ML20134G104

Insp Repts 50-010/96-14,50-237/96-14 & 50-249/96-14 on 961021-1206.Violations Noted.Major Areas Inspected: Operations,Maintenance,Engineering & Plant Support

ML20134G104
Person / Time
Site:	Dresden
Issue date:	02/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134G097	List: ML20134G096 ML20134G102 ML20134G104
References
50-010-96-14, 50-10-96-14, 50-237-96-14, 50-249-96-14, NUDOCS 9702100277
Download: ML20134G104 (23)

See also: IR 05000010/1996014

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U.S. NJCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

50-10: 50-237: 50-249

License Nos:-

DPR-2: DPR-19: DPR-25

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Report No:

50-010/96014: 50-237/96014 50-249/96014

Licensee:

Commonwealth Edison Company

Facility:

Dresden Nuclear Station Units 1. 2 and 3

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Location:

Opus West III

1400 Opus Place - Suite 300

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Downers Grove. IL 60515

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Dates:

October 21 through December 6. 1996

Inspectors:

C. Vanderniet. Senior Resident Inspector

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J. Hansen. Resident Inspector

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D. Roth. Resident Inspector

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C. Settles. Inspe tor. Illinois Department of

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Nuclear Sa ety

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Approved By:

P. L. Hiland. Chief

Reactor Projects Branch 1

9702100277 970204

PDR

ADOCK 05000010

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PDR

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EXECUTIVE SUMMARY

Dresden Nuclear Station Units 1. 2 and 3

iiRC Inspection Report 50-10/96014: 50-237/96014: 50-249/96014

This routine resident inspection included aspects of licensee operations.

maintenance, engineering, and plant support.

The report covered a 7-week

period of resident inspection.

Doerations

The facility was operated in a safe manner and previously identified

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minor deficiencies were corrected (Section 01.1).

The Unit 3 low pressure heater bay had improved accessibility and

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housekeeping; however, minor material deficiencies were identified by

the inspectors (Section 01.2).

A manual reactor trip was initiated in response to a loss of the 3B

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reactor recirculation motor generator set.

Plant and safety equipment

functioned as expected (Section 02.1).

Unit 3 emergency diesel generator (EDG) ejected a cylinder test valve

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after a surveillance run.

No personnel injuries or significant damage

resulted and after minor repairs the EDG was returned to service

(Section 02.2).

Maintenance

In general, maintenance activities were well controlled: however, two

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work stoppages were issued due to non-safety related parts control and

contractor work practices (Section M1.1).

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Significant repair work on the 3B reactor recirculation pump motor was

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well executed and managed.

Root cause for the motor failure was foreign

material intrusion into the stator windings (Section M2.1).

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Construction era rag was found inside the Unit 3 high pressure coolant

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injection (HPCI) lube oil cooler waterbox.

Tube leaks were repaired and

the system was restored to service (Section M2.2).

Enoineerina

The licensee failed to perform post-modification testing on the Unit 2/3

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main control room heating, ventilation and air conditioning (HVAC)

system. This was an apparent violation (Section E2.1).

An engineer failed to enter vendor technical information into the vendor

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equipment technical information program (VETIP) as required by plant

procedures (Section E4.1).

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Ins)ector review of two tem)orary alterations identified some problems

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wit 1 implementation and tecinical evaluation (Section E4.2).

Plant Support

Computer accounting system failed at the beginning of the plant assembly

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drill causing confusion. A thorough drill critique identified

deficiencies and corrective actions (Section P4.1).

Problems were identified with the level indication and switch

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calibration on the Unit 1 diesel-driven fire pump (Section F2.1).

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REPORT DETAILS

Summary of Plant Status

Unit 2 began the period at a reduced load of about 300 MWe as some

maintenance activities were concluded. The unit was returned to full

power on October 22.

On October 27 a 2% power derate was initiated due

to feedwater flow instrument uncertainty. On November 23 a load drop

was made to facilitate a drywell entry to add oil to the 2A reactor

recirculation pump motor. The unit was returned to near full power the

following day.

On November 26 the 2% derate was lifted and the unit

returned to full power. On November 28. power was reducea for changing

condensate demineralizes and exercising control rod drives.

The unit

began a slow power increase on December 2 and returned to full power on

December 3.

Unit 3 commenced this inspection period in coastdown in preparation for

refueling outage D3R14. On October 26. the 3B motor generator (MG) set

tripped and after a short period of single loop operations the reactor

was manually tripped on October 27. and a forced outage commenced.

I. OPERATIONS

01

Conduct of Operations

01.1 General Comments (71707)

Routine day-to-day facility operations were observed by inspectors both

in the control room and in the field.

Main control board walkdowns and

reviews of various operating logs were also performed.

Previous

observations discussed in Inspection Re) ort 50-237/249-96013. dated

December 31. 1996 regarding minor breacdowns in control room decorum.

3-way communications, and responsiveness to annunciators were not

observed during this inspection period. Generally, operator performance

inside the control room continued to be crisp and professional. A

weakness was noted with operations personnel outside the control room.

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specifically, operator knowledge of the Unit 1 diesel-driven fire pump

day tank level switches (paragraph F2.1).

01.2 Tour of Low Pressure Heater Bay (Unit 3)

a.

Insoection Scone (71707)

The inspectors toured Unit 3 low 3ressure heater bay and observed the

general material condition houseceeping, and temporary alterations

installed on heater drain valves.

b.

Observations and Findinos

Overall

the inspectors noted significantly improved housekeeping over

the past nine months; however, numerous undocumented material

discrepancies were identified.

These discrepancies included valves

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missing packing gland fasteners. open junction and electrical cable pull

boxes. and misadjusted piping hangers.

After a discussion about general

conditions, several items were identified to the licensee for

correction.

Followup tours of the Unit 3 LP heater bay found that the specific items

had been addressed and a few additional items had been identified by the

licensee.

One of the additional items identified by the licensee was an

o)en lighting junction box above one of the room exits. The tag for

t11s item was attached to a cable tray protective cover through a hole

where the cover bolt and stud had broken off. Additionally. the cover

had several loose or broken nuts, however, none of these deficiencies

were identified by the licensee.

c.

Conclusions

The significant improvement in the housekeeping of the LP heater bay

allowed a greater portion of the room to be more easily accessible.

The

reduction in contaminated areas further improved accessibility to the

room.

However, the identification of material condition problems in

less traveled areas of the plant continued to be a challenge.

02

Operational Status of Facilities and Equipment

02.1 Recirculation Motor-Generator (MG) Set "B" Trio (Unit 3)

a.

Insoection Stone (71707)

On October 26. at 1758 the 3B Recirculation pump tripped due to tri) ping

of the 3B MG set.

Onsite response to this event was performed by t1e

inspectors, and observation of control room personnel performance during

the power reduction and manual reactor scram was accomplished.

The

following operational procedures were reviewed:

Dresden Annunciator Procedure (DAN) 903-4 A6. 3B RECIRC M-G SET

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GEN LOCKOUT.

DAN 903-4 A7. 3B RECIRC PP DP LO.

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DAN 903-4 08, 3B RECIRC PP LOWER LUBE OIL LVL LO.

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Dresden Operating Abnormal (DOA) 0202-01. Recirculation Pump Trip

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One or Both Pumps.

Dresden General Procedure (DGP) 02-01. Unit 2 (3) NORMAL UNIT

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SHUTDOWN

DGP 02-03. REACTOR SCRAM

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DGP 03-03. SINGLE RECIRCULATION LOOP OPERATION

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b.

Observations and Findinos

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The root cause of the MG set trip was not immediately known and single

loop operation commenced.

The inspectors responded to the site and

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monitored the reactor down power and the subsequent manual reactor trip

at 0201 on October 27. After the 3B MG set tripped, the 3A MG set was

reduced to 60 percent power in accordance with approved procedures and

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the unit was stabilized at about 34 percent power.

Power was further

decreased to 25 percent using recirculation flow and a manual reactor trip signal initiated.

Systems responded as expected with the exception

of rod position indication failures for two rods and two intermediate

range monitor failures.

For the evolutions observed plant operators

followed all appropriate procedures during the course of the shutdown.

Control room decorum and 3-way communications were maintained throughout

the event.

c.

Conclusion

The plant response to the loss of a single reactor recirculation pump

was in accordance with expectations and plant design.

The control room

operators followed procedures and conducted an orderly shutdown.

02.2 Emergency Diesel Generator (EDG) E.iected a Cylinder Test Valve Durina

Troubleshootina Run (Unit 3)

a.

Inspection Scone (71707)

The inspectors observed a test of the Unit 3 EDG and observed the

licensee's response to the observed test failure.

Field observations,

system and equipment inspection walkdowns were performed before and

after the valve ejection occurred.

Additionally, the inspectors

reviewed the following documentation

Vendor Equipment Technical Information Program (VETIP) Manual

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1163. Electro-Motive Diesel Engine.

Dresden Electrical Surveillance (DTS) 6600-01. Diesel Generator

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Governor Oil Change and Compensation Adjustment

Dresden Operations Surveillance (DOS) 6600-01. " Diesel Generator

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Surveillance Test."

b.

Observations and Findinas

On November 24. the inspectors observed performance of Dresden

Electrical Surveillance (DTS) 6600-01 for the Unit 3 EDG.

No

abnormalities were noted during the initial performance of the test.

Subsequent to test performance, the Shift Manager informed the

inspectors that the EDG had ejected a cylinder test valve from

Cylinder 20.

The High Voltage Operator (HVO) had entered the room to

secure the EDG and reported that the test valve had blown out.

The

inspectors returned to the Unit 3 EDG room shortly after the EDG was

secured.

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The test valve had blown out of Cylinder 20 on the EDG generator end.

The valve appeared to have impacted the wall directly adjacent to the

valve and fallen to the floor.

No damage was evident from the valve

ejection, other than carbon buildup on piping near the cylinder test

valve port.

Inspection of the test valve showed no damage or unusual

wear.

No personnel injuries were reported and the licensee immediately

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initiated a prompt investigation into the event.

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During additional inspection on November 25. the inspectors noted that

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the Unit 3 EDG cylinder test valves did not appear to be threaded into

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the cylinder block as far as the test valves on the Unit 2 or 2/3 EDGs.

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This information was conveyed to the licensee's team performing the

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prompt event investigation.

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The prompt investigation c termined that the test valves had been

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replaced in December 1995, and that the ejected valve must have had a

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relaxed torque that was further loosened due to normal EDG vibrations.

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Additionally. Cylinder 20 on the Unit 3 EDG was the cylinder with the

highest compression pressure on the engine. The licensee did not

perform a formal root cause evaluation of this event although several

corrective actions were performed.

The EDG was repaired and was

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returned to service on November 27.

c.

Conclusions

Operations personnel performed the surveillance testing in accordance

with the appropriate procedures and were observed closely monitoring EDG

performance.

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Miscellaneous Operations Issues (92700)

08.1

(Closed) Violation (50-237:249/95010-03):

Control of Overtime Not

Implemented In Accordance With Generic Letter (GL) 82-12.

Revision 1 to

Dresden Operating Procedure 01-09. Control of Overtime authorized

November 14, 1995, incorporated the guidance established in GL 82-12.

This action appeared adequate to prevent recurrence: however, the

recently completed independent safety inspection (ref. IR 50-237:249/96-

201, dated December 24, 1996. Section 6.3.3) identified continuing

problems with corrective action for control of overtime. This item is

closed and further followup will be documented against Independent

Safety Inspection (ISI) Deficiency 50-237:249/96-201-29

08.2 (Closed) Insoector Followuo item (IFI) 50-237:249/96002-04:

Atmospheric

Containment Atmosphere Dilution (ACAD) Operating and Surveillance

Procedures' Bands Differ. The inspectors noted that the ACAD system air

receiver operating pressure band was being maintained at 44 to 57 psig,

which was above the band in Dresden Operating Procedure (DOP) 2500-01.

"ACAD Dilution Subsystem Operation" (41 to 52 psig).

Dresden Operating

Surveillance (DOS) 2500-01. "ACAD Compressor Surveillance," and Dresden

Administrative Technical Requirements (DATR) both listed a pressure band

of 44 to 57 psig.

To resolve this issue, the licensee planned to revise

the appropriate ACAD procedures.

The inspector reviewed the revised

ACAD procedure (DOP 2500-01) and the changes to the UFSAR and had no

further concerns. This item is closed.

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II. Maintenance

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M1

Conduct of Haintenance

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M1.1 General Comments (62707)

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In general, maintenance activities at the facility were well controlled

and performed in accordance with approved work packages and procedures.

Numerous tasks were observed in the field and minor observations were

discussed with the appropriate licensee staff.

Scheduling and work

planning continued to be difficult 3roblems.

This was evident when a

stop work order was issued during t1e conduct of maintenance which left

an oil pump for both the 2A and 2B MG set oil skids out of service,

thereby leaving both MG sets in a more vulnerable condition.

Significant work activities that were performed during this inspection

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period not receiving specific comment included the following;

3D Electromatic Relief Valve Flange Leak Repair

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Unit 3 EDG Power Pack Replacement

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Additionally, during this report period the licensee issued two stop

work orders. The first, issued November 21. regarded the retraining of

contractor personnel in the use of nuclear standard work procedures.

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This was in response to a failure of contract worker personnel to comply

with facility safe work practices. The second, issued November 24

regarded the procurement and use of non-safety related parts.

This was

partially in response to the 3A control rod drive pump discharge

isolation valve that was installed with a through wall pinhole leak.

Both work stoppages were of short duration and were appropriate

resomses to address specific maintenance problems.

H2

Maintenance Material Condition of Facility and Equipment

M2.1

"B" Reactor Recirculation (RR) Pumo Motor Repair (Unit 3)

a.

Inspection Scope (62707)

During the report period, the inspectors observed licensee actions to

troubleshoot and repair the 3B reactor recirculation (RR) motor trip.

Portions of the field preparation and actual repair were observed by the

inspectors.

In addition, work package preparation and s3ecial rigging

and load testing documentation were reviewed including t1e following:

Vendor Manual GEK-26132. " Boiling Water Nuclear Reactor

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Recirculating Water Pump Motors for the Dresden 11 and III nuclear

power station of the Commonwealth Edison Company by the General

Electric Atomic Power Equipment Department."

Special Procedure (SP) 96-11-019. "3B RR Pump Motor In-place

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Repair."

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Dresden Engineering Document 5254777. " Reactor Recirculation Pump

Motor Refurbishment - Details for the Engineered Impact Mat -

Unit 3."

Dresden Engineering Document 5257492. " Reactor Recirculation Pump

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Motor Refurbishment - Details for Pump Bowl Shimming. Engineered

Impact Mat and Rigging."

Dresden Engineering Document 5253222. " Rigging of the 3B Recir.

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Pump Motor End Bell. Rotor and Stator to Repair the Motor in

Place."

b.

Observations and Findinas

After the October 26, 3B RR pump MG set trip. the licensee's

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troubleshooting effort located a ground in the pump motor. Two

approaches to resolve the problem were developed; repair the motor in-

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place, or replacement with a rebuilt motor. A rebuilt motor was

obtained and brought to the site, but work to repair in-place continued.

The repair work included load-testing the drywell monorail: design.

testing, and installation of an engineered impact mat: development of a

rigging plan for the motor endbell, rotor and stator; and identifying

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possible repair techniques. The plan called for the removal of the

motor endbell and rotor and the lifting of the stator.

The stator

needed to be lifted high enough to allow access for inspection and

repair.

Once the package was finally prepared, a special )lant

operations review committee (PORC) reviewed and approved t1e plan.

During the preparation of the work, the inspectors reviewed selected

portions of the packages and observed monorail and impact mat testing.

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The use of a computer-generated animation of the lifting process greatly

aided all personnel in understanding the job. Also, the assignment of

the Operations Manager as a dedicated project manager ensured continuity

on the project.

During the stator inspection a small piece of banding material was

discovered shorting one motor phase. The foreign material was removed

and the damaged area of the windings repaired. After successfully

testing the windings, the motor was reassembled.

The piece of banding

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material most likely entered the motor in late 1990 to early 1991 time

frame when the endbell had been removed for maintenance. The banding

material was similar to material used to secure component identification

label plates inside the drywell. The licensee suspected that some of

this material was dropped into the motor and eventually shorted the

stator.

Additional foreign material found inside the motor was removed.

The intrusion of foreign material into various components at the

facility has been a longstanding problem.

However, the inspectors'

recent observations of foreign material exclusion (ME) practices

indicated that significant improvements have been made over past

practices.

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The ins)ectors observed various activities as the work progressed and

noted tlat the job was well managed and skillfully performed.

Disassembly, re) air. and reassembly progressed as expected and no major

problems with t1e work plans were encountered.

Radiation protection

controls and practices were followed and the use of a video monitor for

the viewing of the work was a good "as low as reasonably achievable"

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(ALARA) practice.

c.

Conclusions

The 3B RR pump motor repair was well coordinated.

Management and Site

Quality Verification oversight were maintained and no significant

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unanticipated problems occurred. The finding of several pieces of

foreign material inside a major component was not a new issue at the

facility and efforts to improve FME continued to receive appropriate

management attention.

M2.2 Rao Found in Hiah Pressure Coolant Iniection (HPCI) Lube Oil Cooler.

(Unit 2)

a.

Inspection Scone (62707)

The inspectors ins)ected the Unit 2 HPCI lube oil cooler and observed

the rag found by t1e licensee during emergent maintenance work. A

review of the licensee's efforts to identify when the rag entered the

system was also performed,

b.

Observations and Findinas

The HPCI system was declared inoperable on November 27. due to excessive

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water contamination in the turbine lubricating oil.

While performing

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maintenance to repair the water leaks in the lube oil cooler,

maintenance personnel discovered a rag in the cooler water box. The rag

covered a significant portion of the cooler tube openings and appeared

to have been acting as a filter for the cooling medium.

The licensee suspects that the rag had been used as an FME cover during

facility construction and was never removed.

The assumption was

substantiated due to the lack of finding any previous maintenance items

that required removal of the HPCI lube oil cooler endbells in the

maintenance database.

Further database searches showed that no recorded

maintenance work had been performed on the cooler or cooling system that

would have allowed visual identification of the rag since the system was

originally placed in service. The licensee also reviewed surveillance

test data and did not identify any instance of the HPCI system being

inoperable or degraded due to inadequate lube oil cooler performance.

Repair efforts were completed and the cooler was reassembled and

satisfactorily tested.

Unit 2 HPCI was returned to service on

December 1, with no further problems.

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c.

Conclusions

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All observed maintenance activities were performed in a skilled manner,

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however, the discovery of the rag in the cooler further emphasized the

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need to continue monitoring FME controls.

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Miscellaneous Maintenance Issues (92902)

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M8.1

(Closed) Insoector Followuo Item 50-237/249-95008-01:

Failure to Follow

Procedure Resulted in Two Inoperable Core Spray Systems.

On April 24,

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1995, the licensee reused o-rings on environmentally qualified equipment

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and only hand tightened the transmitter covers in violation of the

3rocedure. The inspectors reviewed information on reused o-rings and

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land tightened covers in CHRON # 0308805 and a referenced letter from

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Rosemount.

The information a)peared adequate to support the licensee's

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operability determination. T11s item is closed.

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III. Enaineerina

E2

Engineering Support of Facilities and Equipment

E2.1 Failure to Perform Adeouate Post-Modification Testina of the Control

Room Heatina and Air Conditionina (HVAC) System (Units 1. 2 and 3)

a.

Insoection Scope (37551)

The inspectors continued to observe and monitor the licensee's progress

in correcting control room HVAC design and testing deficiencies.

The

following documentation was reviewed:

Modifications M12-2/3-82-1. M12-0-87-005 and M12-0-86-006:

Unit 1

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Control Room Modifications.

DTS 5750-06, " Control Room Standby HVAC Air Filtration Unit, and

Refrigeration Condensing Unit Performance Requirements," dated

August 24, 1996.

b.

Observations and Findinas

The licensee continued work on sealing penetrations into the Unit 2/3

control room, auxiliary computer room, and train "B" HVAC rcom.

At the

close of this report period, efforts to remove a temporary alteration

and return the auxiliary computer roo.n into the control room envelope

were unsuccessful.

The licensee continued testing and achieved and

maintained positive pressure requirements with the exception of the

auxiliary computer room.

Further work was planned to correct problems

in the computer room and return the room to the control room envelope.

Background information on this issue can be found in Inspection Report

96013 (paragraph E2.4) and Independent Safety Inspection (ISI) Report

96-201 (paragraph 4.6.4.1).

The significance of this event was

previously considered an Unresolved Item (50-237:249/95013-02).

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c.

ISI Report 96-201. dated December 24. 1997. Daragraoh 4.6.4.1

Sections 6.4.2 and 9.4-3 of the UFSAR described the design basis for the

control room HVAC system.

Section 6.4.2.4 stated that potential adverse

interactions between the control room emergency zone and adjacent zones

that may allow the transfer of toxic or radioactive gases into the

control room were minimized by maintaining the control room at a

positive pressure of 1/8-inch water gauge (iwg) during emergency

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pressurization modes, and with respect to adjacent areas.

On October 8. 1996, the licensee declared the control room HVAC system

inoperable because of the inability to maintain the control room at a

positive pressure during normal operations and at 1/8 iwg with respect

to the surrounding areas in the emergency mode.

The control room

ventilation system had not been maintained or properly tested 'o ensure

that the system operated within its design basis.

Modifications had

been implemented, or partially implemented, which resulted in negative

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pressure within the control room and the inability to pressurize the

control room to 1/8 iwg in the emergency mode.

In addition,

instrumentation that was used to verify the control room pressure was

positive in the emergency mode had not been calibrated, and had not been

installed in accordance with the piping and instrumentation diagram.

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In September 1996, the licensee began reviewirg open modifications for

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the control room ventilation system, and subsequently determined that

several control room modifications, which had not been completed,

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contributed to the inability to pressurize the control room as stated in

the UFSAR.

These incomplete modifications were identified as a result

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of the licensee's efforts to close all modifications or approve the as-

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built configuration.

The specific modifications affecting the control

room included:

M12-0-87-005-D provided for the installation of security equipment

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such as bullet resistant plating for walls and ceilings, new east-

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west kitchen and locker room area fire and non-fire rated doors.

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and the sealing of new and unused wall and floor penetrations.

Field work was initiated in August 1991 and completed in

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January 1992.

Post-modification testina was not oerformed.

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M12-0-87-005-E provided supply and exhaust ventilation systems for

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the new locker room and kitchen areas, new fire dampers in duct

work penetrating fire walls, control logic for operation of the

isolation dampers, and an interlock for the exhaust fans from the

isolation dampers.

Field work was started in September 1991 and

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completed by June 1993. The oost-modification testina, includina

loaic testina and emergency oressurization testina to verify

1/8 iwa was not oerformed.

M12-0-86-006-C provided supply and return side duct silencers,

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thermally insulated duct work, and manual volume dampers in the

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shared return duct works.

The field work was started in

March 1989 and the documentation closure was completed in

September 1993.

Post-modification testina was not comoleted.

M12-0-86-006-D provided for the removal of existing HVAC duct work

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supports inside the Unit 2 and 3 control room, installed

acoustical tile, installed new duct work including hangers and

safety chains. reworked existing ductwork inside the control room,

and removed existing butterfly dampers inside the control room.

The field work was initiated in June 1989 and the work was

determined to be completed in May 1993.

Post-modification testina

was not completed

M12-2/3-82-1 added the HVAC Train B in 1982; however, the NRC's

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ISI team concluded the modification was not adeouately tested.

Surveillance Procedure (DTS) 5750-06. Revision 3. " Control Room Standby

HVAC Air Filtration Unit, and Refrigeration Condensing Unit Performance

Requirements." dated August 24, 1996, only required 1/8 iwg positive

pressure in the control room and did not ensure thst pressure was

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greater than 1/8 iwg for the surrounding areas.

In addition, the

instrumentation used to verify the control room differential

pressure (d)) was not calibrated nor verified to be appro)riate for the

parameters Jeing measured.

Specifically, dp Instruments )PI-2-5740-

31/32 and 36 for the control room and east turbine building had not been

calibrated. The licensee also identified that the control room

instrumentation was mislabeled with respect to the areas being sensed

and, according to '.he drawings, other sensing lines were misrouted or

were broken.

d.

Conclusions

The licensee's failure to perform testing of modifications performed to

Unit 2/3 control room HVAC system, as discussed above and detailed in

the ISI Irspection Report 96-201, section 4.6.4.1. dated December 24.

1996, is an Apparent Violation of 10 CFR 50. Appendix B. Criterion XI.

" Test Controls." (50-237/249-96014-01).

The apparent violation is being considered for escalated enforcement

action in accordance with the " General Statement of Policy and Procedure

for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600.

Accordingly, no Notice of Violation is presently being issued for this

inspection finding.

The significance of the issue, and short term

corrective actions were discussed with the licensee in the exit meeting

for this inspection period on December 19. 1996.

Before the NRC makes an enforcement decision, the licensee will be

provided an opportucity to respond to the ap)arent violation at a pre-

decisional enforcement conference as descri)ed in the cover letter to

this report.

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E3

Engineering Procedures and Documentation

E3.1 Additional Vodated Final Safety Analysis Report (UFSAR) Discreoancies

a.

Insoection Scooe (71707)

The inspectors used the UFSAR as a technical reference during a review

of findings' from a routine drywell tour. A comparison of actual plant

configuration was made to the descriptions contained in the UFSAR.

Note

that other UFSAR discrepancies regarding the control room HVAC system

were documented in Section E2.1.

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b.

Observations and Findinos

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Prior to performing a Unit 3 drywell routine tour the inspectors

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reviewed various UFSAR sections including section 6.1.1.1

" Materials

Selection and Fabrication." This section stated, "All piping inside

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containment is covered with metallic mirror-type insulation." During

the drywell tour the inspectors found this not to be the case as several

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other types of insulation were used on piping. The licensee confirmed

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that the other types of insulation ident1fied by the inspectors were

acceptable for use in the drywell. This discrepancy was discussed with

the licensee and a change to the UFSAR and a performance improvement

form (PIF) were initiated.

c.

Conclusion

The above example showed that discrepancies between plant configuration

and the UFSAR still exist.

However, the licensee was taking prompt

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actions to resolve identified discrepancies.

E4

Engineering Staff Knowledge and Performance

E4.1 Failure to Uodate Emeraency Diesel Generator (EDG) Vendor Technical

Information Manual (Units 2 and 3)

a.

Insoection Scooe (37551)

While inspecting the licensee's response to a Unit 3 EDG test valve

failure (Section 02.2 of this report), the inspectors reviewed the

approved vendor technical manual.

The inspectors compared the approved

vendor manual to the conditions that existed in the field and conducted-

discussions with the system engineer and engineering management. The

following administrative procedures were also reviewed;

Dresden Administrative Procedure (DAP) 02-10. " Control of Vendor

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Equipment Technical Information," Revision 5.

Nuclear Engineering Procedure (NEP) 07-04. "VETIP Process

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Control," Revision 0.

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b.

Observations and Findings

The inspectors noted that the test valves depicted in the manual were

different from those installed on the EDGs.

During discussion with the

licensee, the correct information was found in the system engineer's

desk.

Maintaining vendor supplied technical information in an

uncontrolled manner was contrary to the licensee's vendor equipment

technical information program (VETIP).

Dresden Administrative

Procedure 02-10. Revision 5. Section E.5 required that " Existing,

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uncontrolled, and ircoming ETI (Equipment Technical Information) shall

be reviewed and added to VETIP so that the latest /most applicable

information is available for station use."

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In addition. NEP 07-04. Section 5.2.1.2. required that "The person

receiving new vendor manual revision data shall forward the information

to the VETIP Coordinator attached to the VETIP Authorization Form

(Exhibit A) or suitable equivalent."

The licensee initiated a PIF documenting the misplaced vendor data and

forwarded the information to the VETIP coordinator for inclusion into

the EDG VETIP manual.

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c.

Conclusions

Past weaknesses in the VETIP program were previously documented in

Inspection Report 96006. section M2.1. dated August 22 1996.

The

licensee was not successful in assuring the VETIP was hroperly

implemented.

Not entering the EDG test valve technical information

change into the VETIP program as required by approved procedures was a

Violation of Technical Specification 6.2. Procedures and Programs

(50-237/249-96014-02).

E4.2 Review of Temocrary Alterations Related to the Control Room HVAC Repair

and the 125Vdc and 250Vdc Batteries (Units 2 and 3)

a.

Insoection Scooe (37551)

The inspectors reviewed two installed temporary alterations. The review

included a field walkdown of the alterations and a review of the

associated documentation and procedures including:

DAP 05-08. " Control of Temporary System Alterations."

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Temporary Alteration No. III-53-96. " Isolate HVAC Supply / Return To

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and From the Aux Computer Room."

Temporary Alteration No. III-33-96. " Supply Temporary Heat to U2

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125V and 250V DC Battery Rooms."

b.

Observations and Findinos

The auxiliary computer room temporary alteration was installed to

isolate the room from the control room while the control room walls were

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sealed.

The temporary alteration called for three portable air

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conditioning (AC) units to be placed in the room and vented out the

auxiliary computer room door.

During the walkdown, the inspectors noted

that the door to the room was left open to accommodate the three exhaust

trunks used to expel heated exhausts from the portable AC units.

This

arrangement essentially countered any benefit received from the AC units

because of the free exchange of warmer auxiliary electrical room air

into the auxiliary computer room.

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The Unit 2 battery rooms temporary alteration was installed to ensure

that the proper temperature was maintained in the battery rooms while

work was in progress on the normal ventilation system.

During the

walkdown, the ins)ectors observed that the alteration had been installed

as intended and tlat a firewatch was present.

Both doors to both

battery rooms were also open which, although allowed by the temporary

alteration. seemed unnecessary and even counterproductive to the

intended design.

Additionally, the inspectors noted that the battery rooms were about

81 F. well abon the required tem)erature of 68 F.

This observation was

conveyed to the licensee and the )attery rooms were returned to normal

and the firewatch secured.

Subsequently, room temperature was monitored

by hourly operator rounds.

A documentation review showed that the technical evaluation had been

identified as not safety related.

The documented explanation stated

that the batteries were safety-related, but the room HVAC system was

not.

The 125V and 250V batteries were the most risk significant system at the

facility and were clearly safety-related. The temporary alteration was

only concerned with maintaining the room temperatures above 68 F to

assure the batteries were not in a degraded condition.

Therefore. the

installation of the temporary alteration directly affected the two

station batteries not just the room HVAC.

c.

Conclusions

Although the alterations were installed as written, the design

effectiveness was flawed. This appeared to be the result of an

ineffective field walkdown of the alteration and a weak review of the

design implementation.

Additionally, the licensee maintained that the

battery room alteration only affected the battery room HVAC system and

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was not safety-related.

Further discussions will be needed to resolve

this issue: therefore this issue will remain an Unresolved Item

(50-237/249-96014-03).

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E6

Engineering Organization and Administration

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E6.1 Enaineerina Deoartment Manaaement Chances (37551)

A new Site Engineering Manager, Mr. Russell Freeman, was ao)ointed

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during the report period.

Previously. Mr. Freeman was the )resden Plant

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Engineering Superintendent.

E8

Miscellaneous Engineering Issues (92903)

E8.1 (Closed) Unresolved Item (50-237/249-95015-05):

Corner Room Steel.

This issue regarded the corrective action for inadequate corner room

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structural steel design margins, and was the subject of escalated

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enforcement and a civil penalty (EA 96-115) on June 13, 1996.

This item

is closed.

E8.2 (Closed) Unresolved Item (50-237/249-96013-02):

Control Room

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Ventilation System Operability.

This issue regarded the licensee's

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corrective actions to resolve inadequate post-modification testing of

the control room HVAC system. This issue was reviewed and is an example

of an apparent violation discussed in Section E2.1 of this re) ort.

Additional followup of this item will be documented against tais reports

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assigned tracking number. This item is closed.

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IV. Plant Suooort

P4

Staff Knowledge and Performance in EP

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P4.1 Performance durina Assembly Drill (Units 1. 2 and 3)

a.

Inspection Scoce (82701)

On November 26 the inspectors observed licensee response to an

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unannounced site assembly drill. Documents reviewed included Emergency

Plant Im)lementing Procedures (EPIP) 0400-01, " Plant Assembly and

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Accounta)ility."

b.

Observations and Findings

The station alarm was sounded at 1230 and the site assembly drill was

announced on the station public address system.

The inspectors

responded to assigned assembly points and noted that the computerized

assembly card reading system was not operating. After being manually

accounted, the inspectors went to other assE.3bly areas to observe

activities.

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In the Administrative Building the accounting 3rocess was in disarray.

The lunchroom and main hallway were filled wit 1 personnel waiting to be

counted.

Twenty minutes into the drill the licensee initiated a manual

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accounting of personnel in the Administration Building.

This was

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accomplished by handing out sheets of paper to management personnel and

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requiring managers to count assigned personnel. At one point a station

supervisor directed assigned personnel to leave the Administration

Building and go to a work area. This was followed by similar direction

from another su)ervisor. The individual in charge of the accountability

activities in t1e Administration Building halted the exodus and stated

that the accounting for all groups would be completed in the

Administration Building.

The licensee was able to gain control of the accounting process;

however, the licensee was not able to complete the accounting within the

allotted time.

Station management determined that aerformance during

the drill was unsuccessful and another drill was scleduled.

The

licensee's critique was thorough and independently addressed all of the

inspectors' concerns.

c.

Conclusions

The difficulty the licensee experienced in accounting for the station

staff manually demonstrated the there had been an over-reliance on the

computer counting. The licensee's thorough post-drill critique

correctiy assessed the weakness in performance and established

appropriate corrective actions.

F2

Status of Fire Protection Facilities and Equipment

F2.1 Problems Identified with Diesel-Driven Fire Pumo (Units 1. 2 and 3)

a.

Insoection Scope (64704)

The inspectors performed walkdowns of the Unit 1 diesel-driven fire pump

and all associated equipment and held several discussions with licensee

staff.

The following documentation was also reviewed:

DAN 901-2 E-8. "U1 Fire PP Day Tank Lvl Hi."

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Dresden Fire Protection Surveillance (DFPS) 4123-01. " Unit 1

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Diesel Fire Pump Operability."

Schematic Diagram 12E-6580F, " Fire Protection System Diesel Driven

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Fire Pump Intake Structure."

Wiring Diagram 12E-6580G. " Diesel Driven Fire Pump."

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b.

Observations and Findinos

On November 15. the Unit 1 diesel-driven fire pump failed a surveillance

run. The cause for the failure was the closing of the fuel su) ply

solenoid valve that occurred when a power lead to the valve vi] rated off

a terminal.

During subsequent walkdowns of the pump and associated

components. the inspectors questioned if the local fuel oil storage tank

level float was operating 3roperly. The work execution center (WEC)

supervisor was contacted a)out the level indicator and stated that the

indicator was working properly. Upon further investigation, the

licensee determined that the level float was not operating properly.

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The installed level float indicated the tank was between 3/4 and 7/8

full, when the tank was only a little more than half full.

The inspectors also questioned the low level alarm switch calibrations

and requested the latest calibration records. The same WEC supervisor

was contacted and stated that there was a high level alarm but no low

level alarm on the tank.

The inspectors reverified that there was a low

level switch, a high and a high-high level switch.

The licensee then

determined that the level switches were not in the calibration

3rogram

and could not find any documentation of the switches being cali) rated.

The fuel tank local level indicator float was repaired and the level

switches were calibrated.

The solenoid power lead was reterminated and

the Unit 1 diesel-driven fire pump successfully passed surveillance

testing and was returned to service.

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c.

Conclusion

The fire protection system has had numerous problems over the last few

months and did not appear to be receiving an adequate level of

attention. The system operation was not fully understood by some

members of the plant staff.

F8

Hiscellaneous Fire Protection Issues (92904)

F8.1

(Closed) IFT 50-237/249-95008-10:

Emergency Lighting.

During a fire

protection inspection, the ins)ectors identified that several emergency

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lights were dirty, several lig1ts were aimed improperly, and one light

was blocked by a plant modification. The licensee permanently relocated

the blocked emergency light to a new location. The affected emergency

lights were correctly aimed.

Also, a procedure change was completed to

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Dresden Electrical Surveillance (DES) 4153-02. Safe Shutdown Emergency

Lighting Quarterly Inspection, to ensure that emergency lights' lamps

would be inspected and cleaned as necessary.

This item is closed.

VI. Manacement Meetinas

X1

Exit Meeting Summary

The inspectors 3 resented the inspection results to members of licensee

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management at t1e conclusion of the inspection on December 19. 1996.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during

the inspection should be considered proprietary.

No proprietary

information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee

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' S. Perry. Vice President. BWR Operations

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E. Connell. Design Engineering Superintendent

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T. Foster. Work Control and Outage Manager

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R. Freeman. Plant Engineering Superintendent

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J. Heffley. Units 2 and 3 Station Manager

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C. Howland. Radiation Protection Manager

R. Kundalkar. Site Engineering Manager

T. Nauman. Unit 1 Station Manager

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T. O'Connor. Operations Manager

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F. Spangenburg Regulatory Assurance Manager

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P. Swafford. Unit 2/3 Maintenance Superintendent

P. Tzomes. Support Services Director

D. Winchester. Safety Ouality Verification Director

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INSPECTION PROCEDURES USED

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IP 37551:

On-site Engineering

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IP 62707:

Maintenance Observations

IP 64704:

Fire Protection Program

IP 71707:

Plant Operations

IP 82701:

Operational Status of the Emergency Preparedness Program

IP 92901:

Followup - Plant Operations

IP 92902:

Followup - Maintenance

IP 92903:

Followup - Engineering

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IP 92904:

Followup - Plant Support

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ITEMS OPENED AND CLOSED

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Ooened

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50-237/249-96014-01 APPARENT Failure to Perform Post-Modification Testing for

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VIO

Control Room HVAC System (Apparent Violation).

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50-237/249-96014-02

VIO

Failure to Follow VETIP Procedure for Incoming

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Vendor Technical Information.

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50-237/249-96014-03

URI

Battery Room Temporary Alteration.

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Closed

50-237:249/95010-03

VIO

Control of Overtime Not Implemented In

Accordance With Generic Letter (GL) 82-12.

50-237/249-95015-05

URI

Corner Room Steel.

50-237/249-96013-02

URI

Control Room Ventilation System Operability.

50-237/249-95008-01

IFI

Failure to Follow Procedure Resulted in Two

Inoperable Core Spray Systems.

50-237/249-95008-10

IFI

Emergency Lighting.

50-237:249/96002-04

IFI

Atmospheric Containment Atmosphere Dilution

(ACAD) Operating and Surveillance Procedures'

Bands Differ.

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LIST OF ACRONYM 3 USED

AC

Air Conditioning

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ACAD

Atmospheric Containment Atmosphere Dilution

ALARA

As Low As Reasonably Achievable

CFR

Code of Federal Regulations

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CRD

Coritrol Rod Drive

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DAN

Dresden Annunciator Procedure

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DAP

Dresden Administrative Procedure

DATR

Dresden Administrative Technical Requirements

4

DES

Dresden Electrical Surveillance

DFPS

Dresden Fire Protection Surveillance

DGP

Dresden General Procedure

2

DOA

Dresden Operating Abnormal

DOP

Dresden Operating Procedure

DOS

Dresden Operations Surveillance

dP

Differential Procedure

DTS

Dresden Technical Surveillance

a

EA

Enforcement Action

EDG

Emergency Diesel Generator

EPIP

Emergency Plan Implementing Procedures

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ETI

Equipment Technical Information

FME

Foreign Material Exclusion

GL

Generic Letter

HPCI

High Pressure Coolant Injection

HVAC

Heating. Ventilation, and Air Conditioning

HVO

High Voltage Operator

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IFI

Inspector Followup Item

ISI

Independent Safety Inspection

IWG

Inches Water Gage

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LP

Low Pressure

MG

Motor Generator

MMD

Mechanical Maintenance Department

MWe

Megawatts Electrical

NEP

Nuclear Engineering Procedure

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NDV

Notice of Violation

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PDR

Public Document Room

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PIF

Performance Improvement Form

PORC

Plant Operations Review Committee

asig

Pounds Per Square Inch Gauge

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1R

Reactor Recirculation

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UFSAR

Updated Final Safety Analysis Report

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URI

Unresolved Item

VETIP

Vendor Equipment Technical Information Program

WEC

Work Execution Center

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