IR 05000237/2009006

IR 05000237-09-006, 05000249-09-006; 05/04/2009 - 05/22/2009; Dresden Nuclear Power Station, Units 2 and 3; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

ML091660594
Person / Time
Site:	Dresden
Issue date:	06/15/2009
From:	Robert Daley Engineering Branch 3
To:	Pardee C Exelon Generation Co, Exelon Nuclear
References
IR-09-006
Download: ML091660594 (18)

Text

une 15, 2009

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000237/2009006; 05000249/2009006

Dear Mr. Pardee:

On May 22, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications inspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed report documents the inspection findings, which were discussed on May 22, 2009, with Mr. T. Hanley and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section VI.A.1 of the NRC Enforcement Policy.

If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -

Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Dresden Nuclear Power Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Dresden Nuclear Power Station. The information that you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by A. Dahbur Acting For/

Robert Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 Enclosure: Inspection Report 05000237/2009006; 05000249/2009006 w/Attachment: Supplemental Information cc w/encl: Site Vice President - Dresden Nuclear Power Station Plant Manager - Dresden Nuclear Power Station Manager Regulatory Assurance - Dresden Nuclear Power Station Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden, and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer, Illinois Emergency Management Agency Chairman, Illinois Commerce Commission

SUMMARY OF FINDINGS

IR 05000237/2009006, 05000249/2009006; 05/04/2009 - 05/22/2009; Dresden Nuclear Power

Station, Units 2 and 3; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.

This report covers a two-week announced baseline inspection on Evaluations of Changes,

Tests, or Experiments and Permanent Plant Modifications. The inspection was conducted by Region III based engineering inspectors. One Green finding was identified by the inspectors.

The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

A finding of very low safety significance and associated non-cited violation of license conditions 2.E and 3.G for Units 2 and 3, respectively, was identified by the inspectors for the failure to restore the Unit 1 diesel-driven fire pump to an operable condition within seven days as required by Technical Requirements Manual (TRM)3.7.i.A.1. Specifically, the Unit 1 fire pump discharge valve was found closed rendering the pump inoperable for greater than seven days. Upon discovery of the valve in the closed position the licensee repositioned the valve in the correct locked open position and initiated Action Requests (AR) 922581 and 922585.

This finding is more than minor because the failure to provide the two required fire pumps could have resulted in a failure of the stations water based fire protection system should the Unit 2/3 fire pump have been out-of-service at the same time. The finding screened as very low safety significance because the performance of the system was not affected by the closed valve as the Unit 2/3 diesel-driven fire pump remained operable to provide water to the stations fire protection system, if required. This finding has a cross-cutting aspect in the area of human performance, work control because the licensee did not properly plan and coordinate activities consistent with nuclear safety.

Specifically, the licensee failed to restore the Unit 1 diesel-driven fire pump to an operable condition within seven days as required by TRM 3.7.i.A.1 as a result of ineffective communications between licensee personnel to verify that valve 1-4199-109 was in its correct locked open position prior to declaring the pump operable H.3(b).

(Section 1R17.2)

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

1R17 Evaluation of Changes, Tests, or Experiments and Permanent Plant Modifications

.1 Evaluation of Changes, Tests, or Experiments

a. Inspection Scope

From May 4, 2009 through May 22, 2009, the inspectors reviewed eight safety evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 19 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests or experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted eight samples of evaluations and 19 samples of changes as defined in IP 71111.17-04.

b. Findings

No findings of significance were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

From May 4, 2009 through May 22, 2009, the inspectors reviewed 12 permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the Unit 2/3 emergency diesel generator, crib house, station blackout diesel, Unit 2 standby liquid control system, Unit 1 and 2/3 diesel fire pumps, and the alternate service water connection to the fire water system. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated;

• the changes were in accordance with the specified design requirements;

• the procedures and training plans affected by the modification have been adequately updated;

• the test documentation as required by the applicable test programs has been updated; and

• post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.

This inspection constituted 12 permanent plant modification samples as defined in IP 71111.17-04.

b. Findings

(1) Diesel-Driven Fire Pump Discharge Valve Found Out of Position

Introduction:

A finding of very low safety significance and associated Non-Cited Violation (NCV) of License Conditions 2.E and 3.G for Units 2 and 3, respectively, was identified by the inspectors for the failure to provide two diesel-driven fire pumps to maintain the required water flow during water suppression system operation as required by Section 2.4.1.1 of the Fire Hazards Analysis (FHA). Specifically, the Unit 1 fire pump discharge valve was found closed rendering the pump inoperable.

Description:

On May 13, 2009, operators were performing a surveillance on the Unit 1 fire pump per Procedure DFPS 4123-07, Unit 1 Fire Pump Capacity Check. The operators closed the fire pump discharge valve 1-4199-109 per Step I.32 of the procedure. Shortly thereafter the operators noticed an oil leak on the oil line going into the bottom of the turbo charger. At that point the operators declared that the surveillance had failed, exited the procedure, and recommended that the oil leak be repaired. Work Order 1235919 was generated to repair the oil leak. The oil leak repair was completed and the Unit 1 diesel-driven fire pump was successfully run and the pump was declared operable on May 19, 2009.

The inspectors found the Unit 1 diesel-driven fire pump discharge valve 1-4199-109 in the closed position on May 21, 2009. Valve 1-4199-109 controls the flow of water from the Unit 1 diesel-driven fire pump to the station fire protection main yard loop. The main yard loop is dedicated exclusively to providing water to the stations fire protection system. When valve 1-4199-109 was closed the Unit 1 diesel-driven fire pump could not supply water to the fire protection main yard loop.

Step I.57 of Procedure DFPS 4123-07 would have required the operators to open and lock valve 1-4199-109. However, this step was not performed because the procedure was stopped upon discovery of the oil leak and was not resumed upon completion of repairs. There was ineffective communication between the group responsible for conducting the surveillance procedure, the group performing the maintenance, and the operators who returned the pump to service, to ensure the pump discharge valve was in its correct position prior to declaring the pump operable.

The TRM 3.7.i.A.1 required that if one fire pump or water supply system was inoperable that it be restored to operable status within seven days. When the Unit 1 diesel-driven fire pump was repaired and successfully run it was declared operable on May 19, 2009.

This was six days after the pump was declared inoperable and therefore the operators believed that the TRM requirement was satisfied. However, valve 1-4199-109 remained in the closed position until discovered by the inspectors on May 21, 2009, eight days after being declared inoperable. Upon discovery of the valve in the locked position, the licensee repositioned the valve in the correct locked open position and initiated Action Requests (AR) 922581 and 922585.

During the entire period the Unit 1 pump was inoperable, the Unit 2/3 diesel-driven fire pump remained operable to provide water to the stations fire protection system, if required, such that the fire protection system was capable of performing its function.

Analysis:

The inspectors determined that the failure to properly restore the Unit 1 diesel-driven fire pump to an operable condition within seven days was contrary to TRM 3.7.i.A.1 and was a performance deficiency.

The finding was determined to be more than minor because the failure to restore the Unit 1 diesel-driven fire pump to an operable condition within seven days was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to provide the two required fire pumps could result in a failure of the stations water based fire protection system should the Unit 2/3 fire pump fail to provide adequate water pressure/supply when required.

In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 3b, the inspectors determined the finding degraded the fire protection defense-in-depth strategies. Therefore, screening under IMC 0609, Appendix F, Fire Protection Significance Determination Process, was required. The inspectors assigned a LOW degradation rating to the finding in Step 1.2, because the performance of the system was not affected by the closed valve as the Unit 2/3 diesel-driven fire pump remained operable to provide water to the stations fire protection system, if required.

Additionally, the Unit 1 diesel-driven fire pump was out-of-service for only eight days.

The inspectors determined that the finding was of very low safety significance (i.e., Green) in Task 1.3.1 because of the LOW degradation rating.

Additionally, the diesel-driven fire pumps are credited as mitigating systems to provide an alternate source of water to the isolation condenser. As a result, the inspectors also evaluated the finding using IMC 0609, Attachment 0609.04. The inspectors determined that a Phase 2 screening was necessary based on Table 4a because the finding represented an actual loss of one non-Technical Specification train of equipment designated as risk significant per 10 CFR 50.65, Maintenance Rule, for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding was screened using Attachment 1 to IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations.

The inspectors reviewed the site specific risk-informed inspection notebook and pre-solved table and determined that the finding was of very low safety significance (i.e., Green) in Phase 2.1 for duration of 3 to 30 days with one diesel-driven fire pump out-of-service.

This finding has a cross-cutting aspect in the area of human performance, work control because the licensee did not properly plan and coordinate activities consistent with nuclear safety. Specifically, the licensee failed to restore the Unit 1 diesel-driven fire pump to an operable condition within seven days as required by TRM 3.7.i.A.1, because of ineffective communication between the group responsible for conducting the surveillance procedure, the group performing the maintenance, and the operators who returned the pump to service. This ineffective communication led to the failure to ensure the correct position of the pump discharge valve prior to declaring the pump operable.

H.3(b)

Enforcement:

License Conditions 2.E and 3.G for Units 2 and 3, respectively, required the licensee to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR)and as approved through Safety Evaluation Reports. Section 9.5.1 of the UFSAR stated that the design of the fire protection system was described in the Fire Hazards Analysis (FHA). Section 2.4.1.1 of the FHA stated that two automatically controlled diesel-driven fire pumps were provided to maintain the required water flow during manual or automatic water suppression system operation. The TRM 3.7.i.A.1 allowed one diesel-driven fire pump to be inoperable for seven days.

Contrary to the above, between May 20 and May 21, 2009, the licensee failed to meet Section 2.4.1.1 of the FHA and TRM 3.7.i.A.1, because two automatically controlled diesel-driven fire pumps were not provided to maintain the required water flow when the Unit 1 diesel-driven fire pump was inoperable for greater than seven days. Specifically, the licensee declared the Unit 1 diesel-driven fire pump inoperable on May 13 and declared it operable on May 19, 2009, however, the discharge valve was in the closed position such that it could not provide the required water flow during manual or automatic water suppression system operation. Because this violation was of very low safety significance and it was entered into the licensees corrective action program as ARs 922581 and 922585, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000237/2009006-01; 05000249/2009006-01).

4OA2 Identification and Resolution of Problems

.1 Routine Review of Condition Reports

a. Inspection Scope

From May 4, 2009 through May 22, 2009, the inspectors reviewed Corrective Action Process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent pant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On May 22, 2009, the inspectors presented the inspection results to Mr. T. Hanley, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented. The inspectors confirmed that proprietary material was reviewed during the inspection and was either returned to the licensee staff or will be handled in accordance with NRC policy on proprietary information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Hanley, Site Vice President

C. Byers, Design Engineering

G. Howard, Rapid Response - Engineering

J. Koach, Design Engineering

D. Lee, Design Engineering

J. Lizalek, Nuclear Oversight

T. Loch, Senior Manager Design Engineering

S. Mattson, Maintenance Superintendent

J. Reda, Mechanical/Structural Design Manager

J. Sipek, Engineering Director

J. Strasser, Design Engineering

S. Taylor, Regulatory Assurance Manager

Nuclear Regulatory Commission

R. Daley, Chief, Branch 3, DRS

C. Phillips, Senior Resident Inspector, Dresden

LIST OF ITEMS

Opened and Closed

05000237/249/2009009-01 NCV Diesel-Driven Fire Pump Discharge Valve Found Out of Position

Discussed

None Attachment