ML17199F929
| ML17199F929 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/17/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17199F930 | List: |
| References | |
| NUDOCS 8610270253 | |
| Download: ML17199F929 (9) | |
See also: IR 05000249/1986012
Text
Docket No. 50-249
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. u'NII~'bsTATES
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NUCLEAR Rii!~~A'tORY COMMISSION
WASHINGTON, D. C. 20555
October 17, 1986
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Vice President
P.O. Box 767
Chicago, IL
60690
Gentlemen:
SUBJECT:
DRESDEN UNIT 3 - SAFETY SYSTEM OUTAGE MODIFICATIONS
INSPECTION (INSTALLATION AND TEST) 50-249/86-012
This letter conveys the results and conclusions of the installation and test
portions of the Dresden Unit 3 Safety Systems Outage Modifications Inspection
(SSOMI) conducted by the NRC's Office of Inspection and Enforcement.
The
inspection team was composed of personnel from the NRC's Office of Inspection
and Enforcement and Region III, and consultants. This inspection, which took
place at the Dresden site, was part of a trial NRC program being implemented
to examine the adequacy of licensee management and contr.ol of modifications
performed during major plant* outages*.
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.
The purpose of the installation and test portions of the trial SSOMI program
was to examine, on a sampling basis, installation and testing of plant modifi-
cations accomplished during the October 1985 - July 1986 outage at the Dresden
Unit 3 plant. This portion of the trial program concludes the trial outage
inspection program at Dresden Unit 3. Reports forwarding .the results of the
design inspection and the vendor inspections have already been issued. The
applicable report numbers are provided in *se9tion 3 of this report.
Section 2 of the report is the detailed discussion of the installation and
testing inspection. The ~ffort was hardware and test oriented and centered
around modifications*accomplished during the outage. Particular attention was
directed toward adequacy of installation, conformance of the modifications to
requirements, adequacy of functional tests, and adequacy of safety-related
maintenance activities.
Section 1 of the report is a summary of the results of the inspection and the
conclusions reached by the team.
The most significant concerns identified
were in the areas of:
(1) inadequate design change control, (2) improper
installation of equipment, (3) inadequate procedures and instructions,
(4) inadequate QA/QC overview of modification activities, and (5) inadequate
control of testing.
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Commonwealth Edison Company
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October 17, 1986
Our letter of May 16, 1986 to you discussed the results to that point in time
of the installation and testing inspection, informed you of the first four
areas of concern noted above, and listed exampl~s of deficiencies identified
in each of the four areas. Although no response to that letter was requested,
two subsequent management meetings (on May 21 and July 2, 1986) were held at
the Region III office to discuss the inspection team findings and the CECo
corrective actions.
Based on our review of the corrective actions which had
been accomplished by the end of the inspection, and of the more comprehensive
corrective actions which were planned for the future, this office found no
reason to delay restart of Dresden Unit 3 at the conclusion of the outage.
The
Dresden station management was so informed during the site exit meeting on
July 16, 1986.
As noted in Section 1 of the inspection report, your corrective
action program did not address a review of modifications performed during
previous outages to determine if similar deficiencies exist.
We believe it
would be prudent to perform such a review, even on a sampling basis, in order
to provide additional assurance that plant safety margins, from a system
functionality standpoint, have not been. inadvertently degraded during the
modification process.*
.
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~
The Appendix to this letter contains a list of potential*enforcement actions
which are based on the deficiencies identified during the installation and *
testing inspection. These wi'l 1 be reviewed by the. Office of Inspection and
Enforcement and the NRC Region III office for appropriate action.* At the
completion of that review, the Region III offi~e will issue any enforcemeht
actions resulting from the installation and testing inspection, as well as
from the earlier design and vendor inspections.
In addition, Region III will
monitor your corrective actions relating to .those enforcement actions.
.
.
In accordance with 10 CFR 2.790(a), a copy of this letter .and the enclosures ,,
will be placed in the NRC Public Document Room.*c No reply to this letter is
required at this time.
You will be required to respond.J:o Region III* regarding
the specific enforcement findings after those findings are issued by the region.
In responding to Region III, we suggest that you consider our views on enhancing
your corrective.action program as discussed above.
.
.
Should you have any questions concerning this inspection, please contact me or
Mr .. James Konklin (301-492-9656) of this office.
Enclosures:
Sincer~{l **.
- Jame~~. Partlow, Director *
Divi~i~n of Inspection Programs
Office of Inspection and Enforcement
1. Appendix, Potential Enforcement Actions
2.
Inspection Report 50-249/86-012
cc w/enclosures:
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See next. page
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Commonwealth Edison Company
cc w/enclosures:
Mr. Michael I. Miller
Isham, Lincoln & Beale
Three First National Plaza
Suite 5200
Chicago, IL * 60602
Mr. J. Eenigenburg
Plant Superintendent
. Dresden Nuclear Power Station
Rural Route #1
Morris, IL
60450
U.S. Nuclear Regulatory Commission
Resident Inspectors Office
Dresden Station
Rural Route #1
Morris, IL
60450
Mr. D. L. Farrar, Director
of Nuclear Licensing
Dresden Nuclear Power Station
Rural Route #1
Morris, IL
60450
Chairman
Board. of Supervisors of Grundy County
Grundy County Courthouse
Morris, IL 60450
Gary N. Wright, Manager
Nuclear Facility Safety
Illinois Department of Nuclear Safety
1035 Outer Park Drive, 5th Floor
Springfield, IL
62704
Ms. Phyllis Dunton, Attorney
General's Office, Environmental
Control Division
Northern Region
160 N. LaSalle Street
Suite 900
Chicago, IL
60601
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October 17, 1986
.;.,.,
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Commonwealth Edison Company
Distribution
NRC PDR
Local PDR
RCPB R/F
DI R/F
JTaylor
RStarostecki
JGPartlow
RLSpessard
JKonkl in
SStein
Rlloyd
BKGrimes
JAxelrad
ELJordan
Regional Administrators
Regional Division Directors
ACRS (10)
.OGC
SSOMI Team Members
RBernero, NRR
JZwolinski, NRR
RGilbert, NRR
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APPENDIX
POTENTIAL ENFORCEMENT ACTIONS
As a result of the NRC Safety Systems Outage Modification Installation and Test
Inspections at Dresden Unit 3 during April 21-May 7, June 9-13 and July 7-16,
1986, the following items are being referred to Region III as Potential
Enforcement Actions.
Section references are to the detailed inspection report.
1.
10 CFR 50.59 requires that safety evaluations be accomplished for
temporary or permanent design changes to the facility to determine
whether an unreviewed safety question exists or whether a change to the
Technical Specifications is involved.
Contrary to the above, the NRC inspectors found that the licensee's
procedures for accomplishing engineering safety evaluations were either
not effectively implemented or were deficient in that:
a.
b.
c.
d.
e.
f.
g.
No safety evaluations had been accomplished for specific lead
shielding installations (Section 2.2.1).
No safety evaluation had been accomplished for an increase in the
hydrostatic test pressure for core spray system flow transmitters
(Section 2.2.3).
No safety evaluations had been accomplished for electrical jumpers
installed prior to December 24, 1985 (Section 2.2.6).
Inadequate safety evaluations were accomplished for Station
Procedure Temporary Change Requests written to functionally test
modifications (Section 2.2.7).
Changes were made in the design of reactor building penetrations
without a safety evaluation (Section 2.2.8).
Safety evaluations were not sufficiently detailed and were not
completed in a timely manner (Section 2.2.15).
Dual safety evaluations completed on the same modification resulted
in different conclusions (Section 2.4.4).
2.
10 CFR 50 Appendix B, Criterion III, as implemented by Commonwealth Edison
Company (CECo) Quality Assurance Manual (QAM) Section 3, requires that
measures be established to assure that appropriate quality standards are
specified and included in design documents and that deviations from such
standards are controlled.
Contrary to the above, the NRC inspectors found that the licensee's
programs were not effectively implemented in that:
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a.
HPCI pipe whip restraints were inadequately designed and installed
(Section 2.2.2).
b.
Design requirements were not controlled for modification package
M12-3-84-8 (Section 2.2.4).
c.
A design change to the installation packages for EQ motor terminal
leads was not reviewed (Section 2.2.5).
d.
Incorrect design requirements were included in the installation
procedures for modification package M12-3-85-50 (Section 2.2.10).
e.
Uncontrolled design changes were made to solenoid operated valves
(Section 2.2.12).
f.
Undocumented and unreviewed design changes were incorporated into
the installation of the torus to reactor building vacuum breaker
valves (Section 2.2.13).
g.
Unauthorized and unreviewed pen-and-ink design changes were made to
a reactor building penetration modification work package (Section
2.2.14).
3.
10 CFR 50, Appendix B, Criterion VI, as implemented by CECo QAM Section 6,
requires that measures be established to control issue and distribution
of procedures and drawings and that changes to these documents be reviewed
and approved by authorized personnel.
Contrary to the above, the NRC inspectors found that the licensee's
document control procedures were not adequately implemented in that:
a.
Modification package drawings were not controlled in that numerous
drawings were improperly changed or had inaccurate information
(Section 2.3.1).
b.
A drawing revision was not reviewed by an engineer to determine
whether the modification package also required related changes
(Section 2.3.2).
c.
The Master Temporary Change Request Log was inaccurate and not kept
current (Section 2.3.4).
d.
Drawings or other work package documents were in conflict with design
requirements (Section 2.3.5).
4.
10 CFR 50, Appendix B, Criterion V, as implemented by CECo QAM Section 5,
requires that activities affecting quality be prescribed by documented
instructions, procedures or drawings of a type appropriate to the circum-
stances, and that these instructions, procedures, and drawings include
appropriate acceptance criteria.
Contrary to the above, the NRC inspectors found that the licensee's
programs were not effectively implemented in that:
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a.
Work packages contained inadequate acceptance criteria for the
inspection and testing of modifications (Section 2.4.1).
b.
Modification packages were not maintained in accordance with Dresden
administrative procedures (Section 2.4.2).
c.
Test steps which were signed as completed contradicted required test
steps which were also signed as completed (Section 2.4.3).
d.
A Maintenance/Modification Procedure (MMP) was not revised to be in
accordance with Technical Specification requirements (Section 2.4.5).
e.
Work packages did not contain required QA/QC hold points (Section
2.4.6).
f.
Sub Station Construction Department approved procedures did not
contain adequate instructions for safety-related work activities
(Section 2.4.7).
g.
Operating procedure review periods are not in accordance with ANSI
N18.7 requirements (Section 2.4.8).
h.
Modification work packages contained incorrect references to
Technical Specifications (Section 2.4.10).
i.
Dresden Administrative Procedure 15-1 "Work Requests," did not
adequately address revisions of work requests for work in progress.
(Section 2.4.11).
j.
Work was not performed or documented per procedural requirements
for removal and installation of interferences associated with
recirculation piping replacement (RPR) (Section 2.4.13).
k.
Inadequate cleanliness and foreign material exclusion practices were
identified during plant walkdowns and procedure reviews (Section
2.4.14).
5.
10 CFR 50, Appendix B, Criterion V, as implemented by CECo QAM Section 5,
requires that activities affecting quality be accomplished in accordance
with the appropriate instructions, procedures and drawings.
Contrary to the above, the NRC inspectors found that the licensee's work
activities were not accomplished in accordance with requirements in that:
a.
Wrong cable connections had been made in two motor control centers
(Section 2.5.1).
b.
Safety-related cables were bundled with nonsafety-related cables in
panels 2203-73A and 2203-738 (Section 2.5.1).
c.
An RPR electrical installation deficiency was not corrected in
accordance with instructions (Section 2.5.2).
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d.
e.
f.
g.
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n.
Cable splices were not made in accordance with vendor requirements
(Section 2.5.4).
LPCI/CS relay wiring did not conform to their wiring diagrams
(Section 2.5.5.1).
All damaged LPCI room cooler motor leads were not repaired, in
addition to other installation deficiencies (Section 2.5.6).
EQ solenoid operated valves were not installed in accordance with
the work procedure (Section 2.5.8).
Uncontrolled and incorrect modifications were accomplished on the
torus to reactor building vacuum breaker valves (Section 2.5.9).
Installation of the Unit 2 CCSW modification was not in accordance
with as-built or design documentation (Section 2.5.11).
A diesel generator instrumentation modification was not installed in
accordance with the work procedure or the design requirements
(Section 2.5r12).
Reactor building penetrations were not fabricated or installed in
accordance with procedures (Section 2.5.13).
Work was accomplished which replaced CCSW piping which was outside
the scope bf the modification (Section 2.4.12).
Snubbers affected by RPR modifications were not properly installed
and inspected (Section 2.5.14).
The fitup of a main steam piping lug was not in accordance with
drawing requirements (Section 2.5.16).
6.
10 CFR 50, Appendix B, Criterion XI, as implemented by CECo QAM Section
11, requires that measures be established to assure that all testing
required to demonstrate that structures, systems and components will
perform satisfactorily in service is identified and performed in accord-
ance with written test procedures.
Contrary to the above, the NRC inspectors found that the licensee's test
programs were not effectively implemented in that:
a.
Test procedures contained a number of inaccuracies, errors and
omissions, even though the tests had been reviewed and approved
(Section 2.7.1).
b.
RPR special test procedures did not include steps to verify the
tests or to document equipment verifications (Section 2.7.2).
c.
Test control was inadequate in that there was a lack of requirements
for documentation of test completion, test acceptability, or
temporary changes to test requirements (Section 2.7.3).
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d.
Discrepancies were found between the FSAR, the Technical Specifica-
tions, and operational surveillance tests of containment isolation
valves (Section 2.7.9 and Table II).
e.
Valve cycling tests were inadequate in that they did not specify
verification of proper stroke times as required by ASME Section XI
(Section 2.7.10).
f.
Test failures or deviations were not properly documented (Sections
2.8.1, 2.8.4, 2.8.6, 2.8.8).
g.
Functional tests for motor operated valves did not provide for
specified acceptance criteria (Section 2.8.9).
h.
Undervoltage and ECCS integrated functional tests were inadequate
(Sections 2.8.10 and 2.8.11).
i.
A hydro test was performed without steps adequate to ensure that each
line was vented prior to the increase in pressure (Section 2.8.17) .
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