ML17180A549
| ML17180A549 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/16/1993 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17180A547 | List: |
| References | |
| 50-237-93-29, 50-249-93-29, NUDOCS 9312280101 | |
| Download: ML17180A549 (21) | |
See also: IR 05000237/1993029
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Repbrt Nos. 50-237/93029(DRP); 50-249/93029(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
Inspection At:
Morris, IL
Inspection Conducted: October 7 through November 29, 1993
Inspectors:
M. Leach
A. M. Stone
M. Peck
R. Landsman
D. Chyu
R. Roton
G. Hausman
R. Zuffa, Illinois Department of Nuclear Safety
Approved By: f~c1-1lLI
- i..//~ /q J
P. L. Hiland, Chief
Reactor Projects Section 18
Inspection Summary
Inspection from October 7 through November 29. 1993 (Report Nos.
50-237/93029(0RP); 50-249/93029(DRP))
Date
Areas Inspected: Routine, unannounced resident inspection of operations,
operational safety verification and engineered safety feature (ESF) system
walkdown, maintenance and surveillance observations, engineering and technical
support observations, plant support observations, safety assessment and
quality verification, licensee action on previous inspection findings,
licensee event report review, and management meetings.
Results: Of the nine areas inspected, one violation concerning failure to pos:
a Notice of Violation was identified in paragraph 6.
Two unresolved items
regarding disconnected drywell
ventilatio~ duct supports and missing main
steam line isolation valve seal assemblies were identified in paragraphs 3.e
and 4.a, respectively .
9312280101 931216
~
ADOCK 05000237.
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EXECUTIVE SUMMARY
Assessment of Plant Operations
Operations continued to control unique activities very well, such as Unit 2
shutdown and startup.
One exception was the level of senior reactor operator
involvement in the approach to criticality. Personnel errors continued to
affect plant operations.
Errors involving supervisors were of particular
concern.
Operations closeout of the Unit 2 drywell was better than previous
occasions.
However, the general cleanliness level in Unit 2 drywell was below
management expectations.
Assessment of Maintenance and Surveillance
Observed maintenance and test activities were performed well.
However, low
priority work requests had the same average age as higher priority items and
the number of safety related work items increased.
Assessment of Engineering and Technical Support
Engineering performed a good review of the modification to the reactor vessel
water level instrument and identified an unreviewed safety question.
Assessment of Plant Support
The licensee failed to post a Notice of Violation within the required time
period .
2
1.
DETAILS
Persons Contacted
Commonwealth Edison Company CCECo)
M. Lyster, Site Vice President
G. Spedl, Manager, Dresden Station
D. Ambler, Executive Assistant to the Site Vice President
E. Carroll, Chemistry Supervisor
R. Flahive, Technical Services Superintendent
L. Jordan, Health Physics Supervisor
M. Korchynsky, Senior Operating Engineer
J. Kotowski, Operations Manager
- G. Kusnik, Quality Control Supervisor
- S. Lawson, Operating Engineer
- H. Massin, Manager, Station Engineering and Construction
T. O'Connor, Maintenance Superintendent
- R. Radtke, Services Superintendent
S. Reece-Koenig, Performance Assistant Administrator
- R. Robey, Director, Site Quality Verification
- J. Shields, Regulatory Assurance Supervisor
R. Speroff, Operating Engineer
R. Stobert, Operating Engineer
- M. Strait, Technical Staff Supervisor
B. Viehl, Modification Design Supervisor
- J. Williams, Operations Support Supervisor
R. Wroblewski, NRC Coordinator
- Indicates persons present at the exit interview on November 29, 1993.
The inspectors also contacted other licensee personnel including members
of the operating, maintenance, security, and engineering staff.
2;
Summary of Operations
Unit 2
Unit 2 power level was administratively derated 1% power due to
feedwater flow nozzle calibration uncertainties.
On October 26, the
reactor was placed in the shutdown mode for a planned 3-day outage to
repair two traversing incore probes.
On October 30, the 2A and lD main steam isolation valves (MSIV) failed a
local leak rate test and required replacement of the seat ring.
The
- outage was extended to facilitate the repair. Also, the licensee
identified an air leak on the 18 MSIV and determined that the
manufacturer had not installed air side seal assemblies in all eight
MSIV actuators.
Unit 2 was made critical on November 28 and synchronized to the grid on
November 29.
3
. \\
Unit 3
Unit 3 operated at power levels up to 99% for most of the period.
The
unit was derated 1% power due to feedwater flow nozzle calibration
uncertainties.
On November 4, the unit began coastdown in preparation
of the March 1994 refueling outage.
No violations or deviations were identified.
3.
Plant Operations (71707, 71710, and 93702)
The inspectors verified that the facility was operated in conformance
with the licenses and regulatory requirements and that the licensee's
management control system was effectively carrying out its
responsibilities for safe operation. During tours of accessible areas
of the plant, the inspectors made note of general plant and equipment
conditions, including control of activities in progress.
On a sampling basis, the inspectors observed control room staffing and
coordination of plant activities, observed operator adherence with
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 .
Accessible portions of ESF systems and associated support components
were inspected to verify operability through ooservation of
instrumentation and proper valve and electrical power alignment.
The
inspectors also visually inspected components for material condition.
Specifically, the following systems were inspected by direct field
observations:
Unit 2
Reactor protection system relays and components
Suppression pool cooling system
2/3 diesel generator
ATWS logic and relay system
Diesel generator
Unit 3
Reactor protection system relays and components
ATWS logic and relay system
Diesel generator
4
Plant Operations Observations
a.
Personnel Errors
A number of significant personnel errors occurred during the
period.
The following provides a summary of the events:
On October 13, an operator failed to wear required
protective clothing for a task in the 34 kv switchyard,
opened the wrong disconnect, and then re-closed the
disconnect without direction.
On October 26, an operator removed Unit 3 offgas filter
train from service instead of Unit 2 train. The operator
failed to self-check.
On October 30, while removing cable from Unit 2 drywell, a
supervisor incorrectly cut a cable for the "B" traversing
incore probe indexer.
On November 8, an electrical mechanic (EM) inadvertently
tripped the 38 fuel pool cooling pump.
The EM was
troubleshooting the 3A pump and worked on the wrong mercury
switch.
On November 9, Unit 3 ECCS jockey pump was found running
with the suction, discharge, and recirculation valves
closed.
The pump had been incorrectly returned to service
earlier in the day. A supervisor had decided not to use the
procedure for this task.
On November 11, a station laborer supervisor directed two
laborers to hang hoses and cable more than 6 feet above
ground.
The required radiological survey was not obtained.
On November 16, instrument maintenance personnel worked on
the incorrect local power range monitor and caused a channel
"A" half scram on Unit 2.
On November 16, while clearing an out-of-service (OOS) for
work on the service air compressors, operators found four
valves open.
As stated on the OOS cards, these valves were
required to be closed.
The initial investigation suggested
that contractors had opened the .valves.
These events demonstrated a continuing problem with licensee
personnel attention to detail and procedural adherence.
The
involvement of first line supervision in three of these events
5
-1
b.
c .
demonstrated that upper management expectations have not reached
the lower levels of supervision. Therefore, first line
supervision was unlikely to set the appropriate standards for the
bargaining unit personnel.
The event involving the high voltage operator in the 34 kV
switchyard showed a disregard for electrical safety as well as a
failure to self check.
The involvement of a trainee in this event
also showed a failure to establish the correct standards for
future operators.
In addition, specific corrective actions for
this event have been slow.
A number of enforcement actions have been taken in the past with.
regards to procedural adherence at Dresden station. The
corrective actions for the most*recent Notice of Violation (50-
237/93020-01) have not yet had sufficient time to be implemented.
Therefore, the above personnel errors are considered further
examples of this violation.
Observations During Unit 2 Shutdown and Startup
The inspectors monitored activities of control room operators and
other operations support personnel during the Unit 2 shutdown on
October 25 and startup on November 28.
Management expectations,
with one exception, were clearly communicated to the operating
crews prior to both activities. The operators were attentive to
the panels and all observed activities were conducted in
accordance with plant procedures.
Discrepancies such as
intermediate range monitor 14 problems were identified and
resolved promptly.
The startup activities were conservatively
controlled with the nuclear engineers and the nuclear station
operators communicating effectively. The pre-job briefing by the
nuclear engineers and the shift control room engineer (SCRE) was
complete, with opportunity for input and questions from personnel.
The inspectors raised a question of senior reactor operator (SRO)
involvement during reactor startup at the beginning of 1993.
Licensee management stated a SRO should devote a majority of
oversight to the startup (Inspection Report 50-237/92036) and the
inspectors considered the lack of management direction to the
operating crews to be a weakness.
On November 28 during rod
withdrawal to criticality, there was no direct involvement by a
SRO.
Both the shift engineer and the SCRE periodically monitored
the startup activities. There was no formal communications to the
SROs on the status of the startup from either the nuclear
engineers or the nuclear station operators.
The level of
involvement of the SROs in reactor startups remained a weakness
and is considered an Inspector Followup Item (50-237/93029-
0l(DRP)).
Operator Response to Unit 3 Electro-Hydraulic Control Problems
6
d.
e.
On October 27, the operators received an electro-hydraulic control
electrical malfunction annunciator and initiated a work request.
The instrument maintenance foreman observed the 24 Vdc power
supply to the turbine supervisory controls was at 22 Vdc.
On
October 28, the foreman noted that the voltage had decreased below
20 Vdc.
The operating engineer immediately authorized a power
reduction to 40% power to prevent a potential reactor trip from a
turbine trip. The inspectors observed the power reduction and
verified the operators were aware of the potential reactor trip
condition.
The inspectors had no concerns.
Operations Involvement in Bus 29 Maintenance Work
On November 10, the inspectors observed operations involvement
with the safety related Bus 29 maintenance troubleshooting.
The
troubleshooting activities rendered several safety related systems
inoperable: high pressure coolant injection, one train of core
spray and low pressure coolant injection, Unit 2 diesel generator
cooling water, and Unit 2/3 diesel continuous lubrication pumps.
The licensee installed a temporary alteration to maintain
operability of the Unit 2/3 diesel generator continuous
lubrication pumps through a Unit 3 motor control center.
The
inspectors verified equipment status, compliance with technical
specifications, system lineups, and equipment tagouts.
No
problems were identified. The heightened level of awareness
meeting for restoration of equipment was very good and resulted in
good communication and coordination between all departments.
The
operations foreman identified a potential concern with breaker
operability and halted further work until the concern was
resolved.
The inspectors had no concerns.
Unit 2 Drywell Closeout
The inspectors accompanied licensee personnel on a Unit 2 drywell
closeout inspection.
The operations department improved in the
ability of finding debris than previous closeouts.
However, the
cleanliness standards for the drywell were lower than the
remainder of the plant; there were still many minor discrepancies.
The operations personnel removed significant quantities of duct
tape from the drywell.
This represented a weakness in the foreign
material exclusion program.
Improving drywell cleanliness with
due consideration for ALARA concerns is a challenge for the
licensee.
The inspectors identified two disconnected ventilation duct
supports in the drywell. This issue is considered an Unresolved
Item pending review of the licensee's evaluation (Unresolved Item
50-237/93029-02(DRP)).
Several examples of a previous violation for failure to follow
procedures were identified.
One inspector followup item was identified
concerning SRO involvement in reactor startup activities.
One
7
4.
unresolved item was identified regarding disconnected drywell
ventilation duct supports.
Monthly Maintenance and Surveillance (62703 and 61726)
Station maintenance and surveillance activities were observed and/or
reviewed to verify compliance with approved procedures, regulatory
guides, and industry codes or standards, and in conformance with
technical specifications (TS).
The following items were considered during this review: approvals were
obtained prior to initiating maintenance work or surveillance testing
and operability requirements were met during such activities, functional
testing and calibrations were performed prior to declaring 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.
The inspectors witnessed portions of the following maintenance
activities:
Unit 2
Troubleshooting of drywell equipment drain sump
Troubleshooting of Bus 29 to motor control centers 29-2 and 4
Repair of 28 control rod drive (CRD) motor
Replacement of 28.circulating water pump motor
Installation of reactor vessel level indication system (RVLIS)
modification
Replacement of service air compressor
Main steam isolation valves refurbishment
Replacement of 2A Reactor recirculation pump lower guide bearing
HPCI turning gear engagement mechanism modification
2/3 Diesel generator 18-month inspection
Unit 3
Installation of 250 Vdc balance-of-plant battery
Installation of fire protection system upgrade
Installation of non-outage piping for RVLIS modification
Installation of station blackout diesels and auxiliary equipment
3A CRD pump reducing gear rebuild
38 Circulating water pump
The inspectors also witnessed sections of the following test activities:
Unit 2
SP 91-10-134 Triennial Fire Main Yard Loop Flow Test
SP 93-3-32 Differential Pressure Testing of MO 2-1501-138
SP 93-3-101 Differential Pressure Testing of MO 2-1501-208
8
DIS 0700-08 Rod Block Monitor Calibration and Functional Test
DIS 1400-06 Core Spray Flow Transmitter Calibration
DOS 0250-02 Closure Timing and Exercising of Main Steam Isolation Valves
DOS 1400-01 Core Spray System Valve Operability Test
DOS 1400-02 Core Spray System Full Flow Test
DOS 1500-06 Low Pressure Coolant Injection System Full Flow Test
DOS 2300-03 High Pressure Coolant Injection System Full Flow Test
Unit 3
DIS 0500-10 Scram Discharge Volume Level Instrumentation Functional Test
and Calibration
DOS 0250-06 ADS Acoustic Monitor Surveillance
DOS 1400-01 Core Spray Pump Test with Torus Available
DOS 1400-05 Core Spray Valve Operability Test
DOS 1500-02 CCSW In-Service Pump Test
DOS 1500-03 CCSW Pump Test
DOS 1500-05 LPCI System Quarterly Flow Rate Test
DOS 1500-10 LPCI Quarterly In-Service Pump Test
Maintenance and Surveillance Observations
a.
Seal Assembly Missing from Main Steam Isolation Valve Actuator
On November 8, a maintenance foreman discovered an air leak on
Unit 2 lA and 28 main steam isolation valve (MSIV) actuators.
The
leakage was past the weep hole on the air side of the operator.
Upon disassembly, the licensee determined the air side seal
assembly had not been installed by the manufacturer, Miller Fluid
Power.
The licensee had ordered 17 actuators in 1991.
Eight of
these were installed in Unit 2 and five were installed in Unit 3
during previous refueling outages.
The licensee replaced the seal
assemblies on Unit 2 MSIVs during the recent forced outage.
The
licensee performed an engineering evaluation and concluded Unit 3
MSIVs were operable. Contingency actions included: raising the
minimum drywell pneumatic system pressure and revising operator
procedures to ensure operability during worst case accident
conditions.
The five Unit 3 actuators will be repaired during the
March 1994 refueling outage.
The inspectors had no concerns with
the operability evaluation.
The licensee's preliminary investigation indicated that the
actuators were designed by Commonwealth Edison Company and built
The double seal was designed in 1982;
however, appropriate design diagrams were not revised.
The root
cause for the missing seal assemblies and corrective actions are
considered an Unresolved Item (50-237/93029-03(DRP)) pending
review of the licensee's investigation .
9
. .
b .
c.
Maintenance Backlog
The maintenance staff has completed a review of the work request
backlog of currently available corrective maintenance items.
The
review showed some weaknesses in the work control and maintenance
programs:
Low priority work requests had the same average age as
higher priority work.
Although the total number of work requests had decreased,
the number of outstanding safety related work requests
continued to increase.
The systems with the largest number of outstanding work requests
were radwaste, ventilation, and some Unit 2 safety related and
important to safety systems. This was a concern because Unit 2
recently completed a major maintenance outage.
One example of failure to complete safety related work in a timely
manner was a work request on Unit 2 diesel generator.
Work
request 016676 involved two loose bolts on the diesel, was written
on March 5, 1993.
As of November 24, this item was not yet
scheduled for work.
Although the diesel generator remained
operable, this did not meet management's expectations for timely
corrective action.
The timeliness of maintenance activities will
be reviewed further in future inspections.
Replacement of Traversing Incore Probes
The inspectors observed the replacement of the traversing incore
probe detector tubing and the recovery of detector probes.
The
work was performed in accordance with WR 022322.
The pre-job
briefing was excellent.
Both health physics support and ALARA
planning considered various contingencies and precautions
associated with the evolution.
In addition, the instrument
maintenance staff performing the evolution was well coordinated,
enthusiastic, and precise.
No violations or deviations were identified.
One unresolved item was
identified regarding MSIV seal assemblies.
5.
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 s_urveillances;
observing on-going maintenance work and troubleshooting; and reviewing
deviation investigations and root cause determinations .
10
6 *
RVLIS Modification in Response to Bulletin 93-03
NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel
Water Level Instrumentation in Boiling Water Reactors," was issued on
May 28, 1993.
The bulletin alerted licensees of potential reactor water
level indication errors during normal depressurization.
The licensee's
immediate corrective actions were reviewed and were discussed in
Inspection Report 50-237/93017(DRP).
The long term corrective actions involved a modification to provide
continuous backfill through the instrument lines using control rod drive
(CRD) water.
Due to the system configuration, the licensee determined
the modification created an unreviewed safety question, in that, the
probability of a loss of coolant accident increased.
An inadvertent
closure of the reference leg root valve would cause the CRD water to
pressurize the instrument line and cause all relief valves to open.
The
licensee planned to implement administrative controls to prevent root
valve manipulation.
However, after further review by NRR, the licensee
was not granted permission to implement the modification.
The licensee
was reviewing possible design changes and planned to resubmit a proposed
design by early 1994.
No violations or deviations were identified.
Plant Support (71707 and 93702)
The inspectors evaluated the involvement of support organizations in
assuring safe and effective plant operation.
Specific areas included:
Radiation Protection Controls
The inspectors verified workers were following health physics
procedures and randomly examined radiation protection
instrumentation for operability and calibration.
An example of
failure to follow radiation protection procedures was discussed in
paragraph 3a.
Security
The inspectors monitored the licensee's security program to ensure
that observed actions were being implemented according to the
approved security plan.
No discrepancies were identified.
The inspectors verified the operational readiness of the control
room technical support center and operation support center.
Non-
routine events were reviewed to ensure proper classification and
appropriate emergency management involvement .
11
7.
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 material.
Posting Notice of Violation
On October 18, the licensee received a Notice of Violation, included in
Inspection Report 50-237/93022(DRSS), for a lack of procedures for
control of contaminated material. This Notice involving radiological
working conditions was not posted within 2 working days as required by
10 CFR 19.11. This Notice was not posted until October 26.
Failure to
post a Notice of Violation involving radiological working conditions
within the required period was a Violation of 10 CFR 19.11 (50-
237/93029-04).
One violation of 10 CFR 19.11 was identified.
Safety Assessment and Quality Verification (SAQV) (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 plant staff, review of
deviation reports, and root cause evaluation reports.
SAOV Related Events
a.
Problem Identification Form (PIFl Review
The inspectors performed a review of the Integrated Reporting
Program, including approximately 20 PIFs, which were originated
during the first 6 months of 1993.
The licensee has commenced
trending causal factors; however, this information has not yet
been incorporated into the corrective action program.
In some
cases, the inspectors observed delays or omissions in submitting
PIFs.
Several weaknesses were observed from the sample of PIFs:
PIF 2-201-93-509 was written to document an adverse trend in
missed NRC commitments.
This PIF was closed by
incorporating it into another PIF, one which addressed some
specific service water system commitments.
The second PIF
did not address the generic concerns raised by the original
PIF .
12
b *
PIF 2-200-93-033 involved problems with using correct
procedure revisions and had an original due date of
February 26, 1993. This PIF due date had been revised seven
times and had a final due date of November 25.
On November 8, an electrical maintenance mechanic
inadvertently tripped the 38 fuel pool cooling pump.
An
entry in the Unit 3 operator logbook stated a PIF would be
written.
However, as of November 24, a PIF had not been
generated. After inspectors' prompting, the licensee
initiated a PIF for the event and a second PIF for the
failure to write a PIF initially.
An operator wrote a PIF on a Unit 3 green backlit
annunciator in October; however, the PIF was not tracked by
the integrated reporting system.
Regulatory assurance
personnel were unaware of the issue.
The operator initiated
another PIF for the concern.
A PIF was also generated to
determine why the original PIF was not included in the
system.
In October a radiation protection technician wrote a number
of PIFs.
These PIFs were not submitted to event screening
for 3 weeks.
Review of Safety Quality Verification Audit
The inspectors reviewed the safety quality verification (SQV)
audit, "License/Technical Specification Compliance and Corrective
Actions," conducted between July 7 and 19, 1993.
The audit
involved a team of five individuals and included conduct of
operations, technical specification interpretations, use of
temporary alterations, equipment status, procedural compliance,
effectiveness of corrective actions for NRC commitments, INPO
issues and corrective action requests (CARs), and corrective
actions for the September 1992 rod mispositioning event.
The inspectors observed the following:
A CAR was written on temporary alterations not reflected in
critical control room drawings.
The lack of critical
control room drawings control was identified by the NRC in
April 1993.
The licensee's corrective actions addressed
design control records, but did not consider temporary
alterations.
The effectiveness of the previous corrective
actions was not evaluated.
The audit did not identify problems with the corrective
actions taken for September 1992 rod mispositioning event.
During initial license examinations, NRC operator licensing
13
'
"
8.
examiners identified problems with job performance measures
on this issue.
The team observed only four surveillances in progress and
did not identify procedural adherence problems.
The team
reviewed 51 completed surveillances and identified
administrative related problems.
Only two equipment operators were observed during the
conduct of operations review.
The inspectors discussed the findings with the SQV supervisor.
The structure of the SQV audits has been modified to allow
auditors flexibility in performing audit activities.
Additionally, the audit periodicity was reduced from 3 months to 6
weeks.
The SQV department was also reorganized and increased by
three auditors.
The inspectors will review the effectiveness of
these changes in future inspections.
No violations or deviations were identified.
Licensee Actions on Previous Inspection Findings (92701 and 92702)
(Closed) Violation (50-237(249)/92009-03(DRP)): Failure to have
procedures to support engineering development and submittal of MDV
thrust calculation. The inspectors reviewed "Guideline for Determining
Target Thrust Windows" which incorporated requirements for documentation
of assumptions when generating target thrust windows.
This item is
closed.
(Closed) Violation (50-237(249)/92009-04CDRP)): Failure to perform an
adequate 10 CFR 50.59 evaluation for the installation of measuring and
test equipment under a temporary alteration.
The inspectors reviewed
Dresden Administrative Procedure (OAP) 10-2, "10 CFR 50.59 Review
Screenings and Safety Evaluations," which required completion of form
10-20, "Design Issues Worksheet" for each safety evaluation prepared.
This item is closed.
(Closed) Violation (50-237(249)/92009-05(DRP)): Failure to complete and
follow administrative procedures.
This item is closed to Violation 50-
237 /93020-01.
(Closed) Violation (50-237(249)/92009-06CDRPll: Failure to document
causes and corrective action taken for MDV non-conformance.
The
inspectors reviewed OAP 2-29, "Integrated Reporting Process" and CECo's
engineering and construction (ENC) integrated reporting program (IRP)
prescribed in ENC-QA-40.
Additionally, the inspectors sampled several
MDV related problem identification forms (PIFs) both from the station
and corporate office. The IRP appeared to provide a mechanism for
tracking issues and a systematic root cause evaluation method for non-
conformance.
This item is closed .
14
. ..
(Closed) Violation (50-237(249)/92009-07(DRP)): Failure to notify the
NRC of conditions that resulted in automatic actuation of engineered
safety feature.
The inspectors reviewed DAP 2-28, "Reportability
Determination and Event Notification 11 and the CECo Reportability
Manual.
This item is closed.
(Closed) Unresolved Item (237/90016-03(DRS); 249/90015-03(DRS)):
Neutron flux monitoring instrumentation did not meet Regulatory Guide
(RG) 1.97, Category 1 requirements. The Office of Nuclear Reactor
Regulation (NRR) completed an evaluation of the boiling water reactor
(BWR) owners group report, NED0-31558, "Position on NRC Regulatory Guide
1.97, Revision 3, Requirements for Post-Accident Neutron Monitoring
System.
11
NRR concluded that for current BWR license holders, the
NED0-31558 criteria was an acceptable alternative to* the recommendations
of RG 1.97.
NRR requested the licensees to review their neutron flux
monitoring instrumentation against the NEDD criteria and submit the
results of that review to NRR.
On August 17, 1993, the licensee
provided some of the requested information; however, the licensee stated
that further review would be required to assess the actions necessary to
comply with those NEDD recommendations not currently addressed by system
design.
The licensee stated that this information would be submitted to
NRR in 90 days.
No further Region III action is required. This item is
closed.
(Closed) Unresolved Item (50-237/91031-03 (DRP)): Division II, 480V
motor control center (MCC) main power feeder cables, located in the
turbine building, were run in Division I cable trays.
During Unit 2
cable walkdowns to resolve degraded voltage concerns, the licensee
identified four safety related cables that did not meet MCC feeder cable
separation requirements.
These cables were classified as balance-of-
plant during original plant construction. Several of the systems fed by
these cables were upgraded from non-safety to safety related after
Dresden received an operating license. The licensee indicated in the
safety assessment that the system upgrades were for future maintenance
and procurement purposes.
The licensee analyzed the potential failure mechanisms for each of the
identified cables.
The analysis included seismic, high energy line
break, internal and external missiles, and fire.
The licensee
determined that the most probable failure mechanism would be a fire.
The fire scenario was analyzed in the Dresden Appendix R Safe Shutdown
Report.
For the cables of concern and the fire areas they were located
in, systems and components from the opposite unit were available to
achieve and maintain safe shutdown.
Procedures were in place at the
time of discovery to mitigate this event.
The licensee has re-routed
the affected cables and now meets the divisional separation
requirements.
Unit 3 MCC safeguards cables were also walked down.
Two
cables were identified with the balance-of-plant segregation code.
However, divisional separation requirements were satisfied. This item
is closed .
15
. .
'
(Closed) Unresolved Item (50-237/92020-07 (DRP)): Apparent Rounds
Falsification. This item has been resolved through generic
communication to the industry. This item is closed.
(Closed) Unresolved Item (50-237/92026-03(DRP)): Loss of CCSW train
separation.
This issue was discussed in previous Inspection Reports
(50-237/93011, 93020, and 93024) and was the subject of Violation (50-
237/93024-03(DRP)).
This item is closed.
(Open) Inspector Followup Item (50-237/92005-01 (DRP)): Extended out-of-
service periods.
The operations department identified those components
with extended out-of-service periods.
System engineers were to review
these for possible modifications or other resolutions. This review did
not occur.
This item remains open.
(Closed) Inspector Followup Item (237/92010-0l(DRP)): Failure to perform
a 10 CFR 50.59 safety evaluation associated with the installation and
use of a portable containment air sample pump.
The inspectors reviewed
the licensee's procedure revisions and the rebaselining of the FSAR
section 5.2.2. This item is closed.
(Closed) Inspector Followup Item (249/92010-02(DRP)): Completion of
licensee initiatives to ensure against radioactive releases when using
the isolation condenser for extended time periods without offsite power.
The licensee's corrective actions included the installation of redundant
diesel driven clean demineralized water makeup pumps to supply makeup to
the isolation condenser shell side. These corrective actions were
either completed or planned for completion at the next refueling cycle.
This item is closed.
(Closed) Inspector Followup Item (50-237/92014-02(DRP)): Licensee
initiatives to improve performance and reduce engineered safety features
actuations associated with the reactor water cleanup (RWCU) system.
The
licensee performed various maintenance activities during last Unit 2
refuel outage.
The licensee planned to perform similar activities
during the next Unit 3 refuel outage. This item is closed.
(Closed) Inspector Followup Item (50-237(249)/92021-02(DRS)): Review of
modification package to eliminate noise in the neutron monitoring
system.
Modification package Pl2-2-92-726 was reviewed and found
acceptable. This item is closed.
(Closed) Inspector Followup Item (50-237/92036-03(DRP)): Elevated high
pressure coolant injection (HPCI) discharge piping temperature due to
reactor feedwater system back-leakage.
One outstanding corrective
action is the installation of a permanent temperature monitor on the
HPCI discharge piping.
The modification will be implemented during a
non-outage period in 1994.
This item is closed .
16
9.
(Closed) Inspector Followup Item (50-237/92036-04(DRP)): Reactor
automatic shutdown following condensate/condensate booster pump failure
and subsequent loss of offsite power.
The significant corrective
actions were completed.
This item is closed.
(Closed) Inspector Followup Item (50-237/92036-0SCDRP)): Manual reactor
shutdown due to feedwater oscillations during surveillance testing.
The
licensee implemented a modification which moved Unit 2 reactor vessel
level reference piping outside containment.
The Unit 3 modification is
scheduled for the next refuel outage.
This item is closed.
(Open) Inspector Followup Item (237/93017-03CDRP)): Incorrect positions
for Unit 2 drywell cooler dampers.
During the Unit 2 forced outage, the
licensee determined the 2D drywell fan was running backward.
The
discrepancy was not identified during the drywell ventilation walkdown
in May 1993.
The licensee's investigation into the root cause will be
evaluated with this inspector followup item.
This item remains open.
(Closed) Inspector Followup Item (50-237/93020-04(DRP)): 10 CFR 21
applicability for failed check valves.
The licensee submitted a 10 CFR
21 report on October 22, 1993.
The licensee identified ten C&S dual
disk check valves with viton seats. One has been replaced and the
remaining will be replaced when suitable valves are available. This
item is closed.
No deviations or violations were identified .
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
recurrence had been accomplished in accordance with technical
specifications.
(Closed) LER 237/89027. Revision 1: Postulated LPCI Swing Bus Loss
Resulting From Diesel Generator Voltage Regulator Failure Due to Design
Deficiency.
The licensee installed under/over voltage and frequency
protective relays. This LER is closed.
(Closed) LER 237/89029, Revision 4: Elevated HPCI Discharge Piping
Temperature.
This event was discussed in Inspector Followup Item (50-
237 /92036-03(DRP)).
This LER is closed.
(Closed) LER 237/91005, Revision 1: Orderly Shutdown Due to Leakage
Through Primary Containment Isolation Valves AO 2-220-44 and AO 2-220-
45.
This LER is closed.
17
. . .
(Closed) LER 237/91029: Main Steam Line Radiation Monitor Setpoints
Found Non-Conservative.
The remaining open action item involved a
possible technical specification change.
The licensee determined the
change was not necessary. This item is closed.
(Closed) LER 237/91-042, Revisions 0 and 1: Cable Separation Not Met.
This LER addresses the same topic as Unresolved Item 50-237/91031-
03(DRP), which was discussed earlier in this report. This LER is
closed.
(Closed) LER 237/92019: Containment Spray Interlock Momentarily
Inoperable Due to Surveillance Testing With the Unit 2/3 Diesel
Generator Inoperable.
The inspectors reviewed the procedure revisions
and the licensed operator training. This LER is closed.
(Closed) LER 237/92020: Unit 2 Reactor Vessel Exceeded Design Basis Due
to Non-Conservative Pressure/Temperature Curves.
This event was the
subject of a previous violation (50-237/92033-0l(DRP)).
This LER is
closed.
(Closed) LER 237/92032: Control Room HVAC Booster Fan Available Voltage
Less Than Required Minimum at Second Level Degraded Voltage Setting.
The licensee replaced the existing 100 volt-ampere (VA) control power
transformer with a 300 VA control power transformer and continued to
perform DOS 5750-1, "Control Room Standby HVAC Air Filtration* Unit
Surveillance," to verify operability. This LER is closed .
(Closed) LER 237/92037: Unit Emergency Bus Undervoltage Relay
Susceptible to Setpoint Drift Due to Design Deficiency.
Immediate
corrective action by the licensee was to modify the Asea Brown Boveri
Type 27N relays by removing the components susceptible to setpoint drift
and loss of time delay function due to elevated radiation dose during a
postulated loss of coolant accident and significant fuel failure.
The
time delay function was transferred to an agastat relay within the
system logic. Corrective actions to permanently resolve this issue will
be completed during the upcoming Unit 2 (D2R14) and Unit 3 (D3Rl3)
refuel outages. This LER is closed.
(Closed) LER 237/93007: ESF Actuation (ADS) Due to Simultaneous
Performance of LPCI and ADS Surveillance. The licensee revised the
necessary procedures to preclude running LPCI and/or Core Spray pumps
and testing ADS logic simultaneously. This LER is closed.
(Closed) LER 237/93011. Revision 00 and 01: Emergency Source of Water to
Containment Cooling Service Water (CCSW) Keep Fill Valved Out.
The
licensee added additional piping from the unit emergency diesel
generators to the respective CCSW systems during the spring of 1993.
This LER is closed .
18
. . .
r
{Closed) LER 237/93021: Defective Check Valves Due to Improper Bonding
of the Viton Seat.
The licensee determined the viton seat adhesive was
applied improperly.
The licensee completed an operability evaluation
and implemented contingency actions until the valves are replaced.
a
10 CFR 21 report was submitted on October 22, 1993.
This LER is closed.
{Closed) LER 249/91013: 250 Vdc Battery Discharge Voltage Decreased
Below Design Basis Limit Due to Inaccurate Vendor Data.
A Part 21
notification concerning the deviation was made in accordance with the
requirement of 10 CFR, Part 21, Sections 21.1.(B), 21.3.a(3), and
21.3.b(4). This LER is closed.
(Closed) LER 249/92012. Revisions 00. 01 and LER 249/92015, Revisions
00, 01, 02, and 03: Low Pressure Coolant Injection (LPCI) Minimum Flaw*
Valve Automatic Closure During Valve Operability Test. Certain volumes
of LPCI piping were de-pressurized during valve manipulation.
When
these volumes were re-pressurized, an instantaneous high flow was sensed
by the flow transmitter resulting in the closure of the LPCI minimum
flow valve.
The licensee revised Dresden Operating Surveillance (DOP)
1500-1, 1600-3, and 1600-5 to caution operation personnel. This LER is
closed.
(Closed) LER 249/93007: Reactor Scram on Reactor High Pressure, Possible
High Pressure Turbine Damage.
This LER is closed.
(Closed) LER 249/93014: Reactor Scram Due to Main Condenser Low Vacuum.
DOP 4400-8, "Circulating Water Flow Reversal," was revised which
established a minimum condenser vacuum on the low hood of 26 inches of
mercury and 27 inches of mercury on the high hood.
Additionally, a
caution was added to warn the operators that reversing condenser flow a
second time when no equipment problems are present should not be
attempted.
This LER is closed.
No violations or deviations were identified.
10.
Management Meetings (30703)
SALP 12 Meeting
On October 19, a public meeting was held in the Training Center at the
Dresden Station to discuss the Systematic Assessment of Licensee
Performance (SALP) 12 report for the Dresden Station. The list of
attendees is included in Attachment A.
Mr. John B. Martin presented
each section and encouraged discussion with the Commonwealth Edison
staff. Mr. Martin concluded the meeting by challenging management to
continue efforts to improve plant material condition, further develop
partnership between management and union personnel, focus on the 1994
goals, develop teamwork between departments, and improve leadership
behaviors .
19
The licensee provided a response to the SALP 12 report dated
November 10.
The NRC will continue to discuss planned improvements at
future management meetings.
No violations or deviations were identified.
11.
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.
Inspector followup item disclosed during this inspection is discussed in
paragraph 3.b.
12.
Unresolved Items
13.
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of
noncompliance or deviations.
Two unresolved items disclosed during this
inspection are discussed in paragraphs 3.e and 4.a.
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 November 29, 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.
Attachment:
Dresden SALP Meeting Attendees
20
Attachment A
OCTOBER 19. 1993 DRESDEN STATION SALP MEETING ATTENDEES
NRC ATTENDEES
J. Martin, Regional Administrator, Region III
W. Axelson, Director, Division of Radiation Safety and Safeguards
D. Chyu, Reactor Engineer, DRP
.
P. Hiland, Chief, Reactor Projects Section lB, Riil
C. Holden, SALP Program Manager, NRR
M. Kunowski, Senior Radiation Specialist
M. Leach, Senior Resident Inspector, Dresden
T. Martin, Deputy Director, Division of Reactor Projects, RIII
M. Peck, Resident Inspector, Dresden
J. Stang, Project Manager, NRR
A. Stone, Resident Inspector, Dresden
J. Zwolinski, Assistant Director for Region III, NRR
ILLINOIS DEPARTMENT OF NUCLEAR SAFETY
R. Schultz, Section Chief
C. Settles, Resident Engineer Trainee
R. Zuffa, Dresden Resident Engineer, IDNS
LICENSEE ATTENDEES
C. Reed, Senior Vice President of Energy Facilities
M. Wallace, Vice President and Chief Nuclear Officer
A. D'Antonio. Site Quality Verification Supervisor
L. Del George, Vice President, Nuclear Operations Support.
R. Flahive, Technical Services Superintendent
L. Jordan, Health Physics Supervisor
J. Kotowski, Operations Manager
M. Lyster, Site Vice President
H. Massin, Site Engineering and Construction Manager
T. O'Connor, Maintenance Superintendent
R. Radtke, Director, Support Services
R. Robey, Director, Site Quality Verification
J. Shields, Regulatory Assurance Supervisor
G. Spedl, Manager, Dresden Station
MEMBER OF THE PUBLIC
D. Kaufman, Chairman, Grundy County Board