ML19340A632

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IE Insp Repts 50-010/75-11,50-237/75-16 & 50-249/75-13 on 750513-15,19,20 & 28.Noncompliance Noted:Roll of Nashua Silver Duct Tape Lost in Reactor Vessel & Control Rods Moved While Personnel Working on Platform Over Reactor Vessel
ML19340A632
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/18/1975
From: Johnson P, Knop R, Martin R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19340A627 List:
References
50-010-75-11, 50-10-75-11, 50-237-75-16, 50-249-75-13, NUDOCS 8009020579
Download: ML19340A632 (25)


See also: IR 05000010/1975011

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U. S. NUCLEAR REGULATORY CONIISSION

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OFFICE OF INSEECTION AND ENFORCEMENT

REGICN III

Report of Operations Inspection

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IE' Inspection Report No. 050-010/75-11

IE Inspection Report No. 050-237/75-16

IE Inspection Report No. 050-249/75-13

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Licensee: Com::ionwealth Edison Company

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P. O. Box 767

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Chicago, Illinois

60690

Dresden Nuclear Power Station

License No. DPR-2

Units 1, 2, and 3

License No. DPR-19

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Morris, Illinois

License No. DPR-25

Category:

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Type of Licensee:

GE BWR, 200 and 810 MWe

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Type of Inspection:

Routine, Unannounced

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Dates of Ir .pection:

May 13-15, 19, 20, and 28, 1975

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Principal Inspector:

P . H.

o ngon

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(Date)

Accompanying Inspector:

R. D. Martin

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(Date)

Other Accompanying Peisonnel:

R. C. Knop

Reviewed By:

R. C. Knop

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Senior Reactor Inspector

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(Date)

Projects Unit 1

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SUMMARY OF FINDINGS,

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Inspection Summary

Inspection on May 13-15,19-20 and 28 (Dresden 1, 75-11):

Review of

chemistry and shutdown information from semiannual report. One

noncompliance item related to reporting requirements.

Inspection on May 13-15, 19-20 and 28 (Dresden 2, 75-16):

Review

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of post-ca-

- startup testing, plant operations, abnormal occur-

rences, information contained in semiannual report, limiting con-

ditions for operation, and licensee actions in response to previ-

ous noncompliance. Five nonce =pliance items, related to reporting

requirements, use of maintenance procedures, control of materials

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during in-vessel maintenance, procedures governing control rod move-

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cents, and non-review of previously identified noncompliance items.

Inspection on May 13-15, 19-20, and 28 (Dresden 3, 75-13):

Review

of preparations for refueling outage, plant operations, abnormal

occurrences, information contained in semiannual report, limiting

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conditions for operation, and licensee actions in response to previous

noncompliance. Two noncompliance items, related to reporting require-

ments and non-review of previously identified noncompliance items.

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Enforcement Items

The following items of noncompliance were identified during the

inspection:

A.

Infractions

1.

Contrary to Paragraph 6.2.A of the Dresden 2 Technical

Specifications and Procedur.e No. FWSR 4.0 (sparger removal),

a complete roll of Nashua silver duct tape was lost into

the reactor vessel due to carelessness and failure to follow

prescribed material control procedure. The tape could not

be recovered prior to resumption of plant operation.

(Paragraph 12, Report Details)

This infraction was identified by the inspector and con-

stituted an occurrence with safety significance.

2.

Contrary to Paragraph 6.2.A of the Dresden 2 Technical

Specifications and Procedure DFP 800-1, control rods were

moved while personnel vera working on the service platform

over the onen acactor vessel.

(Paragraph 5, Report Details)

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This infraction was identified by the inspector and had

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the potential for contributing to an occurrence with

safety significance.

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3.

Contrary to Paragraph 6.1.G.2.a(5) of the Dresden 2 and 3

Technical Specifications, enforcement items contained in

inspection reports transmitted by IE:III letters dated

January 13, February 4, and March 27, 1975, and related

correceive actions planned by the licensee were not re-

viewed by the onsite review and investigati.ve function.

(Paragraph 6, Report Details)

This infraction was identified by the inspector and had the

potential for causing or contributing to an occurrence with

safety significance.

4.

Contrary to Paragraphs 6.2.A.6 and 6.2.E of the Dresden 2

Technical Specifications, the 2A recirculation pump seal

was replaced during the recent refueling outage using a

maintenance procedure which had not been approved by the

Dresden Onsite Review function.

(Paragraph 10, Report

Details)

This infraction was identified by the inspector and had

the potential for causing or contributing to an occurrence

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with safety significance.

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B.

Deficiencies

1.

Contrary to Paragraph 6.6.A of the Dresden 2 Technical

Specifications, 24-hour and 10-day written reports to the

NRC were not submitted for the following abnormal occurrences:

a.

The discovery on April 23, 1975, that control rods

were being coved while persornel were on the service

platfor=, contrary to procedure DFP 800-1.

(Paragraph

5, Report Details)

b.

The failure of the unit 2 diesel generator to start

on April 15, 1975.

(Paragraph 3b, Report Details)

c.

Inability to recover a missing roll of duct tape from

he reactor vessel.

(Paragraph 12, Report Details)

This deficiency was identified by the inspector.

2.

Contrary to Para ;raph 6.6.A of the Dresden 1, 2, and 3

Technical Speciftcations, the July-December 1974 semiannual

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report for these Units did not contain the required infor-

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mation on primary coolant chemistry.

(Paragraph 2.a, Report

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Details)

This deficiency was identified by the inspector.

Licensee Action on Previously Identified Enforcement Items

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A.

The licensee has co=pleted corrective actions re, lated to nuclear

engineer qualifications and rod drive maintenance procedure

as

identified in his letter dated April 17, 1975.

(Paragraphs 6.a

and 6.b, Report Details)

B.

The licensee has co=pleted corrective actions related to adequacy

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of procedure review as identified in his letter dated February 20,

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1975.

(Paragraph 6.c, Report Details)

C.

The licensee has completed corrective c;tions related to excessive

containment at=csphere oxygen concentration, as identified in his

letter dated January 31, 1975.

(Paragraph 6.d, Report Details)

Other Significant Items

A.

Systems and Cceponents

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1.

Four valves in Dresden 1 found by the licensee to have less

than design wall thickness were determined to be acceptable

for continued operation.

(Paragraph 15, Report Details)

2.

Dresden 3 fuel sipping results showed 113 fual bundles to be

leaking, located predominant?.y in the vicinity of control

rods which were withdrawn in regions cf high local power on

October 31, 1974.

(Paragraph 13, Report Details)

B.

Facility Items (Plans and Procedures)

None.

C.

Managerial Items

None.

D.

Nonco=pliance Identified and Corrected by Licensee

None.

E.

Deviation.

None.

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F.

Status of Previously Report Unresolved Items

Not re~ieved.

Management inserview

The inspectors conducted a management interview with Mr. Stephenson

(Station Superintendent) and members of his staff at the conclusion

of the inspection. The following matters were discussed:

A.

The inspector informed the licensee that a selective review of

facility records was conducted for Units 1, 2, and 3 to compare that

information with that presented in the semiannual report for those

units. No discrepancies were found during this comparsion.

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However, an apparent item of noncompliance was determined when

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comparing the content of the semiannual report against the require-

ments of Technical Specification 6.6.A for all three units. The

semiannual report does not contain tne required information on

primary coolant chemistry. The licensee indicated that the

appropriate information had been accumulated and that the problem

would be researched further to determine the appropriate action.

(Paragraph 2.a, Report Details)

B.

The inspector informed the licensee that he had perforaed a review

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of the actions taken by the station with respect tc selected ab-

normal occurrences reported to the NRC, with no discrepancies

noted.

(Paragraph 3, Report Details)

C.

The inspector stated that he had conducted a review of selected

aspects of routine plant operation including checksheet and log-

book reviews, control room manning, and a tour of the Unit 2 and

Unit 3 reactor buildings. He informed the licensee of the follow-

ing:

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1.

The tour of the faciIlity disclosed a number of instances of

poor housekeeping practices. On one occasion, a tour of

the Unit 2 drywell just prior to closure at the end of the

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outage had. disclosed poor housekeeping conditions.

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considerable debris was seen in the downcomers

to the torus, which contains reactor grade water.

(Paragraph

4.d, Report Details) The inspectors requested and r_ceived

a commitment from the licensee that a tour of the facility

would be conducted by senior staff personnel to evaluate

facility housekeeping practices.

2.

The review of the shif t engineer's logbooks disclosed that

during the period of April 21-23, 1975, control rod friction

tests were conducted while personnel were on the service

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platform. The operating staff became aware on April 23

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that this activity was contrary to procedure DFP 800-1

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and took steps to prevent a recurrence.

However, these

steps were inadequate, and another instance of rod move-

ment with personnel on the service platform occurred on

the morning of April 24. This failure to follow procedural

requirements was noted to be an item of noncompliance. The

licensee failed to recognize this as a reportable event

until after discussions with the inspector during this inspec-

tion. This failure to report the event within the required

time period was stated to also be in noncompliance with

Technical Specification requirements.

(Paragraph 5, Report

Details)

3.

The review of the shift engineer's log also revealed an

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instance of the Unit 2 diesel generator failing to start on

April 15, 1975. This failure to start was not related to the

maintenance work which had been performed on the unit prior

to this test. The licensee failed to recognize this as a

reportable event until after discussions with the inspector

during this inspection. This failure to report within the

required time period was noted to be contrary to Technical

Specifications requirements.

(Paragraph 3.b, Report Details)

D.

The inspector requested and received a co=mitment from the

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licensee that an evaluation would be conducted to determine the

need for the jumpers (1-72 and 2-72) placed in 1969 which defeat

the rod block interlock on the service platform hoist.

The

licensee also stated that if their continued use is indicated,

a design change would be considered ratt.er than the continued,

prolonged use of jumpers.

(Paragraph 4.e, Report Details)

E.

The inspector stated that previous enforcement items ideatified

in three licensee responses had not been reviewed by the Dresden

onsite review function, in 9oncompliance with Technical Specifi-

cations requirements. The licensee stated that steps would be

taken to provide th'e required reviews. The inspector noted that

this was a repeat offense, in that a citation had been issued for

the same omission within the previous year.

(Paragraph 6 Report

Details)

F.

The inspector stated that during review of plans for the Dresden

3 outage it had been noted that the 2A recirculation pump seal

had been replaced using an unapproved maintenance procedure, in

ncncompliance with Technical Specifications requirements. The

licensee replied that the station staff had been writing many

maintenance procedures, and that the effort would be expanded

to cover this and other areas.

(Paragraph 10, Report Details)

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G.

The inspector stated that the carelessness involved in the

loss of a roll of tape into the Unit 2 reactor vessel

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represented noncompliance in that precautions required by

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the governing maintenance procedure had not been taken.

The inspector noted that the event also had not been

formally reported as required by the Technical specifications.

(Paragraph 12, Report Details)

H.

The inspector stated that several recent events at the

Dresden station, including the loss of the roll of tape,

rod movements with personnel on the equipment platform,

withdrawal of two adjacent control rods during refueling,

and fuel damage caused by i= proper rod movements caused con-

cern with respect to the adequacy of co'ntrol of plant

activities. The inspector stated that action was needed

to bring about a noticeable increase in middle-manage =ent

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awareness of plant activities. The licensee replied that

a new engineering assistant had been assigned to the dayshift

Shif t Engineer, but that the Shif t Engineer was still a very,

busy man during a refueling outage.

I.

The inspector summarized the followup review of previous

enforecnent items. With respect to the licensee's response

of February 20, 1975, which identified the addition of three

senior licensed operators to the technical staff as part of

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the licensee's corrective action, the inspector noted that

one of these senior licensed operators was now scheduled f<r

transfer away from the Dresden Station. The licensee stated

that this was made necessatf by manning requirements for the

new La Salia County Station.

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The inspector noted that Dresden 2 was being returned to

power operation faster than initially scheduled, and ex-

pressed concern that all required activities be accomplished

prior to and during the return to operation. The licensee

acknowledged the inspector's co= ment.

K.

The Unit 3 fuel sipping results were discussed, with respect

to the October 31, 1974, rod withdrawal event.

In response

to a question from the inspector, the licensee stated that a

followup report discussing the October 31 event and its

consequences would be provided to the NRC by June 20, 1975.

(Paragraph 13, Report Details)

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The inspector noted that another off-gas detonation had occurred.

with no cause identified. He stated the* the licensee should

consider actions v .ich would aid in the investigation of any

future detonation. The licensee acknovledged the inspector's

co==ent.

(Paragraph 11, Report Details)

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REPORT DETAILS

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PART I

Prepared by P. H. Johnson and R. D. Martin

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Persons Contacted

B. Stephenson, Station Superintendent'

A. I ,berts, Assistant Superintendent

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D. Butterfield, Administrative Assistant

G. Abrell, Unit 2 Operating Engineer

D. Adam, Rad / Chem Supervisor

G..Bergan, Chenist

E. Bussean, Engineering Assistant

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R. Cozzi, Engineering Assistant

J. Dolter, Leading Nuclear Engineer

R. Dyer, Job Planner

G. Heintz, Nuclear Station Operator

W. Hildy, Instrument Engineer

E. Johnson, QC Inspector

J. Kolanowski, Unit 2 Leading Engineer

G. Lamping, Maintenance Staff Assistant

C. Lawton, Office Supervisor

C. Maney, Engineering Assistant

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J. Marshall, Unit 3 Leading Engineer

Lt. Hayer, Pinkerton Guard Force

R. Meadows, Engineering Assistant

E. Petrowsky, Nuclear Engineer

R. Ragan, Unit 3 Operating Engineer

R. Thomas, Instrument Maintenance Foreman

T. Watts, Technical Staff Supervisor

M. Wright, QC Engineer

2.

Rev!.ew of Semiannual Report

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Tha inspector conducted a selective review of the operating and

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maintenance section of the Semiannual Report for Dresder. Station

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for the psriod of July 1,1974 through December 11, 1974.

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a.

Conten: Review.

The report content was compared against the

required content discussed in Revision 1 to Regulatory Guide

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1.16.

The report contained sections on:

(1) Operations Summary

(2)

Power Generation

(3)

Shutdowns

(4) Maintenance

(5)

Changes, Tests, and Experiments

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However, the inspector did not find any data which provided

a tabulation on a monthly basis of the maximum, average,

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minimma values of selected primary coolant system chemistry

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parameters as called for in Section C.1.a. (3)(f) of Regulatory

Guide 1.16.(Rev.1). A review of the data in the Semiannual

Report dealing with radioactive waste, environmental monitor-

ing, and occupational personnel radiation exposure also failed

to disclose this information on coolant chemistry.

This

omission was pointed out to the licensee as an item of non-

compliance.

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b.

Shutdowns Review. The inspector compared the shutdown in-

formation contained in the Semiannual Report with Shift

Engineer Logbook entries.

Dates reviewed were:

Unit 1

Unit 2

Unit 3

7/3/74 @ 2148 hrs

8/23/74 G 0230 hrs

7/1/74 @ 0001 hrs

7/5/74 @ 0125 hrs

9/1/74 0 0900 hrs

7/22/74 9 0421 hrs

10/15/74 @ 1238 hrs

9/3/74 @ 0504 hrs

8/15/74 i 1620 hrs

10/15/74 @ 2211 hrs 10/19/74 @ 0320 '..s

11/8/74 @ 1858 hrs

10/16/74 @ 0418 hrs

11/2/74 @ 0327 hrs 11/9/74 @ 1110 hrs

No deficiencies were noted between the information in the

report and that contained in the Shift Engineer's log.

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3.

Abnormal Occurrence Review (Units 2 and 3)

A review of reporting, corrective actions, licensee review and

evaluation, and co=pliance with regulatory requirements was

conducted for the following abnormal occurrences and unusual

events related to Units 2 and 3:

Event Title

Event Date

Licensee Report Date

Unit 2

1.

Failure of Core Spray Valve MO-2-

2/28/75

3/10/75

1402-24A To Open

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Main Steam Line Low Pressure

3/17/75

3/27/75

Instrument Drift

3.

Unit 2 Diesel Generator Fa11cr to Come 3/19/75

3/27/75

up To Voltage

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Violation of Secondary Containment

3/21/75

3/31/75

5.

Unit 2 Diesel Generator Field Failed

4/5/75

4/15/75

To Flash

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Freon Leakage 1%

4/16/75

4/23/75

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Event Title

Event Date

Licensee Report Date

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2A MSIV Mot-Full-Open Scram

2/28/75

3/7/75

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Failure of Core Spray Valve 3-1402-4A

2/25/75 ;

3/19/75

To Close

3/1/75 and

3/4/75

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Thermal Trip of LPCI Valve 3-1501-5A

3/4/75

4/3/75

10.

Main Steam Line Radiation Monitor

3/18/75

3/27/75

setpoint Drift

11.

Core Spray Valve M0-3-1402-4A Failure

3/24/75

4/4/75

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Broken Test Line on Penetration X-105D 4/16/75

4/25/75

The inspector's review included discussions of each event with

licensee representatives and an examination of the report ref-

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erenced above as well as other documents related to the parti-

cular areas reviewed. The following corments resulted from the

inspector's review:

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a.

Event No. 1 - This event referred to the inability to open

valve M0-2-2402-24A with an operator-initiated signal from

the control room whenever valve M0-2-1402-25A is open. The

licensee's report indicated that at the time of the report,

it was not possible to verify their conclusion because the

motor operators were removed from the valves in question.

The inspector reviewed WR 2870 and 2753 in which the con-

clusions were verified and the conformance of the installa-

tion to the original design was also verified. This inter-

-locking of the valves was intentional and the operator

checked the valves in the wrong sequence. During the inte-

grated ECCS test conducted on May 13-14, 1975, the licensee

verified that this interlock design does not interfere with

the automatic actuation of core spray.

The interlock causes

difficulty only when operator-initiated valve checks are

conducted. The inspector had no further questions on this

matter.

b.

Events No. 3 and 5 - These two events were related in that

they both involved the failure of the Unit 2 diesel genera-

tor to develop output voltage.

Event 5 was the determination

of the actual cause (a capacitor failure) whereas event 3

related to the apparent cause (a relay malfunction). The

inspector reviewed WR 4330 (Job No. 591) under which the

condensers were replaced. He also reviewed the successful

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test results of procedure 6600-S-I conducted on April 18,

1975. The time delay between the event (April 5, 1975) cnd

declaring the diesel operable (April 18,1975) was caused

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by an additional malfunction of the air starting motor

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system on April 15, 1975. On that date, the diesel genera-

tor was returned to service for testing following the

capacitor repairs. The diesel, however, failed to start

because of starting motor problems, and it was taken out of

service to repair those motors.

The failure of the licensee

to recognize this starting failure as an abnormal occurrence

was noted to be in noncompliance with Technical Specifications

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requirements.

c.

Event No. 6 - This abnormal occurrence related to a Freon

leak rate test performed on Train 'A'

of the Standby Gas

Treatment System (SBGTS) which gave results in excess of the

limits in Technical Specification 4.7.B.l.b.(2).

The inspector

reviewed WR 4638 which called for replacement and r< testing

of tne units. He also reviewed the test results of procedure

38-7500-S-I, II, and III conducted on April 18,, l??5, after

the repairs had been completed. The inspector had no further

questions on this matter,

d.

Event No. 12 - This event related to a broken leak test line

to the bellows seal for drywell penetration X-105D. The

inspector reviewed WR 4671 which governed the repair of the

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line and included copies of the approved procedure for the

veld repair along with copies of the certifications of the

welders used in the repair. He also reviewed the results of

procedure 38-1600-S-1 which retested the leak rate and no

leakage was measured. This event apparently occurred

because personnel stood on the penetration while conducting

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maintenance in the X-area. To prevent this kind of activity

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frcs recurring, the licensee, in his report, stated that

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grating would be installed in the area. As of the date of

this inspection, the grat1ng was installed in Unit 2, and the

installation was in progress on Unit 3.

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4.

Review of Plant Operations (Dresden 2 and 3)

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The inspector conducted a review of selected aspects of plant

operation. The results of this review are summarized in the

following paragraphs.

a.

Logbook Entries. The inspector reviewed logbook entries

covering the period of March 1, 1975 - May 15, 1975, con-

tained in the following logbooks:

(1)

Shift Engineer Log

(2)

Control Room Log

(3) Unit 2 Operator Log

(4) Unit 3 Operator Log

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No significant deficiencies were noted with regard to

clarity of entries, adequacy of detail, or accuracy of

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logbook entries. The logbooks examined showed evidence

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of review by senior staff personnel. However, entries in

Volume 234 of the Shift Engineer's Logbook made the inspec-

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tor aware of a procedural violation regarding the move-

ments of control' rods on Unit 2 while personnel were on

the service platform. This subject is discussed further

in paragraph 3 of this section of the report,

b.

Routine Checks. The checklists (shift, daily, weekly, and

monthly) completed by Operations-personnel for the months

of March and April, 1975 were reviewed for Units 2 and 3.

No discrepancies were observed by the inspector.

c.

Plant and Control Room Staffing. The staffing for the

plant as recorded in the Control Room Log was selectively

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co= pared against the " Minimum Shift Manning Chart" contained

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in Section 6 of the Technical Specificat1ons for Units 1, 2.

and 3.

The dates selected for the review were:

April 6,1975

April 21, 1975

April 12,1975

May 3, 1975

April 14,1975

May 8, 1975

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In the cases reviewed, the plant staffing met or exceeded

the minimum shif t manning require =ents.

d.

Plant Tour. The inspector conducted a tour of portions of

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the Reactor, Turbine, and Radwaste Buildings for Unit 2 and

3.

The following observations are considered noteworthy:

(1) Preliminary visual inspection of the feedwater spargers

for Unit 3 had been completed. Cleaning of the spargers

to permit dye penetrant inspection was just being com-

pleted.

(Later in the inspection, a visual reexamina-

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tion after this cleaning revealed the existence of

several cracka in the sparger.)

(2) The existence of a number of housekeeping problems was

noted, including trash in cable trays, excessive pu=p

packing leakage, water on floors, and oil soaked com-

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bustibles under the oil coolers at the recirculating

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pump motor generator sets.

A tour of the Unit 2 drywell

shortly before scheduled closure also showed poor house-

keeping conditions, particularly debris in the

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downcomers ; to the torus, which contains reacter

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grade water. These conditions led to the request

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for a commitment from the licensee that senior. staff

would conduct a housekeeping inspection of the facility.

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(3)

Fuel sipping of the Unit 3 fuel was essentially com-

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pleted.

e.

Jumper Log.

The Jumper log was reviewed and no deficiencies

were observed as to the manner in which jumpers were being

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placed and the entries made. However, it was noted that

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several entries were related to jumpers which had been in

place for a substantial period of time.

Fo'r example, Jumpers

1-72 and 2-72 were placed in 1969 to eliminate the rod block

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from the service platform. Discussions with facility staff

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members showed that there was general agreement that these

ju=pers were still necessary.

Because of a feature of the

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control wiring for the service platform, disconnecting the

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control cables for that platform would establish a rod block,

Thus, without the jumpers, removal of the service platform

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in preparation for reactor start-up would, in fact, prevent

that start-up.

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This condition led the inspector to obtain a commitment

from the licensee that jumpers which have been in use for

extended per1ods of time be reevaluated as to their con-

tinued need.

If their continued use is indicated, the

-

,

4

licensee should consider appropriate design changes in

place of the prolonged use of temporary connections.

(See

paragraph D of Management Interview section of this report)

'

5.

Control Rod Movenent With Personnel on Service Pla_tform

4

As mentioned in paragraph 4.a. of this report, a review of the

,

Shif t Engineer's Logbook revealed an instance of a procedural

violatica in that control rods on Unit 2 were moved while per-

sonnel were on the service platform. The pertinent details are

,

summarized in the following paragraphs:

a.

At 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> on April 21, 1975, friction testing of the

control rod drives vcs begun. Friction testing consists

of fully. withdrawing a control rod and then inserting it

continuously and measuring the differential pressure across

the drive piston necessary to achieve this insertion. This

,

differential pressure is a measure of the total forces

'

(including friction) necessary to procuce movement. Values

of differential pressure outside c-

allowed limits call

for further testing and evaluation.

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b.

Section D " precautions" of Procedure DFP 800-1, Revision 0,

April 1975, (approved April 18, 1975), which is the controlling

-

procedure for unit refueling, requires that personnel evac-

.

uate all areas from which the grid of the reactor vessel may

be viewed any- time a control rod is to be witndrawn.

In

discussions with staff members, it appears that fuel handling

personnel brought this requirement to the attention of opera-

tions personnel on April 23, 1975. The friction testing

procedure, 38-300-S-I (Revision 0, February,1973) does not

contain the above precautionary comment.

,

c.

By entry in the Shift Engineer's Log (Volume 234, page 94)

and a Daily Order covering the period 23 April to 24 April

1975, friction resting was halted.

Neither of these entries

was specific as to indicating that friction testing must

not be undertaken whenever people were on the platform or in

),

the line of sight of the core.

d.

From entries on page 99 of Volume 234 of the Shift Engineer's

Log, personnel lef t the platform at 0001 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, on April 24,

and frictirn testing was resumed. Another entry indicated

that at 0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, the Shift Engineer was informed by the

contractor working that no one would be on the platform for

the remainder of the shift. However, when fuel handling per-

sonnel returned from a lunch break at 0435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br />, they found

_

contractor personnel on the service platform. The logbook

entrics are such that the inspector concluded that rods had

been moved during this period (0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> - 0435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br />),

while personnel may have been on the service platform.

The licensee was informed that the violation of the requirements

of procedure DFP 800-1 constituted an item of noncompliance. The

inspector also noted that the occurrence was reportable under the

require: nets of Section 6.6A of the Unit 2 Technical Specifications,

and failure to report this occurrence within the required time

period is an item of nonco=pliance.

(This item was later reported

to the NRC while the inspection was still in progress.)

6.

Followun on Previous Ncncompliance (Dresden 2 and 3)

The inspection included review of the licensee's corrective actions

in response to certain previously identified noncompliance items,

as discussed below. During this review, on additional noncompliance

item was noted, in that the onsite review function had not reviewed

the items of noncompliance and recommended actions to prevent recur-

rence, as required by Paragraph 6.1.G.2.a(5) of the Technical

Specifications.

Enforeccent items reviewed were as follows:

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Nuclear Engineer Qualification.f/ Related corrective actions,

a.

lj

as described in the licensee's letter dated April 17, 1975,

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were verified to have been completed.

.

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b '.

Control Rod Drive Maintenance Procedures.,2_/ Corrective actions

were.found to have been accomplished as descr,1 bed in the

licensee's April 17, 1975 letter. The inspector reviewed a

i

revised and DOSR-approved maintenance procedure which was to

be used for Unit 3 control rod drive maintenance.

Throughness'of Procedure Reviews.:3_/ The inspector's review

c.

determined the licensee's corrective actions as described

in his letter dated February 20, 1975, to have been' completed.

The inspector noted, however, that one of the three engineers

possessing senior reactor operator licenses who had been added

to the technical staff, as stated in the licensee's letter,

1

was scheduled to be transferred to La Salle County Station

following the Unit 3 refueling outage.

d.

Containment Inerting Requirements.4/ The inspector verified

,

nitrogen inerting procedure 8500-1 to have been revised as

discussed in the licensee's January 31, 1975, letter. The

revised procedure specifies (1) a check of the nitrogen tank

level prior to inerting, (2) ordering additional nitrogen if

'

required, and (3) initiating unit shutdown if additional

nitrogen is needed and has not been received within sixteen

,

!

hours after placing the reactor in the run mode.

7.

Safety Limits and Limiting Safety System Settings

(Dresden 2 and.3)

Selected safety limits, limiting safety system settings, and

limiting conditions'for operation were reviewed for the reactor

coolant system, reactivity and power control systems, and reactor

core and internals, as follows (numbers in parenthesis indicate

.

technical specifications references):

!

,

a.

Low reactor level scram setpoint (2.1.C) - reviewed for

January 1975, Units 2 and 3.

b.

Reactor vessel shell-flange differential tnmperature limit

(3.6.A) - verified for Unit 2 cooldown performed in November

-

1974.

1/ IE Inspection Rpt. No. 050-249/75-06.

2/ IE Inspection Rpt. No. 050-237/75-06.

3/ R0 Inspection Rpt. No. 050-237/74-11.

4/ RO Inspection Rpt. No. 050-249/74-12.

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Reactor vessel venting requirements (3.6.B.1) - reviewed

c.

during initial period of current refueling outages, Units

2 and 3.

.

1

d.

Stud tensioning limitation (3.6.B.2) - verified for portions

of current refueling outages, Dresden 2 & 3.

Verification of jet pump flow indication (3.6 G.2) - reviewed

j

e.

verification prior to initial post-outage startup of Unit 2.

f.

High pressure' scram setpoints (2'.2.A) - rev'iewed for February -

April (Unit 3) and May (Unit 2), 1975.

g.

APRM scram and rod block settings (2.1.A and 2.1.B) - reviewed

for April - May (Unit 2) and February - April (Unit 3),1975.

No discrepancies were noted during review of the activities listed

above.

8.

Startuo Testing (Dresden 2)

,

The inspector reviewed records of selected startup testing activities

,

as follows:

b

t

a.

Control Rod Scram Time Tests.

No comments.

_

b.

Shutdown Margin Demonstration. The reactor was demonstrated

to be suberitical with the three highest worth rods fully

withdrawn.

c.

Rod Worth Minimizer Checks. The original test records for

this test could not initially be located, but were subse-

quently seen to have been filed in the startup test file.

Acceptable performance of the rod worth minimizer for rod

sequences Al and B1 was verified on May 18, 1975.

d.

Jet Pump Operability. Flow ' indication from all jet pumps

,-

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was verified prior to startup as required by Paragraph

3.6.G.2 of the Technical Specifications. This verification

was documented by an informal memorandum signed by the

shift engineer.

9.

Post-Refueling Review of Plant Operations (Dresden 2)

The inspector reviewed without comment the following documents

related to the return of Dresden 2 to operation:

a.

LPRM Resistance and Plateau Checks

,

b.

Control Rod Withdrawal Sequence, Approved 5/16/75

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10.

Maior Maintenance Activities (Dresden 3)

The inspector reviewed approved procedures for control rod drive

maintenance, repainting of the torus, replacement of 3B recircu-

lation pump seals, and modification of the scram discharge volume.

The torus painting procedure was noted to provide for coating

portions of the wetted surface of the torus using' six different

protective coatings to determine which coating provides the most

effective protection. No Unit 3 discrepancies were noted.

<

During examination of procedures for replacement of the 3B recir-

culation pump seal, the inspector examined a completed work pack-

aga for replacement of the 2A recirculation pump seal, completed

on December 30, 1974.

The maintenance procedure used for this

replacecent was noted not to have been approved by the Dresden

Onsite Review (DOSR) function. A representative stated that the

procedure had been taken from the vendor's manual; however,

examinntion of the vendor's manual show that significant amounts

,

of additional detail had been added to the procedure, to the

effect that it was a procedure prepared by station personnel.

The inspector stated that use of the procedure without DOSR

approval represented noncompliance with Paragraph 6.2.E of the

Technical Specifications.

11.

Off-gas detonation (Dresden 2)

-

A licensee report 5/ discussed an off-gas detonation which

occurred on May 26, 1975. Review of the control roca log and

discussion with licensee representatives showed the detonation

to have occurred approximately 8 minutes after the recombiner

outlet valve was opened to bleed off a pressure of about 15

psig whi:h had accumulated in the recembiner and its condenser

due to air purge. Whether the detonation occured before or

after opening of the recombiner inlet valve was not clear. The

control room log showed a power reduction to have commenced one

minute after the detonation. Based on review of recorder charts

and discussion with a licensee representative, the stack release

rate was determined to have peaked at approximately 1500,cCi/sec

following the detonation, returning to near its original value

of 300suci/sec within approximately 30 minutes.

5,/

Ltr.,Stephenson to Keppler, dtd 6/5/75

(A0 Rpt No. 75-35).

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12.

Loss of-Tape Roll in Reactor Vessel (Dresden 2)

,

-Prior to the inspection, a licensee representative discussed with

the inspector efforts being taken to recover a missing roll cf

,

Nashua silver duct tape lost in the reactor vessel .

Review of

this event during the inspection resulted in the following find-

ings:

a.

The roll of tape was lost in the reactor vessel on January

16 while' failed feedwater spargers2/ were being removed.

General Electric contractor personnel. were working in the

reactor vessel on a temporary platform seated on the steam

separator supports. The platform was smaller than the

reactor vessel internal diameter, such that an open annulus

was lef t between the platform and the reactor vessel wall.

Representatives stated that one worker in the reactor vessel

requested an additional roll of duct tape from another

worker who was present on the refueling floor. The latter

then responded by throwing a complete roll of tape into the

reactor vessel. The roll of tape was not caught by any of

the individuals on the work platform and was seen to dio-

appear over the edge of the platform into the reactor

vessel, in the vicinity of a recirulation suction line.

-

b.

Internal licensee reports discussed efforts cade to locate

the roll of tape, inacdiately following its loss and con-

tinuing through the end of April. These efforts relied

principally upon the use of binoculars and underwater TV

cameras, and included internal inspection of the recircu-

-

lation suction piping and inspection of portions of the

shutdown cooling system (which was in operation at the

time of loss, with' inlet flow from the recirculation pump

suction line). The search for the roll of tape was

unsuccessfully terminated on May 5, and the reactor vessel

head was reinstalled shortly thereafter.

c.

A licensee representative assigned to follow the feedwater

sparger replacement stated that tool control inside the

vessel had generally been good, although he had pointed

out to contractor personnel on a limited number of occa-

sions that items in the reactor' vessel were not secured.

In particular, an unsecured roll of tape had been noted on

two occasions.

6/

IE Inspection' Rpt No. 050-237/75-01.

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d.

Procedure No. FWSR 4.0, feedwater sparger removal, stated

in Paragraph 5.8, " Care shall be exercised to prevent in-

advertent loss into the reactor pressure vessel of any

piece of tooling, material, or equipment." The inspector

,

informed the licensee that the loss of the roll of tape

~

represented noncompliance with the procedure, in that care

was not taken to prevent its inadvertent loss. To the

contrary, the likelihood of loss was greatly increased by

the negligence involved in throwing the roll of tape into

,

the reactor vessel.

,

The safety evaluation performed by the licensee and reported

e.

7

in an abnormal occurrence report / concluded that "it is

highly improbable that the tape residue could cause flow

blockage of any given fuel asse=bly of 90%.

Blockages

greater than 90% must result before critical heat flux

first occurs." Tests performed by the licensee and by

General Electric Company showed that the roll of tape can

be expected to deteriorate to a brittle residue within 2 to

3 days at reactor conditions; the residue would subsequently

be expected to break apart and be removed by the reactor

water cleanup system.

f.

During the management interview conducted on May 20, the

inspector noted that the licensee was also in noncompliance

with reporting requirements in that the loss of the roll of

tape had not been formally reported as an abnormal occurrence'

-

as required by the Technical Specifications and P.egulatory

,

Guide 1.16, which defines abnormal occurrences to include

]

" observed inadequacies in the implementation of administra-

tive or procedural controls such that the inadequacy causes

!

or threatens to cause the existence or development of an

a

unsafe condition in connection with the operation of the

l

plant." The inspector noted that although he had been

I

informally advised of the occurrence, prompt and ten-day

I

written notifications had not been made.

The inspector

j

"

acknowledged that upon its initial loss into the vessel,

the event could rersonably not have been considered an

l

abnormal occurrence, in that recovery was at that time

anticipated. However, the event should have been reclassi-

fied an abnormal occurrence when recovery efforts were

terminated and the reactor vessel head was installed.

,

2/

Ler..Stephenson to Keppler dtd 5/23/75

(A0 Rpt No. 75-44).

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13.

Fuel Sipping Results (Dresden 3)

-

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Out-of-core fuel sipping results obtained from a licensee repre-

l

sentative during and subsequent to the inspection showed 113 of

!

the installed 724 fuel bundles to be Icaking

(Iodine-131 greater

i

than background). Approximately 20 of these appeared to be ran-

j

domly dispersed throughout the core, with the balance of the

failed bundles located in the vicinity of control rods which were

withdrawn under high' local power conditions during the event which

occurred on October 31,1974.8/ A core diagram' showing the loca-

tion of the failed fuel bundles and the involved control rods is

]

attached to this report. The licensee representative stated that

no 8 x 8 or i= proved 7 x 7 (GE3) fuel bundle was included in the

,

'

112 bundles found to be leaking.

In response to a question from

.

'

the inspector during the management interview, the licensee stated

-

'

that a followup report on the October 31, 1974, event would be

submitted to the NRC by June 20, 1975.

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8/

Ltr., Stephenson to Keppler dtd 1/17/75

(AO.Rpt No. 74-38).

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.

REPORT DETAILS

.

Part II

-

Prepared by:

f5

Ead'[

7//I/I

C. M. Erb

./(Date)

h'M'

M8

7//f/7 5'

Reviewed by: f

ha

J. C. LeDoux

V(Date)

,

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/

14.

Persons Contacted

'

2

Commonwealth Edison Ceepany (CECO)

.

,

i

J. Wujciga, Technical Staff

i

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15.

Valve Wall Thickness Measurecents (Dresden 1)

f

a.

Historv

1

During the valve wall thickness verification program at

!

D-1, four stainless steel Globe valves purchased by General

-

Electric in 1958 from Chapman Valve Co. indicated wall

thickness below the 0.719" thickness which was the lower

li=it for 900 lb. valves.

Investigation shows that these valves were in a special

category, which derives from a 100% radiographic inspection

at the source of the pressure retaining walls prior to

assembly.

b.

Desi9n Review Actions

These valves were procured to be used under design conditions

,

of 1250 psig and 573 degrees

F., and operating conditions of

,

'

1035 psig and 575 degrees F.

Chapman has submitted and CECO has verified, calculations

>

for these special valves showing that they meet the require-

'

ments of the Manufacturer's Standardization document,

,

MSS-SP-66, which is accepted by the valve industry.

These

calculations show that a minimum wall thickness of 0.515

would be adequate for the design conditions.

s

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The minimum wall thickness actually found was 0.641" which

~

occurred in Valve No. MO-173.

The inspector verified that

-

the calculations were on file and that these valves are

acceptable for continuing service.

Attachment:

Dresden 3 Fuel ' Sipping Results

e

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e

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IRESDEN U! TIT

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ow

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Fuel failures, based upon out-of-core sipping conduct'ed during 3rd refueling

.

outage, April-May 1975

Rods withdrawn at high local power on October 31, 1974:

C-6, C-10, N-6, N-10 and (to lesser degree) C-8, G-8, J-8, N-8

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