ML17199F823
| ML17199F823 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/30/1986 |
| From: | Bjorgen J, Dunlop A, Eng P, Falevits Z, Hehl C, Key W, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199F822 | List: |
| References | |
| 50-237-86-15, 50-249-86-17, NUDOCS 8607070263 | |
| Download: ML17199F823 (18) | |
See also: IR 05000237/1986015
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report Nos. 50-237/86015(DRS); 50-249/B6017(DRS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
P. 0. Box 767
Chicago, Illinois 60690
Facility Name:
Dresden Nuclear Power Station, Units 2 and 3
Inspection At:
Morris, Illinois
Inspection Conducted:
May 19 through May 23, 1986
Inspectors:~
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Approved By:
C. W. Hehl, Chief
Operations Branch
Inspection Summary
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Date *
Inspection on Ma} 19 through 23, 1986 (Report Nos. 50-237/86015(DRS);
50-249/86017(DRS )
Areas Inspected: Special team inspection to followup on modification package
problems identified by the Safety Systems Outage Modification Inspection Team
from the Office of Inspection and Enforcement on Unit 3 to determine if
similar problems were present on Unit 2 and, if problems were present, to
determine if they jeopardized the return to operation of Unit 2.
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Results:
The inspection team determined that in the thirteen Unit 2
modification packages inspected about half contained similar problems as had
been identified for Unit 3.
The problems identified were evaluated by the team
to not jeopardize the return to operation of Unit 2.
One violation was
identified in the area of as-built drawings versus as-found electrical
configuration (failure to ensure drawings are kept updated and installation is
performed in accordance with drawings - Paragraph 4) .
2
- 1.
2.
DETAILS
Persons Contacted
- N. Kalivianakis, Nuclear Division, Vice President
- D. Scott, Station Manager
- J. Brunner, Assistant Superintendent, Technical Services
- J. Doyle, Quality Control Supervisor
- D. Farrar, Director of Nuclear Licensing
- D. Adam, Regulatory Assurance Supervisor
- R. Flessner, Services Superintendent
- J. Wujciga, Production Superintendent
- M. Strait, Station Nuclear Engineering Department
- J. Achterberg, Technical Staff Supervisor
- G. Smith, Assistant Technical Staff Supervisor
- J. Ballard, Zion Quality Control Supervisor
- J. Wojnarowski, Nuclear Licensing Administration
- T. Ciesla, Assistant Superintendent, Operations
- R. Jeisy, Quality Assurance Supervisor
- Denotes those personnel attending the May 23, 1986, exit interview.
Additional station technical and administrative personnel were also
contacted by the inspectors during the course of the inspection.
Background
From April 21 to May 7, 1986, an inspection team from the NRC's Office of
Inspection and Enforcement performed the second part of a three part Safety
Systems Outage Modifications Inspection (SSOMI) at the Dresden Unit 3 site.
(Note:
The last part of the SSOMI inspection is expected to be completed
July 1986.)
The results of that inspection raised several concerns
regarding the adequacy of modifications performed at the Dresden site,
and the decision was made to perform a Regional followup inspection
beginning May 19, 1986.
The concerns identified during the SSOMI were also
documented in a letter dated May 16, 1986, from James M. Taylor, Director,
Office of Inspection and Enforcement (IE) to Cordell Reed, Vice President,
Commonwealth Edison Company (CECo).
The purpose of the followup inspection
was primarily to determine if problems similar to those identified by the
SSOMI team on Unit 3 were also present on Unit 2.
This information was
necessary because the SSOMI team's inspection was largely focused on Unit 3
and because Unit 2 was operating at power at the time. Additional
objectives of the followup inspection were to determine if any problems
identified presented immediate threat to continued operation of Unit 2 and
to assess CECo corrective actions.
CECo made a presentation to Region III
and IE management personnel at a meeting in Region III offices on May 21,
1986, regarding CEC0
1s assessment of Dresden's modification program
problems and proposed corrective actions. Since CEC0
1s corrective actions
were not finalized by the time of the exit on May 23, 1986, the followup
team did not perform this objective and no further assessment of CEC0
1s
complete corrective actions is contained in this report; however, some
specific corrective actions are addressed with the individual modification
3
3.
packages.
In addition, the followup team expanded the inspection in the
areas of as-built drawings compared to the as-found condition of the plant
and work requests.
The remainder of this report describes the findings of
the followup inspection team.
Modification Packa9~~
The followup inspection team reviewed portions of thirteen (13)
modification packages for Unit 2 which had been performed on Unit 3.
The results of the examination of each package are detailed in the
following paragraphs.
a.
Modification Packa9es_~1~:~:84:~1-~~d MJ2-~:84:28
These modifications consisted of replacing the pilot solenoid valves
(S0-2-1601-50A and S0-2-1601-508, respectively) for the torus to
reactor building vacuum breaker valves (A0-2-1601-20A and
A0-2-1601-208) with Environmentally Qualified (EQ) solenoids.
The specific problems with these two packages noted on Unit 3
by the SSOMI team which were communicated to the followup team
were:
(1)
The air actuator lines to the vacuum breaker valves were
installed per the modification drawing, but the drawing was in
error. This resulted in the lines being reversed from their
correct configuration.
(2)
The solenoid valves had been installed horizontally instead
of vertically.
(3)
The operational tests did not require valve stroke time tests
as required by Section XI of the ASME Code.
acceptance criteria were changed by the modification.
(4)
Splices (Raychem) on the solenoid valve leads were made
improperly.
(5)
Anti-rotation stops of wrong material were welded on the
valves.
(6)
The operational test was inadequate in that it would not have
verified the fail position on loss of air.
The SSOMI team also noted that the licensee's Quality Control (QC)
representative had signed for correctness for items (1) and (2).
The SSOMI team had verified via photograph that the Unit 2 air
actuator lines were installed correctly (i.e., not in accordance with
the instructions); however, no field change or other vehicle was used
to document the correct method on Unit 2 so that it could be
translated into the Unit 3 modification package.
4
For item (1), the followup team with the assistance of the Senior and
Resident Inspectors physically verified that the Unit 2 air actuator
lines to the vacuum breaker valves were installed correctly.
The
modification drawing for the Unit 2 modification was still in error,
however.
For item (2), the solenoid valves were observed to be installed with
the coil horizontal in Unit 2, the same as was observed for Unit 3.
This problem was judged to not be technically significant in that
the modification package for Unit 2 contained additional information
from the valve manufacturer, ASCO, which stated, "This valve is
designed to perform properly when mounted in any position.
11
An
additional memo from Bechtel indicated, "Coils vertical and upright
or no more than 90° to any side of vertical and upright would
present no problem,
11 and "If vertical and downward, problems
relating to moisture and dirt can be expected to be more severe.~
While this information indicates the solenoid valve coils do not
have to be vertical, both Unit 2 and Unit 3 modification packages
contained operator or QC signatures stating,
11Solenoid mounted with
the coil upright and vertical.
11
The valves were observed to be
physically mounted such that the valve shaft was vertical while the
coil was horizontal. While the installation does not represent a
problem for valve operation, it supports the SSOMI concern as to
whether the personnel involved in the valve installation,
including QC, adequately understood the modification instructions
or the operation of the valves .
For item (3), the Unit 2 packages were found to be satisfactory in
that they contained a stroke time test.
The Unit 2 valves were
found to stroke in 2 seconds which is considered satisfactory.
For item (4), the Unit 2 splices on the solenoid valve leads had
already been redone by the time the followup team arrived onsite.
Discussions with the Assistant Technical Staff Supervisor indicated
that the Unit 2 splices were in the same condition as those of
Unit 3; however, CECo does not believe they were improper.
The
followup team did not attempt to pass judgement on the correctness
of the splices since this issue was known to be in dispute from the
SSOMI team inspection.
The followup team merely confirmed that the
same condition had existed on Unit 2 and was now corrected.
For item (5), the followup team did not examine the anti-rotation
stops and has no conclusion on this item.
For item (6), the followup team did not uncover conclusive evidence
that the operational test was or was not incorrect with respect to
fail position.
The test instructions were vague in that personnel
were instructed to
11 loosen air connection" and
11close supply valve
11
without specifying exactly which connection or valve.
There are
more than one connection and valve such that it is possible to
perform the test correctly or incorrectly depending on which
locations are chosen.
The data in the test merely consists of
11yes
11
and a signature indicating successful performance.
The followup
5
team did not interview the individuals who actually performed the
test and hence no definitive conclusion was reached.
Licensee
personnel indicated that they believe the operational test as
written could have caught the incorrect air actuator installation
for Unit 3.
(Note:
The test had not yet been performed on Unit 3.)
The followup team believes this to be probable in that the test
would not have worked; therefore, an investigation into the cause
may have uncovered the incorrect installation. However, since the
drawing was in error and the installation was correct per the
drawing, the team believes there is an equal likelihood that the
error would not have been recognized and that another fix, such as
reversing electrical leads, would have been incorrectly attempted.
b.
Modification Packages Ml2-2-84-49 and Ml2-2-84-50
These modifications consisted of replacing the Low Pressure Coolant
Injection (LPCI) room cooler motors with EQ motors.
The specific
problems with these two packages noted on Unit 3 by the SSOMI team
which were communicated to the followup team were:
(1)
Questionable method and integrity of Raychem splices,
specifically braiding penetrating the heat shrink to an
indeterminate depth.
(2)
Failure to repair all damaged braiding on motor lead
insulation .
(3)
Questionable seismic analysis for LPCI room coolers and
motors.
(4)
One Unit 3 room cooler fan belt was not installed and the
other was loose.
The followup team reviewed the modification packages noted above
for Unit 2 and the related package for Unit 3.
Due to licensee
manpower constraints resulting from the Environmental Qualification
inspection which was being conducted during the same time period,
the inspectors were only able to view the Unit 2 LPCI room cooler
motor installation. The followup team inspectors noted that the fan
belts were properly installed for Unit 2.
Review of the modification
packages revealed that with the exception of the damaged leads on
Unit 3 equipment, package content was virtually identical.
For item (1), the integrity of the Raychem splices were found to be
similar on Unit 2 to those on Unit 3.
For item (2), the modification on Unit 2 did not have damaged
braiding on motor lead insulation associated with it; consequently,
there was no
11failure to repair
11 on Unit 2.
Subsequent physical
inspection of the coolers found damaged braiding/insulation on one
of the motor leads for the east LPCI room cooler.
The licensee
initiated a work request to repair the damaged leads.
6
For item (3), the Unit 2 installation was identical to that on
Unit 3.
With regard to the seismic adequacy, the inspectors noted
that the motor was rigidly attached to the cooler; however, the
room cooler itself was not rigid and could be swayed by hand.
The
licensee subsequently provided a copy of the seismic evaluation
performed by Westinghouse of this installation. The evaluation has
been forwarded to the SSOMI team for further analysis.
The inspectors also observed that although the modification packages
for Unit 2 were signed as being complete with respect to work and
microfiched, the Quality Assurance approval of the Final
Documentation Checklist was missing.
This item is considered an
example of lack of adequate quality control of the modification
packages as previously identified by the SSOMI team.
c.
Modification packages Ml2-2-85-50; M12-2/3-85-31
These modifications consisted of installing pressure gauges on each
of the Diesel Generator Cooling Water (DGCW) Pump suction lines for
Inservice Testing purposes. Modification packages for Unit 2 and
the swing diesel had been signed off as being complete with regards
to both work and documentation.
The concern raised by the SSOMI team for Unit 3 was that the
modification package specified an isolation valve rated at 2000 psig.
Field inspection revealed that a 150 psig valve was actually
ins ta 11 ed.
Region III inspectors reviewed the modification packages for
Unit 2, Unit 3 and the
11-swing
11 or Unit 2/3 DGCW pump suction lines
and noted that when first authored, all three packages specified use
of a 2000 psig valve.
Prior to installation of the pressure gauge in
Unit 2, however, a pen and ink change was made changing the valve to
150 psig.
Field inspection revealed that 150 psig valves were
installed in all three locations. Consequently, the concern raised
by the SSOMI team is applicable to the Unit 3 and swing DGCW pump
suction lines only.
The licensee stated that a Deviation Report
describing the error was being routed and upon completion of the
approval process would be inserted into the modification package.
In addition, during review and comparison of the three modification
packages, the inspectors noted the following:
(1)
For Unit 2, the modification checklist required valve identifi-
cation tags to be hung and the ISI Coordinator to be notified of
the modification.
The signatures verifying both these tasks
were missing.
(2)
The fabrication sketch of the pressure ~auge installation for
Unit 2 identified two items as Part #2 {pipe) and required
Part #2 to be safety-related. The material certification cards
attached to the modification package only note one item.
Further
investigation revealed that the Part #2 was not used for both
7
(3)
applications, but a reducer was substituted in the field.
However, no changes were made to the modification package to
authorize or document the change made in the field.
A Quality Assurance (QA) holdpoint was required for the fitup
and alignment associated with one of the welds on the swing
diesel installation.
The signature block for the hold point
is dated October 19, 1985, two months prior to work initiation
and states,
11 N/A per phone call.
11
Discussions with the licensee
personnel involved could not clarify the reason for .or the
disposition of the holdpoint; however, the licensee believes
this to be an incorrect recording of the date in that the work
was performed on December 19, 1985.
The above 3 items are considered further examples of a lack of
adequate quality control of the modification packages as previously
identified by the SSOMI team.
d.
Modification Packa9e M12-2-84-9
This modification consisted of modifying the control circuit to the
core spray inboard isolation valves to prevent hammering on a
continuous close signal.
The problem noted on Unit 3 by the SSOMI
team and communicated to the followup team was that the Raychem
splices did not meet the minimum bend radius requirements.
The
inspectors examined core spray inboard isolation valve MOV 2-1402-25A
and found that the splices were not bent in excess of the minimum
bend radius as was observed in Unit 3.
The wiring in the valve was
bent to some degree and the outer jacket was cracked; however, the
inner insulation appeared to be intact.
e.
Modification Package M12-2-83-29
This modification consisted of a change to LPCI suction valves
M03-1501-5A, B, C, and D to ensure closure upon ECCS actuation.
The
problem with this package noted on Unit 3 by the SSOMI team and
communicated to the followup team was incorrect installation of the
Raychem splices. This problem was not found by the followup team to
be present on Unit 2 in that this modification had not yet been
performed on Unit 2.
Modification Package M12-2-83-30
This modification consisted of modifying the Core Spray (CS) suction
valves M03-1402-3A and 38 control circuitry to allow closure upon
ECCS actuation.
The problem with this package noted on Unit 3 by the
SSOMI team which was communicated to the followup team was an
incorrect cable termination on both motor control centers (MCC).
This problem was not found by the followup team to be present on
Unit 2 in that this modification had not yet been performed on Unit 2 .
8
g.
Modifi ca ti on PackE_ge M12-2-84-14
This modification consisted of installing 4-way valves, flanges and
gauges to allow end tank removal on the Containment Cooling Service
Water (CCSW) piping to the pump vault coolers.
The specific problems
with this package noted on Unit 3 by the SSOMI team which were
communicated to the followup team were:
(1)
The mechanic installed the 4-way valve in a manner not in
accordance with the procedure, and initiated a Field Change
Request (FCR) after installation.
(2)
150 psig flanges were installed instead of the 300 psig flanges
required by the drawing.
(3)
Sheet gasket material was used rather than the flexitallic
gaskets required by the specification.
The followup team reviewed the repair program for this modification
which was developed by Sargent and Lundy (S&L) outlining the
requirements for the modification including:
installation of new
piping, fittings, valves and supports; welding and inspections;
retesting of lines; and documentation.
The following documentation
was reviewed:
welding procedure specifications and qualification
records, welder qualification records, inspection and examination
reports, examination procedures and personnel qualifications,
complete station traveler, and certificates of conformance
for all piping, fittings, structural steel, filler metal, valve
body and all other material.
Regarding items (1) and (2), the
inspector's review determined that on Unit 2 the modification had
been performed in accordance with both the drawings and the repair
program including the use of both 150 psig and 300 psig flanges.
However, use of some of the 150 psig flanges in 300 psig locations
was not correct per the drawings and conf'irms the findings from the
SSOMI team also exist on Unit 2.
Regarding item (3), however, the
inspector's review confirmed that sheet gasket material had been
used on Unit 2 also, instead of the required flexitallic gaskets.
During the above review, the inspectors also noted an apparent
additional problem with material traceability. Dresden Station uses
red tags to identify items stored in the warehouse and for material
traceability to the CMTRs.
Review of S&L drawing no. M-487, Revision
A, noted that twelve - 300 psig CCSW flanges were required per pump
unit and four - 150 psig CCSW flanges per unit at the 4-way valves.
Upon examination of the red tags for materials withdrawn from the
warehouse, 24 tags for the 150 psig flanges and one tag for the 300
psig flanges were found.
There appeared to be no traceability for
eleven of the 300 psig flanges. Further discussion with licensee
personnel revealed that the personnel performing the modification in
the field found seven - 300 psig flanges already installed and in
adequate condition so they were reused.
One new 300 psig flange was
used; thus, producing one new red tag. This explanation shows that
150 psig flanges were used in some of the 300 psig locations and no
9
h.
changes were made to the modification package to document what was
actually done.
This item appears to be similar to item (1) of the
SSOMI team's problems and is considered a further example of lack of
adequate quality control of the modification packages as previously
identified by the SSOMI team.
Mod if i cat i_g.D_ Packa_ge M12-2-83-40
This modification consisted of replacing reactor water level
instrumentation and modifying the instrument racks for new EQ
transmitters.
The problems with this package noted on Unit 3 by the
SSOMI team which were communicated to the followup team were incorrect
Raychem splices and separation less than 6 inches as required by
drawing.
The followup team did not find problems with Raychem splices
on Unit 2 in that different types of splices were used for the Unit 2
modification.
The followup team was unable to examine the separation
issue during the week of inspection.
i.
Modification Packa_ge M12-2-83-57
This modification consisted of installing shear lugs on the Main Steam
lines to prevent the restraints from slipping down the pipe.
The
SSOMI team did not communicate any problems with this package on
Unit 3 to the followup team.
The followup team examined this
package for Unit 2 and did not find any discrepancies with the
Unit 2 package, either.
j.
Modification PackE_9~_M12-2~§4-~
This modification consisted of replacing/rewiring various HGA-11
relays due to potential difficulty in meeting seismic requirements.
The specific problems with this package noted on Unit 3 by the SSOMI
team which were communicated to the followup team were:
(1) A lead was terminated to an incorrect terminal point and then
jumpered to the correct point.
An additional modification
would remove the jumper.
(2)
Drawings contained incorrect information.
(3)
Construction test contained steps where either A or B was
to be performed.
Both A and B were signed indicating
performance.
The followup team reviewed both the Unit 3 and Unit 2 packages in
order to better understand the Unit 3 problems and determine if they
were present on Unit 2.
With regard to item (1), the inspectors noted that while the manner
in which the lead and jumper were connected was not strictly in
accordance with the letter of the package description, it would
10
electrically accomplish the same function.
A note on drawings
12E-2758L and 12E-3758L stated that when modification M12-2(3)-82-27
(the additional modification described in item (1) earlier) was
performed, the jumper was to be removed and the lead terminated
at the correct terminal point.
The modification packages for
M12-2(3)-82-27 were not in a condition to be performed at the time
of the inspection and, therefore, the inspector could not determine
if the package would specifically describe the correct electrical
installation.
With regard to item (2), following the 1icensee's drawings and
drawing control system was found to be extremely difficult. The
licensee utilizes four categories of drawings:
As-built drawings,
Construction drawings, Completed Hold File drawings and Critical
drawings.
To determine physical configuration in the fie1d, a
combination of the first three types of drawings was often
required.
Even Critical drawings, which the licensee described
as being correct field drawings, appeared to have discrepancies.
Further discussion of drawings versus configuration in the field
is contained in Paragraph 4 of this report.
Paragraph 5 of this
report discusses the inspection team's examination of work requests
which was motivated by the drawing concerns.
With regard to item (3), the followup team found that Unit 2 did
not have this problem in that the Unit 2 construction test did not
contain either/or steps described in item (1) .
The inspectors also encountered an additional concern as a result of
modification M12-2-84-8.
When leads were lifted or landed on a
relay or terminal board which already contained other leads at the
same point, the only circuits that were checked for continuity were
the newly landed leads. Other leads that had been installed at the
same time were not checked to see if they remained properly landed
even though they may have been disturbed by the new actions. This
practice produces the potential of other systems, not specifically
involved in the modification, not getting adequately tested to
ensure proper operation.
Upon field inspection of electrical
cabinets, the inspectors noticed loose leads which were not
terminated and which were not taped over or otherwise marked as
spares.
This observation, without tracing back the specific wires,
does not necessarily reflect a problem.
However, it tends to give
credence to the concern over a need to verify other leads not
specifically involved in the subject modification remaining properly
terminated.
The licensee agreed to review this area for possible
corrective action.
The inspection attempted to verify the ability of surveillance tests
to adequately test the features of a system following performance of
a modification with the drawing difficulties described in Paragraph 4
present.
The followup team was unable to complete this effort in
the week spent onsite, but this issue is expected to be pursued in
the second part of the SSOMI team effort.
11
No new violations or deviations were identified in this area; however,
several of the issues identified in the preceeding paragraphs were
previously identified by the SSOMI team and may be considered violations
pending the completion of the SSOMI effort.
4.
Modification and As-Built Plant Configuration Review
a.
During the various modification package reviews (primarily
M12-2-84-8), the inspectors noted that considerable difficulty
was experienced when trying to compare the licensee's electrical
design drawings (including those designated as the
11
drawings) with the configuration or wiring of electrical components
as found installed in the plant.
Some modifications were found
incorporated into the design drawing but not yet installed in the
field, while others related to the same design drawings had been
partially or completely installed in the field but were not
reflected on the drawings.
The inspectors noted that modifications
to a particular design drawing are not necessarily implemented in
the field in a chronological order.
For example, a modification
issued in 1986 to a particular electrical circuit can be installed
prior to a modification issued in 1980, which impacts the same
circuit on the drawing.
While it is not a specific requirement that
modifications be accomplished in chronological order, the system
which the licensee uses to try and control this situation coupled
with the numbers of modifications implemented over the current plant
lifetime have combined to produce a very confusing situation. It is
extremely difficult, if not impossible, to determine the as-built
condition of Dresden's electrical systems by utilizing only the
design or
11 drawings.
This situation may have contributed
to the findings in the remainder of this section.
(1)
For modification package M12-2-84-8~ the modification was
completed on Unit 2 in January 1985 and, therefore, per the
licensee's document control system, the drctwings affected by
M12-2-84-8 should have been listed as "Completed Hold File.
1
-'
The licensee's Records Retention Vault, however, still listed
the modification as incomplete and the drawings were marked
11 For Construction Only.
11
Communications between the
modification group and the Records Retention Vault were
inadequate in that only oral communications between the groups
were required to change the status of the modification.
The
licensee has corrected the specific deficiency in the Records
Retention Vault.
In addition, a change to the Dresden
Administrative Procedures (OAP) will be initiated to require
the modification group to complete a form signifying final
installation approval which is then sent to the records vault
to implement the change to the status of the drawings.
(2)
The inspectors reviewed drawing 12E-2697, Revisions AF through BB,
and compared the drawings to the actual configuration found in
the field.
Revisions AF through BB of drawing 12E-2697 show an
internal conductor connecting terminal EE-10 to device CPT.
This conductor was not found installed in the field.
12
(3)
Revisions AF through BB of drawing 12E-2697 show only one
internal conductor attached to terminal EE-13 (connecting
device HJ-4); however, field inspection found a second field
conductor attached to terminal EE-13.
(4)
Revisions AB through AJ of drawing 12E-2758B show a jumper
between terminal DD-19 and DD-20 on Auxiliary Electric
Equipment Room panel 902-33. This wire was not found installed
in the field.
(5)
The licensee utilizes a system of as-built drawings designated
Critical drawings in the control room which are marked up to
show modifications and changes.
This system has been
established for use by operating and maintenance personnel per
OAP 2-9 for shift decisions, outage management and trouble
shooting.
From a sample of four Critical drawings, drawing
12E-3437A, Revision P, did not reflect the as-built plant
condition in that Revision J had been designated the as-built
drawing.
(6)
As-built Drawing 12E-2758B, Revision AB, for panel 902-33 shows
a jumper between points 7 and 9 of relay 1530-202.
This wire was
not found installed in the field.
The inspectors recognize
these points are spare contacts.
(7)
As-built Drawing 12E-2758B, Revision AB, shows wire FF-71 on both
sides of terminal block DD-21 and wire FF-72 on both sides of
terminal D0-22.
Field inspection indicated that only the
internal sides of DD-21 and 22 are wired.
(8) As-built Drawing 12E-2758B, Revision AB, shows AQ-2 connected
to point DD-54, but field inspection found AH-2 connected to
DD-54.
These items (1) through (8) represent examples of a failure to
assure that changes and modifications to as-built drawings are
properly controlled and implemented, and to assure that the as-built
drawings are kept updated to reflect the condition of the plant.
These items are considered to be a violation of 10 CFR 50, Appendix B,
Criterion VI (237/86015-0l(DRS); 249/86017-0l(DRS)).
This violation
is similar to a previous violation (237/86001-02(DRS);
249/86008-0l(DRS)) and a previous open item (237/86005-0l(DRS);
249/86008-0l(DRS)) issued at Dresden.
b.
In addition to the examples of a violation discussed previously, the
inspectors also noted the following problems while comparing
drawings with field configuration:
(1)
The inspector selected Core Spray - LPCI Containment Cooling
system drawing 12E-2697, Revisions AF through BB, and drawing
12E-2758B, Revisions AB through AJ,for a field inspection to
determine if modifications applicable to these drawings had
13
been properly implemented in the field, and whether the
drawing revisions designated by the licensee as
11 As-Built~
reflect the actual condition of the plant. The inspector also
attempted to determine the method used to identify, control and
update the as-built drawings located in Central File.
Review
of Central File records indicated that the following
modifications and revisions associated with drawing 12E-2697
have already been implemented in the field.
Modification Nos.
M12-2-80-33
M12-2-79-52
Record~evision
DCR-83-55 (M12-2-82-46)
FCR-2386
M12-2-84-16
M12-2-83-40
M12-2-8T-30
Applicable
Drawing Revisions
AJ
AK
AT
AZ
AW/BB
BA
(Note:
80 denotes the year the modification was issued.)
The following modifications have not been implemented in the
field yet, but the design was incorporated into drawing
Modification Nos.
M12-2/3-80-06
M12-2-80-=36
M12-2-8~-29
Applicable
Drawing Revisions
AG/AL/AS
AM/AN/AP/AR
(2)
The licensee designated Revision AF of drawing 12E-2697 as the
as-built revision.
The inspector attempted to verify the
as-built configuration of Main Control Board panel 902-3 using
the as-built Revision AF and the latest Revision BB of design
drawing 12E-2697.
Due to the perplexity of the existing
drawing control system the inspector had to use 18 different
revisions to drawing 12E-2697, AF through BB, to determine if
field installed components or panel wiring appear on the
drawings.
The inspector could not determine the as-built
configuration of this panel using the existing system.
During
the limited review of this panel the inspector observed the
following discrepancies:
(a)
The white conductor of external cable no. 22839 was
improperly spliced to a green conductor approximately
18 inches away from point EE-76 where it was terminated.
The splice contained a ring-type lug on each conductor
and was held together with a nut and bolt.
Black tape was
wrapped around this splice. This splice was not in
accordance with existing procedures or industry practices.
14
(b)
The metal protective cover over device
11 GHC
11 was observed
to be in contact with the exposed resistor and capacitor
of the printed electronic circuit board mounted inside the
panel.
(3)
The inspector examined a portion of the Auxiliary Electric
Equipment room panel 902-33 as shown on wiring diagram
12E-2758B, Revision AB (as-built) through Revision AJ (latest).
Central File records indicated that the following modifications
and drawing revisions ~o drawing 12E-2758B had been implemented
in the field:
Modification Nos.
M12-2-82-27
M12-2-84-08
M12-2-84-118
Applicable
DrE-~l!!.9 Revisions
AC/AF
AH
AJ
During this inspection the inspector observed the following
discrepancies:
(a)
Conductors terminated to points DD-89 and DD-90 were
observed to be very loose.
(b)
Point DD-84 contained a lug that extruded away from the
terminal point and appeared not be be securely held
underneath the terminating screw.
(c)
The red conductor of cable no. 22646 was found terminated
to point DD-80 in the panel, but was not shown on any of
the design drawing revisions. This conductor was later
determined to be a spare.
(4)
Drawings 12E-3437, Revision S, and 12E-3438, Revision V, showed
portions of the LPCI pump start circuitry, which do not
appear to be functional as shown.
The licensee indicated that
during the drawing revision process these portions should have
been removed from the drawings, but the balloon encircling the
portion of the circuitry to be removed faded with each copy of
the drawing.
Eventually the drawing no longer showed the
circuit was removed.
The licensee had work requests complete or in progress to
correct the items described in previous items (2) through (4);
however, these findings are considered further examples of the
issues identified by the SSOMI team.
One violation was identified in this area.
15
5
Work Requests
During the review of modification M12-2-84-8, the inspectors became
concerned about the licensee's method for updating drawings to reflect
the "as-built" condition of systems in the plant.
The inspectors were
concerned that the licensee would have a significant problem selecting the
appropriate drawing revisions that would accurately reflect the
as-installed condition of plant systems without a detailed system walkdown.
In an attempt to resolve this concern, several
work requests were reviewed to determine which
routinely utilized for maintenance activities.
are identified as follows:
completed safety-related
drawing revisions were
The work requests reviewed
Unit
3
3
2/3
2
2
2
2
Work
Request
42217 &
42218
47867
44726
48239
43469
44028
48180
Date
03/86
10/85
12/85
10/85
04/85
10/85
10/85
Description
Inspect/repair pressure suppression
1 evel trasnmitters for "EQ"
Replacement of ECCS fill pump
motor
Repair cables to the 2/3 diesel
cooling water pump
Maintenance on limitorque operator
for the isolation condenser valve
2-1301-1
Replaced motor & rewired operator
for isolation condenser valve
2-1301-4
Replaced motor on valve 2-1301-4
Rebuilt operator on valve 2-1301-4
Of the eight packages reviewed, only three referred to specific drawings
for the maintenance to be performed.
Several of the packages referred to
"manuals and drawings available in maintenance files under EP number."
The
licensee's procedure for drawing control, OAP 2-3, authorizes maintenance
to be performed with "as-built" drawings from the maintenance department
satellite files.
As noted in Paragraph 4, the licensee's "as-built" drawings may or may not
reflect the actual conditions in the plant. It was also noted that the
five work packages that did not invoke specific drawings were closed
without the drawing(s) number(s)and revision(s) utilized to perform the
work being documented in the package.
The inspector, therefore, was unable
to determine which drawings or revisions were used to perform the work.
16
Based on this uncertainty, the inspector requested the
licensee to remove the connection cover on the Unit 2 isolation
condenser inboard isolation valve 2-1301-1 in order to perform
a detailed wiring inspection. This particular valve had been
internally rewired under work request 48239 in October 1985.
The work request invoked drawings 12E-2674E, Revision T, and
12E-2507A, Revision F, for the wiring details. A review of
these drawings found that drawing 12E-2674E, Revision T,
invokes drawing 12E-2507B for the wiring schematic for the
valve.
It was noted that drawings 12E-2507A and 12E-2507B
provide different wiring schematics for the valve.
During the
actual valve wiring inspection on May 22, 1986, the licensee's
technical staff engineer selected Revision U to drawing
The inspector noted that, for the area of interest,
Revisions U and T of the drawing are the same.
The limitorque
wiring for valve 2-1301-1 was found to conform with drawing
The wiring at the motor control center 28-1, however, did not
agree with the drawing.
Connection points, although
electrically equivalent, did not match the connection drawing.
During the wiring of valve 2-1301-1, several problems were
noted.
These included:
(a) A leaking torque switch housing gasket that allowed grease
to cover many of the wires.
(b)
The outer shielding on the cables from the power supply
junction box to the operator showed signs of aging.
The
condition of the actual cables could not be evaluated.
(c)
The rotor contacts for the limit switches were severely
corroded.
(d) Three lug connections were damaged with one lead to the
closed torque switch damaged to the extent that it broke
while moving the attached wire during the inspection.
(e)
The insulation on the motor leads was nicked adjacent to
the Raychem splice.
(f) The insulation on one of the leads to the lower rotor
connections was cracked exposing bare wire.
(g)
In motor control center (MCC) 28-1 compartment J-4, two
wires were noted to be spliced with short lengths of
unidentified gray wire such that it was difficult to
confirm the proper wire color code.
Items (a) through (f) above were referred to the environmental
qualification team, which was onsite for evaluation.
The
results of that evaluation will be included in report 237/86013.
Item (g) was pointed out to the electrician foreman for action.
17
- r
-
.
,._
During the review of work request 47867 for replacement of the
Unit 3 Emergency Core Cooling System (ECCS) keep full pump in
the west corner room, it was noted that a non-safety-related
motor was installed in the safety-related application. Although
the appropriate form, OAP 11-5a, was included in the package, the
acceptance criteria utilized to upgrade the motor application
was not readily apparent in the data. The needed technical
comparison and evaluation of the original installation
specifications versus the part being utilized was not included
in the package.
Pending resolution, this issue will remain an
unresolved item (249/86017-02(DRS)).
No violations or deviations were identified; however, one issue
requires further review and is documented as an unresolved item.
6.
Unresolved Items
7.
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, violations or
deviations.
An unresolved item disclosed in the inspection is discussed
in Paragraph 5.
Exit Interview
The inspection team met with the licensee representatives denoted in
Paragraph 1 on May 23, 1986, at the conclusion of the inspection.
The
inspectors summarized the scope of the inspection and the findings.
The
licensee acknowledged the statements made by the inspectors with respect
to the unresolved item and the violation denoted in Paragraph 4.a.
The
inspectors also discussed the likely informational context 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/processes as proprietary.
18