ML17179A944
| ML17179A944 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/02/1993 |
| From: | Burgess S, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17179A942 | List: |
| References | |
| 50-237-93-08, 50-237-93-8, 50-249-93-08, 50-249-93-8, NUDOCS 9306110065 | |
| Download: ML17179A944 (26) | |
See also: IR 05000237/1993008
Text
{{#Wiki_filter:* U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-237/93008(DRS); 50-249/93008(DRS) Docket *No. 50-237; 50-249 License No. DPR-19; DPR-25 Licensee: Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515 Facility Name: Dresden Nuclear Power Station - Unit 2 and 3 Inspection At: Dresden Site, Morris, IL 60450-9766 Inspection Conducted: March 29, through April 30, 1993 Inspection Team: S. Burgess, Team Leader M. Bielby A. Dunlop . C. Ga i nty W. Pegg NRC Consultants: G. Cha, Engineering Planning and*M~nagement, Inc. Approved By: Approved By: ~--¥ Team Leader Region II -fat-~{ M1 n /G. C. w;:ig<<,?hief Engineering Branch Inspection Summary: (,-1-.93 Date c /2/(3 Date Inspection on March 29 through April 30, 1993 (Report No. 237/93008(DRS); 249/93008(DRS)). Service water system operational- performance inspection (SWSOPI) in accordance with NRC Temporary Instruction 2515/118. Results:
The team determined that the service water system (SWS) design and operation we~e effective. Engineering and technical support were adequate based -0n their involvement in the SWS design and operation and th~ quality of recently performed calculations .. System design and enginee~ing support strengths and weaknesses are provided in the Executiv*e Summary of this report. One violation with two examples was identified regarding failure to test valves identifi~d in the IST program (Section 8.1.1). Two inspection followup items were identified regarding the licensee's evaluation on testing the LPCI heat 9306110065 930603 ~DR ADDCK 05000237* PDR
- J TABLE OF CONTENTS EXECUTIVE SUMMARY.................................................... i 1.0 INSPECTION SCOPE AND OBJECTIVES .................*.. : ........... 2 2.0 LICENSEE ACTION ON PREVIOUS INSPECTION FINDINGS .*......*..***.. 2 3.0 GENERIC LETTER 89-13 IMPLEMENTATION .*.....................**.*. 3 4.0 SYSTEM DESCRIPTION............................................. 3 5.0 MECHANICAL DESIGN REVIEW ..........*... i************************ 3 6.0 OPERATIONS..................................................... 6 7.0 MAINTENANCE.................................................... 9 8.0 SURVEILLANCE AND TESTING....................................... 10 9.0 QUALITY VERIFICATION AND CORRECTIVE ACTIONS .................... 13 10.0 INSPECTION FOLLOWUP ITEMS...................................... 14 11. 0 -E_XIT MEETING . .-................................................. 14 Appendix A - Personnel Contacted Appendix B - Requests for Information Appendix C - Generic Letter 89-13 Action Items
exchange~s (Section 5.1.1) ~nd the result$ of a subsequent DGCW pump inservice test (Section 8.1.2) . 3
Executive Summary During the period March 29 through April 30, 1993, a Region III inspection team conducted a service water system operational performance inspection (SWSOPI) at the Dresden Nuclear Power Station. The service water system (SWS) encompassed the containment cooling service water (CCSW) and the diesel generator cooling water (DGCW) systems. For these systems, the inspection included a limited mechanical design review; detailed system walkdowns; review of system operation, maintenance, and surveillance; and assessment of quality verification and corrective actions required by Generic Letter 89-13, "Service Water System Problems Affecting Safety Related Equipment," as well as system unavailability. The team considered Dresden's SWS design and operation to be effective. In addition, the team concluded that, overall, the engineering and technical support organizations were qualified and involved in SWS design and operation. However, the team did not consider the current LPCI/CCSW heat exchanger analyses adequate to ensure the heat transfer capability for various reduced flow scenarios. The team also identified the following weaknesses:*
initial efforts to implement the GL 89-13 guidelines were found to be weak, and in some cases, did not meet the GL's intent. Many GL
- commitments Dresden made were not met; therefore, the licensee agreed to
revise the commitment letter,
failure to test valves identified in the IST program, expanding ASME Code allowable ranges for the DGCW pump testing, and the exclusion of valves and/or tests from the IST program scope,
an operations crew's failure to verify proper DG operation during a simulated event. As a result, U-2 and U-2/3 DG ran, on the simultor, without cooling water for 10 minutes before overheating and seizing,
corrective actions were slow and narrowly focused to address . deficiencies identified in three SWS/GL 89-f3 self-assessments. The report identifies the IST weaknesses as a potential violation. The other issues are being tracking as followup or unresolved items. The team identified the following strengths:
SWS material condition appeared to be good,
the reliability centered maintenance effort for the SWS was considered thorough and beneficial in improving system preventive maintenance,
recently performed analyses and calculations were of good quality.
DETAILS 1.0 Inspection Scope and Objectives* Numerous problems identified at various operating plants in the country have. called into question the ability of the service water systems (SWSs) to perform their design function. These problems have included: inadequate heat removal capability, biofouling, silting, single failure concerns, erosion, corrosion, insufficient original design margin, lapses in configuration control or improper 10 CFR 50.59 safety evaluations, and inadequate testing. NRC management concluded that an in-depth examination of SWSs was warranted based on the identified deficiencies. The inspection team focused on the mechanical design, operational control, maintenance, and surveillance of the SWS and evaluated aspects of the quality assurance and corrective action programs related to the SWS. The inspection's primary objectives were to:
assess SWS performance through an in-depth review of mechanical systems functional design and thermal-hydraulic performance; operating, maintenance, and surveillance procedures and their implementation; and operator training on the SWS,
verify that the SWS's functional designs and operational controls are capable of meeting the thermal and hydraulic performance requirements and that SWS components are operated in a manner consistent with their design bases,
assess the licensee's planned and completed actions in response to Generic Letter 89-13, "Service Water System Problems Affecting Safety Related Equipment," July 1989, and
assess SWS unavailability resulting from planned maintenance, surveillance, and component failures. The areas reviewed and the concerns identified are described in Sections 3.0 through 9.0 of this report. Conclusions a.re provided after each section. Personnel contacted and those who attended the exit meeting on April 30, 1993, are identified in Appendix A. A complete listing of the team's requests for information is attached as Appendix B. Details pertaining to Generic Letter (GL) 89-13 action items are attached a~ Appendix C. 2.0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item 50-237/93011-02{DRP): The safety related combined Unit 2/3 control room 118 11 HVAC unit had no safety related water supply when both trains of Unit 2 CCSW were taken out of service during the Unit 2 outage. The licensee committed to revise Dresden Administrative Technical Requirements (DATR) to impose administrative controls for operability of CCSW to support the 11 8 11 HVAC unit. This issue is discussed further in Section 5.4. This item is closed. 2
3.0 Generic Letter 89-13 Implementation The NRC issued GL 89-13, "Service Water Systm Problems Affecting Safety Related Equipment," requesting that licensees take certain actions related to their SWS. These actions included establishing the appropriate frequencies for testing and inspecting safety related heat exchangers over three operating cycles, to ensure the operability of SWSs that are credited for cooling safety related equipment. The team considered Dresden's initial response and certain aspects of the initial program to be weak in addressing the concerns of GL 89-13. In some cases, Dresden's actions did not meet the GL's intent. Examples included: testing was not performed as committed to in the GL response, inadequate CCSW and HPCI room cooler testing methodology, and not including instrument lines in the flush and clean program. See Appendix C for details pertaining to each GL 89-13 Action Item. The licensee has taken corrective actions to address the weaknesses. If implemented, the actions should assure that the ~L issues were integrated into existing programs. 4.0 System DescriRtion The safety related service water system consisted of the containment cooling service water (CCSW) and the diesel generator cooling water (DGCW) systems. The CCSW system passes cooling water through the LPCI/CCSW heat exchanger's tube side to provide heat removal from the containment. There are four, 3500 gpm each CCSW pumps; two are needed to provide required cooling capacity. Dresderi's FSAR listed total system flow as 7000 gpm; however, tests in 1992 indicated that the maximum available CCSW pump flow to the LPCI/CCSW heat exchangers., for two pump operation, was 5600 gpm. This issue is the subject of a pending enforcement action as documented in NRC inspection report 50-237/92034; 50-249/92034. The DGCW system provides cooling water to three DGs. In addition, the system provides an alternate water sup~ly for the ECCS room coolers and the CCSW keep-fill system. The DGCW system consists of three pumps, each dedicated to one DG. Each pump is rated for 1100 gpm at 115 foot total discharge head. At design basis cooling water temperature of 95°F, a flow rate of 840 gpm is required to adequately cool one DG. Pump suction is from the circulation water bays. A cross-tie header allows the pumps to take suction from alternate bays for maintenance purposes. The pumps automatically start upon starting the associated DG; manual start is available from local control switches in the associated DG rooms. 5.0 Mechanical Design Review The mechanical design review of Dresden's SWSs included determination of whether the system's design bases, design assumptions, calculations, analyses, boundary conditions, and models met licensing commitments and regulatory requirements. Also reviewed was the SWS's capability to meet the thermal and 3
hydraulic performance specifications during accident or abnormal conditions. The team also reviewed the system's seis~ic qualification, design vulnerabilities, flooding mitigation charactristics, and selected modification packages. 5.1 On-Going Safety Related Service Water Issues Two safety related service water issues were pending with the NRC during this inspection. The first was on the impact of reduced CCSW flow on the peak containment pressure and temperature. The second was on the transient temperatures in the high pressure coolant injection (HPCI) and low pressure coolant injection (LPCI) rooms with room coolers out of service during a DBA. The team did not duplicate any on-going efforts but reviewed only those specific areas not previously covered. 5.1.1 LPCI/CCSW Heat Exchanger Capability Based on review of the LPCI/CCSW heat exchangers thermal conductivity (K-factor}, the team could not conclude that Dresden's calculations were sufficiently accurate to substantiate General Electric Company's (GE) K-factor values, nor demonstrate the magnitude of conservatism that was available. The LPCI/CCSW heat exchanger's capability was defined by the K-factor (Btu/sec-°F), with heat transferred (Q) = K * (TLPCI i - Tees\\./ in). Because GE's derivation of K-factors was not available, the' ficensee'performed an independent verification of the GE K-factors. The team found that in developing the shell side heat transfer coefficient, the licensee used a conservative exponent of 0.8 for the dimensionless Reynolds Number; 0.6 was generally found in standard technical references. Also, the K-factors were derived using 2368 tubes, or 6% less than the 2512 tubes installed in the heat exchanger, this was again conservative. On the other hand, the team found that the K-factor derivations used the original data sheet tube side fouling factor of 0.002 from the original data sheet for all tube side flow rates. The Standards of Tubular Exchanger Manufacturer Association's (TEMA) table of fouling resistance for average river water with velocity less than 3 ft/sec is 0.003. One proposed reduced CCSW flow rate was 3500 gpm, which would result in an average tube. side velocity of 2.84 ft/sec for 2368 tubes and decreased to 2.68 ft/sec for 2512 tubes. Furthermore, the effects of baffle leakage or bypass, and fluid recirculation at significantly reduced flow rates were not considered in K- factor derivations. The team concluded that LPCI/CCSW heat exchanger testing was necessary to develop baseline performance parameters that would confirm the heat exchangers capability for each proposed flow reduction scenario. Finally, the tests would provide the LPCI/CCSW heat exchangers with site specific tube side - fouling factors, which may or may not be the same as those recommended by the TEMA Standards . In response to the team's concern, the licensee committed to re-examine the possibility of conducting a temperature effectiveness test on the LPCI/CCSW 4 , I
heat exchangers. Pending completion and review of this evaluation, this is considered an inspection followup item (50-237/93008-0l(DRS); 50-249/93008-0l(DRS)). 5.1.2 Equipment Qualification of Components in the HPCI and LPCI Room After a DBA The team concluded that, from an environmental standpoint, all electrical and mechanical equipment in the HPCI and LPCI rooms would perform their intended _ function without room coolers during and after a OBA.
Since August 1989, the licensee has provided analyses to NRR on the subject of deleting the HPCI and LPCI room coolers as safety related loads on the CCSW. These analyses provided the transient room temperatures resulting from heat loads after a OBA. NRR's review focused on the heat load portion of the analyses. The SWSOPI team ensured that all equipment required to mitigate the consequences of a OBA, both electrical and mechanical, would be available to perform their intended functions with the elevated room temperatures. The team identified that equipment qualification temperatures (EQT) presented in the analyses were evaluated against electrical components only, and did not consider the mechanical components that would also be required to operate. Components missed in the analysis included the LPCI pump seals and LPCI pumr motor bearing lubricants, and the HPCI cooler fan motor and fan belt, since the fan was required to operate without the coils during the proposed DBA scenario. The licensee produced the necessary information for the mechanical components and added the information to the analysis. The team had no further concerns. 5.2 Modification Package Review The team-determined that modifications performed on the SWSs were thorough, contained appropriate safety analyses, and showed strengths in the seismic analysis of the hanger and support design. For example, new support and hanger designs were developed, qualified, and installed whenever pr.evious documentation could not be located. In two instances the appropriate documentation for seismic qualification was readily available. 5.3 Seismic Review The team noted that the licensee did not have seismic qualification information for the HPCI room cooler hangers and the LPCI/CCSW heat exchangers. The licensee was organizing a Seismic Qualification Users Group (SQUG) program to address seismic qualification of components under NUREG 1211, "Unresolved Safety Issue (USI) A-46 11
The HPCI room cooler hangers were identified as components included under that program. Also, the LPCI/CCSW heat exchangers were on the Safe Shutdown Equipment List, which will be the initial list of equipment/components to be qualified under SQUG. The licensee anticipated that the program would require two years for completion. 5
The licensee provided p1p1ng analysis, which included load combinations of pressure, gravity, thermal, and seismic loads for the large bore piping and valves in and out of the LPCI/CCSW heat exchangers and LPCI pumps. Also provided were the structural steel calculations for the heat exchangers' seismic supports to the concrete embedment plates. The team.found these calculations satisfactory and complete. 5.4 CCSW Supply to Train "B" HVAC Unit A vulnerability existed in the CCSW supply that could potentially disable the safety related cooling capability for the common Unit 2/3 control room. Unit 2 CCSW provided the only cooling water to the safety related train 8 HVAC unit for the common Unit 2/3 control room. Should Unit 2 CCSW be out of service (inoperable), there would be no safety related cooling water supply for the refrigeration condenser, thus disabling the safety related cooling capability for the common Unit 2/3 control room, regardless of the status of Unit 3. In response to the team's concern, the licensee presented a proposed techni~al specification (TS) revision, currently under review by NRC. In addition, the Dresden Administrative Technical Requirement (DATR) ACTION section will be revised by May 7, 1993, to allow operation for 14 days in the event that the control room emergency ventilation system refrigeration condensing unit (RCU) is inoperable. If the 14 day limit was exceeded, the DATR would require unit shutdown. The DATR would also prohibit irradiated fuel handling in the secondary containment if the RCU was inoperable. Finally, the Limiting Condition for Operation (LCO) and the DATR BASES section would be revised to ensure CCSW flow available to the RCU as part of RCU operability. The team considered the above action effective in addressing the concern. This issue is discussed further in Appendix C of this report and closes the unresolved item in Section 2.0. 5.5 Conclusions The team concluded that the mechanical design of the CCSW and the DGCW systems was effective and each system was capable of performing its safety related functions under the OBA scenario. The team did not; however, consider the current LPCI/CCSW heat exchanger analyses adequate to ensure the heat transfer capability for various reduced flow scenarios. 6.0 Operations The team reviewed plant operations to assess operator knowledge and the accuracy and completeness of procedures and training with regard to the SWS. The team performed detailed system walkdowns; reviewed procedures for normal, off-normal, and emergency conditions; assessed conduct of operations in the field and control room; and evaluated training manuals, lesson plans, and operator actions on simulated SWS malfunctions . 6
6 .1 System Configuration Walkdowns During detailed SWS walkdowns, the team noted numerous discrepancies between the as-built SWSs and the piping and instrumentation drawings (P&IDs), * including locked valve status indicated on the P&IDs and found in the plant. The licensee previously identified locked valve status discrepancies between the P&IDs and as found in the plant. The licensee explained a new program to delete valve status from the P&IDs and rely on valve checklists for valve status information. The team compared the valve lineup checklists with the plant and found the checklists accurately reflected the locked valve status in the plant. Because operators currently use the checklists to verify locked --valve status,- the team cqn_sidered this to be effective until the licensee's new program for P&IDs was i ncorpor-ated. -~ The licensee incorporated all P&ID discrepancies noted by the team into their corrective action program. *The team considered this response acceptable. 6.2 Operations Procedures* The team identified the following weakness in one abnormal operating procedure:_.
Abnormal procedure DGA-12, "Partial or Complete Loss of AC Power," Revision 10, did not contain an immediate action step to have an auxiliary operator verify proper emergency diesel generator (DG)* operation when it was required to start and load during undervoltage conditions. The licensee had also identified this weakness and a revision to DGA-12 had been prepared to include an immediate action step to dispatch an operator to the DG. The revision was in the licensee's onsite review process. Additionally, a procedure inquiry was written to ensure a review of associated operating and annunciator procedures incorporated this change as appropriate. The team considered this action acceptable. 6.3 Operations Scenarios/Training Overall, the team determined operations training was effective. However, weaknesses in operator procedural usage and electrical breaker actuation knowledge were observed during a simulator scenario. The scenario was initiated by a loss of transformer TR-22 followed by a main - turbine trip and scram resulting in a loss of offsite electrical power. Both Unit 2 and 2/3 DGs started and electrically loaded, however, the scenario was designed to prevent both DGCW pumps from automatically starting. The following weaknesses were observed by the team:
When Unit 2 (2/3) annunciators "U2 (2/3) DIESEL GEN CLG WTR PP TRIP/LKOUT," "U2 (2/3) DIESEL GEN TROUBLE," and "U2 (2/3) DIESEL GEN AUTO START" alarmed, the associated annunciator response procedures were reviewed by a control room operator, but associated procedural actions 7
.. - - .. **- ---*- ~ .... *- ..... _ ....... - ---- . : . to verify proper local DG operation were never directed. As a result, the crew fail~d to recognize that the DGCW pump were not operating and. allowed th DGs to run loaded without cooling water for approximately ten minutes before overheating and seizing. - , After both Unit 2 and 2/3 DGs tripped, one crew member unsuccessfully attempted to cross-connect Unit 2 and Unit 3 electrical distribution systems. The cross-connect breaker tripped open because the operator failed to hold the actuation switch in the "CLOSE" position for a sufficient length of time.
--I~imulationreinforced the licensee's observation that the operations training pr1fgram-needed-to_s_tr.e~e importance of expeditiously di ~patching an operator to verify proper DG operafionand--assoe-i-a-ted_D_G_cJi_Jlump (Section 6.2). To address the team observed weaknesses, the operations -fraining--staff---- implemented the following actions:
Licensed: operator requalification training, scheduled for April 3 through June 11, 1993, and initial license operator training will incorporate this event with additional emphasis on verification of proper DG operation after an automatic start and use of annunciator response procedures.
Additional operator training lesson plans were prepared on operation of breakers and associated relays with heighten awareness on holding the actuation switch in the "CLOSE" position long enough to allow the
- closing relays to pickup before releasing tbe switch.
The operations crew involved in the scenario was immediately remediated~ The team reviewed lesson plans prepared for the associated training with this event and licensee actions taken and concluded proper corrective action had been taken. 6.5 Conclusions The team determined the litensee was operating the SWSs in an appropriate _manner. - Plant equipment labeli~g was good and the licensee was reviewing station procedures and P&IDs to ensure discrepancies were corrected. Although some weaknesses were identified, operating procedures, operator training program relating to the SWSs, and operator-knowledge of SWS equipment operations and procedures were considered effective. - 7.0 Maintenance The team reviewed maintenance procedures, work history, completed work request packages, LERs, deviation reports, and preventive maintenance tasks for selected components to determine if the CCSW and DGCW components and piping were being adequately maintained and to detect any system equipment that required frequent maintenance. The team also evaluated implementation of GL 89-13 commitments in the maintenance area. 8
7 .1 Reliability Centered Maintenance The licensee's reliability centered maintenance (RCM) effort for the SWS was considered to be beneficial to improve preventive maintenance (PM) in the future. The RCM study was thorough in that vendor recommendations, work history, and component importance to system performance were all considered. For the CCSW and DGCW systems, the study identified several tasks that should be added to the PM schedule. All newly identified tasks had been added to the PM schedule. Some tasks had not been completed yet, however, there were no safety concerns. 7.2- _ SWS Preventive Maintenance The team noted general weaknesses -in the-PM-schedule for rQutine lubrication of components identified in the general surveillance schedule (GSRV). -some- - tasks were performed by GSRV description only, without a procedure or specific training to provide instructions. For example, GSRV task for CCSW pump oil change specified frequency, amount and type of lubricant, but no instructions or training were provided for operations personnel regarding how to perform the task. The licensee agreed to review the need for procedures or training in a timely manner. 7.3 Heat Exchanger Insgection and Cleaning The team noted that the initial implementation of heat exchanger inspection and cleaning to satisfy GL 89-13 commitments was weak. The licensee had not established special procedures or instructions, but instead used regular work requests for the performance and documentation of this task. After two outages, the licensee determined that work requests provided inconsistent and inadequate-documentation of as-found conditions. The team considered the new procedures to be effective. 7.4 SWS Instrument Line Maintenance SWS instrument lines susceptible to fouling were cleaned on a reactive rather than proactive basis. This was not consistent with the GL intent, which recommended licensees establish routine maintenance of SWS piping and components to ensure that silting and biofouling could not degrade system performance. In response to the team's concern, the licensee identified critical instrument lines that may be susceptible to fouling and agreed to revise procedures to clean instrument lines on a periodic basis. 7.5 Silting The team was concerned that acceptance criteria had not been established for the amount of silting allowed. The program also did not require documentation of silting evaluations. In accordance with GL 89-13 commitments, the licensee identified approximately 12 low flow SWS locations susceptible to silting, which were incorporated into the Erosion/Corrosion Program, however, no acceptance criteria were established. In response to the team's concerns, the licensee agreed to review the program to determine appropriate requirements for evaluation of identified silting. The inspection of high flow locations, 9
which had specific acceptance criteria, was considered to be effectively performed. 7.6 Conclusions Overall, the team determined that maintenance performed on CCSW and DGCW components was effectively accomplished and that system problems were properly addressed and, where necessary, corrected. However, weaknesses were identified with the GL maintenance program. Examples included reactive cleaning of SWS instrument lines, no acceptance criteria for erosion/corrosion silting inspections, and insufficient documentation of as-found conditions -~uring jniti~l heat exchanger maintenance. 8.0 Surveillance and Testing The team reviewed preoperational test procedures, surveillance procedures, and the licensee's inservice test (IST) program and implementing procedures to determine if sufficient testing had been conducted to confirm system design requirements and system operability. 8.1 Inservice Testing of Pumps and Valves 10 CFR 55.55a required the CCSW and DGCW systems to be in compliance with the -American Society of Mechanical Engineers (ASME) inservice pump and valve testing specified in Section XI of the Boiler and Pressure Vessel Code, except where relief had been granted by the NRC, or where alternative testing was justified in accordance with Generic Letter 89-04. The team reviewed the implementing TS surveillance procedures and identified the following concerns. 8 .1.1 Program Scope The scope of the SWS IST program was adequate with a few exceptions. In most cases these issues had been previously identified by the licensee. These issues included:
LPCI/CCSW flow control valves 2(3)-1501-3A and 2(3)-1501-38 were not included in the IST program even thbugh they are normally closed and required to open to provide CCSW flow to the LPCI heat exchangers. Required IST included valve stroke time in the open and closed direction and position indication test (PIT). The licensee was developing reference values for stroke timing the valves using a special procedure. The licensee committed to complete testing prior to unit startup, continue testing on a quarterly basis, and update the program during the next IST program revision.
Control room HVAC valves 2/3-5741-048A and 2/3-5741-0488 position indication on the B train control room HVAC panel was not tested as required by Section XI, IWV-3300. The valves were included in the IST program to be full stroke exercised and stroke timed .. While the valves received some IST type testing, the two year PIT was not performed to verify valve position matched the position indication. The licensee did not consider these remote indicators because they were located in the 10
8.1. 2 same room as the valves. However, based on the team's concern, the licensee committed to include PIT in the IST program for these valves. Testing will be performed prior to returning Unit 2 to service and then in accordance with the ASME Code requirement. The CCSW pump discharge check valves, 2(3)-1501-0lA-D, have a closed safety function to prevent backflow through an idle pump. This function was not identified in the IST program; however, the valves were tested in the closed direction by DOS 1500-02, "Quarterly Containment Cooling Service Water Pump Test," Revision 13. These valves will be included in the next program revision. Missed Testing The team identified the following examples of missed inservice tesffn~ (IST)-:
Control room HVAC valve 2/3-5741-062 was not fail safe tested (FST) as stated in Dresden's IST program. ASME Code, Section XI, IWV-3415 required valves with a fail safe function be tested on a quarterly basis. The valve had been installed during the control room HVAC modification in 1985 and included in the IST program since July 12, 1989. Failure to perform quarterly IST as required by the ASME Code is considered an example of a violation of 10 CFR 50.55a(f)(4) (50-237/93008-02a(DRS); 50-249/93008-02a(DRS)).
The valve was FST in December 1992, by removing air to the valve; therefore, valve operability was not a concern. The licensee will test the valve prior to the Unit 2 startup and will continue testing on a quarterly basis per DOS 1600-04, "Unit 2/3 Quarterly Valve Timing.". Control room HVAC check valve 2/3-1599-103 was not exercised on a quarterly basis to the required open position to fulfill its safety function as stated in Dresden's IST program. ASME Code, Section XI, IWV-3522 required check valves to be exercised on a quarterly basis to the position required t~ fulfill their safety function. Check valve 2/3-1599-103 was required to open to supply CCSW to the B train control room HVAC cooler. The valve had been installed during the control room HVAC modification in 1985 and included in the IST program since May 6, 1988. It was noted that the valve was listed in the IST program as 2/3- 3999-200. The licensee informed the team that- the valve number had beeh revised; although, the program was not properly updated. Failure to perform quarterly IST as required by the ASME Code is cons.idered an example of a violation of 10 CFR 50.55a(f)(4) (50-237/93008-02b; 50-249/93008-02b). The valve was tested in the open direction in December 1992 by verifying the valve could pass the required 102 gpm flow to the B train control room HVAC cooler. As such, valve operability was not a concern. The licensee will test the valve prior to the Unit 2 startup and will continue testing on a quarterly basis per DOS 1600-04. The IST program would also be revised to incorporate the correct valve number during the July 1993 revision. 11 , I
8.1.3 Pump Testing Pump testing was in accordance with the ASME Code requirements with one exception. IST procedure DOS 6600-08, "Quarterly Diesel Generator Cooling Water Pump Test for the In-Service Test (IST) Program,M Revision-IO, contained acceptance limits for flow that were expanded beyond those allowed by the Code without adequate justification. ASME Code Table IWP-3100-2 stated the high values for flow were 1.02 and 1.03 times the reference value for the alert and required action range, respectively. The licensee's test acceptance limits were 1.05 and 1.07 times the reference value. The-1icensee's justjfication for the expanded ranges was the fluctuation exhibited in the flow meters did not allow _consistent readability. This justification did not appear to be adequate based on test data that indicated the measured flow rates were within the ASME Code allowable limits since-the- expanded ranges were used. In addition, the team witnessed a Unit 3 DGCW pump operability test in which the flow rate did not fluctuate substantially. The licensee committed to review this issue during a subsequent DGCW pump irrservic~ tRst to determine if the expanded acceptance limits were needed or if other means could reduce tho flow fluctuations. Based on the previous test result~ that were within the ASME Code allowable, thi~ wa~ not a technical concern. This will be considered an inspection follow-up item pending subsequent inservice test results for the DGCW pumps (50-237/93008-03; 50-249/93008-03). - 8.2 Conclusions The tea_m and the licensee identified several concerns with IST program implementation. These included not testing valves identified in the program, expanding ASME Code allowable ranges for DGCW pump testing, and the exclusion of valves and/or tests from the program scope. The licensee was reviewing the entire IST program at the time of this inspection. Based on the team's findings in the service water area, the licensee should ensure-this review will identify and correct issues for other safety related systems in a timely
- fashion.
9.0 Quality Verification and Corrective Actions The team evaluated CCSW and DGCW systems, and GL 89-13 program implementation assess~ents and technical audits, reviewed the corrective action tracking system to ensure adequate treatment of SWS items, and reviewed SWS operational history to assess the adequacy of root cause evaluations. While organizations conducted effective performance based audits on the SWSs, resultant corrective actions to address the deficiencies identified were slow and narrowly focused. For example:
In April 1992, a System Performance Review addressed Dresden's GL 89-13 response and implementation. The assessment effectively identified weaknesses-such as deficiencies in the chemical addition program for controlling biofouling, inconsistencies in the methods used to document 12
9.1 as-found conditions when inspecting heat exchangers, and discrepancies between plans implemented to address the GL and commitments made to the NRC to meet the GL requirements. The*NRC team identified the same deficiencies during this inspection. In December 1992, Dresden had the benefits of a "lessons learned" review . of their GL program from a Quad Cities group leader who was involved in the NRC SWSOPI pilot inspection. Recommendation for program improvements and implementation deficiencies similar to the April 1992 audit were identified. The NRC team identified the same deficiencies during this inspection. A contracted SWSOPI Review was complet~d in March 1993. The review effectively i dent ifi ed a 11 regulatory req1fl rements and l i c~nsee commitments, and provided a current licensing basis for the Dresden SWS. -- The effort did not, however, evaluate the Dresden SWS as implemented per the GL but focused on issues that were expected to be addressed during this NRC inspection. The review for this latter objective was considered to be narrowly focused and not in-uepth in verifying that Dresden had addressed issues from previous NRC SW inspections. For exdmple~ many procedures were listed as covering the required commitments, but the review aµµarently never verified the procedures adequately; the NRC team identified inadequate procedures. Also, many items were verified only by interviews. Conclusions Dresden had conducted good performance based audits on the SWSs; however, corrective actions to address the deficiencies identified in the self assessments were slow and narrowly focused. 10.0 Inspection Followup Items Inspection followup items are matters that have been discussed with the l ice:isee, _which will be reviewed further by the inspector, and _which involve some action on the part of the NRC or licensee or both. Inspection follow~up items disclosed during the inspection are discussed in Sections 5.1.1 and 8.1.2. 11. 0 . Exit Interview -The team conducted an exit meeting on April 30, 1993, at the Dresden Nuclear Power Station to discuss the major areas reviewed during the inspection, the strengths and weaknesses observed, and the inspection results. Licensee representatives and NRC personnel in attendance at this exit meeting are documented in Appendix A of this report. The team also discussed the likely informational content of the inspection report with regard to documents reviewed by the team during the inspection. The licensee did not identify any documents or processes as proprietary. 13
Appendix A Dresden Nuclear Power Plant C. s*chroeder, Dresden Station Manager J. Bandurski, Finance Services Director T. Bezouska, Maintenance Staff P. Boyle, Chemistry E. Carroll, Chemistry Supervisor A. D'Antonio, Station Quality Verification Superintendent -S-.- -Davi~, Quad Cities Technical Staff J. Dawn, Site -Engineering_ N. Digrindakis, Technical Staff _ R. Fl~hive, Technical Services Superintendent R. Hylka, Quality Control Training Coordinator R. Jackson, Balance of Plant Group Leader R. Johnson, OPEX Administrator J. Kotowski, Operations Manager D. Lowenstein, Regulatory As*surance G. Lupia, Engine_ering and Construction (ENC) G. Manious, Site Engineering H. Mentink, Technical Staff Consultant W. Morgan, Corporate Performance Monitoring T. O'Conner, Maintenance Superintendent G. Paramore, Technical Staff P. Piet, Nuclear Licensing Administration B. Pikelny, ENC R. Radtke, Executive Assistant to Dresden Site VP - R. Ralph, Technical Staff Supervisor B. Rybak, M&SD Engineering Supervisor J. Shields, Regulatory Assurance Supervisor M. Strait, Technical Staff Supervisor L. Taylor, ENC Regulatory Assurance . R. Testin, Inservice Testing (IST) Coordinator T. Theesfeld, Operations Shift Supervisor B. Viehl, Engineering Design Supervisor G. Wagner, Electrical/Instrumentation & Control Engineering Superintendent R. Weidner, Training Supervisor G. Whitman, ISI/IST Group Leader J. Williams, Engineering Design Supervisor D. Zebrauskas, M&S Design IST Engineer U.S. Nuclear Regulatory Commission
- B. Davis, Regional Administrator
T. Martin, Acting Director, Division of Reactor Safety S. Burgess, Team Leader M. Bielby, Operator Licensing Examiner G. Cha, NRC Consultant A. Dunlop, Reactor Inspector C. Gainty, Reactor Inspector P. Hiland, Section Chief M. Peck, Dresden Resident Inspector
I. 2. 3. 4. 5. 6. 7. 8. 9. 10. II. 12. 13. 14. 15. 16. 17. 18. 19. 20.
- ii.
22.
23. 24. 25. 26. 27. 28. 29. 30. . 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43.
44. 45. 46. Appendix B PROVIDE DESIGN BASIS AND OTHER DESIGN DOCUMEl'ITS INCLUDING: PROCUREMEl'IT SPECS OF ALL EQU!PMEITT SUCH AS PUMPS, HEAT EXCHANGERS, VALVES, ORIFICES, ETC; SIGNIFICAITT DESIGN CHANGES WITH ASSOCIATED DOCUMEl'ITATION; THERMAL AND HYDRAULIC CALCULATIONS AND ANALYSES; AND AND ACCIDENT" HEAT LOAD INPlJf TO THE SERVICE WATER SYSTEM (SWS). PROVIDE CERTIFIED PUMP CURVES (WITl\\!ESSED TEST CURVES). PROVIDE CROSS-SECTIONAL DRAWINGS OF MAJOR EQUIPMEITT SUCH AS*PUMPS AND HEAT EXCHANGERS. PROVIDE P&W. OF THE SWS, ITS LUBE WATER SYSTEM, AND OTHER llITERCONNECTED AND AUXIlJARY SYSTEMS. PROVIDE LICENSING REQUIREMEl'ITS AND COMMITMEl'ITS, IF NOT ALREADY IN THE FSAR. PROVIDE ANALYSES SUPPORTING SINGLE ACTIVE FAILURE ADEQUACY. PROVIDE FLOW DATA FOR SYSTEM COMPONElffS AND HEAT TRANSFER DATA FOR HEAT EXCHANGER/COOLERS FOR VARJOUS MODES. PROVIDE WATER HAMMER/SURGE PRESSURE PROTECTION INFORMATION. PROVIDE A LIST OF MODIFICATIONS TO THE SW SYSTEM. PROVIDE ALL RELEVAITT DOCUMEl'ITATION, ANALYSES, IMPLEMEl'ITATION PROCEDURES, INSPECTION RESULTS, ETC CREDITED FOR SATISFYING THE ACTIONS REQUESTED BY GENERIC LETTER 89-13 IN THE DESIGN AREA. PROVIDE SW SYSTEM OPERATING PROCEDURES (INCLUDING ULTIMATE HEAT SINK, TRAVELING SCREENS, ETC) TRAINING INFORMATION FOR LICENSED/NON-LICENSED OPERATORS INCLUDING LESSON PLANS, TRAINING TEXT, HANDOUT MATERIAL, TASK PERFORMANCE MEASURES, ETC COVERING SYSTEM Al..IGNMEl'IT, OPERATION, _AND ABNORMAL CONDITTON OR EMERGENCY RESPONSE. PROVIDE SW SYSTEM OPERATING PROCEDURES (INCLUDING'ULTIMATE HEAJ_ SINK, TRAVELING SCREENS, ETC) FOR SYSTEM ALIGNMEITT, OPERATION, AND ABNORMAL CONDITTON OR EMERGENCY RESPONSE. PROVIDE SW SYSTEM RESPONSE PROCEDURES, IE, TIIOSE PROCEDURES FOR EVALUATING AND RESPONDING TO-CONTROL ROOM OR LOCAL ALARMS THAT MAY LEAD INTO Q-12. PROVIDE ALL RELEVAITT DOCUMEITTATION, ANALYSES, IMPLEMENTING PROCEDURES, INSPECTION RESULTS, ETC CREDITED FOR SATISFYING THE ACTIONS REQUESTED BY GENERIC LETTER 89-13 IN THE OPERATIONS AREA. , PROVIDE PREVENTIVE AND CORRECTNE MAINTENANCE PROCEDUREs FOR THE SW SYSTEM, ITS COMPONEl'ITS, RELATED INSTRUMEl'ITATION, AND POWER SUPPLIES. PROVIDE VENDOR MANUALS RELATED TO Q-15. PROVIDE MAINTENANCE fDSTOR Y OF SELECTED COMPONEl'ITS (LIST TO BE PROVIDED) FOR THE LAST 2 YEARS. PROVIDE SW SYSTEM TRAINING INFORMATION FOR MAIITTENANCE PERSONNEL INCLUDING LESSON PLANS, TRAINING TEXT, HANDOUT MATERIAL, TASK PCRFORM/\\NCE MEASURES, ETC COVERING TRAINING AND QULAIF!CATION FOR SKILLS TO BE USED IN THE SYSTEM (INCLUDING ULTIMATE HEAT SINK, TRAVELING SCREENS, ETC). PROVIDE A LISTING OF THE SW MAINTENANCE BACKLOG (CORRECTNE ANU PREVENl"IVE, OUTAGE AND NON-OUT AGE). PROVIDE A LISTING OF ALL SW SYSTEM MAINTESANCE ACTIVITIES SCHEDULED DURING THE INSPECl"ION PERIOD, PROVIDE IMPLEMEITTING PROCEDURES AND TRE..>;DING INFORMATION ASSOCIATED WITH THE ASME SECTION XI INSERVICE TESl'ING PROGRAM FOR THE SW PUMPS AND VALVES. PROVIDE COPIES OF LCO LOGS (FOR THE LAST 2 YEARS) OR OTHER RELEVAITT INFORMATION THAT WOULD PROVIDE INFORMATION ON SYSTBI AND SWCOMPONEITT UNAVAILABILITY * PROVIDE ALL RELEV AITT DOCUMEITT ATION, ANALYSES, IMPLEMENTING PROCEDURES, INSPECTION RESULTS, ETC CREDITED- FOR SATISFYING THE ACTIONS REQUESTED BY GENERIC LETTER 89-13 IN THE MAINTENANCE AREA. PROVIDE A COPY OF THE COMPUITED PREOPERATIONAL TEST PROCEDURE, OR COPY OF ANY SUBSEQUE!ff COMPUITED TEST PROCEDURE THAT MAY HAVE SUPERSEDED THE PREOPERATIONAL TEST. PROVIDE THE MOST REC8T COPY OF COMPLETED TECHNICAL SPECIFICATION PROCEDURES, INCLUDING THE INTEGRATED ESF TEST IF APPLICABLE. PROVIDE A COMPREHENSIVE LISTING OF PROGRAMS AND PROCEDURES THAT THE LICENSEE CREDITS FOR MAfi','T AINING THE CONDITTON ASD DEMONSTRATL>.;G THE OPERABILITY OF THE SW SYSTEM (EG, PERIODIC INSPECTION PROGRAM FQR BIOFOULING, SILTING, CORROSION, ETC). PROVIDE A LISTING OF OVERDUE SW SYSTEM SCHEDULED SURVEILLANCE TASKS. INCLUDE DUE DATE AND DATE SURVEILLANCE WAS LAST PERFORMED. PROVIDE A LISTL-.:G OF ALL SW SYSTEM SURVEILLA.-.:CE ACIWITIES SCHEDULED DURING THE INSPECTION PERIOD. PROVIDE ALL RELEVAITT IX>CUMEITTATION, ANALYSES, IMPLEMENTING PROCEDURES, INSPECTION RESULTS, ETC THAT ARE CREDITED FOR SATISFYING THE ACTIONS REQUESTED BY GL ~13 L-.: THE SURVEILLANCE AREA. PROVIDE PLM'T ON-SITE REVIEW COMMITTEE A.'1l OFFSITE REVIEW COMMITTEE MEETING MINUTES FOR THE PAST 6 M01THS. PROVIDE A LIST OF ALL SW SYSTEM ITEMS IN THE QA OPEN ITEM TRACKING SYSTEM . PROVIDE NPRDS REPORTS, 10 CFR 50.72 AND 10 CTR 50.73 REPORTS, ENFORCEMEITTS, AND NONCONFORMANCE REPORTS RELATED TO THE SW SYSTEM FOR THE LAST 2 YEARS. PROVIDE LICENSEE QUALITY VERIFICATION ACTIVITIES RELATED TO THE SW SYSTEM (IE. TECHNICAL AUDITS). PROVIDE A LISTING OF ALL SW SYSTEM DEFJCIESCIES (AS REPORTED IN DEFICIENCY LOGS, CONDITTON REPORTS). BLM"K. PROVIDE 5 COPIES OF THE FOLLOWING PRINTS (I~ x 11): M-517, M-194, M-23. REFERENCE Q-17. PROVIDE A BRIEF MA!NTENA.-.:CE (PREVENTIVE & CORRECTIVE) fDSTORY FOR THE PAST 3 YEARS FOR THE FOLLOWING COMPONEl'ITS. INCLUDE V.'Rll, COMPONEITT #, TI"PE OF MAINTENANCE, DESCRIPTION OF PROBLEM & CORRECTNE ACTIOS, SAFETY RELATED/NON-SAFETY RELATED CLASSIFICATIOS. 2 & 2f.l DGCW PUMP & MOTOR, 2 & 2f.l DGCW DISCHARGE CJ-IECK VALVE, DGCW 3 WAY VALVE, FLOW ELEMEl'IT, DGCW DISCH PUMP GAGE. 4-WAY HPCI RM COOLER VALVE, MOVTHROTfLE VALVE FOR CCSW HXs, dP CONTROLIER FOR MOV 2-1501*3A&B, CCSW PUMP & MOTOR, CO~'TAJ:\\"t.IEl'IT COOLING HEAT EXCHANGER, HIS CCSW PUMP CUBICLE COOLER. PROVIDE CHECKLISTS ESTABLISHED IN RESPoNSE TO GL 89-13 ITEM V, AS REFERENCED IN CECo LETTER DATED JAN 29, 1990, ATTACHME.T A. PAGE A-9. GIVE 2 EXAMPLES EACH OF TRAINING CHECXLJSTS THAT HA VE BEEN FILLED IN AND COMPUITED. REFERENCE Q-32. PROVIDE NPRDS DATA FOR THE LAST TWO YEARS FOR DGCW AND CCSW. ON P&ID M-3121, VALVE XCV 213-5741 048A FAILl TO OPEN ON LOSS OF AIR. (I) IS THIS AIR SUPPLY FROM THE INSTRUME.T AIR SYSTEM? C1 IS THE SYSTEM SEISMIC QUALIFIED? (3) WHAT IS THE CCSW FLOW THROUGH THE REFRIGERATION CONDENSING UNIT WHEN XCV 2f.l 5741 048A FAILS OPEN? (4) WHAT IS THE IMPACT OF THE DIVERTED FLOW THROUGH THIS FAILED OPEN VALVE ON THE LPCI HEAT EXCHANGER? WHAT IS THE L\\IPACT ON USIT 3 (Wl!JLE OPERAn...Gl OF HAVING THE BACK-UP CONTROL ROOM HVAC UNIT our OF SERVICE SINCE 1/1719:!'? WAS THERE A SAFETY ANALYSIS COMPLETED FOR THIS CONDITTON? REFERENCE CECo DOCUME/\\'T# 455 DATED 318193. -EQUIPMEITT QUALIFlCATION DATA .* -*. IDENTIFY THE COMPONE!ffS V.TIH RESPECT TO THE VARIOUS LOCATIONS IN THE PLAITT (ROOM LOCATIOSS_ ETC) IN WfDCH THEY ARE LOCATED. PROVIDE COPY OF EOP FLOWCHARTS . PROVIDE COPIES OF PROBIDI IDEITTIFICATION FORMS (PIF) RELATED TO CCSW, DGCW, AND SW FOR THE LAST 2 YEARS. REFERENCE CECo DOCUM8T# 508, 509, 519, 549. WHAT PROCEDURES ARE THE ELECTRICAL/MECHANICAUINSTRUMEITT Al..IGNMEITT LISTS . ASSOCIATED WITH? (U2 DOP 1500-EI, U3 DOP 1500-EI: L'2 DOP 1500-MI; DOP 1500-TI) REFER..E.-.:CE CECo DOC# 532. MOV 1501*3A&B. (I) REPORT STATED "CAPABILITY HAS A MINIMAL MARGIN." WHAT IS THE MARGIN? (2) REPORT STATED MODIFICATION IS IN PROGRESS TO REPLACE THESE VALVES AND ACTUATORS. IS THE MODIFICATION COMPUITE? (3) WHAT IS THE PRESSURE MODULATION"S L\\IPACT ON FLOW THROllGH THE CCSW HEAT EXCHANGER?
47. _48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58. 59. ro. 61. 6:!. 63. ~- 65. 66. 67. 68. 69. 70. REFERENCE CECo OOC# 470, CCSW PUMP ROOM COOLER HEAT LOAD STUDY. PLEASE RESUBMIT LEqlBLE COPY AND ALSO SUBMIT FIGURES REFERENCED IN REPORT. PROVIDE A GSERV REPORT FOR THE COMPONENTS LISTED BELOW A."D THOSE LISTED IN Q-37. INCLUDE TASK PROCEDURE, FREQUENCY, LAST 3 DATES COMPLETED, AND WR/I (IF USED). D02-1543A (dP XMITTER), 003-1501-@JADPIS (dP INDICATING SWITCH), D02-1501--0003A LD5 (MOY), 2-1503A (CCSW BX), 3-1503A (CCSW BX). PROVIDE COPIES OF THE FOLLOWING D\\!Rs: 12-3-92--053, 12-3-92-XI, 1~-:?/.l-91-089N .. (2) FOR THE FOLLOWING CANCELLED DVRo, PROVIDE REASON FOR CANCElLATION AND ANY AS.'>OCIATED DOCUMENTS OR WR: DVR 12-2-92--06, 12-3-91--026. _ REFERENCE CECo DOC# 136. THE ANALYSIS USES A CROSS-TIE FROM THE 00 PIPING TO SUPPLY CONTINUOUS MAKE-UP TO THE CCSW PIPING SYSTEM. ACCORDING TO P&ID M-22, THE WATER SUPPLY IS FROM THE SW PUMPS. EXPLAIN THE INCONSISTENCY. PROVIDE PROCEDURES FOR INSPECTION OF INTAKE BAYS AND INSPECTION OF HEAT EXCHANGERS (ROOM COOLERS, LPCO COMPLETED. WHAT TECHNICAL SPECIFICATIONS ARE ASSOCIATED WITH CONTROL ROOM INAC OPERABIUI'Y'I WHAT ARE THE DRESDEN ADMINISTRATIVE TECHNICAL REQUIREMENTS FOR CONTROL ROOM INAC OPERABIUTY? REFERENCE CECo DOC# I. MEMO DELINEATED THE RECOMMENDATIONS SUBSEQUENT TO S&L REPORT# SL-4785. (I) WHAT IS THE STATUS OF THESE RECOMMENDATIONS'! (2) HOW MANY RECOMMENDATIONS WERE ACCEPTED? (3) HOW MANY WERE IMPLEMENTED? (4) HOW MANY ARE CURRENTLY BEING IMPLEMEITTED AND THE RESPECTIVE COMPLETION DATES? (S) FOR RECOMMENDATIONS NOT ACCEPTED, PLEASE PROVIDE .. RAT)ONALE. ACCORDING TO P&ID M-355, THE U3 HPC1 ROOM COOLER DOES NOT HAVE A 4-WAY VALVE FOR BACKFLUSHING PURPOSES. WHY IS U3 DIFFERENT FROM UZ? PROVIDE DETAILS, APPLICABLE CORRESPONDENCE AND COMMITM~"'TS FOR :_rHE RESOLUTION OF NUREG 0737, ITEM 111.D.3.4 FOR THE DRESDEN STATION. PROVIDE A CHRONOLOGICAL SUMMARY ON THE DEVELOPMENT OF THE LOSS OF ECCS ROOM COOLERS. REFERENCE CECo DOC# 14 (RSA-D-92--06 & 07). PROVIDE RATIONALE FOR THE 185"F EQ TEMPERATURE. PROVIDE COPIES OF THE FOLLOWING WORK REQUESTS: D78589 (2f2l8'1), 096125 (12/26/'90), 098720, DI 1429 (BtSm), DJ0645 (7/Jlm), 001167 (Jl/S/91), 089934 (1119/90), 098799 (211Sm), D05878, 005700, DOES DRESDEN HAVE A SURVEIU.ANCE PROGRAM THAT PERIODICALLY REQUIRES REVERSING FLOW THROUGH THE DGCW AND CCSW HEAT EXCHANGERS'! PROVIDE THE SEISMIC ANALYSIS AND THE DESIGNS FOR SUPPORTS, ANCHORS, AND SNUBBERS FOR THE FOLLOWING EQUIPMENT: CONTAINMENT COOLING HEAT EXCHANGER (CCHX), THE 16" INLET CW LINE TO THE CCHX, THE 14" OUTLET CW LINE FROM THE CCHX, MOV 2-1501-3A. ON P&ID M-29, MOV 2-ISOl-3A IS A GATE VALVE WHEREAS THE OTHER THREE (IJ-2 3B, U-3 3A&B) ARE GLOBE VALVES. ALSO, 3 OF THE MOVs ARE SHOWN CLOSED WHEREAS ONE IS OPEN. EXPLAIN THE DIFFERESCES. USING DWG M-10, SHOW IN PLAN AND ELEVATION, THE LOCATIONS OF THE FOLLOWING: (I) BIOCIDE INJECTION POINTS, (2) SUCTION TO THE DGCW PUMPS, AND (3) SUCrION TO THF. CCSW PUMPS. PROVIDE A LUBQ REPORT FOR THE FOLLOWING COMPONENTS. INCLUDE: TASK DESCRIPTION, PROCEDURE USED (IF ANY), FREQUENCY, LUBRJCANT, WORK REQUEST (IF USED), AND LAST 3 DATES COMPLETED. D02-1501--0003A & B (MOVs), 2-3903 &213-3903 (DGCW PMP & MTR), 2A-1501-44 AND 28-1501-44 (CCSW PMP & MTR). NRC INFORMATION NOTICE 93-12, "OFF-GASING IN AUX FEEDWATER SYSTEM RAW WATER SOURCES," DISCUSSES DISOLVED AIR IN WATER THAT IS RELEASED WHEN THE WATER IS HEATED IE, OFF GASING. nns FREE AJR CAN ACCUMULATE IN HIGH POINTS OF sYsi:EM PIPING AND IMPEDE FLOW.- HAS DRESDEN EVALUATED THIS OFF-GASING PHENOMENA FOR THE CCSW SYSTEM \\ESP WITH I PUMP OPERATION)? IF SO, PLEASE PROVIDE THE EVALUATION. REFERENCE: GENE 770-26-1092, NOV 1992, "LPCl/CONTAINMENT COO!.r'G SYSTEM EVALUATION". PROVIDE REFERENCES I, 2, 3 AND 7 FOR REVIEW. SPECIFICALLY, WITH RESPECT TO TABLE 3 PAGE 14 OF REPORT. PROVIDE THE RATIONALE Of HOW THE LPCI BX K-FACTORS WERE DEVELOPED. ALSO, THE LPCI BX DUTY AND THE LMTD FOR EACH OF THE FOUR CASES. PROVIDE A LIST OF CURRENT TEMPORARY SYSTEM MODIFICATIONS OR ALTERATIONS FOR THE CCSW AND DGCW SYSTEMS. INCLUDE DESCRIPTION, DATES, COMPONENTS, ETC. REFER TO NRC Q-41. "B" CR llVAC SYSTEM WAS OUT OF SERVICE SL"CE 1/17193 AND NO SAFETY ANALYSIS WAS COMPLETED. WHEN DO DRESDEN STATION PROCEDURES REQUIRE A SAFETY ANALYSIS OR O~-SITE REVIEW TO DOCUMENT A CONDITION SUCH AS THIS'! REFERENCE: FSAR 6.2.4-17, REV 0. THIRD PARAGRAPH STATED, * ... l~"'Tll.. ALL FOUR HEAT EXCHANGERS ARE COMPLETELY RETUBED WITH THE NEW MATERJAL." FOURTH PARAGRAPH STATED* ... THE TOTAL NUMBER OF PLUGGED TUBES PLUS TUBES REPLACED WITH THE NEW MATERJAL WILL BE LIMITED TO 6% OF THE TOTAL HEAT EXCHANGER TUBES.* PLEASE CLARIFY THE APPARENT CONTRIDICTION BETWEEN THE 1WO STATEMENTS. REFERENCE: M-12-2-86-011 ROOM COOLER PIPING SUPPORTS MODIFICATION. THE MODIFICATION MENTIONED ONLY UNIT 2. WHAT ABOUT UNIT 3? BOTH UNITS HA VE THE SAME VAULT ROOM COOLER FLOW REVERS!:"G CAPABILITY. WHY IS ONLY UNIT 2'* SUPPORTS REVISED? (I) P&ID M-29, SITT 2, CCSW PUMP A1B DISCHARGE TO 2A LPCUCCSV.' HX, REFERS TO M-23, SITT I (E-10). SHOULD IT BE M-29, SITT I (D-9)? (2) P&ID M-22, CCSW HX A&B DISCHARGE TO CW DISCHARGE HEADER (E~. SHOULD ARROW READ M-29, SllT I INSTEAD OF SllT 2? (3) P&ID M-22, DGCW PUMP DISCHARGE TO CCSW KEEP-FILL SYSTEM. ARE FLOW ARROWS BACKWARDS'! (SEE M-29, SllT 2 (F-4) & (B-4)). (4) P&ID M-29, SllT i. ARROW REFERENCE AT CCSW A&B PUMP DISCHARGE SHOULD READ M-29 INSTEAD OF M-23. (S) P&ID M-360, 4-WAY VALVE OUT OF :>-1501-44B PUMP JS LABELED :>-1599-80C INSTEAD OF l!OB. 71. PROVIDE A COPY Of SURVEILLANCE PROCEDURE FOR THE SW RAD MONITOR. T-.. PROVIDE A COPY OF THE INSPECTION RESULTS FROM THE CHECK VALVE PROGRAM FOR THE FOLLOWING VALVES: CCSW PUMP DISCHARGE CHECK VALVES, DGCW PUMP DISCHARGE CHECK VALVES, 213-1599-103. 73. PROVIDE A COPY OF THE MODIFICATION THAT TIES THE DGCW TO THE CCSW KEEP-ALL SYSTEM. ALSO PROVIDE THE SAFETY ANALYSIS FOR THE MOD. WHEN IS THE MOD SCHEDULED TO BE PERFORMED ON BOTH UNITS'! 74. WHY ARE A LARGE NUMBER Of VALVES LOCKED IN THE FIELD, Bl!T NOT DENOTED ON THE ASSOCIATED P&IDs? 75. DGCW PUMP/MOTOR TECH MANUAL, PAGE 5, RECOMMENDS CHE<::lill'G THE OIL LEVEL WHEN THE PUMP IS COOL. IS THIS DONE PERIODICALLY? HAS THIS EVER BEEN DONE? THERE IS NO SUCH TA.SK IN GSERV. 76. TllE FOLLOWING TASKS WERE RECOMMENDED BY THE RCM STUDY. HA VE THEY BEEN INCLUDED IN GSERV YET? CECo ITE.'-1# 444, DOES NOT SHOW THEM. EID-D02Z3931S25-Vl5 (DISASSEMBY AND INSPECTION); EID-DO:?Zl50144A-MIO (CLEAN MOTORS, EXTERNALLY & INTERNALLY I/REFUEL); EID-D02Zl59980B-Vl5 (REBUILD EVERY 3 REFUEL OUTAGES). 77. (I) CCSW PUMP VENDOR MANUAL V--030, PG 5, SPECIFIES DRAINING &: FLUSHING OIL EVERY 6 MONTHS. ARE THE BEARJNGS FOR THESE PUMPS GREASE-LUBRICATED OR OIL-LUBRICATED? JS THERE ANY PERIODIC LL'BRICATION OF THESE BEARINGS'! (2) THE MAINTENANCE SECTION FOR STEELFLEX COUPLING RECOMMENDS LUBE CHECK ONCE PER YEAR. IS THIS DONE? 78. UNIT 3 HPCI ROOM COOLER IS LOCATED DIRECTLY ABOVE HPCI ISJECTION LINE VALVE 3-2301-9 OPERATOR. THE COOLER DOES NOT APPEAR TO BE SEISMICALLY MOUNTED. SHOULD THE COOLER BE SEISMICALLY MOUNTED TO ENSURE OPERABILITY OF THE HPCI SYSTEM? 79. DOES CCSW SUPPLY STRAINER (EID# 213-73XI) TO llVAC UNIT HAVE A..'-Y PERIODIC CLEANING, BLOWDOWN, OR ANY OTHER CHECKS? ARE THERE ANY TASKS IN THE GSERV FOR THIS COMPONENT? 80. PROVIDE COPIES OF THE FOLLOWING WORK REQUESTS: DSl 134, D793>1, D76538, D8S397, 079204, D81927, D83995, D74522, 076578, D80821, 064304, 067217, 068459. SI. PROCEDURE DMS 6600-02 REV 3, PG 26, STEP 1.24.H SPECIFIES TO CU'.A.,>; DGCW HEAT EXCHANGER FIRST AND THEN INSPECT. PROCEDURE DCP 1008--04, REV 0 E.4 AND F.4 SPECIFIES THAT INSPECTIONS SHOULD BE PERFORMED PRIOR TO CLEANING. WHICH IS CORRECT? WHAT WAS DONE ON HEAT EXCHANGERS TO MEET GL 89-13 COMMITMENTS DURING U'...RI~ AND D3RIZ?
-- --- --------- ----- 82. HOW ARE COMMITMENTS TO GL 89-13 IN JAN 29, 1990 LEITER. PG A-4 AND IN NOVEMBER 14, 1990 LEITER. ATTACHMENT I (SPECIFICALLY TO TEST, FLUSH, OR DP TEST) MET FOR THE DGCW PUMP COOLER? IT APPEARS AS IF THE ONLY TASK IS TEMP MONITORING, WHICH MAY NOT PROVE HEAT REMOVAL CAPABILITY AT DESIGN CONDmONS. 83. GL 89-13 EVALUATION CHECKUSf SPECIFIES THAT CCSW PUMP MOTOR PM.IS PERFORMED EVERY S YRS PER DES 6700-4 AND SUGGESTS THAT THIS WILL ENSURE PUMP MOTOR WINDINGS WILL BE INSPECTED FOR DIRT, MOISTURE, ETC. HOWEVER, PROCEDURE IS FOR SWITCH GEAR AND DOES NOT APPEAR TO ADDRESS MOTOR. 84. ON PRINT M-22, TWO LINES ARE SHOWN ENTERING THE PUMP COOLER FROM THE DISCHARGE 9F THE PUMP. ONE LINE HAS A Y STRAINER AND THE OTHER DOES NOT. IS IT POSSIBLE FOR WATER TO ENTER THE COOLER THROUGH THE LINE THAT DOES NOT HAVE STRAINER? IF SO, HOW IS THE Cil:ANLINESS OF THE COOLER ENSURED? IS THERE ANY PERIODIC BACKFLUSIIlNG OF THE COOLER? SS. PROCEDURE 6(00.J I CHECKS PUMP MOTOR CASING TEMP WITH A HAND HELD THERMOMETER, BUT DOES NOT SPECIFY WHAT TYPE OR WHERE TO TAKE TEMP MEASUREMENT. HOW CAN YOU ENSURE CONSISTENCY OF THE READINGS? ALSO, THERE IS NO ACCEPTANCE CRITERIA FOR THE TEMPERATURE MEASUREMENT IN THE PROCEDURE, SHOUU> THERE BE? 86. THE TECH MANUAL FOR THE DGCW PUMP SHOWS A Fll.TER ASSEMBLY ON DWG 066488, PC 6. IS THIS Fll.TER INSTALLED? IF SO, IS IT PERJODICALL Y CHECKED FOR CLOGGING TO MEET COMMITMENrS TO GL ~13? 87. GL 89-13 EVALUATION CHECKUST 2.3.2 SPECIFIES THAT MOY* ARE STROKED PER PROCEDURE DEP 04Q..17 TO VERJFY THAT NO DEBRJS HAS B~ THE v AL VE SEATS. HOWEVER, WHAT IS THE FREQUENCY OF THE PERFORMANCE OF THE PROCEDURE AND DOES nns MEET THE INTENT CiF THE PERIODIC f::J-{ECK OF VALVE FOR LACK OF DEBRJS? 88. WHAT SYSTEM COMPONENTS WERE"IN THE GL 89,IJ_PROGRAM AT THE TIME OF D2Rl2 AND D3Rl2 THAT WERE INSPECTED OR CLEANED TO MEET DRESDEN"S COMMITMENTS TO THE GL? THE RCM STUDY.WAS COMPLETED AFTER THIS TIME AND THE TEAM IS LOOKING FOR THOSE COMPONENTS ORJGINALLY IN THE PROGRAM. PROVIDE A UST OF THE COMrONOOS (VALVES, PUMl'S, ¥RA!NERSl AND THE DOCUMENT THAT WAS USED (WORK REQUESr OR PROCEDURE). . 89. WHAT ARE THE REQUIRED FLOW RATES FOR THE DGCW PUMP MOTOR COOLER AND THE CCSW PUMP ROOM COOLERS? 90. "QUAD cmES LESSONS LEARNED" SUMMARY LEITER. DATED 12110192 MENTIONED A RECOMMENDATION TO VERJFY THE SELECTED EROSION/CORROSION INSPECTION POINTS FOR OUTLEr PIPING OF "B" CR JNAC UNIT. WASTIDS RECOMMENDATION EVALUATED AGAINST DRESDEN GL PROGRAM? 91. HOW ARE FINDINGS OF SILT OR FOULING IN THE SW EROSION/CORROSION PROGRAM IDENTIFIED AND DISPOSmONED? WHAT DOES THE "PROGRAM" REQUIRE FOR THESE TYPES OF FINDINGS? WHAT WAS DONE SPECIFICALLY FOR 2123193 INSPECTION OF 2SW02A, WJilCH FOUND o.ss* SEDIMENT ON INSIDE WALL SURFACE? 92. CONTROL ROOM JNAC TRAIN "B' REFRJGERATION UNIT HEAT EXCHANGER: IS THERE A BIOCIDE TREATMENT PROCEDURE FOR TIIlS UNITT PROVIDE FOR REVIEW. . 93. IN THE EVENT OF I CCSW PUMP OPERATION, THE FLOW RATES IN THE CCSW HEAT EXCHANGERS AND PIPING SYSTEM WILL BE SIGNIFICANTLY LOWER THAN DFSIGN. TIIlS COULD CAUSE ACCELERATED DEPOsmoN OF SILT. HAS DRESDEN EVALUATED TIIlS ISSUE? IF YES, PROVIDE RESULTS FOR REVIEW. 94. CCSW PUMP ROOM COOLERS - IS THERE A BIOCIDE TREATMENT PROCEDURE FOR THESE COOLERS? PROVIDE FOR REVIEW. 95. I) HPCI ROOM COOLER: IN THE EQ REVIEW, IS THE MOTOR/FAN BELT QUALIFIED? 2) PROVIDE A TRANSMITTAUCOVER LETTER TO THE GOS CALCll EDC-DR-015, VERIFYING CECo HAS REVIEWED AND APPROVED THIS CALC. 96. REFERENCE DGCW PUMP DISCHARGE PIPE MODIFICATION. MOD PACKAGE DISCUSSED S&W ANALYSIS TO REDUCE DG COOUNu FLOW TO 830 GPM. PROVIDE ANALYSIS FOR REVIEW. ALSO, PROVIDE THE FOLLOWING: (A) CONFIGURATION OF PIPING SEISMIC ANALYSIS, (B) VALVE. SEISMIC QUALIFICATION DOCUMENTATION, (C) ADVISE WHICH VALVES WERE INSTALLED .
APPENDIX C Generic Letter 89-13 ~ction Items I. Biofoulinq Control and Surveillance Techniques - Action I of GL 89-13 requested that licensees implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling. The action requested included intake structure inspections, chemical treatment of service ~atef *systems, an~_periodtc service water system flushing/flow testing. The team reviewed the actions taken by the 1 icensee_ to address the generic letter request. Intake structure and service bay insp~ctions were cond~cted in accordance with procedure DTS 3900-07, "Unit 2/3 Service Water System --
-
Cribhouse Inspection," Revision 0. The procedure inspected for sediment build-up, debris, and mussels or clams, and sampled depositional sediment for material composition and presence of live or relic clams and mussels. The procedure was weak in providing guidance for the crib house inspection and safety related SW systems. Weaknesses included insufficient guidance on documentation requirements, no inspection acceptance criteria, an option to delete the diesel fire pump bay inspection, and lack of specific inspection of safety related pipe openings. The procedure was revised during this inspection to correct the concerns identified; although, guidance on as-found inspection documentation was not formalized. Last summer the licensee heated the intake water in an attempt to reduce the live mussel population with some success. During the current outage, the licensee noted a significant increase_ in the number of zebra mussels from the previous year. Divers mapped the location of zebra mussels colonies on the intake bay walls; although, videotaping (as performed in 1992) was not possible due to the cloudy water. The intake structure walls were mechanically scraped to remove zebra mussels and asiatic clams. In 1989, the licensee implemented a chlorination program to arrest the growth of Asiatic clams, micro-biofouling, slime, algae, and zebra mussels. The initial program was considered weak due to short injection time limits, few injection locations, inconsistencies as to when chemicals were injected, and inadequate system sampling for chemical residue. An expanded program was developed incorporating the experience gained by the licensee during outages. The new program included a new hypochlorite chemical injection system that injected into both the circulation water bays, the diesel fire pump bay, and directly into the DGCW system at the pump discharge. Solutions were also injected into the circulation water bays prior to running the CCSW pumps. Dilution water was also used to flush the injection pumps after each use, which minimized maintenance efforts and improved the biocide treatment equipment availability. The upgraded program will be implemented in 1993 when Units 2 and 3 are returned to service. New procedures were developed that provided sampling of residues to ensure proper concentration of free available chlorine (FAC) and total residue chlorine (TRC) when the safety related heat exchangers were laid-up between . .
Appendix C 2 surveillance tests; procedures also contained a~ceptance criteria for biocide concentration. Sampling points were located at the LPCI/CCSW heat exchanger tube side drain and_near the DGCW heat exchangers. The biocide residue concentration for the CCSW pump-- room coo le rs and the train B contra l room HVAC refrigeration condenser were assumed -to b-e --the- same -~s the CCSW heat exchangers s i nee they are on the same hydraulic circuit. Th~ rin1y safety _rQlated heat exchanger that would not benefit from the direct injection would be -th~ DGGW pump_ motor coolers; nevertheless, these coolers still receive biocide treatment when -- - introduced to the service water at the crib house. In most cases, safety related piping for the CCSW and DGCW systems was periodically flushed at full flow during surveillance and IST testing to minimize silt accumulation. Flow through the CCSW piping to the train B control room HVAC system, however, was not performed on a periodic basis. IST requirements discussed in Section 8.1.1 will now perform the necessary periodic flushing. The team consider the current program sound and responsive to the GL request. The effectiveness of this program needed to be evaluated after heat exchangers were either tested and/or inspected to determine if changes and modifications were required. II. Monitoring Safety related Heat Exchanger Performance Action II of GL 89-13 requested that licensees implement a test program to periodically verify the heat transfer capability of all safety related heat exchangers cooled by the SWS. The test program should consist of an initial test program and a periodic retest program. Dresden's test program consisted primarily of inspecting and cleaning of safety related heat exchangers. The exceptions to this were the DGCW pump motor cooler and the CCSW pump room coolers because their design would not allow cleaning. The licensee also decided this outage to inspect and clean the nonsafety related HPCI and LPCI room coolers. The heat exchangers would be inspected and cleaned every refueling outage to determine a proper cleaning frequency. Inspection results were documented on work requests, which did not
- always provide adequate as-found documentation.
This outage the licensee issued DCP 1008-04, "Heat Exchanger Inspection Program," Revision 0, to provide inspection and documentation guidance. Based on the inspections conducted, most heat exchangers were found in good condition with the
- exception of the LPCI room coolers, which were found significantly plugged.
The licensee evaluated two methods for verifying the heat transfer capability of LPCl/CCSW heat exchangers. These two methods were the temperature effectiveness test and clean/inspect method.
,. (. Appendix C 3 Dresden elected the clean/inspect method over the temperature effectiveness test citing that steady state temperatures and flows could not be obtained; and heat loads would not be available, due to plant conditions, without reducing safety margins.
The -te-am--cons idered the licensee's current posture of verifying the LPCI/CCSW heat exchanger heat transfer-capabiJity_by the clean/inspect method as weak. The intent of GL 89-13 is to conduct a bas-eline test_to_ verify the safety related heat exchanger's heat transfer capability' with subsequent --sche_dul ed cleaning and maintenance for performance restoration. - - _The licensee committed to re-examine the possibility of conducting a temperature effectiveness test. Pending completion of this evaluation, this is considered an inspection followup item (50-237/93008-0l(DRS); 50-249/93008-0l(DRS)). During this outage, a Unit 3 CCSW vault performance test was performed to provide baseline data for future periodic testing. The team noted that flow though cooler B decreased a significant amount (41 to 24 gpm) over the hour test. This decrease could indicate some blockage in the heat exchanger. This issue was not identified during the licensee's test data review even though the final flow rate was less than the required 30 gpm flow rate. The licensee committed to review this issue and take additional heat exchanger flow data to determine the cause. _The issue had minimal safety significance since calcula~ion results indicated that one room cooler receiving the required flow would have sufficient capacity to maintain the CCSW vault temperature in the acceptable range. A periodic testing program was also being developed to perform differential pressure (d/P) testing and temperature monitoring. Testing would be conducted during normal system recorded surveillances with recorded data graphed to determine trends. The team identified the following weaknesses with the periodic testing program:
CCSW room cooler d/P testing was performed after backflushing the cooler; therfore, as-found .conditions were not documented. This was also the case for the HPCI room cooler test that was being developed during this inspection. Dresden committed to revise these procedures to correct the deficiency.
Data from these tests were graphed but it was not apparent that adequate review was performed t~ understand the reason the measured values had changed.
(.> Appendix C 4
The licensee identified that some testing had not been performed as committed to in th~ GL response; Deficiencies included not testing the safety related train B control room air handling unit (AHU) condensing heat exchanger, not testing Unit 2 and 2/3 DGCW pump motor coolers _____ monthly for temperature, and not testing Unit 2 HPCI and LPCI room -co-olers -for -d/P or flow. The 1 icensee initiated several PIFs concerning this problem and-~ill revise _th~fa~ ~ommitment letter to the NRC. The team concluded that the licensee's initial response--fo-Gt--89-13,_ Action II was weak. With the recently issued heat exchanger inspection procedures, - correction of inadequate testing methodology, and proper trending of test results, the GL intent will be met. III. Routine Inspection and Maintenance Action III of GL 89-13 requested that licensees implement a routine inspection and maintenance program for open-cycle SWS piping and components. This program should ensure that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety related systems supplied by the SWS. The licensee implemented a SWS erosion/corrosion inspection program. Periodic visual inspection and cleaning of all safety related heat exchangers was planned, however, procedures had only recently been established to ensure consistency of cleaning and documentation of as-found conditions. System engineer participation in the inspections was recently included in the new procedures. The team considered the implementation of the SWS PM program in response to GL 89-13 Action item III to be slow; however, based on recent changes to the program and commitments obtained during the inspection, including periodic instrument line maintenance, specific procedures for documentation and performance of heat exchanger inspection, and acceptance criteria for erosion/corrosion inspection of low flow locations, the program should be effective. IV. Design Function Verification and Single Failure Analysis Action IV of GL 89-13 requested that licensees confirm that the SWS will perform its intended function in accordance with the licensing basis for the plant. This confirmation should include a review of the ability to perform required safety functions in the event of a single active component. In response to Action Item IV of GL 89-13, the licensee conducted a detailed review of the safety related SWS; namely, the CCSW and the DGCW systems. The review included system configuration, flood protection,
Appendix C 5 pipe supports, emergency power supply, and functional logic evaluation. Specific consideration was given to identify failure of any single active component that could potentially* affect the performance of safety related systems served by either CCSW and DGCW. The study results were documented in SL-4?85, "Service Water System Design Review," Revision 0, dated 9/15/1992. Except for concerns n.oted* in Section _5 .1.1 regarding the LPCI/CCSW heat exchariger',s heat removal capability, the team*rnncurre_d that the CCSW and DGCW systems would perform their intended functions in accoidinte ~ith-the __ licensing basis for the plant. However, as discussed in Section 5.4 of this* - - -- report, the team identified one vulnerability in the CCSW supply that could potentially disable the backup cooling capability for the common Unit 2/3 control room. Unit 2 CCSW provided the only safety related source of cooling water to the safety related train B HVAC unit for the common Unit 2/3 control room. Should Unit 2 CCSW be out of service (inoperable), there would be no safety related cooling water supply for the refrige~ation condenser, thus disabling the safety related cooling capability for the common Unit 2/3 control room. - Results of SL-4785 also identified this concern, but considered the design acceptable by citing two references:- the first being the system design description, and the second being an NRC letter on NUREG-0737, Item III.D.3.4, which discussed protection against radiation and toxic gases. The team did not consider these references applicable in that neither established the temperature criteria for human and equipment habitation. Although the corrective actions listed in Section 5.4 of this report effectively addressed the single failure concern, the team considered this a weakness in the licensee's single active failure analysis performed to meet* GL Action Item IV. V. Training Action V of GL 89-13 requested that licensees confirm that maintenance practices, operating and emergency procedures, and training that involves the SWS were adequate to ensure that safety related equipment cooled by the SWS will function as intended and that operators of this equipment will perform effectively. Licensee commitments to this item included the completion of a procedure review checklist to determine the adequacy of all applicable procedures prior to outage D2Rl2. The team concluded that this review was poorly accomplished. For example, several checklists did not verify the steps that were contained within procedures, but instead assumed that the intent of an item would be met simply because the procedure existed. If the checklist had been thoroughly completed earlier in the program as indicated in GL 89-13 commitments, the
Appendix C 6 licensee would have had the opportunity to identify other GL 89-13 program weaknesses discussed in this report in a more timely manner. Based on the team's review of specific operating procedures, practices and training documentation, the team concluded that overall, Action V regarding operations materials was appropriately accomplished.
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