ML17201J593
| ML17201J593 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/07/1988 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17201J550 | List: |
| References | |
| 50-237-88-17, 50-249-88-18, NUDOCS 8809130052 | |
| Download: ML17201J593 (9) | |
See also: IR 05000237/1988017
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-237/88017{DRP); 50-249/88018(DRP)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
P. 0. Box 767
Chicago, IL
60690
Facility Name:
Dresden Nuclear Power Station, Units 2 and 3
Inspection At:
Dresden Site, Morris, IL
Inspection Conducted:
July 5 through September 2, 1988
Inspectors:
S. G. Du Pont
P. D. Kaufman*
Approved By:
M. A. Ring, Chi'~uO"'v£7*
-
Reactor Projects Section lB
Inspection Summary
Nine previously identified Diagnostic Evaluation Team findings remain open.
Of these, 8 will be reviewed by Regional inspections in the areas of IST
implementation and maintenance activities~
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1.
DETAILS
Persons Contacted
Commonwealth Edison Compan.r *
- E. Eenigenburg, Station Manager
J; Wujciga, Production Superintendent
- C. SchroederJ Services Superintendent
L. Gerner, Superintendent of Performance Improvement
T. Ciesla, Assistant Superintendent - Planning
D. Van Pelt, Assistant Superintendent - Maintenance
J. Brunner, Assistant Superintendent - Technical Services
J. Kotowski, Assistant Superintendent - Operations
R. Christensen, Unit 1 Operating Engineer
G. Smith, Unit 2 Operating Engineer
W. Pietryga, Unit 3 Operating Engineer
J. Achterberg, Technical Staff Supervis6r
R. Geier, Q.C. Supervisor
D. Adam, Radiation Chemistry Supervisor
J. Mayer, Station Security Administrator
D. Morey, Chemistry Supervisor
D. Saccomando, Radiation Protection Supervisor
E. Netzel, Q.A. Superintendent
- Denotes those attending one or more exit interviews conducted on
September 2, 1988, and informally at various times throughout the
inspection period.
The inspectors also talked with and interviewed several other licensee
employees, including members of the technical. and engineering staffs,
reactor and auxiliary op~rators, shift engineers and foremen, electrical~
mechanical and instrument personnel, and contract security personnel.
2.
Review of Previous Diagnostic Evaluation Team (DET) Items (92701)
(Closed) Open Items (237/88017-01 and 249/88018-01):
DET Item 2.2.1.1,
Evaluate Dresden procedures for draining and changing control rod drive
hydraulic control units (HCU).
The inspector verified that Dresden
ope rat i hg procedures .DOP 300-6, "Contra 1 Rod Drive System Accumulator
Charging," and DOP 300-11, "Control Rod Drive System Accumulator Water
Removal" were revised to include the caution during closure of HCU valve
305-111 which could render a HCU inoperative. This item is considered
to be closed.
(Closed) Open Items (237/88017-02 and 249/88018-02):
Evaluate non-license
training for adequate training on procedures DOP 300-6 and DOP 300-11 for
HCU operations.
The DET observed an operator closing HCU valve 305-111 during evolutions
per DOP 300-6.
A review of DOP 300-6 revealed that the procedure did not
require closure of the valve and it was believed that the operator error
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was due to inadequate training on DOP 300-6.
However, the inspector's
review of the training received by the operator concluded that it was
adequate which the ope~ator further demonstrated by correctly answering
the training test associated with charging HCU accumulators.
Additionally, the inspectors' review revealed that the root cause of
the operator error was associated with the lack of adequate transition
between the charging (DOP 300-6) and draining (DOP 300-11) procedures.
The licensee also determined that the cause of the error was due to an
inadequate procedure instead of operator error or inadequate training
and revised the procedures to provide the correct transition~
(Closed) Unresolved Items (237/88017-03 and 249/88018-03):
DET item
2.2.1.1, determine compliance of HCU draining evolution.
As noted above,
the actual root c_ause was due to inadequate transition between procedures
for charging (DOP 300-6) and draining (DOP 300-11) HCU accumulators.
The licensee adequately identified the actual root cause and provided
corrective actions prior to the issuance of the DET report. This item is
considered closed.
(Closed) Open Items (237/88017-04 and 249/88018-04):
DET item 2.2.1.2,
the control room had uncontrolled piping and instrumentation diagrams
(P&ID) and electrical schematics whith wete used routinely by plant
operations personnel.* At the time of the DET it had been Dresden's
policy to have available uncontrolled P&IDs for "information only" and
require controlled P&IDs issued from the Central File for safety related
activities.
The licensee revised administrative procedure OAP 3-5, "Out
of Service" to state that "only controlled reference material may be
utilized when determi~ing isolation points for an OOS.
Additionally,
the licensee eliminat.ed the "For Information Only" prints, both P&ID and
electrical schematics, from the control room and shift engineer's
office.
The inspector has verified the elimination of uncontrolled
reference material by several.direct inspections of the control room and
shift engineer's office between January and July 1988.
This item is
considered to be closed.
(Closed) Open Items (237/88017-05 and 249/88018-05):
DET item 2.2.1.3,
the poor physical appearance of the control room represented a poor
working environment.
During the DET inspectiQn in August 1987, the
licensee had commenced modification (M12-2/3-86-68) of the control room.
The modification included several human factors revisions, installing
new lighting and changing the overhead and ventilation to reduce noise
and improve lighting of the control room.
The inspectors reviewed the
modification and verified that adequate administrative controls were
in place. Since the activities associated with M12-2/3-86-68 are included
in the routine inspection efforts by the resident inspectors and are being
continuously monitored, this item is considered to be administratively
closed. Additionally, the progress of M12-2/3-86-68 is currently 80%
complete and expected to be complete by September 1988.
(Closed) Open Items (237/88017-06 and 249/88018-06):
DET item 2.2.1.4,
the use of formal overtime by Nuclear Station Operators (NSOs) was
routine, and in a number of cases exceeded station limits. This item
resulted in a Notice of Violation in the resident inspectors' reports
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237/87026 and 249/87025.
Additionally, the inspectors have ~erified
that the licensee's corrective actions have prevented recurrence since
August 1987.
This item is considered to be closed.
(Open) Open Items (237/88017-07 and 249/88018-07):
DET item 2.2.1.5, NRR
to evaluate Technical Specification Table 3.1.1 for adequacy of APRM/IRM
Companion requirements while in the RUN mode of operation.
The inspectors
verified that the licensee has submitted a request for change to Technital
Specification Table 3.1.1 and NRR is evaluating the Technical adequacies
of the request.
(Open) Open Items (237/88017-08 and 249/88018-08):
DET item 2.2.1~5, NRR
to evaluate Technical Specification Surveillance (TS) 4.5.C.1 for adequacy
of testing the High Pressure Coolant Injection (HPCI) system at reactor
pressures between 1150 to 150 psig.
The inspectors verified that the
license~ has submitted a request for change to TS 4.5.C.l.
(Closed) Unresolved Items (237/88017-09 and 249/88018-09):
DET item
2.2.1.6, determine compliance of requal.ification training cycles to
The inspectors verified that the licensee~s requalification
training program had been revised to require mandatory attendance of
all training cycles by all license holder~. This jtem is considered to
be closed.
(Closed) Open Items (237/88017-10 and 249/88018-10):
DET item 2.2:1.6,
verify that a mechanism* exists for evaluation of NSO comments .on training
by the training department.
The inspector verified that the "Training
Inquiry" process was being utilized during training cycle 3 and that the ,
Training Department Policy #14 requires every effort for instructors to
respond to student comments by an assigned ~ate. This item is considered
to be closed.
(Closed) Ope~ Items (237/88017-11 and 249/88018-11):
DET item 2.2.1.7,
the team found that Shift Engineers (SE)* and Shift Control Room Engineers
- (SCRE) were not routinely informed about the schedule of maintenance
activities during their shift. The inspectors have verified through
direct observations and interviews that.maintenance and testing ~ctivities
are being adequately communitated between the Maintenance Department and
Additionally, the licensee has issued Policy Statement
- 19, "Maintenance/Operations Communication Requirements" which contained
clear instructions for informing operations of maintenance activities and
a seven-day rolling schedule of testing activities. Both of these
programs have been effective and, ftS such, this item is considered to be
closed.
(Closed) Open Items (237/88017-12 and 249/88018-12):
DET item 2.2.1.9,
the team found that the NSOs believed that lack of a preventive main-
tenance program contributed significantly to a lack of trust in the
reliability of plant equipment.
For example, recent*modifications to the
Feedwater Control System (FWCS) had resulted in numerous oscillations
within the system.
During September and October 1987, the licensee
aggressively tested the Feedwater System and found that the. oscillations
4
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in the system were due to the Feed-Regulating Valve Actuator design and,
as such, both the NSOs and DET were mistaken in believing that the FWCS
modifications contributed to the oscillations.
The inspectors witnessed
the Feedwater system testing and observed that the operators trust of the
FWCS increased during the testing activities. However, the licensee's
preventive maintenance program has recently been significantly revised and
the effectiveness of this revision is planned to be evaluated by Region
III prior to February 1989, and, as such, this item is administratively
closed.
{Open) Open Items (237/88017-13 and 249/88018-13):
DET item 2.2.1.10,
the team observed that there were considerable activities at Dresden to
improve the performance of the facility, but few long-lasting changes.
The inspectors noted several existing long-lasting changes such as,
personnel errors decreasing from 56 in 1986 to 24 in 1987 and less than
14 for the first half of 1988, scrams reducing from 15 in 1987 to only
one during the first half of 1988, less than 100 days of dual unit
continuous operation increasing to a CECo record of 155 days and an eight
month improving trend on 86 of 88 major performance indicators.
However,
this item will remain open until December 1988 to verify that the improve-
ment trends are maintained for greater than 12 months.
{Open) Unresolved Items (237/88017-14 and 249/88018-14):
DET item
2.2.2.1, 17 drywell MOVs us.ing MOBIL MOBILUX EP-0 grease should be
evaluated. This item is planned to be evaluated by Regi-0n III inspectors
prior to December 1988.
(Closed) Unresolved Items (237/88017-15 and 249/88018-15):
DET item
2.2.2.1, safety related MOV torque switch settings were not based upon
expected d~sign differential pressures and the settings of MOV limit
switches were inconsistent with the procedure guidance. This item is
being tracked by Region *III Open Item Listing 249/87032-01 and, as such,
is administratively closed.
(Closed) Open Items (237/88017-16 and 249/88018-16):
DET item 2.2.2.2,
licensee's root cause analysis program for equipment failures should be
evaluated.
Region III currently is evaluating the program and has
assigned an OIL 249/87008-01, as such, these items are administratively
closed.
(Closed) Unresolved Items (237/88017-17 and 249/88018-17):
DET item
2.2.2.2, the team noted that the HPCI room cooler fan did not have a
preventive maintenance procedure associated with the fan belts such as
DMP 5700-3 for the LPCI room cooler fan belts. The licensee initiated
a preventive maintenance activity to inspect the fans every refueling
outage to ensure fan blades are secured to the shaft, to align drive
belt pulleys and sheaves, to replace the drive belts a*nd to inspect
bearings for wear.
This activity was completed during the Spring 1988
Unit 3 outage and has resulted in no failures of the Unit 3 room cooler
through August 1988.
In addition, the activity has been included in
the General Surveillance Program for future performance during outages
on both units, including the scheduled Fall 1988 Unit 2 outage.
Additionally, fan failures were included in the equipment failure
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analysis per Chapter 16 of the Corporate Conduct of Maintenanc~. This
item is considered to be closed.
(Closed) Unresolved Items (237/88017-18 and 249/88018-18):
DET item
2.2.2.3, maintenance procedures DMP 040-15, 16, 19 and 23 should be
evaluated to verify that guidance is provided for the removal and
installation of MOV motors and pinion gears.
The licensee.deleted the
current procedures of the DMP 40 series and initiated riew electrical
procedures (DEP) for the October 29,* 1988 Unit 2 refueling outage. A
review of the procedures (DEP 040-9, DEP 040-11, DEP 040-17-and DEP
040-18) revealed adequate instructions for removal, installation and
inspection of the motor pinion gear, including a clear drawing showing
the pinion arrangement for SBMs 000-0, 1, 2, 3 & 4. -This item is
considered to be closed.
- (Closed) Unresolved Items (237/88017-19 and 249/88018-19):
DET item
2.2.2.3, maintenance procedures should be evaluated to verify that all
safety related (non-EQ) MOV de motors are encompassed i*n the MOV program.
The licensee initially revised procedure DMP 040-9, "Limitorque Valve
Operator Maintenance," in December 1987, to include safety related,
non-safety related and environmentally qualified de motors by inspecting
brushes and commutator and measuring the motor armature, series and shunt
field megger data.
In addition, a*new procedure, DEP 040-9 was issued to
replace DMP 040-9.
The inspector verified that DEP 040-9 incorporated
the revision to DMP 040-9 and included verification of motor brushes spring
tension. This item is considered to be closed.
(Clos.ed) Open Items (237/88017-20 and 249/88018-20):
DET item 2.2.2.3,
verify that procedure DMP 040-11 is revised to contain a caution statement
to ensure that a valve is back-seated at its normal operating temperatur~.
The inspector verified that procedure DMP 040-11, Electrical Back-seating
of Limitorque Operated Valves," was revised in October 1987 and that
adequate caution statements were included; These c~µtions included
administrative tracking of back-seated valves. This item is considered
closed.
(Open) Unresolved Items (237/88017-21 and 249/88018-21):
DET item
2.2.2.3, corrective maintenance procedures are not established for all
safety-related *and Balance of Plant (BOP) system equipment components.
This item is expected to be resolved prior to August 1989.
(Closed) Open Items (237/88017-22; 237/88017-23; 249/88018-22 and
249/88018-23):
DET item 2.2.2.4, the Work Request trending should be
evaluated for effectiveness of equipment failure trending.
These items
are administratively closed since Region III is currently evaluating
the program per item 249/87008-01.
(Open) Open Items (237/88017-24 and 249/88018-24):
DET item 3.2.3,
measurement and testing equipment (M&TE) should be verified to be
controlled, including logged per DMP 100-2.
No action taken on this
item during this inspection, the item is documented here for tracking
purposes.
6
(Open) Open Items (237/88017-25 and 249/88018-25):
DET item 2.2.2.5,
the maintenance staffing should be evaluated to verify that adequate
personnel are available, including maintenance engineers for procedure
writers and work analysis.
No action taken on this item during this
inspection, the item is documented here for tracking purposes.
(Open) Open Items (237/88017-26 and 249/88018-26):
NRR should review the licensee's second 10 year IST
taken or. this item during this inspection, the item
for tracking purposes.
DET item 2.2.3.1,
program.
No action
is documented here
(Open) Un~esolved Items (~37/88017-27 and 249/88018-27):
DET items
2.2.3.3, 3.3.1, 3.3 .. 2 and 2.2.3.6, verify the adequacy of the IST
program; including comparison of Technical Specifications and ASME to*
the IST program, administrative procedures are in place to control IST,
that all ASM~ XI valves contained in the program are tested, that IST
procedures record "as found" and "as left" values, that all required
testing are performed, evaluated and trended and that the HPCI pumps are
being tested at the standard reference value as required by ASME XI.
No action taken on this item during this inspection, the item is
documented here for tracking purposes.
(Open) Unresolved Items (237/88017-28 and 249/88018-28):
DET item
2.2.3.5, the team found that the pump test results for LPCI and diesel
generator cooling water were outside the acceptance criteria without
corrective actions and documentation.
No action taken on this item
during this inspection, the item is documented here for tracking purposes.
(Closed) Open Items (237/88017-29 and 249/88018-29):
DET item 2.2.4.1,
the retraining classes for licensed and non-licensed operators should be
separated.
The inspector verified that the retraining cycles 1 through
3 had separated the attendance by licensed and non-licensed personnel.
This item is considered to be .closed.
(Open) Open Items (237/88017-30 and 249/88018-30):
DET items 2.2.4.1,
2.2.4.2, 2.2.4.3, 2.2.4.4 and 3.4.2, the team identified training
problems.
These include inadequate plant experience in the training
department, poor classroom instructional practices, inadequate emphasis
on indepth job required knowledge and significant differences between
the GE simulator and Dresden actual systems.
No action taken on this
item during this inspection, the item is documented here for tracking
purposes.
(Closed) Open Items (237/88017-31 and 249/88018-31):
DET item 2.2.5.1,
the Quality Assurance department appears to be understaffed for routine
QA surveillance.
The inspectors have reviewed the QA staffing plan and
evaluated the effectiveness of the QA department.
Although many of the
QA departments are used for non-routine evaluations, the inspectors found
that the QA department has significantly improved in identifying problems
at Dresden, such as failure to follow procedures and resulted in
corrective actions. This item is considered administratively closed since
this item is routinely verified by the inspectors.
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(Closed) Open Items (237/88017-32 and 249/88018-32): * DET item 2.2.5.2,
the QA department appeared to have little active or direct participation
in the development of the Dresden station improvement plan (DSIP)~ The
inspector verified that the QA department directly participates in
monitoring the DSIP through surveillance and audit~ of the various DSIP
action plans.
This item is closed.
(Closed) Unresolved Items (237/88017-33 and 249/88018-33):
DET item
2.2.5.3, Dresden improvement initiatives are fragmented without a
centralized followup or tracking function.
The licensee initiated the
Dresden Station Improvement Plan (DSIP) in October 1987 and implemented
the DSIP action plans.
The action plans contain description of the
plans, goal, and actions to be taken by the implementing department and
measurement standards for completion.
The inspector reviewe*d the DSIP
and found it adequate in controlling and tracking the improvement plans.
Additi6nally, the licensee. assigned the DSIP responsibilities to the
Superintendent of Performance Improvement to ensure centralized control.
This item is considered to be closed.
(Closed) Open Items (237/88017-34 and 249/88018-34):
DET item 2.2.5.4,
ver1fy that the lessons .learned from the Safety System Functional
Inspecticn (SSFI) have been applied to other .systems.
Since the Division
of Reactor Safety is currently monitoring the SSFI efforts at all CECo
facilities, including application of lessons learned, these items are
considered to be administratively closed.
(Open) Open Items (237/88017-35 and 88018-35):
DET item 2.2.5;6, the
Regulatory Assurance Department's internal and external commitment*
tracking system did not adequately address internal discrepancy and
deviation reports.
No action taken on this item during this inspection,
the item is documented here for tracking purposes.
(Closed) Open Items (237/88017-36 and 249/88018-36):
DET item 2.2.6.2,
verify that the backshift Radiation/Chemistry Foremen are providing
adequate job planning, infield support and directing job coverage.
Regional based rad/chem specialist inspectors verified through direct
observation that the backshift foremen adequately provided support during
both normal operating cycles and outages. This item is considered closed.
(Closed) Open Items (237/88017-37 and 88018-37):
DET item 2.2.6.4,
evaluate the acceptance criteria (fit factor of 50) of respirator fit
te~ting. Regional based inspectors evaluated the respirator fit testing
program and found the program to be adequate, including the fit factor.
This item is considered to be closed.
N6 viola~ions or deviations were identified.
3.
Exit Interview ___ (30703)
The inspectors m~t with licensee representatives (denoted under Persons
Contacted) on September 2, 1988, and informally throughout the inspection
period, and summarized the scope and findings of the inspection activities.
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The inspectors also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the inspection.
The licensee did not identify any such
documents/processes as proprietary. *The licensee acknowledged the
findings of the inspection.
9