05000237
G
Assessment of Plant Operations
Operations personnel conducted themselves in a professional manher.
Control
room demeanor was good.
Fuel handling operation~ during the Unit 2 reload was
good.
A decision associated with the main control room habitability system
was non-conservative. Housekeeping was poor during the inspection period.
Assessment of Maintenance and Surveillance
The performance of maintenance and surveillance activities was good.
A
violation for a poor work package and examples of poor foreign material
exclusion practices were identified.
Ari out-of-service error by contractor
personnel resulted in the flooding of an emergency core cooling system corner
room.
The conduct of the Unit 2 refueling outage was significantly better
than previous outages.
Assessment of Engineering and Technical Support
Engineering and technical support was considered weak.
Concerns were
identified during review of a fire protection safety evaluation, control of
critical control room drawings, and a contractor prepared hydraulic analysis.
Assessment of Radiological Controls
Work practices were good as evidenced by the low.dose received by workers
associated with the remova.l of a source range monitor .
2
DETAILS
1.
, Persons Contacted
C.
~chroeder, Manager, Dresden Station
_
- D. Booth, Electrical Maintenance Department Master
- E~ Carroll, Chemistry Supervisor
- A D'Antonio, Site Quality Verification Supervisor
- R. Flahive, Technical Superintendent
.
- B. Gurley, NRC Coordinator, Regulatory Assurance
- M. Hayworth, *Lead Heal th Physicist-Operator
- R. Janecek, Independent Review Group Member
- R. Johnson, OPEX Administrator
F. Kanwischer, Services Superintendent
M. Korchynsky,' Senior Operating Engineer
- J. Kotowski, Manager of Operations
S. Lawson, Operating Engineer
T. Mohr, Operating Engineer
- T. O'Connor, Assistant Superintendent, Maintenance
- R. Radtke, Executive Assistant to Sit~ Vice- President
J. Shields, Regulatory Assurance Supervisor
R. Stobert, Operating Engineer
M. Strait, Technical Staff Supervisor
- B. Viehl, Engineering Supervisor
- Indicates p~rsons present at the exit interview on May 5, 1993.
- The inspectors al so contacted other licensee personnel fnc l ud i ng members
of the operating, maintenance, security, and engineering staff.
2.
Licensee Actions on Previous Inspection Findings (92701, 92702)
Violations
(Closed) Vi6lation (237/92009-0JfDRP)):_ inoperability of a low press~re
coolant injection sYstem due to ~n jmproperly set torque switch on a
reactor recirculation valve (2-202-SA}~ On August 7, 1991, operations
personnel were unable to.close the 2-202-5A valve against system
differential pressure during the recirculation pump start sequence.
The
failure was due to a misinterpretation of the VOTES trace data and
subsequent incorrect closing thrust value.
The licensee's corrective
actions included:
The station motor operated valve (MOV} coordinators w~re trained
- to use an e_nhanced diagnostic software package by the VOTES
vendor.
A commitment to involve corporate engineering personnel for the
proper disposition should any uncertainty in data interpretation
exist in the future.
3
Dresden Maintenance Proced_ure 40-10,
11VOTES System Operating
Procedure," was enhanced to require independent review of the
valve thrust windows.
All corrective actions were complete. This viQlation is closed.
{Closed} Violation {249/92023-03{DRPll:
Failure to perform a techni~al
specifi~ation (TS) required reactor water sample.
Th~ licensee
implemented a computer tracking system for chemistry related TS
surveillances. All corrective actions were complete. This violation is
closed.
Unresolved Items
(Closed) Unresolved Item (237/92005-06(DRP)):
Degraded containment
cooling service water system flow and incorrect low pre~sure coolant
injection system heat exchanger duties. This unresolved item- was the
subject of Special Inspection Report_50-237/92034(DRP).
This item is
closed.
Inspector Followup Items
{Closed} Inspector Followup Item (249/92002-0l{DRPll:
Corrective
actions prior to the Unit 2 refuel outage.
The inspectors reviewed the
licensee's corrective actions in the areas of fuel handling, procedural
-upgrades, equipment upgrades, and training enhancements.
The corrective
actions were complete. This item is closed.
Temporary Instructions (Tl)
(Closed} TI 2515/119:
Water Level Instrumentation Errors During and
After Depressurization Trarisients (Generic Letter 92-04).
The TI
focused on the licensee's response to water level instrumentation
anomalies resulting from non-condensible gases evolving in level
reference legs during rapid reactor depressurization events.
The
inspector's reviewed licensee action in response to Generic Letter 92-0~
and noted the following:
Licensed operators were found knowledgeable and capable of
executing the g~idance provided by Boiling Water Reactor Owners
Group (BWROG) Emergency Procedures Committee (EPC) '.
All licensed operators received classroom training on BWROG
guidance.
Operations personnel had not received specifit simulator trainin~
on the phenomenon.
However, during the inspection period the
plant simulator software was modified to model the anomalies.
The
inspectors observed an operating crew correctl~ responded to a
transient using the modified software.
4
The Emergency Operating Procedures were consistent with the BWROG
guidance.
-
The licensee did not routinely inspect the reference legs for
indications of leakage to minimize the likelihood of level
indicating errors.
The licensee had not reviewed past depressurization events to
determine if the instrument anomaly occurred at the station.
No violations or deviations were identified.
3.
Summary of Operations
Unit 2
The unit was maintained in cold shutdown condition durin~ the
inspection period for refueling and modifications.
Unit 3
The unit was restarted on April 28 following a 60-day forced outage to.
facilitate repair of the main high pressure turbine.
No violations or deviations were identified.
4. -
Plant Operations (71707 & 93702)
Tours of accessible areas of the plant were conducted to observe plant
equipment conditions including potential fire hazards, fluid leaks and
excessive vibration, and to verify that equipment discrepancies were
noted and being resolved by the licensee .
On a sampling basis the inspectors observed control room staffing and
coordination of plant activities; observed operator aqherence to
procedures and technical specifications; monitored control room
indications for abnormalities; verified that electrical power was
available and observed the frequency of plant and control room visits by
- station managers.
The inspectors also monitored various administrative
and operating records.
The specific areas observed were:
Engineered Safety Features (ESF) Systems
Accessible portions of ESF systems and associated support
components were inspected to verify operability through
observation of instrumentation and proper valve and electrical
power alignment.
The inspectors visually inspected components for
material conditions.
The following systems were inspected by
direct field observations:
5
Unit 2
Control Rod Drive* (CRD) *
Containment Cooling Service Water (CCSW)
Unit 3
Low Pressure Coolant Injection (LPCI)
Isolation Condenser (IC)
High Pressure Coolant Injection Turbine and Support Compo~ents
4.lKV and 480V Electrical Distribution Systems
Radiation Protection Controls
The inspectors ~erified that workers were following health physics
procedures and randomly examined radiation protectfon
instrumentation for.operability and calibration.
The Unit 3 source range monitor 24 was remtived using a special
procedure and equipment on April 20. *The llcensee ~sed a shielded
bucket method de~eloped at Duane Arnold Energy Center.
Thi~
method was used because of the radiation hazards involved and the
high activation of the detector cable and tubing.
Special
equipment was obtained from the Duane Arnold Energy Center for the
removal.
Personnel from Duane Arnold were present to assist
during the evolution.
The licensees' ~slow as*reasonably
.
achievable (ALARA) planning resulted in no personal contaminations
and a dose exposure to workers of less than 570 millirem.
Security
During the inspection period, the inspectors monitored the
licensee's security program to ensure that observed actions were
being implemented according to the licensee~s approved security
pl an.
Housekeeping and Plant Cleanliness
The inspectors monitored the status of housekeeping and plant
cleanliness for fire protection and protection of safety-related
~equipment from intrusion of foreign matter.
Housekeeping during the inspection period was poor.
Examples
included the following:
Seventeen non-secured trunks and several piles of fencing
material, trash, and scaffold1ng stored in .the Unit 3
isolation condenser room.
Trash and tools stored in the Unit 3 480-volt reactor
building board room .
6
Grout chips left on equipment and on the floor of the Unit 2
high pressure coolant injection room.
Debris taken out of
the room was left piled in the doorway.
Improperly Stored Compressed Gas Cylinders
Multiple examples of improperly stored compressed gas cylinders
were observed by the inspector. This included unsecured
cylinders, flammable gas cylinders stored next to oxygen
cylinders, and cylinders restrained by chains around valves.
The
licensee promptly corrected the conditions. Also, the Plant
Safety Advisor requested all department supervisors review the
compressed gas cylinder safety policy for use and storage, ensure
all employees and contractors understand and follow the policy,
and to inspect work areas to confirm compliance.
Shutdown Safety Management Signs
The inspector identified a Shutdown Safety Management Protected
Pathway component sign lying on the Unit 2 drywell grating.
The
sign indicated the electromagnetic relief valves (EMV) were a
"protected component."
However, the sign was not attached to the
EMVs or related components.
The inspector previously identified
an unattached Protected Pathway sign in the drywell on March 10,
1993, as documented in Inspection Report Nos. 50-237/249-
93011 (DRP).
Failure to adequately control the placement and removal of the
Protected Pathway signs was considered a weakness in the
implementation of the shutdown safety program.
The signs
prevented inadvertent operation of components that could
potentially affect reactor vessel inventory.
The signs were used
during periods when shutdown risk activities were in progress.
This is considered an Inspector Followup Item (50-237/93012-01)
pending review of the licensee's corrective actions.
Prior to Unit 3 startup the inspectors found a metal air hose
coupling and a spray nozzle attachment lying in a main generator
potential current transformer (PCT) pull-out drawer.
The coupling
could have resulted in a failure of the main generator due to its
proximity to the PCT wiring and fuse terminal blocks.
The licensee's foreign material exclusion (FME) program was
described in Dresden Administrative Procedure (OAP) 3-23, "Foreign
Material Exclusion Program," and OAP 7-35, "Foreign Material
- Exclusion Program for the Unit 2/3 Refueling Floor."
However,
electrical cubicles and compartments were not included in the
licensee's FME program.
7
The inspectors observed FME measures during maintenance on the
Unit 2 reactor feed pumps.
The casings of two pumps were removed
in preparation for*machining the stationary vanes.
Numerous
visible gaps existed between the synthetic fabric FME barrier and
the pump casing surfaces. Undetected debris could have entered
the pump discharge piping and be fl us_hed into the feed.water
system.
The observations noted above were discussed with cognizant
licensee personnel as examples where the FME program could be
strengthened.
a.
Operational Events
The Unit 2/3 emergency diesel generator (EOG) automatically
started when operations personnel transferred plant loads
from the rese_rve auxiliary transformer to the station
auxiliary transformer on April 28.
The ESF actuation was
the result of a broken auxiliary contact on one of the
feeder breakers to bus 33.
This event will be further
reviewed in a subsequent report.
A Unit 3 Group V isolation occur~ed on April 21.
The
isolation occurred during valve operator diagnostic testing
on the isolation condenser condensate return valve to the
reactor (MOV 3-1301-3).
The isolation signal resulted from
flow induced vibrations when the valve ~as man~ally opened_
from the fully closed position. This event will be further
reviewed in a subsequent report.
The Unit 2 EOG output breaker failed to close during an
undervoltage test on April 18.
The failure resulted from a
misaligned linkage. to an auxiliary contact on an alternate
bus feed breaker. This event will be further reviewed i~ a
subsequent report.
A standby gas treatment system automatic start and a partial
Unit 2 group II isolation occurred following a blown fuse on
.April 6.
The fus~ blew after engineering and construction_
personnel caused an electrical short circuit while working
on the drywell floor drain sump isolation valves
(2-2001-105 and 106). This event will be further reviewed
in a subsequent report.
-
An unexpected Unit 2 partial Group II isolation occurred on
March 30.
The isolation occurred when electrical
maintenance personnel lifted the neutral lead from the relay
coil for the drywel l equipment sumps (2-2001-106Xl). This
event will be further reviewed in a subseq~ent report.
8
5.
b.
Observations of Plant Operations
Control room operators generally performed licensed dutfes well.
The inspectors observed good procedural adherence, communications,
and use of repeat-backs.
However, the in~pectors observed
examples of poor attention to control room panels {looking toward
center-desk for long periods) and lengthy discussions on n6n-work
related,subjects during the Unit 3 startup by the on-shift crew.
One example of horseplay in.the control room involving a licensed
operator was noted by a quality assurance inspector. The licensee
took disciplinary action against the individual involved.
An example of a non-conservative operational decision was noted
during the inspection period. The licensee proceeded with Unit 2
core alterations and the restart of Unit 3 with an inoperable main
control room emergency ventilation system.
As discussed in
Inspection Report 50-237/93011, both trains of the qualified
service water supply were intentionally removed from service in
January for scheduling considerations.
The decision to allow the
Unit 2 fuel reload and the start-up of Unit 3, although permitted
by technical specification, with the degraded main control ro.om
emergency ventilation system was non-conservative.
No violaticins or deviations were identified.
One inspector followup
- tern was identified regarding the shutdown safety program.
Monthly Maintenance and Surveillance (62703 and 61726)
Routinely, station maintenance and surveillance activities were,observed
or reviewed to astert~in that they were conducted in accordance with
approved procedures, regulatory guides and industry codes or standards,
and in conformance with technical specifications.
The following items we~e also considered during this revjew: approvals
were bbtained prior to initiating the work and testing and that
operability requirements were met during such activities; functional
testing and calibrations were performed prior to declari~g the component
operable; discrepancies identified during the activities were resolved
prior to' returning the component to service; quality control records
were maintained; and activities were accomplished by qualified
personnel ..
a.
- Maintenance and Surveillance Related Activities
Unit 2
Removal and Overhaul of the 2C LPCI Pump Motor
Rebuild of 28 and 2C CCSW Pumps
Replacement of Unit 2 CCSW Flow Orifice
CRD Return Line Capping
Rebuild of the Condensate and Condensate Booster Pump
MSIV Pilot Operator Replacement
Fue 1 Grapp'l e Repair
9
-.
Source Range Monitor 21 Repair and Replacement
Feedwater Nozzle Repair
_
Core Spray Penetration Bellows (X-149A) Replacement
Rebuild Isolation Condenser Steam Supply Inboard Isolation Valve
Unit* 3
Main Turbine High.Pressure Turbine Repair
. Rebuild of the* 3C Reactor Feed Pump
3B LPCI Pump Impeller Balancing
Electrical Disconnection_ of MOV-3-2301-6 (HPCI).
SRM 24 Replacement
3D LPCI Pump Vibration Testing and Analy~is
The inspectors witnessed portions of the following test activities
Unit 2
DIS 1500-05, LPCI Logic Testihg
DOS 6600-06, Bus Undervoltage and ECCS Integrated Functional Test
for the Unit 2/3 Diesel Generator
Unit 3
DOS 1500-02, Quarterly CCSW Pump.Test
DOS 1500-06, LPCI System Pump Operability Test
DOS 1500710, LPCI Quarterly Pump fn Service Test
DOS 1400-01, Core Spray System Pump Test
DOS 2300-03, HPCI Operability Verification
.
DOS 1600-05, Unit 3.Quarterly Valve Timing
DTS 8138, Nuclear Instrumentation Overlap Verifications for IRMs
DOS 1600-14, Oxyg~n Analyzer and Sampling System Calibration and.
Functional Test
DTS 8135, Source Range Monitor Performance
DOS 2300-03, HPCI *system Operability Veri fi cation
DOS 2300-08, HPCI Pump Discharge Line Temperature Monitoring
b.
Maintenance and Surveillance Observations
Unit 2 HPCI Turbine Repair
The inspectors reviewed the installation of the Unit 2 high
pressure coolant injection turbine exhaust piping.
The bolts used
to secure the t~rbine top flange were ultrasonically tested prior
to installation. A temporary Garlock gasket was used on the
.
turbine exhaust flange to provide a ~attern for the permanent
gasket. A Flexitallic ga~ket was subsequently installed on the
flange prior to completion of the work.
Th~ inspectors observed
both contract and station craftsmen review work packages and
discussed with those individuals available methods to report
problems.
-
10
Incorrect Breaker Installed in Unit 2 Cubicle
On March 10, 1993, the main feed breaker for motor control center
29-5/6 failed to open during the performance of Dresden Instrument
Surveillance (DIS) 1400-01, "Core Spray L~gic Testing on B Core
Spray System."
The breaker failed to open because the *shunt trip
device, as specified on drawing 12E-2374, was not installed ..
The breaker was modified, per M12-2-91-25, in Decemb~r 1991 to
included the shunt trip device.
The modification ensured adequate*
voltage for the diesel generator cooling water pump by providing
load shed of the non-essential condensate storage tank heater
during a loss of coolant accident.
On October 12, 1992, the
breaker was removed for preventative maintenance.
The breaker
cubicle remained empty until February 4, 1993, when a different
refurbished manual breaker was installed. However, the work
package failed to specify a manual breaker with a shunt trip
device.
The work package preparer did not know a shunt trip
device was required on the breaker.
The safety significance of this event was minimal because the
error was identified before startup. However, the potential
. existed for an inoperable diesel under different plant conditions.
Corrective actions included:
Installation of the shunt trip device and retesting,
Review of other breakers for speci~l characteristics and
feature_s, and
Revision to the work analysts' breaker removal and
installation instructions.
Failure to install a shunt trip device on the 29-5/6 feed breaker,
in accordance with Drawing 12E-2374, revision AA, is a Violation
of 10 -CFR 50, Appendix B, Criterion V (50-231/93012-02).
However,
the corrective actions were reviewed by the inspectors prior to
the close of the inspection perind and were found adequate.
Therefore, no response to this_ violati6n was required.
Unit 2 West ECCS Corner Room Flooding Due to Personnel Error
Approxima'tely 9,500 gallons of service water sprayed into an
emergency core cooling system (ECCS) corner room on April 1.
The water level in the room rose to about 18 inches. Operatlons
p~r~onnel, in the ar~a at the time of event, quickly responded to
isolate the service water line upstream of the breach.
The
licensee entered the appropriate emergency procedures and verified
redundant safety system operability.
The licensee inspected
instrumentation, junction boxes and conduits for water intrusion
and meggered the affected ECCS pumps.
11
6.
The flooding occurred when contractor maintenance pe~sonnel
disconnected a flange on the service water piping upstream of an
out-of-service boundary.
The event was caused by mis-
communication and failure to properly review the work package.
Contributing to the event was a generic misunders~anding of out-
of-service boundaries by the contractors and inadequate
communication of the foreman's expectations.
Corrective actions
included:
Stopping all contractor work to reinforce procedure and out-
of-service boundary adherence.
Termination of employment for the individuals involved.
Revision of the pre-job briefing checklist to include a
required check list for each work request.
Reinforced the self check program and personnel safety
practices during pre-shift briefings.
Dresden Administrative Procedure (OAP) 03-05, "Out-Of-Service and
Personnel Protection Cards,
11 controlled the out-of-service program
with regards to equipment and personnel protection.
Disconnection
of the flange up-stream of an out-of-service boundary was contrary
to OAP 03-05 and was considered another example of Violation 50-
237/93011-0l(DRP).
The licensee established a team to investigate
the root cause and develop corrective action for this and other
out-of-service errors.
The results of that investigation will be
reviewed in a subsequent inspection.
One violation and an example of a previous violation were identified .
Engineering and Technical Support (37700)
The inspectors evaluated the extent to which engineering principles and
evaluations were integrated into daily plant activities. This was
accomplished by assessing the technical staff involvement in non-routine
events, outage-related activities, and assigned TS surveillances;
observing on-going maintenance work and troubleshooting; and reviewing
deviation investigations and root cause determinations.
Fire Protection System Concerns
The inspectors reviewed the ability of the fire protection system to
provide makeup water to the isolation condenser during fire suppression.
The inspectors were concerned about the adequacy of the safe shutdown
and surveillance procedures *to ensure adequate inventory was available
for the isolation condenser.
The inspector's concerns included:
The cross-tie valve between the lA Condensate Storage Tank (CST)
and 2/3A and 2/3B CSTs was closed since April 1988.
The safe
shutdown procedures did not provide instructions to the operators
12
to open the cross-tie valve to ensure water in the lA CST would be
made available to the isolation condenser during safe shutdown
6perations.
The licensee took credit for the water in all three
CSTs to satisfy the 260,000 gallonrequirement.
The 260,000
gallons ensured adequate makeup water to the isolation condensers
and proper operation of th~ high pressure.coolant injection (HPCI)
system.
The Fire Hazard Analysis (January 1986).assumed administrative
controls were in place to ensure adetjuate make-up was available
for the isolation cohdenser and the reactor pressure vessel (RPV).
Prior to August 1989, the licensee did not have surveillance
mechanisms to ensure the necessary amount of water was maintained
in the CSTs.
The licensee used an unqualified local instrument to verify IA CST
level.
The licensee failed to compensate for the head differences between
the CST level instruments and the piping leading to the isolation
condenser during level surveillances.
As a result,*the indicated
CST volume was non-conservative.
The licensee did not perform an adequate safety evaluation for
reactor operation with the lA CST cross-tie valve closed. The
licensee also failed to evaluate the effect on the makeup
capability to the isolation condenser.
Professional Loss Control, Inc. (PLC) performed a hydraulic study of the
fire protection system in February 1985.
The study concluded the
limiting case scenario existed when th~ most critical section of piping
was out of service. The limiting case prevented the system from meeting
design requirements; therefore, the licensee modified the fire*
protection system. A new limiting case was createp i.e. 2/3 diesel fire
pump out of service. Since other scenarios were not evaluated after the
modification, assurance that a new limiting case had not been created
was not proVided.
These concerns ~ere discussed with the licensee and are considered an
Unresolved Item (50-237/93012~03(DRP)) pending furthe~ NRC review.
Inspection of Recirculation Manifold Cross .Tie Valve
A through wall circumferential crack, located at the weld connecting the
equalizing line to the recirculation manifold cross-tie valve, was
identified at the Quad Cities facility on April 2.
Sirice the Dresden
piping configuration was similar to Quad Cities, the licensee also
inspected the Dresden equalizing line.
No problems were identified .
13
Control of Critical Control Room Drawings
The inspector identified several discrepancies with the critical control
room drawings.
The licensee performed a self assessment which
identified additional deficiencies with thirty three percent of the 484
critical drawings.
The problems found included~
Outstanding design change requests were not marked on drawings.
Inaccuracies between identical critical drawings stored at
different locations.
Numerous temporary alterations not reflected on drawing.
The licensee promptly corrected all identified problems.
Long term
corrective actions included revision of the critical drawing procedure
and review of all outstanding temporary alterations prior to Unit 3
start-up.
Dresden Administrative Procedure (OAP) 02-09, "Control of Critical
Orawings,
11 outlined the method required to ensure accuracy of field
installations and plant drawings.
Technical Specification (TS) 6.2.A
required that written procedures listed in Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978 shall be established, implemented
and maintained.
The failure to follow OAP 02-09 was considered a
Violation of TS 6.2.A.l.
However, the licensee identified a majority
of the violation examples and implemented prompt corrective actioni.
Therefore, a violation is not being cited because the criteria specified
in
10 CFR 2, Appendix C, part VII.B were satisfied.
One unresolved item and one non-cited violation were identified.
No
deviations were identified.
7.
Safety Assessment and Quality Verification (40500)
The effectiveness of management controls, verification and oversight
activities in the conduct of jobs observed during this inspection.were
evaluated.
Management and supervisory meetings involving plant status
were attended to observe the coordination between departments.
The
results of licensee corrective action programs were routinely monitored
by attendance at meetings, discussion with the plant staff, review of
deviation reports, and root cause evaluation reports.
No violations or deviations were identified.
8.
Licensee Event Reports (LERs) Followup (92700)
Through direct observations, discussions with licensee personnel, and
review of records, the following event reports were reviewed to
determine that reportability requirements were fulfilled, immediate
corrective action was accomplished, and corrective action to prevent
14
recurrence had been accomplished in accordance with technical
specifications.
The LERs listed below are considered closed:
UNIT 2
(Closed) LER 237/91-028:. Violation of Technical Specification Limits on
Torus Bulk Water Temperatuie. This item was the subject of Violation
50-237/91035-0l(DRP).
(Closed) LER 237/92-024:
HPCI Declared Inoperable Due to Turning Gear
Motor Failure.
(Closed) LER 237/92-027-01:
Failure to Sample Reactor Water Due to
Personnel Error and Programmatic Weakness.
The missed sample discussed
in the LER was considered a Violation of Technical Specification *4.6.C.2
{249/92023~03(DRP)). *This supplemental LER addressed the inspector's
concerns documented in Inspection Report 50-237/92023.
UNIT. 3
(Closed) LER.249/89-005:
HPCI Declared Inoperable Due to.Cable Terminal
Blocks Not Environmentally Qualified.
{Closed) LER 249/92-015:
Low Pressure Coolant Injection Pump Minimum
Flow Auto~atic Closure During Valve Operational Test.
The inspectors reviewed the licensee's problem. identification forms
(PIFs) generated during the inspection period. This was done to monitor
the conditions re1ated to plant or personnel perfor~ance and potential
trend: Tha results of the investigations were also reviewed to ensure*
that PIFs were generated appropriately and dispositioned in a manrier
consistent with the applicable procedures and the quality assurance
manual.
No violations or deviations were identified.
9.
Refueling Activities (60710)
The inspector verified that refueling activities were conducted and
controlled as required by technical specifications and approved
procedures. This was done on a sampling basis through direct
observation of activities and equipment, tours of the facility,
interviews and discussions with licensee personnel, and independent
verification of safety system status and limiting conditions for
operation (LCOs) action requirements.
The inspector observed fuel
movement during the D2Rl3 core reload and verified core alterations were
performed in a safe manner.
Fuel handling personnel displayed a positive application of. the "Self-
Chetk" process during. the Unit 2 fuel reload.
Fuel handling was
suspended several times to collectively verify previous actions and
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procedure compliance ..
An aggressive questioning attitude by the fuel
handling personnel led to a completed Unit 2 core reload without
significant error.
No violations or deviations were identified in this area. *
10.
Report Review (90713)
During the inspection period, the inspector reviewed the licensee's
Monthly Performance Reports for January, February and March 1993.
The
inspector confirmed that the information provided met the requirements
of Technical Specification 6.6.A.3 and Regulatory Guide 1.16.
~o violations or deviations were identified.
11.
Management Meetings (30703)
A management meeting was conducted at the Dresden station on March 30,
1993.
Mr. J. A. Zwolinski, Assistant Director for Region III Reactors,
Office of NRR, was in attendance.
Monthly Dresden Plant Information meetings were held at the Region III
office on March 31 and at the Dresden site on April 30.
The Region III
Regional Administrator, A. B. Davis, attended both meetings.
The
meetings discussed the resolution of technical issues, outage dose,
outage schedule, and self assessment.
NRC Commissioner J. R. Curtiss met with several licensee management
personnel on April 9.
The meeting focused on the current status of the
facility and improvement initiatives.
12.
Inspector Followup Items
Inspector followup 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.
One
inspector followup item disclosed during this inspection is discussed in
paragraph 4.
13.
Unresolved Items
Unresolved items are matters about which more information is iequired in
order to ascertain whether they are acceptable items, items of
noncompliance or deviations.
One unresolved Item disclosed during this
inspection was discussed in paragraph 6.
14.
Licensee Identified Violations
The NRC uses the Notice of Violation as a standard method for
formalizing the existence of a violation of a legally binding
requirement.
However, because the NRC wants to encourage and support
licensee's initiatives for self-identification and correction of
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problems, the NRC will not generally issue a Notice of Violition for a
violation that meets the tests of 10 CFR 2, Appendix C, Section VII.B.
These tests are:
t
It was not a violation that could reasonably be expected to have
been prevented by the licensee's corrective action for a.previous
violation.
t
The violation was or will be corrected, including measures to
prevent recurrence, within a reasonable time; and
t
It was not a willful violation.
One violation of regulatory requirements identified during this
inspection for which a Notice of Violation will not be issued was
discussed in Paragraph 6.
15.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in
-Paragraph 1) throughout the inspection period and at the conclusion of
the inspection on May 5, 1993, to summarize the scope and findings of
the inspection activities. The licensee acknowledged the inspectors'
comments.
The inspectors also discussed the likely informational
content of the inspection report with regard to documents or processes
reviewed by the inspectors during the inspection. The licensee did not
identify any such documents or processes as proprietary.
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