ML17180B154
| ML17180B154 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/14/1995 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17180B153 | List: |
| References | |
| 50-237-95-07-EC, 50-237-95-7-EC, 50-249-95-07, 50-249-95-7, EA-95-030, EA-95-30, NUDOCS 9504070190 | |
| Download: ML17180B154 (25) | |
See also: IR 05000237/1995007
Text
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-237/249-95007{DRP)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
Opus West I II
1400 Opus*Place
Downers Grove, IL 60515
Facility Name:
Dresden Nuclear Power Station, Units 2 and 3
Meeting Conducted:
March 9, 1995
Meeting Location:
NRC Region III Office
801 Warrenville Road
Lisle, Illinois
Type of Meeting:
Enforcement Conference
Inspection Conducted:
Dresden Site
Morris, Illinois
January 25 to February 10, 1995
Inspectors:
C. J. Phillips.
Approved By:
A. M. Stone
~2//Lf
Patrick L. Hiland, Chief
Reactor Projects Section lB
Meeting Summary
Enforcement Conference on March 9, 1995 {Report No. 50-237/249-95007(DRP))
Areas Discussed:
Three apparent violations identified during a special safety
inspection were discussed, along with the corrective actions taken or planned
by the licensee.
The enforcement options pertaining to the apparent
violations were also discussed with the licensee. The apparent violations
concerned: (1) improper control of primary containment integrity, (2)
recirculation pump restart in violation of technical specification
requirements, and (3) inadequate instructions and/or failure to follow
procedures associated with the above evolutions .
9504070190 950315
ADOCK 05000237
G
DETAILS
1.
Persons Present at Conference
Commonwealth Edison Company
T Joyce, Site Vice President, Dresden
E. Eenigenburg, Unit 3 Station Manager, Dresden
J. Kotowski, Unit 2 Operations Manager
G. Tietz, Unit 3 Operations Manager
W. Sheldon, Unit 2 Maintenance Superintendent
S. Barrett, Radiation Protection Manager
U. S. Nuclear Regulatory Commission
H. Miller, Deputy Regional Administrator, Region III
T. Martin, Deputy Director, Reactor Projects, Region III
B. Clayton, Acting Deputy Director, Reactor Projects, Region III
P. Hiland, Chief, Reactor Projects, Section 18, Region III
M. Jordan, Chief, Operator Licensing, Section 1, Region III
R. DeFayette, Director, Enforcement and Investigation Coordination
Staff, Region III
M. Leach, Senior Resident Inspector, Dresden, Region III
C. Phillips, Resident Inspector, Dresden, Region III
R. Capra, Director, Project Directorate III-2, NRR
J. Stang, Project Manager, Project Directorate III-2, NRR
M. Satorius, Enforcement Specialist, OE
2.
Enforcement Conference
An Enforcement Conference was held in the Region III office on March 9,
1995.
The conference was conducted to address three apparent
violations:
(1) improper control of primary containment integrity,
(2) recirculation pump restart in violation of technical specification
requirements, and (3) inadequate instructions and/or failure to follow
procedures associated with the above evolutions.
The inspection
findings were documented in Inspection Report 50-237/249-95004(DRP)
which was transmitted to the licensee by letter dated February 17, 1995.
The purpose of the conference was to: (1) discuss the apparent
violations, causes, and the licensee's corrective actions; (2) determine
if there were any escalating or mitigating factors; (3) obtain
information which would help determine the appropriate enforcement
action; and (4) provide any additional information developed subsequent
to the inspection noted above.
Regional representatives presented a brief description of the pertinent
facts that led to the apparent violations, the regulatory requirements,
and potential safety significance of the event.
Licensee
representatives provided a description of the sequence of events, the
apparent violations, the safety significance, root cause analysis, and
corrective actions .
2
At the conclusion of the conference, the licensee representatives were
informed that they *would be notified in the near future of final
enforcement actions.
Attachments:
1.
NRC Presentation
2.
ComEd Presentation
3
.-*
. .. . :. '
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U.S. NUCLEAR REGULATORY
COMMISSION
REGION III
ENFORCEMENT CONFERENCE
COMMONWEALTH EDISON
DRESDEN STATION *
- MARCH 9, 1995
10:00 .A.M. (CST)
REPORT NUMBER 50~237 /249-95004
. *EA NUMBER 95~030
NRCREGIONID
801 WARRENVILLE ROAD
LISLE, ILLINOIS
+..i:@ U!S i _Q.UZQ(i_
& J t . ! UWA&i< ii
ME
-*
DRESDEN STATION
ENFORCEMENT CONFERENCE AGENDA
MARCH 9, 1995
INTRODUCTION AND MEETING PURPOSE -
H. Clayton, Acting Deputy Director, DRP
. ENFORCEMENT PROCESS
R. DeFayette, Director EICS
APPARENT VIOLATIONS SUMMARY
M. Leach, Senior Resident Inspector
LICENSEE PRESENTATION AND DISCUSSION
. CLOSING REMARKS
H. Miller, Deputy Regional Administrator
. * ....
' ** .. **
\\: ...
' .
I '. .
I
.
i
. *
.
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THREE APPARENT VIOLATIONS
1. T.S. 3m 7 .A.2,
Primary Containment Integrity
-
- January
6
primary
co*nt.aiiFHmierart::
boundaries were broken iin err-arr* fair
testing
Required LLRT was not performed .
Identified *through site engineering
.
review
February 3 LLRT result could not b*e
quantified
I*.
I
- .
- .-
'*
. -*~ :* .. , ...
..
2. T.S. 3/4.6.H.5,
. . :
~
Recirculation Pump Restart Limitations
28 recirculation pump tripped due to
maintenance error
Temperature differential between
reactor vessel stea*m space coolant
and* the bottom head drain coolant
was great~r than 145 ° F
. Operator workarounds - The bottom
heaq drain was plugged for years
.Engineering and management were
not consulted
Non-conservative decision making
by operating crew
. .. :*. '.
.*
.
.--~------ .*............
.
aas
3. 1 OCFR 50, Appendix B, Criterion V,
Instructions, Procedures and Drawings
- Instructions
not*
ade*quate
for
locating .and. removing access plate
outside the primary containment
boundary
Procedure inadequate and/or lack of
adherence to isolate seal purge flow
to the idle recirculatio.n loop *
Recirculation
pymp. restart
procedure.* did
~,not .. match
the
.,_
requirement of *pl~'nt r.s .
,*:
.
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tXSSUSM&J&Q_
_ t4UZM.a;awmws:.a. a a z
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c. *a* - _a
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- -
DRESDEN UNITS 2 & 3
INSPECTION REPORT 50-237/249-95004
ENFORCEMENT BOARD
FEBRUARY 16, 1995
ITEM 1 - CONTAINMENT BREECH
ITEM 2 - RECIRC PUMP START
1.
ITEM 1 -
CONTAINMENT INTEGRITY BREECH*
Facility:
Unit(s):
Docket No(s):
License No(s):
Insp. Dates:
Lead Inspector:
ESCALATED ENFORCEMENT
BOARD PACKAGE
DRESDEN
Unit 3
50-249
DPR 25
February 6 - 10, 1995
Charles Philli:gs
BRIEF SUMMARY OF EVENT(S)
January . 6,
1995, an operator performed Dresden Operating
surveillance (DOS) 1600-13 on Unit 3. The surveillance was an
operational verification of a
check valve in the reactor
building to torus vacuum breaker. line.
- *
The surveillance was performed incorrectly.
The operator
opened an access plate to the check valve hinge pin and broke
the pr1mary containment boundary.
The correct method was to
open
a
different access plate outside the
containment
boundary.
The valve was returned to service without a type B
LLRT.
Engineering had been performing this surveillance for the last
two years.
When it was reviewed by the IST coordinator, on
February 3, 1995, Operations was questioned as to how the
surveillance was performed.
When it was determined. on Feb. 3 ,fi' *that the procedure was
performed incorrectly a LLRT was performed on both the 31A and
31B valves.
Both valves failed with indeterminately high
leakage rates~ Sixty percent of La is 488 SCFH.
l ):. fvJI fr-./._ .,() 'f'GScrl!
There was an air operated valve upstream of both these valves.
- The leakage past the AOV was about 2-5 SCFH.
However, this
valve fails open on a loss of instrument air.
Instrument air
at Dresden would be lost within minutes of a loss of offsite
power .
2
DRESDEN CONTAINMENT BREECH
Discussion:
The licensee failed to implement corrective actions to prevent
recurrence of a
problem that resulted in exceeding the
technical specification limits for type
B
& C primary
containment leakage.
On January 6, 1995, operations performed Dresden Operating
Surveillance (DOS) 1600-13, "Suppressi_on Chamber to.Reactor
building Vacuum Breaker Full Stroke Exercise Test" on both 3-
1601-3 lA & B valves.
The operator improperly performed the
surveillance. The operator was required to open an inspection
hatch upstream of the check valve and check it's operation
with a broom handle.
Instead, *the operator performed the
surveillance the way it used to be performed which was to
remove an .access plate for the check valve hinge pin and use
a socket tool to open the valve.
The access plate he opened
was part of the primary containment boundary.
When the
operator reinstalled the.plate, a type B local leak rate test
(LLRT) was not perfor.med on either 31A or 31B.
This was discovered on February 3, 1995, by site engineering.
Engineering had performed this test for Operations for about
two years.
Engineering was aware that the test was due but
had
not
been
contacted.
Engin~ering asked
about the
performance of the test and was told when and how it was
performed.
Engineering performed LLRTs on February 3 whicn
failed.
The
leak rates at both of the flanges were
indeterminately high.
This problem was identified by the licensee in the past.
The
resident inspectors became aware of the problem through a
review of corrective actions in an LER.
The licensee was
previously cited in Inspection Report 94014 for the failure to
conduct Type-B LLRTs.
The past violation required no response
because the licensee had already changed the surveillance
procedure so as not to operate the valve by removing the
access plate that was part of the primary containment
boundary.
History:
Unit, 3
had technically "inoperable" primary containment
isolation boundaries for the majority of the time between 1987
and 1994.
The Unit 3 reactor building to torus
valves (3-1601-31A&B) have flanges that
pins.
These
are
primary
3
vacuum breaker check
cover the valves hinge
containment
boundary
DRESDEN CONTAINMENT BREECH
2.
From
1987 to 1992,
a
surveillance verified the vaives
operability by removing the flange and cycling the valve
quarterly. The flanges were then reinstalled. However, local
leak rate tests were not performed to check the penetrations
as required by 10 CFR 50, Appendix J.
A 1987, on-site review
determined that the flanges were not part of the primary
containment and the surveillance procedure was changed to
remove the_ requirement to perform a LLRT.
A 1989, LLRT of the
3-1601-JlB valve was 159 SCFH.
An investigation revealed that
the 1987 on-site review decision was incorrect.
A corrective
action from that investigation was to evaluate using a
downstream access port to cycle the valve.
The surveillance procedure was not changed to use the
downstream access port until October 1992 and, no change was
made to the existing procedure to perf arm LLRTs after the
flange was removed and replaced.
However, even after the
procedure was changed, no effort was made to LLRT the flanges
until the as-found tests were performed for 3DR13 in March
1994.
The as-found for the March 1994, LLRT on 3-1601-31B was
257 SCFH.
This in combination with other type B and C leakage
exceeded the technical specification limit of 488 SCFH (0.6
La) .
[x]
A Notice of Violation (without "boilerplate"), including
recommended severity levels, is attached.
[ x J
Thi.s
NOV has been reviewed by the Branch Chief or
Di vision Director and each violation includes appropriate
specificity including how and when the requirement was
violated.
3.
[x]
Copies of the appropriate technical specifications or
license conditions are attached.
4.
Identify the enforcement policy supplement(s) that best fits
the violation(s):
Supplement 1.C.1. (b)
&
Supplement 1.C.2. (a)
ITEM 1 & ITEM 2 =Supplement 1.C.7
4
DRESDEN CONTAINMENT BREECH
5.
What is the apparent root cause of the problem?
(NOTE:
If
the root cause is programmatic maintenance deficiencies,
escalation of any civil penalty will be considered.)
Poor corrective actions requiring procedural changes.
6.
What actions have been taken by the licensee to correct the
specific violation(s)?
When the problem was found, the licensee entered Technical
Specification 3.0.A, which required the unit to be in hot shut
down in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
When the flanges failed, the unit began a
shutdown.
When the flanges were repaired and LLRT's were
passed, the shutdown ceased.
7.
Briefly state the message that should be given to the licensee
through this enforcement action.
corrective actions at the station are poor.
between departments are poor *
5
communications
- -
DRESDEN CONTAINMENT BREECH
8.
Factual information related to civil penalty ESCALATION or
MITIGATION factors:
a.
IDENTIFICATION AND REPORTING:
Violations were identified by licensee; an SEC engineer
identified the problem during an engineering review of
the surveillance.
Reported? Yes
(If so, LER #)
ENS Call
Report required?
Yes*
b.
CORRECTIVE ACTION TO PREVENT RECURRENCE;
UNKNOWN
c.
PAST PERFORMANCE:
(For
two
years or covering last two
inspections,
whichever is greater.)
Violation 50-249/94014-0S(DRP)
10 CFR so, Appendix J,Section III, D.2.
Pertinent SALP category and rating for last two SALP
periods.
Operations 3,3
Engineering 3,3.
d.
PRIOR NOTICE OF SIMILAR EVENTS:
Did the licensee have prior knowledge of this problem as
result
of
review
of
specific
NRC
or
industry
notification,
and fail to take effective preventive
steps?
Yes
Between 1987 and 1994 the lisensee was unable to
take effective corrective action.
6
DRESDEN CONTAINMENT BREECH
e.
MULTIPLE OCCURRENCES:
Were
multiple
examples
of
a
particular violation
identified during this inspection?
Yes
If yes, identify the violation and number of examples:
Both the 31A and 31B valves were found outside
limits.
f.
DURATION:
g.
How long did the violation(s) exist? 28 days
When did the licensee become aware of the violation(s)?
February 3, 1995
- Should the licensee * have been aware of the problem
earlier?
No
SAFETY SIGNIFICANCE:
The upstream containment isolation valves are designed to
fail open on a loss of instrument air.
On a loss of
offsite power the instrument air system would have
depressurized in minutes.
In an accident scenario with
a loss of offsite power primary containment integrity
(0.6 La) would have been lost.
7
,*~SUE 1 - TECH. SPE *. 3.7 .A.2.b.(2}(a)
- 3. 7 LIMITING CONDITION FOR OPERATION
(Cont 1d.)
(1) An overall
integrated
leakage rate
for Type A
tests of:
(a) L
less
tR~n or
equal t.o 75
percent of
La.
(b) Lt less
tri~n or
equal to 75
percent of
L .
(2) (a) A combined
leakage rate
of less than
or equal to
60 percent
of L for*
a 1i ~es table
and isola-
tion valves
subject to.
Type B and
C tests ex-
cept for
isolation
valves.
3/4.7-6
DRESDEN II
OPR-19
Amendment No. 122
4.7 SURVEILLANCE REQUIREMENTS
(Cont 1d.)
.*
DRESDEN CONTAINMENT BREECH
ITEM 1 NOTICE OF VIOLATION
1.
Technical Specification 3.7.A.2.b.(2). (a) states in part that
when primary containment integrity is required,
primary
containment leakage rates shall be limited to .*. a combined
leakage rate of less .than or equal to 60 percent of La for all
.u,1"'~testable penetrations and isolations valves subject to Type B
n
and c tests.
- ,J ,_
t"
....
.
,. ,..((.,1-r'°r
,.!"*contrary to the above on January 6, . 1995,
the primary
V".
1
~ ti/' containment boundaries on valves 3-1601-31A & B were broken,
ile~ ~*
0
and when tes~ed on F~bruary 3,, 1995, the leakage rates were
r ~*
found to be indeterminately high.
These results exceeded 60
f *
percent of La for Type B and C leakage* on Unit 3.
2.
3 *.
10 CFR 50, Appendix B, criterion XVI, states in part that
measures shall be established to assure that conditions
adverse to quality are promptly identified and corrected. In
the case of signi'ficant conditions adverse to quality, the
measures shall assure that the cause of the condition is
. determined and corrective action taken to preclude repetition.
Contrary to the above, on January 6, 1995, a flange that was
part of the primary containment boundary was removed and
reinstalled on valves 3.-1601-31 A & B but no Type B local leak
rate test was performed.
On August 24, 1994, the licensee was
issued violation 50-249/94014-05 for failing to perforni. Type
B local leak rate tests on the same containment boundary
Dresden Operating Surveillance (DOS). 1600-13, "Suppression
Chamber to Reactor building Vacuum Breaker Full Stroke
Exercise Test," ~evision 7, required that the 3-1601-31A & B
valves be checked by removing an access plate outside the
primary containment boundary and cycling the valve with an
extension tool.
Contrary to the above,
on January 6, 1995,
DOS 1600-13,
Revision 7, was inadequate in that the operator followed the
procedure as written and tested the 3-1601-31A&B valves by
opening an access plate that was part of the primary
containment boundary.
8
ITEM 2
~ RECIRC PUMP START
Facility:
ESCALATED ENFORCEMENT
BOARD QUESTIONNAIRE *
Dresden
Unit(s):
Unit 2
Docket No(s):
50-237
License No(s):
Insp. Dates:
Jan. 23 - Feb. 10, 1995
Lead Inspector:
BRIEF SUMMARY OF EVENT(S)
2B recirculation pump tripped because instrument maintenance
technicians
worked
on
the
wrong
motor
generator
set
temperature control valve.
Operations realized that the procedural requirement to have
less than a 145 degree temperature differential between the
bottom head thermal couple and the reactor steam space prior
to pump restart could not be met.
Operations
realized
that
the
technical
specification
requirement to have less than a. 145 degree temperature
differential between the bottom head drain line coolant and
the steam space could not be met.
Pump restart procedure temperature requirements differed from
the technical specificat~on requirements.
Shift personnel decided that using different temperature
indications met the intent of the technical specifications.
A site quality verification inspector was present in the
control room and questioned the operators as to whether their
course of action was in compliance with the procedure prior to
the pump restart.
Seal purge flow to the 2B recirculation pump was never
secured.
The pump trip procedure required isolating seal
purge flow if the pump was not restarted within an hour.
The pump was restarted 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 22 minutes after the trip
using temperature indications that were not listed in either
the procedure or the technical specification.
Operations
1
RECIRC PUMP START
management, station management, and engineering advice and
consent were not sought or obtained prior to the pump start.
In the last 12 months the NRC has identified 19 examples of
the licensee failing to follow procedure and two examples of
inadequate procedures.
Eight of these examples were within
the operations department and five of those examples were by
licensed operators. The NOV's are att.ached at the end of this
package.
Discussion:
On
January
10,
1995,
instrument maintenance
was
performin9
troubleshooting on the 2A recirculation pump motor generator set
temperature control valve (TCV) controller.
The technicians went
to the wrong controller. The technicians closed the TCV for the 2B
recirculation pump motor generator.
The motor generator (MG)
tripped on high temperature resulting in the loss of the 2B
recirculation pump.
The cause of the recirculation pump trip was quickly identified as
the maintenance error on the TCV.
The operators were preparing to
start the 2B recirculation pump when it was discovered that the
pump start procedure could not be met. Dresden Operating Procedure
(DOP)
0202-01,
"Unit 2 Reactor Recir,-culation System startup, II
Revision 14, stated that prior to sta~ting a second pump verify the
following temperature limitations, "If reactor pressure is greater
than or equal to 25 psig,
then reactor vessel bottom head
thermocouple temperature is within 145 degrees of the steam space
temperature."
Technical specification 3.6.H.5 states, "An idle
rec.:j.rculation pump . shall not be started * unless the temperature
differential between the reactor vessel steam space coolant and the
bottom head drain line is less than or equal to 145 degrees."
The
temperature differences between the bottom head drain line and
steam space, and the bottom head and the steam space were both
greater than 145 degrees.
However, the temperature differences
were greater than 145 degrees while the pumps were still operating.
Thus the restart of the pump was technically not possible via the
technical specifications or.the procedure.
The shift determined that alternate temperature indications could
be used to meet the technical specification and procedural intent.
A site quality verification inspector present in the control room
pointed out the procedural problem to the operating crew prior to
the pump start.
The operators interviewed all stated that the
problem had been discussed and the course of action agreed upon.
However, there appeared to be a difference between what the reactor
operator understood and what the unit supervisor understood.
The
unit operators log stated that the temperature difference between
the bottom head and the active recirculation loop discharge
2
RECIRC PUMP START
temperature was used and was less that 145 degrees.
The shift
managers log stated that the temperature difference between the
running recirculation pump discharge and the steam space was used.
The
shift managers
log
also
stated that this
temperature
differential met the intent of the technical specification. *
The shift did not isolate seal purge flow to the 2B recirculation
pump.
The pump trip procedure stated that * if the pump was not
planned to be restarted within an hour than isolate the seal purge
flow.
The purpose for isolating seal purge flow was that the loop
cooled down at about 22 degrees per hour with seal purge flow on
and also may not be seen by the operator because the loop has spots
below the thermocouple.
In fact, the idle loop recirculation
discharge temperature did take an eight degree step change downward
when the pump was started.
However, the loop to loop differential
temperature was still within technical specification requirements.
The
licensee
has
demonstrated
significant
problems
in the
preparation and adherence to procedures.
Technical Specification
Amendment
127
which
introduced
the
requirement
to
verify
differential temperatures from the drain line coolant to the steam
space became effective on July 17, 1994.
The procedure revision
that was
intended to
implement the technical specification
requirements did not agree with the technical *specifications and
were not made until November 3, 1994.
In addition, there was no
documentation that the operations department was ever trained on
the procedure change.
Over the past 12 months the NRC_identified
19
examples
of failing to
follow
procedure
and
inadequate
procedures.
2.
[x)
A Notice of Violation (without "boilerplate"), including
recommended severity levels, is attached.
[ x)
This NOV has been reviewed by the Branch Chief or
Di vision Director and each violation includes appropriate
specificity including how and when the requirement was
violated.
3.
[x]
Copies of the appropriate. technical specifications or
license conditions are attached.
4.
Identify the enforcement policy supplement(s) that best fits
the violation(s):
Supplement I.C.7
3
RECIRC PUMP START
5.
What.is the apparent root cause of the problem?
operators have a
long standing belief that technical and
procedural problems can be worked aro2und.
station has an ineffective training program.
6.
What actions have been taken by the licensee to correct the
specific violation(s)?
Operations manager talked to the unit supervisor and the
.shift manager about procedural adherence the week of
January 10.
Operations
procedural
discussions.
managers
began
talking
to
adherence
during
weekly
crews
about
operations
The shift operations supervisor held a meeting with the
shift managers
on January 25
on human performance
problems and used the 2B MG set problem as an example.
Shift operations supervisor sent a message via electronic
mail to all shift managers that discussed the technical
specifications as a matter of law. It was re-emphasized
that 100 percent procedure adherence is expected.
The Vice President of BWRs held a lengthy discussion with
upper station management that detailed his disappointment
with the way the event was reviewed.
station management designated a full root cause analysis
team on January 28.
All-station meetings were conducted on February 8 by the
station managers concerning the importance of procedural
adherence.
SEE LER 50-237-95003-00
7.
Briefly state the message that should be given to the licensee
through this enforcement action.
Procedural and technical specification adherence is required
for safe operation of the plant.
4
...
RECIRC PUMP START
8.
Factual information related to civil penalty ESCALATION or
MITIGATION factors:
a.
IDENTIFICATION AND REPORTING:
Violation (s) identified by licensee or NRC? Licensee/NRC
The licensee identified after the fact that the procedure
and technical specifications were not met.
Reported? Yes
(If so, LER #) 50-249-95003-00
Report required? Yes
b.
CORRECTIVE ACTION TO PREVENT RECURRENCE;
SEE LER
c.
PAST PERFORMANCE:
Numerous
issued last 12 months for procedural
adherence problems.
See HANDOUT.
Identify pertinent SALP category and rating for last two
SALP periods.
Operations 3,3
d.
PRIOR NOTICE OF SIMILAR EVENTS:
Did the licensee have prior knowledge of this problem as
result
of
review
of
specific
NRC
or
industry
notification, and fail to take effective preventive
steps?
If yes, describe:
e.
MULTIPLE OCCURRENCES:
f.
DURATION:
g.
SAFETY SIGNIFICANCE:
5
ISSUE 2 - TECH. SPE *. 3.6.H.5
LIMITING CONDITION FOR OPERATION
(Cont'd.)
g.
The MAPLHGR Operating
Limit shall be reduced
by the appropriate
multiplicative factor
from the Core Operating
Limits Report
(Specification 3.5.I).
!ff. concurrently, one
Au omatic Pressure
Relief Subsystem relief
valve is out-of-service,
the MAPLHGR Operating
Limit shall be reduced
by the appropriate
multiplicative factor
from the Core Operating
Limits Report.
4.
With no reactor coolant system
recirculation loops in
operation~ reduce core thermal
power to 1ess than 25% of rated
within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and place the
unit in hot shutdown within the
following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
5.
Idle Recirculation Loop Startup
An idle recirculation pump shall
not be started unless the
temperature differential between
the reactor vessel steam space
coolant and the bottom heaa
drain line coolant is less than
a.
equal to 145°F*, .and:
When both pumps have been
idle, unless the temperature
differential between the
reactor coolant within the
idle loop to be started up
and the coolant in the
less than or equal to S0°F,
or
b.
When only one loop has been
idle, unless the temperature
differential between the
reactor coolant within the
idle and operating
recirculation loops is less
than or equal to 50°F and
the speed of the operating
pump is less than or equal
to 43% of rated pump speed.
I. Snubbers (Shock Suppressors}
DRESDEN.
Amendment No .. 127
4.6
SURVEILLANCE REQUIREMENT
(Cont'd.)
5.
Idle Recirculation Loop Startup
The temperature differentials and flow
rates shall be determined to be within
the limits within 15 minutes prior to
startup of an idle recirculation loop.
I. Snubbers (Shock Suppressors)
The following surveillance
requirements apply to safety related
- Only applicable with reactor pressure vessel steam space pressure~ 25 psig.
3/4.6-16
RECIRC PUMP START
1.
ISSUE 2 -
,:,*I).!' Je* //"'"'"'-'- ~n1 }-
Technical Specification ~
states in part that the
temperature differential eween the reactor vessel steam
space and the bottom head drain line coolant must be verified
to be less than 145 degrees within 15 minutes prior to
starting a recirculation pump in an idle loop.
Contrary to the
above,
on
January
10,
1995,
the
2B
recirculation pump was started in an idle loop when the bottom
head coolant drain line temperature was not within 145 degrees
of the reactor vessel steam space temperature.
2.
Technical Specification 6. 2 .A.1 states in part that written *
procedures shall be established, implemented and maintained
covering applicable procedures recommended in Appendix A of
Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory
Guide
1. 33,
Appendix A,
Section 4. a
recommends startup
procedures for the recirculating system.
a.
Technical Sp.ecif ication~f:1:~r ~~res in part that the
temperature differential between the reactor vessel steam
space and the bottom head drain iine cooiant [EMPHASIS
ADDED]
must be verified to be less than 145 degrees
within 15 minutes prior to starting a recirculation pump
in an idle loop.
Dresden Operating Procedure
(DOP)
0202-01,
"Unit
2
Reactor Recirculation System startup," Revision 14, step
G.10
states
in
part that
if starting
a
second
recirculation pump, then within 15 minutes of starting
the pump verify . that the bottom head thermocouple
temperature is within 145 degrees of the steam space
temperature.
Contrary to the above, when the 2B recirculation* pump was
started on January 10, 1995, the procedure did not meet
the requirements of the technical specification.
b.
Dresden Operating Abnormal (DOA) 0202-01, "Recirculation
Pump Trip -.One or Both Pumps," Revision 10, step D.12
~ 0
states, "If idle loop starts are not~ithin one
~
t d
,L/hour, then isolate seal purge flow to~le loop per
r
DOP 0202-11."
.
.
- V"'
.
,L'} I
I
.
~JG
~
Contrary to the* above, on January 10, 1995, the 2B
recirculation pump tripped and was restarted 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and
22 minutes later without securing seal purge flow.
,VP~ IJ- I Y ,,Jr.,,...-
.
,
~*
6
'.*
ISSUE 1 & 2 NOTICE OF VIOLATION
Technical Specification 6.2.A.1 states in part that written
procedures shall
be established,
implemented
and maintained
covering applicable procedures
recommended in Appendix A of
Regulatory Guide 1. 33, Revision 2, February 1978. Regulatory Guide
1.33, Appendix A, Section 4.a recommends startup procedures for the
recirculating system.
a.
Technical Specification 4. 6. H. 5 states in part that the
temperature differential between the reactor vessel steam
space and the bottom head drain line coolant must be verified
to be less* than 145 degrees within 15 minutes prior to
starting a recirculation pump in an idle loop.
Dresden Operating Procedure (DOP)
0202-01, "Unit 2 Reactor
Recirculation system startup," Revision 14, step G.10 states
in .part that if starting a second recirculation pump then
within 15 minutes of starting the pump verify that the bottom
head thermocouple temperature is within 145 degrees of the
steam space temperature.
Contrary to the above, when the 2B recirculation pump was
started on January 10, 1995, the procedure did not meet the
requirements of the technical specification.
b.
Dresden Operating Abnormal (DOA) 0202-01, "Recirculation Pump
Trip - One or Both Pumps," Revision 10, step D.12 states, "If
idle loop starts are not planned within one hour, then isolate
seal purge flow to the idle loop per DOP 0202-11. 11
Contrary to the
above,
on
January
10,
1995,
the
2B
recirculation pump tripped and was restarted 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 22
minutes later without securing seal purge flow.
c.
Dresden Operating Surveillance (DOS)
1600-13, "Suppression
Chamber to Reactor building Vacuum Breaker Full Stroke
Exercise Test," Revision 7, required that the 3-1601-31A & B
valve~ are checked by removing an access plate -0utside the
primary containment boundary and cycling the valve with an
e~tension tool.
Contrary to the above,
on January 6, 1995,
DOS 1600-13,
Revision 7, was inadequate in that the operator followed the
proc
rit~.§n, and tested the 3-1601-31A&B valves :Oy
opening an access !plate that was part of the primary
6ontainment boundary.
\\
1