ML17194A464
| ML17194A464 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/26/1982 |
| From: | Jordan M, Knop R, Robinson D, Tongue T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17194A462 | List: |
| References | |
| 50-010-81-20, 50-10-81-20, 50-237-81-37, 50-249-81-29, NUDOCS 8202160485 | |
| Download: ML17194A464 (9) | |
See also: IR 05000010/1981020
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-010/81-20; 50-237/81-37; 50-249/81-29
Docket Nos,50-010, 50-237, 50-249
Licenses No. DPR-02, DPR-19, DPR-25
Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, IL
60690
Facility Name:
Dresden Nuclear Power Sta.tion, Units 1, 2 and 3
Inspection At:
Dresden Site, Morris, IL
inspection Conducted:
Decembe~ 5-30~ 1981
Inspectors:
.,
I .
. . °'
.... _ r .... " i
- *--'--*-***
T. M. Tongue
. '
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M J. Jordan
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Approved By:
R. C. Knop, Chief
Projects Branch 1
Inspection Summary
- :
. /~ -~
'*
Inspection on December 5-30, 1981 (Reports No.50-10/81-20; 50-237/81-37;
50:-249/81-29)
Areas Inspected:
Routine unannohnced resident inspection of Operation
Safety Verification, Monthly Maintenance Observation, Monthly Surviellance
Observation, Licensee Event Reports Followup, Plant Trips, Inspection during
long term shutdown, Preparation for Refueling, Independent Inipection, Pre-
paration for Guard Force Strike", and Headquarters and Regional Requests.
The inspection involved a total of 93 inspector-hours onsite by three NRC
inspectors including 20 inspector-hours during offshift.
Results:
Of the ten areas inspe~ted, there were no items of noncompliance
in nine areas.
There was one item of noncompliance (Severity Level IV -
Failure to have and to follow adequate procedures - Paragraph 7) in one area .
8202160485 820128
PDR ADOCK 05000010
G
.L
DETAILS
1.
Persons Contacted
Corporate
B. Lee, Jr., Executive Vice President
D. Galle, Operations Manager - Nuclear Stations Division
Station
- 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, QC Supervisor
D. Adam, Waste Systems Engineer
G. Myrick, Rad-Chem Supervisor
B. Saunders, Station Security Administrator
B. Zank, Training Supervisor
E. Wilmer, QA Coordinator
A.S.M.E
H. F. Jackson, ASME N Stamp Survey Team Chairman
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, elec-
trical, mechanical and instrument personnel, and contract security
personnel. .
- Denotes those attending one or more exit interviews conducted on
December 11, December 23, and December 30, 1981.
2.
Management Meeting.
A management me~ting between members of the Region III staff, and
Commonwealth Edison Corporate and Dresden Station staffs to discuss
concerns related to recent events at the Dresden Nuclear Power
Station.
The meeting was held on December 22, 1981, at the NRC,
Region III office in Glen Ellyn, Illinois.
The concerns were generally related to delays in pursuance of the
causes of events, lack of indepth investigation when events occur,
reluctance to declare affected systems inoperable when evidence
clearly indicates operability is unknown, and the need for some
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form of verification that systems are properly returned to service
following maintenance, surviellance, etc.
Each of the concerns will
be treated as an open inspection item.
The meeting also included comments from the security section discus-
sing operational events that occur with no ready explanation, or
non-operational events that occur related to personnel causes with
potential malicious mischief.
When events of this sort occur, the
NRC expects a determination of individual security significance,
plus a review for trends identifiable from a security standpoint.
It is believed that this will require coordination between security
and operations departments.
Examples identified were the recent Unit 3 emergency diesel generator,
emergency fuel cutoff valve found shut and safety related instrument
valves were found in inc.orrect positions.
This matter was discussed
prior to this meeting with CECo corporate security personnel. It was
pointed out that the NRC is also independently reviewing such events
for trends.
This is open inspection item 50-237/81-37-01 and
50-249/81-29-0i.
'
Representatives from the Division of Resident and Projects Inspection
expressed concern that delays in review of events can result in con-
fusing or conflicting information that eventually can compound the
investigation of a problem.
One *recent example cited was the.Unit 2/3
and Unit 3 Emergency Diesel generator cooling water pump problems,
where delays in agressive solution seeking contributed ~o confusing
information and a prolonged NRC investigation.
This .is open inspec":'
tion it~m 50-237/81-37/02 and 50-249/81-29-02.
It was pointed out that licensee investigations of events should be
conducted in sufficient depth to identify generic or related applic-
ability.
An example discussed was the recent Unit 3 scram with a
short period that resulted from an inadvertent control rod double
notch withdrawal.
The investigation addressed only that event; but
should have been expanded .to look at a similar event under different
reactor conditions, e.g., a newer cor~, a more reactive control rod,
and possibly greater than a two notch withdrawal.
This is open
inspection item 50-237/81-37-03 and 50-249/81-29-03.
Another point of concern was ?n apparent reluctance ~r resistance
of licensee.personnel to declare a system inoperable*when evidence
clearly points out that damage has occured to the system or when
there is doubt that the function can meet it's design criteria.
Examples pointed out were the recent events when pipe hangers and
supports were found damaged on the Unit 2 and 3 HPCI steam lines and
the 2B CCSW system, and water was identified in the HPCI steam lines.
This is open inspection item 50-237/81-37-04 and 50-249/81-29-04.
The final item of concern discussed was the need for some means of
verification that a system or component has been properly returned
to service following surviellance or maintenance, etc.
The licensee
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has addressed this matter in the tag out system for safety related
equipment per the T.M.I. Task Action Plan. *However, there is an
apparent need for verification of system changes when the tag out
system is not used such as surviellances.
A recent example is the
instrumentation valves found mispositioned where a verification of
the valve positions following the reference leg back fill could have
prevented the event.
This is open inspection item 50-237/81-37-05
and 50-237/81-29-05.
Following some discussion, the licensee representatives expressed
concern about some of the recent events at Dresden and acknowledged
the concerns of the NRC.
The response to the open items will be reviewed during a future
inspection.
3.
Operational Safety Verification
The inspector observed control room operations, reviewed applicable
logs and conducted discussions with control room operators during the
period of December 5-30, 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 2-3
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 p1an.
The inspector observed plant housekeeping/cleanliness conditions and
verified implementation of radiation protection controls.
During the
period of December 5-30, 1981, the inspector walked down the accessible
portions of the Unit 2 HPCI, 2B. LPCI, 2B Core Spray, Unit 3 HPCI, 3A
LPCI, 3B Core Spray systems to verify operability.
The inspector also
witnessed portions 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 administrative procedures.
No items of noncompliance were identified.
4.
Monthly Maintenance Observation
Station maintenance activities of safety related systems and components
listed below were observed/reviewed to ascertain that they were conducted
in accordance with approved procedures, regulatory guides and industry
codes or standards and in conformance with technical specifications.
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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 procedures and were
inspected as applicable; functional testingand/or calibrations were
performed prior to returning components or systems to service; quality
control records were maintained; activities o/ere accomplished by
qualified personnel; parts and materials used were properli certified;
radiological controls were implemented; and, fire prevention 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 3
3A Standby Liquid Control. Pump
Semi-annual Maintenance *
3B LPCI Heat Exchanger.
No items of noncompliance were identified ..
5.
Monthly Surveillance Observation
The inspector observed technical specifications required surveillance
testing on portions of Unit 2 HPCI Valve Operability and Core.Spray
Operability and verified that testing was performed in accordance with
adequate procedures, that limiting conditions for op~ration were met,
that removal and restoration of the affected components were accom-
plished, that test results conformed with technical specifications
and procedure requirements and were reviewed by personnel other than.
the individual conducting the test, and that any deficiencies
identified during the testing were properly reviewed and resolved
by appropriate management personnel*:
No items of noncompliance were identified.
6.
Licensee Event Reports Followup
The licensee reported finding two safety related pressure switch
isolation valves shut related to low pressure core spray permissive
alarm and isolation condenser initiation on December 14, 1981.
On
,
December 15, 1981, the licensee reported finding a pressure transmitter
(PT) isolation valve shut and it's test connection open, related to the
anticipated transient without Scram (ATWS) system that would have pre-
vented the 2B recirc pump from tripping and one ARI valve would not
have opened if an ATWS event had occuired.
Normal scram functions
were not affected. .All of the valves identified, were on the same
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instrument racks (2202-5&6) and licensee personnel stated that they
believed the valves were left in the wrong position when the reactor
vessel level reference legs were back filled following a scram on
December 13, 1981.
The back fill was done with a modified procedure *that had not received
proper review and approval.
At the request of the NRC, the licensee conducted a check of the
position of all safety related instrument valves and test connections
.on December 16, 1981.
The check of these valves revealed two addi-
tional pressure switches valved out.
One was for the 2B LPCI heat
exchanger differential pressure indication used to minimize a release
of radioactive material from LPCI to theCCSW systems and the other
was a high pressure turbine inlet pressure switch that had no auto-
matic control function.
The cause of these valves being mispositioned
is unknown, however, it is .evident that had a procedure been followed
properly, these valves would not have been mispositioned.
This is not in accordance with Technical Specification 6.2.A requiring
_detailed written procedures including applicable check off lists pre-
pared, approved, and adhered to for instrumentation operation which
could have an affect on the safety of the plant, and for surviellance
and testing requirements.
This is considered noncompliance
(50-237/81-37-06) (50-249/81-29-06).
The licensee reported that the fire deluge system had automatically
activated in the Unit 2 HPCI room on December 23; 1981.
This resulted
in the HPCI being inoperable due to water in the lube oil.
This was
later found to have been caused by welding in the HPCI room that
caused.a smoke detector to activate the deluge system.
During the
process of conducting the required surviellances, the 2B Electromatic
safety/relief valve failed to operate.
This required an orderly
reactor shutdown per Technical Specifications.
The cause of the
Electromatic S/R valve failure was an inadequately suspended wire on
the pilot solenoid junction box that prevented contacts from making
up allowing the solenoid to properly energize.
This problem was
promptly corrected by taping the cable up with other cables.
After
the HPCI oil was changed, the reactor was started up. on December 24,
1981.
During the startup, the HPCI and the 2B S/R valve were tested
satisfactorily.
The licensee also inspected the 2D S/R valve pilot
solenoid and found no problems.
In subsequent discussions-with the-
Ass.istant Superintendent for Maintenance, he committed to have the
remainder of the electromatic S/R valves on Units 2 and 3 inspected
for similar problems.
This is an open inspection item (50-237/81~37-07)
and (50-249/81-29-07).
The licensee will submit appropriate events
reports.
With respect to LER 50-249/81-40/0lT-0~ a regional inspector arrived
onsite on December 2, 1981, in response to the event.
The inspector
noted that no Technical Specifications had been violated and that
the observed notch worths had not exceeded those predicted in the
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CRDA analysis.
From discussions with Tech Staff personnel and the
Nuclear Fuel Services Department, the inspector concluded that the
high control rod notch worths would be expected near the top of the
core at low power, end of life conditions due to insu.f f icient voiding
and excessive fuel depletion in the lower portions of the core.
The
corrective actions proposed by the licensee were addressed in a man-
agement meeting at the Region III office on December 22, 1981.
At
that time the licensee was requested to review its overnotching
history and take appropriate measures to prevent recurrence.
Since
the timing and contact condition of the single notch control switch
is under investigation, the LER remains open.
One item of noncompliance was identified.
7.
Plant Trip*s
Following the plant trips on Unit December 13, 1981, the inspector
ascertained the status of the reactor and safety systems by obser-
vation of control ro6m indicators and discussions* with licensee
personnel concerning plant parameters, emergency .system status. and
reactor coolant chemistry. The inspector verified the establishment
o*f proper communications and reviewed the corrective* actions taken
by the licensee.
All systems responded as expected, and the plant was returned to
operation on December 14, 1981.
No items of noncompliance were identified.
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 December 5-30, 1981.
~he inspector verified-su~veillance
tests required during the shutdown were accomplished, reviewed tagout
records, and verified applicability of containment integrety.
Tours
of Unit I accessible areas, including exterior areas were made to make
independent assessments of equipment conditions, plant conditions,
r~diological 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, includiffg potential fire hazar_ds, and* verified
implementation of radiation protection controls.
The inspector by
observation and direct interview verified that the physical secur1ty
plan was being implemented in accordance with the station security plan.
No items of noncompliance were identified.
9.
Preparation for Refueling
The inspector verified that technically adequate procedures were ap-
proved for the upcoming refueling of Unit 3.
The specific procedures
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reviewed were those refueling procedures that had been revised or
modified during 1981.
Other procedures had been reviewed for the
Unit 2 refueling that took place in early 1981.
The inspector also
veiified that the licensee's 10 CFR 50.59 safety evaluation of the
reload core showed that no unresolved safety questions existed.
However, the inspector did verify that Technical Specification changes
were submitted for NRR approval of the change in fuel vendors (Exxon
vie General Electric) and the Exxon analytical models and methodology.
In correspondence reviewed, it was found that the licensee has .ex-
pressed concerns about a timely review and approval in order to
prevent a delay in the planned restart of Un~t 3.
The inspectors also reviewed the licensee's program for overall outage
control.
No items of noncompliance were identified.
10.
Independent Inspection
On December 8, 1981, an ASME survey team conducted a recertification
audit for renewal of the licensee's NA and NPT certificates (N-Stamp).
These certifications authorize the licensee to conduct ASME Code
related work on nuclear systems and to handle materials used for
nuclear grade work.
Licensee personnel and the ASME survey team
leader cordially invited the Resident Inspectors to participate in
the review.
During the review, several minor discrepencies were
identified and immediately corrected.
The licensee passed the *audit
and the review board is recommending that the National board recertify
the licensee.
The Station Superintendent agreed to provide the
Resident Inspectors with a copy of the report.
Due to the interest of the NRC in ASME Code work, the report information
will be treated in the same manner as INPO reports.
No items of noncompliance were identified.
11.
Preparation for a Guard Force Strike
The inspectors verified that the licensee was prepared to implement
their contingency plan in the event of a strike by the security guards.
A potential threat of a strike occurred on December 11, 1981, when the
unionized guard force, held a strike vote which resulted in favor of
continuing to work.
This issue was also followed by Region III Security
Specialists.
No items of noncompliance were identified.
12.
Headquarters and Regional Request
The Senior Resident Inspector conducted interviews with six licensed
Reactor Operators and Senior Reactor Operators, relavent to specific
corporate instructions and their training on the subject.
These were
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- --
the result of allegations received pertaining to Dresden, Quad-Cities,
Zion, LaSalle stations and Commonwealth Edison Corporate Office.
The
results will be forthcoming under a special investigation report.
13.
Meetings, Training, and Offsite Functions
During this inspection period, the Resident Inspectors attended a
Resident Inspectors' seminar on December 15-18, 1981, at the Region_III
Office in Glen Ellyn,. Illinois.
The Resident Inspectors were also absent from the site on annual leave
for a total of 12 inspector days during the report period~
14.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph 1)
throughout the month and at the conclusion of the inspection on December 30,
1981 7 and summarized the_ scope and findings of the inspection activities.
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