ML17194A303

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IE Insp Repts 50-010/81-14,50-237/81-28 & 50-249/81-21 on 810905-1002.Noncompliance Noted:Three Lifted Leads in Control Room Panels Tagged But Not Entered in Jumper & Lifted Lead Log
ML17194A303
Person / Time
Site: Dresden, Indian Point  
Issue date: 11/24/1981
From: Jordan M, Reimann F, Tongue T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17194A301 List:
References
50-010-81-14, 50-10-81-14, 50-237-81-28, 50-249-81-21, IEB-80-11, IEB-80-16, NUDOCS 8112080258
Download: ML17194A303 (11)


See also: IR 05000010/1981014

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-010/81-14; 50-237/81-28; 50-249/81-21

Docket No.50-010, 50-237, 50-249

License No. DPR-02, DPR-19, DPR-25

Licensee:

Commonwealth Edison Company

Post Office Box 767

Chicago, IL

60690

Facility Name:

Dresden Nuclear Power Station,.Units 1, 2, & 3

Inspection At:

Dresden Site, Morris, IL

Inspection Conducted:

September 5 through October 2, 1981

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Inspectors:

T. M. Tonguer

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Approved By,:

F. 'w*.'* Rf!*tni:ahn, *Acting Chief,

Reactor Projects Section lC

Inspection Summary

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Inspection on September 5 - October 2, 1981 (Report No. 50-10/81-14;

50-237/81-28; 50-249/81-21)

Areas Inspected:

Routine unannounced resident inspection of Operational

Safety Verification, Monthly Maintenance Observation, Monthly Surveillance

  • Observation, IE Bulletin Followup, Immediate Action Letter Followup, Plant

Trips, Inspection during long-term shutdown, GSEP Drill and concerns of

ex-security guards.

The *inspection included a total of 101 inspector-hours

onsite by two NRC inspectors including 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> onsite during off-shifts.

Results:

Of the nine areas inspected, there were no items of noncompliance

in eight areas, and one item of noncompliance (Failure to follow jumper and

lifted lead procedure, Paragraph 2) in one area.

8112080258 811124

PDR ADOCK 05000010

Q

PDR

DETAILS

1.

Persons Contacted

i*D. Scott, Station Superintendent

  • R. Ragan, Operations Assistant Superintendent
  • J. Eenigenburg, Maintenance Assistant Superintendent
  • D. Farrar, Administrative Services and Support Assistant Superintendent

J. Brunner, Technical Staff Supervisor

J. Wujciga, Unit 1 Operating Engineer

J. Almer, Unit 2 Operating Engineer

M. Wright, Unit 3 Operating Engineer

J. Doyle, Q.C. Supervisor

D. Adam, Waste Systems Engineer

i*G. Myrick, Rad-Chem Supervisor

B. Saunders, Station Security Administrator

B. Zank, Training Supervisor

  • E. Wilmer, Q.A. Coordinator

The inspector also talked with and interviewed several other licensee

employees, including members of the technical and engineering staffs,

reactor and auxiliary operators, shift engineers and foremen, electri-

cal, mechanical and instrument personnel, and contract security per-

sonnel.

  • Denotes those attending one or more exit interviews conducted on

September 25 and October 2, 1981, and informally on several occasions

throughout the report period.

2.

Operational Safety Verification

a.

The inspector observed control room operations, reviewed appli~

able logs and conducted discussions with control room operators

during the period of September 5 through October 2, 1981.

The

inspector verified the operability of selected emergency systems,

reviewed tagout records and verified proper return to service of

affected components.

Tours of Units 2 and 3 reactor buildings

and turbine buildings were conducted to observe plant equipment

conditions, including potential fire hazards, fluid leaks, and

excessive vibrations and to verify that maintenance requests had

been initiated for equipment in need of maintenance.

The inspector

by observation and direct interview verified that the physical

security plan was being implemented in accordance with the station

security plan.

b.

The inspector observed plant housekeeping/cleanliness conditions

and verified implementation of radiation protection controls.

During the period of September 5 through October 2, 1981, the

inspector walked down the accessible portions of the Unit 2 and

3, HPCI, LPCI, Core Spray, and Standby Liquid Control systems

to verify operability.

The inspector also witnessed portions

- 2 -

  • f.

of the radioactive waste system controls associated with radwaste

shipments and barreling.

These reviews and observations were conducted to verify that

facility operations were in conformance with the requirements

established under technical specifications, 10 CFR, and adminis-

trative procedures.

c.

During routine inspection of Control Room activities on

September 25, 1981, the SRI conducted a verification of the

Units 2 and 3 Jumper and and Lifted Lead Logs.

A sampling of

the log entries compared to the actual jumpers and lifted leads

were not correct.

The SRI noted several lifted leads or lifted

connectors with caution cards and one set of thermocouple leads

lifted in association with a tagged jumper, but with no identi-

fication.

The items found were as listed below:

Caution Tag Number

II-20-81

III-12-79

III-25-81

Information

Charcoal Absorber Radiation Monitor, lifted

lead

Jumper between Recirculation loop tempera-

ture monitors OK. Lifted leads for the

affected a thermocouple had no identifica-

tion or caution card - corrected immediately

by the SCRE.

Charcoal Absorber Radiation Monitors, lifted

lead.

Items II-20-81; and III-25-81 were found in the respective unit

Caution Card Log vice the Jumper and Lifted Lead Log as required.

This is in noncompliance with the Commonwealth Edison "Quality

Assurance Program for Nuclear Generating Stations" Topical Report,

CE-1-A, January 1976, Revision 18, July 21, 1981, Section 5,

Instructions Procedures, and Drawings which states, in part,

"Generating Station operations, procedures and instructions will

be provided by the Station Superintendent and will be included

in the Station Procedures Manual in a timely manner consistent

with NRC license requirements for administering the policies,

procedures and instructions from the time that the operating

license is issued through the life of the station.

These pro-

cedures and instructions include:

Administrative Procedures, ... "

Dresden Administrative Procedure DAP7-4, Revision 5, May 1981,

states "This procedure provides guidance to assure that adequate

control of the use of jumpers or lifted leads is maintained."

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d.

Contrary to the above, the items identified by the SRI were not

listed in the Jumper and Lifted Lead Log as required.

Indepen-

dent interviews by the shift foreman, shift engineer and SCRE/STA

confirmed the findings of the SRI.

This is an item of noncompliance (50-237/81-28-01, 50-249/81-21-01).

During this report period, licensee personnel conducted a review

of the applicable Caution Card Logs to identify other items that

should be in the Jumper and Lifted Lead Log.

There were several

additional items found in addition to those found by the SRI.

These items were listed in the Jumper and Lifted Lead Log as

required and verified by the SRI.

In addition to those items listed in the citation, the Resident*

Inspector identified at least 12 leads in the panels with open

lugs and no identification tags.

These were found to be leads

left ~rom equipment removed for unit modifications, and were no

longer of use.

This was brought to the attention of station

management personnel who agreed to have the lugs removed and

the ends of the electrical leads taped as with past modifica-

tions.

This will prevent confusing the leads with those that

are intended for reuse.

This is an open inspection item

(50-237/81-28-02; 50-249/81-21-02).

During the inspection, Commonwealth Edison Company personnel

identified and logged several discrepancies found with an outage

on the 3A Reactor Feed Pump (RFP).

After the outage tags had

been placed and maintenance began, it was found that the suction

valve was not fully shut although tagged as shut, the discharge

valve was open with the breaker racked out and identified as sh~t,

and no tag was available on the discharge valve control switch

in the control room.

The licensee found that the maintenance

supervisor had not conducted a verification walk down of the

outage prior to commencing work on the affected components.

The Senior Resident Inspector expressed concern regarding this

situation as it has recently resulted in other citations for

similar problems with outage tag-outs, (see items 50-237/81-13-01;

50-249/81-02-01).

If it were a safety-related outage it is

recognized that the unit shift foreman would have conducted a

walkdown verification of the outage prior to the start of work.

In this occurrence, a minimum of three individuals including

one from management, apparently missed the discrepancies.

It

is recognized that this is a nonsafety related system, and

therefore noncitable, however, it is further evidence of a

breakd0wn in managerial control of the outage (tag-out) system.

The licensee has subsequently conducted two meetings regarding

this matter.

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In exit interviews, the licensee was requested to make a state-

ment regarding actions* taken or planned to reinforce the apparent

breakdown in management control of the outages.

This is an open

inspection item, (50-237/81-28-03, 50-249/81-21-03).

e;

While reviewing changes to plant procedures, the resident inspector

noted that the procedure for adjusting the APRM gains had been

changed due to a modification of the Technical Specification (T.S.).

This change was to increase the APRM gains by the ratio MFLPD/FRP

in lieu of adjusting the APRM flux scram trip setting by the ratio

of FRP/MFLPD, which accomplished the same degree of protection.

However, a review of the T.S. change indicated that the change had

been authorized for Unit 2 and had not been authorized for Unit 3.

The procedure was issued applicable to both Units 2 and 3.

This

was brought to the attention of the Nuclear Engineer staff who

issued a temporary procedure change restricting the new change for

APRM gains adjusted to Unit 2 only.

Discussions with Commonwealth

Edison Company management indicated that they could not explain

why the change was issued for both plants when only Unit 2 T.S. 's

had been authorized to change.

The licensee thought that both

T.S.'s had been authorized the change.

There appears to be a

breakdown in the review committee's program, a noncompliance

was not warranted as this appears to be an isolated occurrence.

The Resident Inspector also noted that when a temporary procedure

change is issued, the parent procedure is not *annotated as to

the existance of a temporary procedure change.

All temporary

procedures for operations are stored in a single notebook on the

Shift Control Room Engineer's (SCRE) desk.

However, when an

operator attempts to use an issued procedure, he may be unaware

of an existing temporary procedure, unless he goes through the

lists of existing temporary procedures for each procedure he

uses.

During an event, the operator may not have time to

research the existance of a temporary procedure change for each

procedure used.

The licensee was made aware of the inspector's concern ~nd is

in the process of developing and implementing a change whereby

a procedure that is the subject of a temporary change is identi-

fied to the operators by some conspicuous means.

This is an open inspection item, (50-10/81-14-01, 50-237/81-28-04,

50-249/81-21-04).

One item of noncompliance was identified.

3.

Monthly Maintenance Observation

Station maintenance activities of safety related systems and compon-

ents listed below were observed/reviewed to ascertain that they were

conducted in accordance with approved procedures, regulatory guides,

industry codes or standards, and in conformance with technical speci-

fications.

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The following items were considered during this review:

the limiting

conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedu*res and were

inspected as applicable; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by quali-

fied personnel; parts and materials used were properly certified; radio-

logical safety controls were implemented; and, fire pr~vention controls

were implemented.

Work requests were reviewed to determine status of outstanding jobs

and to assure that priority is assigned to safety related equipment

maintenance which may affect system performance.

The following maintenance activities were observed/reviewed:

Unit 2

HPCI Steam Line Repair

2A-CCSW Pump Repair

Unit 3

HPCI Steam Line Repair

Units 2 and 3

Diesel Generator*

Reactor Building Crane Repair

Following completion of maintenance on the Unit 2/3 Diesel Generator

an~ Unit 2 HPCI system, the inspector verified that these systems had

been returned to service properly.

No items of noncompliance were identified.

4.

Monthly Surveillance Observation

The inspector observed technical specifications required surveillance

testing on the Unit 2 HPCI pump operability, and verified that testing

was performed in accordance with adequate procedures, that test instru-

mentation was calibrated, that limiting conditions for operation were

met, that removal and restoration of the affected components were

accomplished, that test results conformed with technical specifications

and procedure requirements and were reviewed by personnel other than

the individual directing the test, and that any deficiencies identified

during the testing were properly reviewed and resol~ed by appropriate

management personnel.

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The inspector also witnessed portions bf the following test activities:

Unit 2 HPCI valve operability, Main Steam Radiation Isolation and Scram

Calibration; Unit 3 Low Water Scram and Low Low Water Isolation Surveill-

ance, LPCI valve operability, LPAM Calibration, HPCI valve operability.

No items of noncompliance were identified.

5.

IE Bulletin Followup

For the IE Bulletins listed below the inspector verified that the

written response was within the time period stated in the bulletin,

that the written response included the information required to be

reported, that the written response included adequate corrective

action commitments based on information presentation in the bulle-

tin and the licensee's response, that licensee management forwarded

copies of the written response to the appropriate onsite management

representatives, that information discussed in the licensee's written

response was accurate, and that corrective action taken by the licensee

was as described in the written response.

lE Bulletin 80-11

IE Bulletin 80-16

Masonry Wall Design (Open)

Potential Misapplication of Rosemont,

Inc., Models 1151 and 1152 Pressure

Transmitters with either "A" or "D"

Codes (Closed)

Regarding IE Bulletin 80-11, the Senior Resident Inspector received

a combined Headquarters/Region III request as follows:

a.

Was the study completed to determine the seismic operability of

masonry walls in the plant completed?

b.

If any of the walls did not meet the operability for a seismic

event, was a 10 CFR 50.59 review conducted to determine if those

walls that would affect safety related equipment?

c.

If safety related equipment would be affected, was a Technical

Specification Licensee Event Report (LER) submitted?

By letter dated November 6, 1980, the licensee committed to have a

restart analysis complete by July 1981, and a complete analysis and

report by November, 1981.

Through interviews with licensee personnel, the inspector found that

the analysis and review are in progress.

The inspector informed the

licensee of the questions of the IE-HQ/RIII request.

This bulletin

remains open.

No items of noncompliance were identified.

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6.

Immediate Action Letter (IAL)

The licensee received an IAL dated September 4, 1981, discussed in

the previous inspection (50-237/81-24; 50-249/81-18).

The IAL

set forth items whereby the Unit 2 HPCI steamline would be analyzed

for damage, examined by nondestructive testing, repairs made to

damaged items (pipe hangers and whip restraints) and a long-term

study performed to determine the cause.

During the tests for damage

to the HPCI steamline, several inches of water were detected at a

horizontal portion that passes over the T~rus. This was corrected

by installation of a drain line that diverts the con'densate from

t.he low point of accumulation to a point down stream in the steam-

line for final drainage via the designed drain system.

Initial

studies by a licensee engineering contractor (E.D.S., Inc) and

by Commonwealth Edison Company, found no damage to the steamline.

After pipe hanger and whip restraint repair, and with the concurr-

ance of Region III, the HPCI steamline was unisolated, heated up

and tested by ultrasonic (UT) Technique for water accumulation with

negative results.

The HPCI was declared operable following a sat-

isfactory surveillance test.*

A similar condition was found on the Unit 3 HPCI steamline via UT

where up to four inches of water were detected and minor or question-

able whip restraint damage was found.

The HPCI was declared inoper-

able, a steam line drain similar to Unit 2 installed, and the HPCI

was tested and returned to service in about 5 days .

. Presently, the licensee is visually examining the HPCI steam lines on

both units for abnormal indications anytime the HPCI is operated and

whenever the HPCI steam line containment isolation valves are operated.

This will remain in effect until Commonwealth Edison Company provides

the detailed study of the cause and effects of this event, which is

being conducted by E.D.S., Inc.

The study results and followup action

with Region III concurrence are open inspection items (50-237/81-28-05,

50-249/81-21-05).

.

7.

Plant Trips

Following the plant trips on Unit 2 on September 21 and September 23,

1981, and Unit 3 on September 26, 1981, the inspector ascertained the

status of the react6r and safety systems by observation of control room

indicators and discussions with licensee personnel concerning plant

parameters, emergency system status and reactor coolant chemistry.

The

inspector verified the establishment of proper communications and re-

viewed the corrective actions taken by the licensee.

All systems responded as expected, and the plants were returned to

operation as follows:

Unit 2 on September 23, 1981, and Unit 3 on

September 26, 1981.

  • No items of noncompliance were identified.*

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8.

Inspection During Long Term Shutdown

The inspector observed control room operations, reviewed applicable

logs and conducted discussions with control room operators during

the period of September 5 through October 2, 1981.

The inspector

verified that the surveillance tests required during the shutdown

were accomplished, reviewed tagout records, and verified applicabil-

ity of containment integrety.

Tours of Unit 1 accessible areas,

including exterior areas were made to make independent assessments

of equipment conditions, plant conditions, radiological controls,

safety, and adherence to regulatory requirements and to verify that

maintenance requests had been initiated for equipment in need of

maintenance.

The inspector observed plant housekeeping/cleanliness

conditions, including potential fire hazards, and verified implementa-

tion of radiation protection controls.

The inspector by observation

and direct interview verified that the physical security plan was

being implemented in accordance with the station security plan.

No items of noncompliance were identified.

9. *

GSEP Drill

On September 23, 1981, the licensee conducted an assembly drill that

was observed by several Region III inspectors.

On September 30, 1981,

the licensee conducted its full scale annual GSEP drill in conjunction

with their Chicago Response Center, State of Illinois, and Grundy

County.

During the drill on September 30, 1981, the Resident Inspectors

observed activities in the Control Room and T.S.C. The response of

licensee personnel in the Control Room was excellent.

The SCRE/STA,

Operating Engineer, Shift Engineer, and Shift Foreman, and other

personnel demonstrated good team work in problem solving, respons-

iveness, etc., and recommending corrective actions in anticipation

of subsequent drill events.

If the situation had been an actual

event, they would have taken preventative steps prior to further

degradation of the original event.

The details of the NRC Region III observations will be documented

in IE Inspection Report 50-10/81-13, 50-237/81-26 and 50-249/81-19.

10.

Concerns of Ex-security Guards

On several occasions during the inspection period, the SRI spent

considerable time in telephone discussions with one of several guards

who's employment had been terminated in April, 1981, for failure to

meet firearms qualifications.

Additionally, the SRI received copies

of correspondence that had been sent from another ex-security guard

to several members of the U.S. Congress and copies of the congressmen

responses.

In each case, the ex-guards correspondence expressed

concerns that were found to be inaccurate or dissenting.

These were

or had been reviewed with licensee and NRC information and found that

the licensee and/or the NRC had previously taken appropriate action.

This information was forwarded to Region III Security Inspection Group

for future reference if necessary.

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11.

Meetings, Training and Offsite Activities

The Resident Inspectors attended a Region III "Resident Inspectors

Seminar on September 17 and 18, 1981, in Mishicot, Wisconsin.

12.

Exit Interview

The inspector met with licensee representatives (denoted in Paragraph

1) throughout the month and at the conclusion of the inspection on

October 2, 1981, and summarized the scope and findings of the inspection

activities.

The licensee acknowledged the findings of the inspection.

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Commonwealth Edison Company

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November 24, 1981

in the NRC's Public Document Room.

If the letter or enclosures contain any

information that you or your contractors believe to be exempt from disclosure

und~r 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by

telephone within seven (7) days from the date of this letter of your intention

to file a request for withholding; and (b) submit within twenty-five (25)

days from the date of this letter a written application t6 this office to

withhold such information.

Section 2.790(b)(l) requires that any such appli-

cation must be accompanied by an affidavit executed by the owner of the

information which identifies the document or part sought to be withheld, and

which contains a full statement of the reasons which are the bases for the

claim that the information should be withheld from public disclosure.

This

section further requires the statement to address with specificity the con-

siderations listed in 10 CFR 2.790(b)(4).

The information sought to be

withheld shall be incorporated as far as possible into a separate part of

the affidavit.

If we do not-hear from you in this regard within the speci-

fied periods noted above, a copy of this letter, the enclosures, and your

response to this letter will be placed in the Public Document Room.

-t'!WC.J.

.

We will gladly discuss any questions you have co~f~'.~;/m.ng this inspection.

Enclosures:

1.

Appendix A, Notice

of Violation

2.

Inspection Reports

No. 50-010/81-14, No.*

50-237/81-28 and No.

50-249/81-21

cc w/encls:

Louis 0. DelGeorge

Director of Nuclear

Licensing

D. J. Scott,

Station Superintendent

DMB/Document Control Desk (RIDS)

Resident Inspector, RIII

Mary Jo Murray, Office of

Assistant Attorney General

Sincerely,

<J? .:!. _,(/J"'>-e,-y).-;r_,.,,l-,

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.

R. L. Spessard, Director

Division of Resident and

Project Inspection

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