IR 05000249/1988200

Insp Rept 50-249/88-200 on 880222-26 & 0307-11.No Violations Noted.Major Areas Inspected:Unresolved & Deficiency Items from NRC Safety Sys Outage Mods Insps 50-249/86-009 & 50-249/86-012 & Evaluate Corrective Actions

ML17201J325
Person / Time
Site:	Dresden
Issue date:	06/13/1988
From:	Haughney C, Konklin J, Stein S Office of Nuclear Reactor Regulation
To:
Shared Package
ML17201J324	List: IR 05000249/1988200 ML17201J323
References
50-249-88-200, NUDOCS 8807110399
Download: ML17201J325 (47)

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Report No. :

U.S. NUCLEAR REGULATORY CO~MISSION OFFICE OF NUCLEAR REACTOR REGULATION Division of React~r Inspection and Safeguards 50-249/88-200 Licensee:

Commonwealth Edison Co~pany P.O. Box 767 Chicago, IL 60690 License No:

DPR-?.5 Docket No.:

50-249 Fae il i ty Name:

Dresden Unit 3 Inspection at:

Dresden Nuclear Power Station Unit 3, and CECo corporate offices, Chicago, Illinois Inspection Conducted:

February 22-26, March 7-11, 1988 A-~/DRIS Inspector:

Consultants:

• R. Compton, *M. Good, *D. Ford, *R. Jacobstein,

• D. Prevatte Accompanying Personnel:

~8 Dategned

• Marshall Grotenhuis, NRR Project Manager; *Mark A. Ring, Projects Supervisor, Region III; *Stevie Dupont, Acting Senior Resident Inspector; *Paul D. Kaufman, Resident Inspector Reviewed by:

Approved by:

Scope:

nspect on G/J:J/U Di'te srgned An NRC Headquarters team perfonned a special announced inspection to examine selected open, unresolved, and deficiency items from NRC's Safety Systems Outage Modifications Inspections (50-249/86-009, 50-249/86-012), and evaluate the effectiveness of the licensee's corrective actions for those item *Attendea exit meeting on March ll, 198.

PDR, ADOCK 0500024 G PDR

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Results:

A total of 60 items were reviewed:

29 can be closed with no additional action, and 17 can be closed with their common corrective action tracked under a new open item, "corrective action related to procedure adherence" (02.4-1).

The remaining 14 items remain ope The reviews also identified one new unresolved item and one other new open item:

"determination of design basis for high pressure coolant injection high flow instruments" (U2.4-l), and control of motor-operated valve (MOV) overload heater sizing and replacement" (02.4-2).

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TABLE OF CONTENTS Followup Inspection to Safety Systems Outage Modifications Inspections at Dresden Nuclear Power Station Unit 3 (Inspection Report 50-249/88200)

PAGE

INSPECTION OBJECTIVES..................................

2 DETAILED INSPECTION FINDINGS........... ;...............

1 Items Closed:

No Additional Action Required...........

1 Items Closed:

Additional Program Followup Required....

17 Items Remaining Open After the Inspection..............

. 25 New Items Identified During the Inspection...... *.......

3 CONCLUSIONS. *.... * * *...... *..... *........ *........ *....

4 MANAGEMENT EXIT MEETING...................*.... ~.......

5 PERSONNEL CONTACTED....................................

6 DOCUMENTS REVIEWED.*.............. ~....................

ABBREVIATIONS.... *.........*....................*.........*........

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1 INSPECTION OBJECTIVES One objective of this inspection was to evaluate the effectiveness of the corrective actions taken by Conmonwealth Edison Company (CECo) as a result of the NRC's Safety Systems Outage Modifications Inspections (SSOMis) conducted in 1985 and 1986 at the Dresden Unit 3 facility. A second objective was to resolve and close the open, unresolved, and deficiency items that remained unresolved from the SSOMi The inspection effort included an evaluation and review of a selection of items that remained unresolved from SSOMI Design report 50-249/86-009 and SSOMI Installation and Test report 50-249/86-012, and the actions taken to correct the specific concerns and to prevent their recurrenc DETAILED INSPECTION FINDINGS The two SSOMI reports documented approximately 126 deficiencies, unresolved items, and observations from the Headquarters outage inspection conducted during the October 1985 through July 1986 outage at Dresden Unit Some of the deficiencies were included as violations in the civil penalty issued by the NRC via the letter from A. Bert Davis to J. J. O'Connor, dated April 23, 198 The letter required CECo to respond to each of the violations and deficiencies in the notice of violation and the two inspection report The licensee*s response to the notice of violation was dated June 23, 1987 and included items described in the notice, items from the Potential Enforcement Actions in the inspection reports, and inspection report observations not identified in either the Potential Enforcement Actions or notice of violatio Of the 122 items being tracked by Region III, this followup inspection reviewed 56 items that remained open and 4 additional items from the SSOMI reports to which CECo responde The sections that follow describe the items that were closed during the inspection and the items that require additional information or review and remain open following the inspection. A third group includes those items for which the technical aspects were resolved but that require additional followup to ensure adequate corrective action* to preclude recurrenc The program followup items have been combined into a new open item and the applicable individual items from the SSOMI reports have been close In addition, the inspection team identified two new items that need to be resolve.1 Items Closed 2.2-6 50-249 86012-06 and Observation 2.2-1 50-2 9 6-0 :

a et va uations for Tern orar Jum ers: The NRC SS I team note t at 0

. 9 rev ews a not een con ucted on temporary jumpers installed before December 24, 1985. After concurring that such safety evaluations did not exist, the licensee completed safety evaluations on all jumpers during the period the SSOMI team was on sit The SSOMI team observed that in many cases the safety.evaluations per-formed for these jumpers lacked sufficient technical justification The Dresden response to the notice of violation reported that safety evaluations had been completed on all jumpers. Although the licensee resolved the items during this inspection, the response did not address-1-

• the observation regarding the adequacy of those evaluation The NRC SSOMI followup team asked for copies of all safety evaluations for jumpers that had been installed before December 24, 1985 and that were still in service in the plant, but Dresden staff could not locate the safety evaluations. The NRC team reviewed the plant jumper log, which indicated that all but six of the original jumpers installed before December 1985 had been removed from service. Again, the licensee completed safety evaluations for those six jumpers during this followup inspectio Th~ SSOMI followup inspection team reviewed the ~valuations and found them acceptabl The specific aspects of these two items have been resolved, and the items are close However, generic corrective actions for implementation of an adequate safety evaluation program will be addressed by deficiency 2.2-7 in Section 2.3.5 of this inspection repor.1.2 Deficienc 2.2-8 50-249/86012-10 : * Safet Evaluations for Reactor Bui ng enetrat1ons:

e S M Insta at1on an est team, enti 1ed a deficiency involving the installation of two hose penetrations in the common wall between the Units 2 and 3 reactor buildings that did not accurately reflect the configuration depicted in the design modification packag Specifically, the locations and size of the core bores varied considerably from those analyzed by the firm of Sargent & Lundy Engineers (S&L) in its report referenced by the 10 CFR 50.59 safety revie The licensee responded that the modification involved the installatton of a flange sleeve with a 4-inch inner diameter but, allowing for sleeve thickness and grouting area, the final diameter of the penetration through the reactor building wall was approximately*5 inche S&L provided a structural analysis based on the as-installed penetration size and concluded that the installation was structurally acceptable. A separate 10 CFR 50.59 safety evaluation was completed to review the final desig *

Although the licensee took actions during this inspection to resolve this item, the SSOMI followup team considered the licensee's initial response unacceptable:

The response only addressed the issue of the size of the penetrations and not the problem related to the location of the penetra-tion In response to the NRC team's co11111ents during this inspection, S&L reevaluated the installation and revised the analysis to reflect the true configuration of the penetrations. The licensee also reperformed the 10 CFR 50.59 safety evaluation to reference the final and correct S&L analysi To preclude recurrence, the licensee had stren~thened the Dresden plant modification program with the latest revision (Rev. 16) to Dresden Administrative Procedure (OAP) 5-The procedure required strict adherence to design documents and revision of the associated 10 CFR 50.59 safety evaluations should design changes or deviations modify or other-wise affect the assumptions of the original evaluation This item is close :1.3 Deficienc 2.2-11 50-249/86012-14):

Torus Vacuum Breaker Solenoid Va ve es1gn ontro :

e S nsta at1on an est team, enti 1ed inadequate design control on the torus vacuum breaker valve solenoids involving the following three basic concerns:

o The maintenance department had issued work requests and had partially completed work on ch~nges to valves that had been replaced earlier by a modificatio The maintenance department should have been aware of the earlier modification and should not have issued the work request o The work requests specified a change that would achieve a target stroke time of 10 to 25 seconds, although a valve timing surveil-lance procedure specifi~d a maximum time of 20 second Addition-ally, no 10 CFR 50.59 safety evaluation was performed for changing the stroke time for this safety-related valv o The Dresden maintenance department had performed a design change by welding antirotation bars on the valve and by changing material for valve-to-actuator bolt No 10 CFR 50.59 safety evaluation was performed and no drawings were revised to ensure that future work on the valve would comply with the latest approved design and material requirement CECo responded to the notice of violation indicating that the mechanical

.maintenance department knew it could not modify the stroke times because the valves had been replaced. This awareness was not apparent to the NRC SSOMI team during the original inspection and the licensee's response did not address why the work requests had been approved, issued, and ini-tiated without maintenance personnel knowing about the separate modifica-tion packag However, the procedural improvements that were reviewed during this followup inspection and the heightened awareness about modification and maintenance noted by the team during personnel inter-views should minimize this type of problem in the futur The licensee stated that no maximum stroke times for these valves were specified in the stroke timing surveillance procedure or in the technical specifications. The NRC review team concurred with this conclusio However, American Society of Mechanical Engineers (ASME) Code Section XI requires that the licensee specify the maximum allowable stroke time for power-operated valve CECo was correcting this error by extensively upgrading the Dresden In-Service Test (IST) Progra *

The licensee revised the parts list for these valves to reflect the new bolting material. The licensee indicated that the field walkdowns required for future modifications would ensure compliance with design requirement This item is close.

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10 CFR 50.59 safety evaluations, and with inadequate justifications for 10 CFR 50.59 safety evaluation CECo responded that OAP 9-2 had been revised to require evaluation of any procedure revision outstanding longer than three months, and required separate procedure history and justification if multiple sources were making changes to the same procedur During this inspection, the Dresden staff was in the process of drafting a new safety evaluation instruction which would incorporate all site guidance for 10 CFR 50.59 evaluations into one procedure. This guidance would include items such as set point changes, procedure changes, and jumper The NRC SSOMI followup team concluded that this consolidated procedure would help reduce the program fragmentation and overlap which had been noted during the original SSOM *

Although resolved during this inspection, the licensee's response did not address corrective actions for specific 10 CFR 50.59 safety evaluations that were found to be inadequate by the SSOMI tea The specific concerns related to two evaluations for revisions to two Dresden Opera-ting Surveillance (DOS) Procedures:

DOS 6900-6, 11125 VDC Station Battery Capacity Test, 11 and DOS 6700-7, 11 125 VDC Ground Detection - Unit 3. 11 The NRC team reviewed the original safety evaluations to confirm the SSOMI findings, and discussed the issue with Dresden personnel. The Dresden staff indicated that no action had been taken to review or correct the safety evaluation As a result of this followup inspection, Dresden staff reviewed the original safety evaluations, found them inadequate, and completed new safety eva.luations during the inspection. The new safety evaluations confirmed that no unreviewed safety questions existed for these example Correttive action-on this deficiency is adequate and this item is close However, the adequacy of generic corrective action fa~ 10 CFR 50.59

safety evaluations will be verified under deficiency 2.2-7 in Section 2.3.5 in this repor The licensee's formal response to this deficiency indicated that the test for modification Mt2..:3-84-8 had been corrected to document the actual test steps perfonned and that the issue was discussed with test personnel to avoid further occurrences. Although the determination of specific root cause was not detailed in the fonnal response, discussions with the licensee indicated that the identified deficiency was isolated and was attributed to one individual. The NRC SSOMI followup team reviewed additional test records and found no evidence of additional deficiencies or that the deficiencies were generic or prograrrmatic in natur Considering this information, the licensee's response is acceptable, and this item is close ~..

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2. ~efici~mc;:y 2.474 (50-249/86012-25): *Conflicting S~fety Evaluations:

This def1c1ency 1nvolved two 10 CFR 50.59 safety rev1ew determinations for a plant instrumentation replacement modification, which had conflic-ted with regard to the effect of the modification upon the facility final safety analysis report (FSAR) and plant technical specification The original safety review for modification Ml2-3-83-39 had indicated that a change was required to the technical specifications, but not to the FSA A subsequent 10 CFR 50.59 review had reversed this determination indica-ting a change was required to the FSAR, but not to the technical specification The licensee's formal response to this deficiency stated "Further review

. by the Station Nuclear Engineering Department concluded that only the Technical Specifications required a change." However, upon questioning by the NRC followup team, the licensee reevaluated this issue and*once again changed the 10 CFR 50.59detenninatio On the basis of concerns expressed by the NRC. team, the licensee provided clarification in a letter dated March 8, 1988, concerning the effects of the subject modifi-cation on the Dresden FSAR and technical specification In su1TD11ary, the letter concluded that the existing 10 CFR 50.59 safety evaluation for modification Ml2-3-83-39 was valid and that the identified FSAR change did not raise any safety concern The letter further stated that the plant technical specifications would not require revision and assured that plant documentation would accurately reflect the completed modificatio Given the infonnation provided during this inspection, this item is close However, the generic aspects of an improved 10 CFR 50.59 program

• will be evaluated under deficiency 2.2-7 in Section 2.3.6 of this inspection repor.1.7 Deficienc 2.4-9 50-249/86012-32 : Technical S ecification Refer-ences:

T 1s e ciency invo ve t e incorrect re erenc1ng o p ant technical specifications in modification package document In response tothis deficiency the licensee issued a memorandum (May 1986) instructin9 shift engineers, shift foremen, and shift control room engineers (SCREs) to reference appropriate sections of plant technical

~pecifications in modification packages. Additionally, section (h) of OAP 15-1 was revised to include the following requirements:

Part 2 of Attachment B shall contain the specific section(s)

and title(s) of the Technical Specifications that apply to the repai In addition, detailed precautions taken to assure Technical Specification compliance shall be liste On the basis of a review of these actions, the licensee's response is considered to be acceptable and this item is close.1.8 Deficienc 2.8-6 50-249 86012-75 :

MOV Test Acee tance Criteria:

The N C nsta at1on an est report ocumente e ic1enc es in the functional tests for modification packages M12-3-84-103 and 104 {valve operator motor replacement); the tests did not incorporate an acceptance criterion reconmended by the station nuclear engineering department-5-

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The acceptance criterion required checkir.g the valves for hammering when cycling the*valves full open er full closed from the control room; this would require stationing a person at the valve During the SSOMI, new procedures were written to position personnel at the valves to check the valves for hammerin The SSOMI followup team reviewed the current revision of OAP 5-1, "Plarit Modification Program," which now requires a postmodification test committee to review and approve all postmodification tests. The team concluded that the licensee had taken adequate corrective action on this ite *

This item is close.1.9 Deficienc 2.8-9 (50-249/86012-82 S stem Ventin for H drostatic Testing:

e NR SS team note t at t e contractor modi ying t e fire protection piping had not adhered to the hydrostatic test procedure that required the system to be vented to eliminate trapped air. Only 3 of 47 risers in the system bein9 tested were vented before the test, creating a potential safety problem (compressed air "bomb") as well as yielding questionable test result Althoug~ technical justification could be developed for leaving small volumes of air in the system, none was provided and the procedure did not authorize or detail partial ventin Although the licensee took actions to resolve the item, the SSOMI follow-up team did not find that the CECo response to the notice of violation adequately addressed the issue. The licensee's response simply stated that the contractor's test procedure was based on the National Fire Protection Association code and corrmon industry practice. Although this statement is true, the response did not indicate whether the test was performed adequately or safely or whether anything would be done dif-ferently in the futur Discussions between the NRC followup team and CECo fire protection engineers during this inspection detennined that the test results had not been invalidated. The additional controls on modification test proce-

dures contained in OAP 5-1, a new nuclear station work procedure for pressure testing, and increased quality control (QC) involvement and

• surveillance of contractor activities should prevent similar conditions in future tests. The SSOMI followup team also noted that the contractor involved is no longer o.n CECo's approved bidders list for safety-related, ASME Code, specific quality-classified or fire protection activities..

On the basis of infonnation provided during this inspection, this concern was adequately addressed and this item can be close.1.10 Oeficienc 5.3-3 50-249/86009-36 : Safet -Related MOV Test Pro ram:

The I es gn team a een concerne t at t e eve o motor protec-tion assumed in the engineering analysis might not be provided as a result of raising the high acceptance limit in the licensee's procedure for testing overload relays in safety-related motor-operated valves (MOVs); the 480-V MOV test procedure did not include valves 1201-lA, 1201-4, and 2301-4; and no procedures existed for testing safety-related 208-V or de MOV *

The licensee responded that the philosophy, as stated in the Systematic Evaluation Program (SEP), was to 11drive the valve to its proper position to mitigate the consequences of an accident, rather than to be concerned with degradation or failure of the motor due to excess heating 11 and that the increased high acceptance limit was consistent with this.philosoph This philosophy was also reinforced and even extended by Regulatory Guide 1.106 which allows continuous bypassing of the thermal overloads, thereby providing no protection for the motor The licensee also responded that valve 1201-4 is a nonsafety-related reactor water cleanup (RWCU) system valve, and therefore should not have been listed in the test procedures. Valves 1201-lA and 2301-4 are safety-related and were both included in the December 1987 revision of test procedure Dresden Maintenance Procedure (DMP) 040-6, and the September 1987 revision of test procedure DMP 7300- In addition, both 208-V ac and de MOVs have been incorporated into the latest revisions of test procedures DMP 040-6 and DMP 7300- This item is close.1.11 Unresolved Item 2.4-1 Lines:

e teams 1n ing a invo ve speci icat on

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- 7, wmcn established requirements for the removal and reinstallation of

instrumentation and drain lines as required for work-related to the recirculation pipe replacement (RPR) modification. Slope requirements wer~ omitted for 13 instrument line$ and 5 drain lines. After the SSOMI team identified the problem, Impell performed an analysis to justify the final 11as-built" configuration of the lines in question. *The SSOMI team had considered this analysis inadequate because it did not adequately address adherence to industry standards or potential line blockage as a result of a buildup of corrosion products or other foreign materia CECo's response to the notice of violation had indicated that the original Impell analysis of instrument and drain slopes, dated May 20, 1986, had determined that the current configuration did not raise a safety concern; however, the SSOMI report questioned the conclusions of*

this analysis as contradicting Instrument Society of America (ISA)

standard 2186 9 which recorrmends slopes to prevent measurement error Subsequent contact with the chairman of ISA by Impell revealed that standard 2186 is not currently in use and that ISA-567.02, "Nuclear Safety-Related Instrument Sensing Line Piping and Tubing Standards for Use in Nuclear Power Plants," was the appropriate standar However, ISA-S67.02 does not supply specific slope requirement The chairman of ISA stated that, in some cases, it is not possible to attain certain

• slopes and that it is up to the designer to ensure that the system will function properl On the basis of the original Impell analysis, which concluded that the equipment would function properly, and considering years of operation without any instrument problems related to inadequate slope or corrosion buildup blockage, CECo concluded that no further action was necessar The SSOMI followup team reviewed Impell report No. 09-0590-.86, Rev. 0, and the licensee's response, and discussed the issue with licensee representative The licensee had adequately addressed this issue with-7-

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respect to the specific instrumentation and drain lines identified by the SSOM This item is close.1.12 Unresolved 2.4-3 Room Cooler Motor Installation Oeta1 s:

e team a i ent1 ie concerns regar ing t e ack of installation details and bolting torque requirements fer the modifi-cations that involved replacing the low-pressure coolant injection (LPCI)

room cooler motor In response to this unresolved item, the licensee analyzed existing bolting materials used in the installation of the LPCI room cooler motor The analysis indicated that the materials used possess suf-ficient tensile and shear strength to meet the requirement of the original seismic analysis. Administrative controls have been established through a revision to OAP 15-1 which added the following requirements to section (i) of the procedure:

Compare the new component(s)/part(s) with the old component(s)/part(s) being removed to verify that they are

"like-for-like" and installation of the new component(s)/

part(s) will not inadvertently change system/component function or design. This comparison should verify proper component/

part number, physical size, shape, color, material, etc...

Additionally, for work packages related to specific quality-classified systems, plant personnel have been instructed by procedure to fill out attachment F of OAP 15-1, entitled "Suitability of Application Data," to ensure that replacement parts will be evaluated for seismic and environ-mental qualification aspect On the basis of the team's review of this information, the licensee's formal response is considered acceptable and this item is close.1.13 Observation 2.6-1 50-249 86012-57 : E ui ent Condition and House-keeping: T e R S M team o serve spec ic examp es o poor ouse-keeping, damaged equipment, and generally poor maintenance in several electrical panel In response to this open item, the licensee issued several work requests to clean the identified electrical panel Inspection of these items and general observation of plant conditions by the SSOMI followup team indicated that the licensee had improved housekeeping activities. The damaged terminal block and missing wireway covers identified in the SSOMI report have been replaced. Additionally, as indicated in the licensee's response to the notice of violation, a memo dated May 20, 1986 was sent to plant personnel to stress the importance and proper use of "out-of-service" cards at the Dresden facilit The licensee's response is considered acceptable and this item is close.1.14 Unresolved Item 2.7-1 50-249 86012-61 : Documentation of Incom lete Test ng:

D P 5-1, ant Mo i ication Program, paragrap B.22, n ica-ted that, if a modification package had not *been completed, the operating-8-

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engineer may authorize equipment operation after an

!~complete Modifica-tion Review Checklist, OAP Form 5-lC, was complete The SSOMI Instal-lation and Test team had been concerned that a Form 5-lC, which had been initiated to allow fuel load before completion and closeout of recircula-tion pipe replacement (RPR) modification package Ml2-3-85-16, did not document certain fuel load prerequisite system and component tests that were incomplete because of test discrepancies, test deviations, and the lack of evaluation of test results that failed to satisfy the stated acceptance criteri The licensee responded that the RPR test group performed a final detailed evaluation and review of outstanding items in relation to the incomplete modification checklist for M12-3-85-16 before fuel loa The evaluation concluded that the status of the modification was sufficient to allow

. fuel loa As a corrective action, the RPR test group was instructed to perform more timely test review The licensee reviewed all of the outstanding items and determined that they had no impact on the oper-ability of systems necessary for fuel loa The SSOMI followup team reviewed the licensee's evaluation of test discrepancies and agreed with the licensee's conclusion that the incom-plete preoperational tests did not adversly affect fuel loa In addi-tion, the SSOMI followup team reviewed a revision to OAP 5-1 that prohibited system turnover before all related preoperational tests have been completed and reviewe This item is close In response to this issue, the licensee indicated that the incorrect references resulted from recent changes to the plant technical specifica-tions, and that the affected procedures have since been revised to reference the proper technical specification The followup team reviewed test procedure DOS 6600-5, "Bus Undervoltage and ECCS Integrated Function Test for 2(3) Diesel Generator," and verified that technical specification references have been correcte Similar revisions have been proposed for procedures DOS 6600-3, and DOS 6600-4 originally identified in the SSOMI report. Additionally, the review of plant technical specifications indicated that the technical specifications had been revised just before the diesel generator test was performed and this revision appears to have been the cause of the incorrect reference The licensee's response is acceptable and this item is close.1.16 Unresolved item 2.8~1 50-249/86012-73):

Main Steam Safet Valve Test:

Ores en maintenance proce ure DMP 200-30, n ts 2/3 6-nc Sa ety Valve Overhaul and Test Procedure," had been used to test main steam-9-

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safety valve The SSOMI Installation and Test team raised the follo~ing concerns:

o The test procedure did not include a requirement for monitoring the temperature of the valve spring while wanning the valve "to normal operating temperature, approximately 200 deg-F," although the expected operational temperature was approximately 500 degrees o The instruments used during the lift test were calibrated according to Dresden instrumentation surveillance (DIS) procedure 5700- Test personnel recorded only initial values and failed to record final values after completing the tes The licensee responded that extensive evaluations had been performed to detennine why safety valves had opened below the set point during the early cycles of the plan As part of that analysis, thermocouples were attached to the coils of the valves and temperatures were recorded during normal operating conditions. Since these temperatures were approximately 200 degrees F, that value was used for the surveillanc DMP 200-30 specified that the instrument department is to conduct a "before" and

"after" calibration of the pressure recording instrumentation before and after a successful test has been made on each valve~ The instrument department used DIS 5700-1 for all calibrations, since the techniques were identica This SSOMI followup team reviewed two documents that dealt with the effects of temperature on valve setpoints. These documents were:

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"Dresden Safety Valve Analysis - Conclusions From Six Months of Investigations Into Causes of Premature Safety Valve Actuations,"

January 10, 1973 (Preliminary Draft).

o Conunonwealth Edison Report No. M-944-72, "Operational Analysis Department Report on Safety Valve Springs From Nuclear Stations,"

August 21, 197 A review of the documents indicated that the prescribed temperature o degrees F is satisfactory for testing these valve Work requests (WRs) 45659 and Q42929, under which the valves were tested during the SSOMI, and the associated data package were also reviewed by the SSOMI followup team with respect to the calibration of test instrumentatio It appears that appropriate calibrations were perfonned before and after the test, as prescribed in DMP 200-3 This item is close.1.17 Unresolved Item 2.8-2 50-249 86012-79 :

Lon -Tenn Tern orar Jum ers:

The NRC S

nsta at1on an test report state t at a ma or ty o t e temporary jumpers installed in the plant had been in place for two years, and that some had been in place for as long as six years. This practice violated the irttent of OAP 5-1, "Plant Modification Program," that pennanent changes can be made to the plant only via the plant modifica-tion proces *

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The Dresden response to the notice of violation reported that OAP 7-4,

"Control of Temporary System Alterations," had been revised to require a quarterly review of all temporary alternations (jumpers).

The quarterly review would be conducted by the procedures coordinator who would review the written justification for all jumpers that had been in place more than three months, verifying that a work request has been written to make the temporary alteration permanent, and assigning an appropriate priority for modifications associated with temporary alteration OAP 7-4 also required that critical drawings be updated and temporary procedure changes be made for temporary alterations in place more than three month In addition, DOS 10-6 was revised to require daily, monthly and semiannual operating actions which included reviewing the effects of temporary alterations on plant conditions, field verification of temporary alterations, and verifying accuracy of entries in the jumper lo The NRC SSOMI followup team reviewed the jumper log in the control room ~nd noted no deficiencie In addition, several OAP 7-4 and DOS 10-6 reviews, (three quarterly, five monthly, and one semiannua*l review)

were examined and found to be in accordance with their applicable procedure The SSOMI followup team concluded that corrective action and recurrence control was adequat This item is close.1.18 Observation 2.8-4 50-249/86012-80 : Vibration Test Procedure Defic1enc es:

n accor ance wit spec1a proce ure P 86- -, "Reactor Reci rcul ati on Systems Preoperational Test," vi bra ti on readings were to be taken on the recirculation pumps to detennine whether any gross abnormal-ities existed in the piping, valves, or pump The SSOMI team considered the procedure deficient because it failed to specify the instrumentation that was to be used and did not clearly identify the points at which the measurements were to be take The Jicensee responded that the instrument used has been specified in Appendix 10.1 of the test procedur Various instruments were capable of performing the required function and it was not clear which. instrument would be available when the test procedure was written. The licensee's response also indicated that the test engineer specified the instruments before perfonning the test, and the points on the pumps or motors where the readings were taken had been also specified on the data sheets by the test engineer just before performing the test. These locations were adequately identified so that the tests could be repeated if necessar The data package associated with ~he completed procedure was reviewed during this followup inspection and it supported the licensee's respons This item is close.1.19 Observation 2.8-5 50-249/86012-81 : Test Failure Documentation:

Valve -

1-2 was teste using res en tee n ca surve ance S)

procedure 1600-1, "Local Leak Rate Testing of Primary Containment Isola-tion Valves." The SSOMI team had been concerned that although the valve failed to pass the test, no discrepancy report was mad '..

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The licensee responded that procedure DTS 1600-1 included criteria to determine reportability requirement The test, witnessed by the SSOMI inspector, occurred after maintenance was performed on the valve and at a time when primary containment integrity was not required to be establishe When the valve failed this test, the appropriate action was to inform the mechanical maintenance department that additional work was required. It was not necessary to prepare a discrepancy report under these condition The repaired valve passed the final local leak rate test after repairs were complet The licensee's response is satisfactory and this item is close.1.20 Observation 2.10-1 50-249/86012-87 :

ector Trainin : The NRC SSOMI team note t at tra1n1ng an qua 1 1cat1on o QC inspectors needed to be improved because the team uncovered numerous instances of failure to follow procedures and improper documentation, and*because inspectors primarily trained in one discipline inspected activities in another disciplin~.

The licensee did not respond to th.is issue adequately although they took actions to resolve the ite The SSOMI followup team interviewed the Dresden site QC supervisor and the CECo corporate supervisor of reli-ability and QC programs and was provided the following documents for review that appeared to strengthen the QC training program:

Nuclear station quality control procedure (NSQCP)-1, "Nuclear Station Quality Control Inspector Qualification and Certification,"

Rev. O, February 3, 1988. This procedure provided for developing, documenting, and maintaining the qualification and certification of inspector o Nuclear station work procedure (NSWP) G-1, "Preparation and Process-ing of Work Packages," Rev. O, March 9, 198 (See conment with next entry.)

o

"Standard Nuclear Station Quality Inspection Program - Modifications and Maintenance." These were draft compilations of checklists for 49 plant activity inspections for use with NSWP-G-1 which were being used on a trial basi o On-the-job-training (OJT) and individual training records for the mechanical section of the Nuclear QA/QC Training Program *. These documents outlined specific proficiency requirements for various inspection activitie The implementation of the documents listed above and other generic im-provements in the modifications and maintenance programs at Dresden adequately addressed the concerns identified in this observatio (

This item is close.1.21 Unresolved Item 2.5-2 50-249 86012 : Visual Ins ection of Welds:

The NR SSOMI team cite an unreso ve tern re ate to v1sua we inspection test M12-3-84-14 (modification of piping to the component-12-

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cooling service water pump room cool~r). The test document from the modification package did not require all new welds made during the modification to be inspected and *did not define the term "defects" or specify the action to be taken if defects were foun Although the licensee took action to resolve the item, CECo did not address this item in its response to the notice of violation. The SSOMI followup team reviewed modification package documents and revised site procedures and interviewed responsible personnel to provide the informa-tion necessary to close this ite The test procedure originally in-cluded in the modification package has since been voide This test was never actually required because the welds had been visually inspected and the inspections documented on the weld inspection records for each wel A new walkdown inspection procedure to verify installation conformance to the design drawings was issued and performe Revision 16 to OAP 5-1,

"Plant Modification Program," provided for a modification test ~omrnittee to review and approve tests that are included in the modification package NSWP-M-5, "Pressure Testing," Rev. 0, issued December 10, 1987, provided detailed requirements and a spe~ific inspection checklist for conducting pressure test The specific actions taken and the improvements in the modification program adequately address the concerns of this issu This item is close.1.22 Observation 2.9-4 (50-249/86012): Testing Out of Seauence:

The NRC

• SSOMI team noted that the fire protection contractor ha hydrostatically tested five fire-protection piping systems before completing the final QC inspection and. had tested two of the systems before the craft had signed off that the system had been installed in accordance with the drawing * CECo did not address this issue in its response to the notice of viola-tion; however, CECo took action to resolve it. The SSOMI followup team interviewed responsible engineering and QC personnel about this concern and reviewed the following revised procedures that should prevent this problem from happening in the future:

o Quality procedure (QP) 3-51, "Design Control for Operations - Plant Modification, 0 Rev. 15, November 17, 1987, required QC review of modification packages (procedures, tests, etc.) for adequacy and QC review of completed work and final documentatio o OAP 9-5~ "Review and Approval of Non-Station Work Group Procedures,"

Rev. O, November 1987, provided for contractor procedure reviews by the cognizant superintendent, technical staff or maintenance personnel, and QC department personne QP 11-1, "Development, Performance, Documentation and Evaluation of Construction Tests," Rev. 14, November 17, 1987, required contractor construction tests to include a construction test release and a data evaluation form providing for review and acceptance by CECo personnel.

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• Although this item was not addressed in the CECo response to the notice of violation, the revisions to procedures governing the content, review, and conduct of contractor activities appeared to adeauately address this concer This item is close.1.23 Unresolved Item 4.1-6 50-249/86009-17):

Common Torus Pressure Instrument Line:

e SS es1gn team was concerne tat t e re undan~

torus vacuum monitoring instruments were connected to the containment th~ough a common sensing lin The team was concerned that a single failure in this line could prevent both trains of the instruments from functioning, thereby threatening the containment integrit The licensee responded that the sensing line was not a part of the modification but rather was part of the original plant design, and that no industry standard or design specification prohibited the original single line configuratio Since the SSOMI Design report had not specified an active or passive faiJure as the concern, the followup inspection team analyzed the system to dete~ine what mode{s) and mechanism(s) of failure are credible *

. There a re on 1 y two components in the sensing 1 i ne:

the line i tse 1 f and a manual, normally open, globe valve. Neither of these components are active components. Therefore, active failure was eliminate Next, all conceivable mechanisms for passive failure were considered, and none were concluded to be credible failures. They included detachment of the valve disk from the stem, incorrect positioning of the valve, blockage in the line, seismic failure of the line, and impact by a Seismic Category II component. These were all addressed as follows:

o If the disk were to become detached, without the force of the stem on the disk, it would be unlikely to seal adequately to prevent the vacuum instruments from sensing torus pressur *

o During the life of the plant, the globe valve needs to be operated very infrequently. The valve is highly unlikely to be positioned incorrectly because Dresden Operating Procedure (DOP) 1600-Ml/El, Rev. 6 requires that this valve's position be verified open each time the plant is started up. Other plant procedures control the positfon of the valve at any time that position may be changed during operatio o The c011111on line is connected to the containment atmosphere and is exposed only to gase The team could identify no credible source of material to block the lin o This line is 3/4-inch, schedule 80 pipe, and there are no components in close proximity to the line whose failure could cause the line to fail.* Therefore, it does not appear credible that the common line could break as a result of a seismic event.

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The team concluded that no credible mechanism exists to cause single failure, either active or passive, in this lin This item is close.1.24 Unresolved Item 4.5-1 50-249/86009-23 :

Rod Worth Minimizer Desi n Changes:

e S es1gn team was concerne t at t e or1g1na concep-tual design of the rod worth minimizer had been altered in the nonconservative direction by two design modifications:

(1) removing the 11dead man" feature which imposed rod blocks whenever the rod ~orth minimizer equipment was inoperative and (2) omitting from the equipment specification the requirement to impose rod blocks upon loss of power until a keylock bypass switch was operate The licensee presented documents to show that the "dead man feature was described in the Updated FSAR in Section 7.9.3, and it has been rein-corporated in the design of the rod worth minimizer; and the rud block feature upon loss of power was incorporated in the design of the rod worth minimizer and the requirement for this feature had been incorp-orated in the latest revision of the hardware specificatio This item is close.1.25 Observation 5.1-6 Seismic Evaluation Documentation of 8-atteries:

en new 2 8-atter1es were pure ase or t e Ores en station, t e required seismic response spectra for Dresden were not specified. Rather, the vendor was required to furnish the same seismic qualification report as was provided for the batteries for the Quad Cities plant. This requirement was based on CECo's conclusion that the Gould generic seismic test response spectra for the batteries was

adequate for Dresde However, the SSOMI Design team had been concerned that the basis for this conclusion was not documente The licensee performed a documented evaluation of the seismic qualifica-tion of the new batteries. It concluded that the Gould test response spectra enveloped the Dresden floor response spectra for the building elevation above where the batteries would be. located. This elevation was used because the actual location response spectra were not available, and this approach was considered conservativ The SSOMI followup team reviewed the documentation and found it supported the licensee's conclusion that the test response spectra enveloped the Dresden floor response spectra and that the battery is seismically qualifie This item is close.1.26 Observation 5.1-7 DC Coordination Stud for Reserve Fee o e:

n response to a 10 ppen x concern, o a modified the 125-V de distribution system to physically separate the division I distribution equipment from the division II equipment. A coordination study performed as a part of this modification did not address one of the possible modes of operation of the system, the reserve-15-

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feed mod The SSOMI Design team had been concerned that there was no analysis showing that for this mode, a fault on the reactor building de bus would not result in the loss of both division load CECo's original response was that no corrective action was required since this mode was rarely used and the probability of failure when the system was in the reserve feed mode was lo Although the SSOMI followup team did not consider this response adequate, the licensee resolved the ite During the inspection, the licensee initiated a temporary procedure change (88-2-121) to the 125-V de electrical system operating procedure, DOP 6900-2, to add a limitation that the Unit 2 and Unit 3 125-V de systems are not to be connected in parallel unless both units are in cold shutdow In addition, the SSOMI followup team was shown a revision to the 250-V de electrical system operating procedure dated February 1988, which imposed the same limitatio The team considered that this item has been satisfactorily reso*lve This item is close.1.27 Unresolved Item 5.1-8 50-249/86009-31 : Batter Surveillance Tern er-ature ower t an at na empurature:

ant operat ng survei ance procedures had require that the battery cell temperatures be maintained above 60 degrees However, the battery sizing calculations reviewed by the SSOMI Design team had not accounted for the loss in battery capacity below the standard battery rating temperature of 77 degrees Without such an analysis, it was not possible to verify that the batteries had sufficient capacity as required by Section 4*.9 of the technical specifications.

Although the licensee had taken actions to resolve and close this item, the initial response had not been ad~quate because several elements were not responsive to the issue described in the SSOMI design repor Notwithstanding the licensee's official response, discussions with licensee representatives during this review indicated that appropriate actions had been taken to resolve the item since the original SSOM All of the 24/48-V batteries, 125-V batteries, and the 250-V batteries have

• been replaced, and they are of the size to provide the required capacity with temperature correction down to 65 degrees Also, the heating,

• ventilatio~, and air conditioning (HVAC) system has been modified to provide a design minimum temperature of 65 degrees F for the battery rooms, and surveillance procedures have been revised to require this minimum battery cell temperature~

The team'*S review of the actions taken by the 1 icensee determined that this item is closed *

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The licensee responded that the concerns identified in the IE notice were based on continuous overvoltage applications, and that the equalizing charging period for the batteries which results in the overvoltage condition was not continuou Although the licensee resolved the item during this inspection, the followup team informed the licensee that this interpretation of the IE notice was not correct. The second of three examples in the IE notice is an example of a noncontinuous application similar to the situation in question at the Dresden plant, i.e., over-voltage during equalizing charging of the batter In response to q~estions from the followup team, the licensee obtained documentation from the equipment vendor which showed that the voltage drop through the Rosemount trip unit output drivers, which supply power to each of the Agastat relays, is 1.9 Since the maximum bus voltage during equalizing charging is 28 V, the maximum voltage at the relays is 26.1 V, without considering the other resistances in the circuits. This voltage is less than the relays' maximum rated voltage of 27 v.*

This item is close.2 * Items Closed:

Additional Program Followup Required The licensee's response to the notice of violation did not address the root cause of many of the SSOMI concerns:

the failure of personnel to follow procedures properly. Although CECo has improved its program in this area (revisions to several DAPs and informal training), the followup team did not consider the improvements sufficient, in light of the significance of the problems attributed to that caus *

The following 17 items have had their specific concerns satisfied. However, a new open item, Open Item 2.4-1, "Corrective Actions Relative to Adherence to Procedures," has been established for the purpose of verifying that the underlying cause for these 17 items has been properly correcte (See Section 2.4.2 of this report.)

2.2.1 Deficienc 2.2-10 50-249 86012-13 : Solenoid Valve Desi n Control:

This SS team e c1ency regar ng es1gn c ange contra o solenoid valve modifications involved modification packages that provided incorrect drawings showing valve operator air lines reversed from their proper arrangement. These tncorrect installation drawings had been issued previously with Unit 2 modification packages; but the error was apparently identified and corrected on Unit 2, but not documented. This drawing error was then duplicated in the Unit 3 modification packages, and the solenoid lines were thus installed incorrectly on Unit The modiftcat1on packages for both units were subsequently corrected to reflect the correct as-built orientation, the Unit 3 lines were reversed to the correct positions, and the valves were satisfactorily tested for functionalit The CECo response correctly noted that the functional test (which had not yet been performed on the Unit 3 installations when the SSOMI concern was identified) would have identified the reversed operator lines. Although changes the licensee has made in their modification program should reduce the chance of similar problems, CECo's response was not complete:

the-17-

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response did not address how or why the error in Unit 2 was identified and corrected without documentation and withbut correcting the drawings in the packages, and the inadequate development of the Unit 3 modifi-cation package that incorporated an erroneous drawin The NRC followup team considered that the heightened awareness of the Dresden technical staff to this issue and the improvements in OAP 5-1, including the requirement for pre-work field walkdowns, should minimize the occurrence of this type of problem in the futur Considering these improvements and the correction of hardware and documentation directly related to the valves in question, this item is close.2.2 Deficienc 2.3-3 50-249/86012-19 : Master Tem orar Chan e Re uest Log:

e NR SS I team 1 ent1 ie severa e c1enc1es in t e master temporary change request (TCR) log in the control roo Defici-encies included 33 instances of missing entries for onsite review of TCRs, 17 instances of missing onsite review entries after TCR termination, and 31 instances of TCR termination dates that had passed with no indicated action to remove TCRs from applicable procedure Although the licensee took actions that resolved the item, the Dresden response to the notice of violation did not address correction of any specific examples noted in the SSOMI report. It merely indicated that a letter would be sent to the shift control room engineer (SCRE) to docu-ment the change in status of a TCR, and that a biweekly review of the log would be conducted by the procedures coordinator. The NRC SSOMI followup team reviewed OAP 9-2, "Procedure Preparation," Rev. 18, which addresses TCRs; the procedure did not reference either the status change letters to the SCRE or the biweekly revie The Dresden staff indicated that a draft procedure, OAP 9-6, "Temporary Changes to Procedures," had been prepared to separately address control of temporary procedure changes but to allow coordination with other OAP procedures and to ensure continuity of procedural coverage, draft OAP 9-6 had not yet been issue The draft procedure, which was reviewed by the NRC followup team, required more detailed control and review of the TCR process and included actions committed to in the Dresden respons The NRC review team concluded that proper implementation and subsequent adherence to the new procedure as written would improve the progra The NRC inspector also reviewed the master TCR log in the control room and identified no deficiencies. The NRC team concluded that the present program was being adequately implemente This item is close.2.3 Deficienc 2.5-6 50-249/86012-46 E Solenoid Valve Installation:

This e c1ency cons ste o t e o ow ng our nsta at on an ocu-mentation discrepancies regarding replacement of environmentally quali-fied (EQ) solenoid valve '.

...

Although the work traveler had specifically required that the solenoid is mounted with the coil upright and vertical,

11 the valves had been installed in a horizontal positio o The air operating lines had been ~onnected to the wrong ports which would have made the valves cycle opposite to the intended position o The environmental checklists in the modification package had listed different catalogue numbers from the numbers on the installed valves, and the serial numbers listed in the packages and on the quality assurance (QA) material tags had been reverse o The air supply tubing on one valve had been severely bent and kinke *

CECo responded that the solenoid valves had been verified, through discussions with the vendor, to function in the horizontal or vertical positions; that the damaged air supply tubing had been repaired; and that the modification packages for both units have been corrected and reflect actual valve installation configuration The NRC followup team reviewed a letter from Bechtel Engineering Company to CECo indicating that the valve vendor had determined that the valves would be acceptable if they were installed within 90 degrees of the full upright positio The team reviewed corrected modification package drawings which showed proper operator line connections, reviewed the corrected EQ checklists that had correct valve catalog numbers, and reviewed the modification documentation packages to verify they now contained copies of the correct material tags. The NRC team also verified that the kinked air supply tubing was repaire The specific technical concerns related to this deficiency have been satisfactorily addressed and improved procedures for developing and reviewing modification packages should minimize the chances of the.

documentation errors recurrin This item is close.2.4 Deficienc

Work Controls on Vacuum Breaker Va ves:

is e c ency concern ng t e torus to reactor bu1 ing vacuum breaker valves involved a lack of construction and installation control This lack of controls allowed issuance of a work request and work on valves that had already been replaced by a modification performed during the same outage, issuance of instructions that bolts be staked when, in fact, they physically could not be staked, and work request instructions and actual installation of one type of bolting material when the work request material list and weld map specified a different typ CECo corrected the work request documentation for Unit 3 to indicate the proper material. The licensee inspected the Unit 2 valves, found them to have the wrong material installed and reworked the valves to correct the installation. The documentation was corrected to reflect use of Locktite and the possibility that some bolts can not be staked. Revisions to OAP-19-

• 5-1 and OAP 15-1 should strengthen the relevant areas between maintenance and modification activitie This item is close.2.5 Unresolved Item 2.5-4 50-249/86012-56 : Securit Diesel Modification:

The iscrepancies i enti ie by t e NRC SSOMI team wit t e secur1tv diesel modification included components installed that were not in ~

• accordance with the traveler, components procured or specified in the traveler that did not conform to design specification requirements, only a partial listing in the work request of materials used, and a note on the work request that no fire hazard review was required because no welding was involved when, in fact, welding was require The licensee's corrective actions included an engineering review that concluded that the as-built installation was technically acceptable. The modification traveler was revised to reflect the work actually performed, and applicable drawings have been revised to reflect as-built condition The SSOMI followup team solicited and reviewed revised procedures that would help prevent problems of this type in the futur OAP 5-1 and OAP 15-1 have been revised to provide specific actions to ensure that instructions conform to specifications and to procedure requirement SNED procedure Q.6, "Modifications Originated by Station Technical Staff," requires the modification design package issued to the site to include specific design documents (drawings) and a bill of materia Concerns about this security diesel modification were answered and revisions to modification procedures should provide increased controls for future wor This item is close This test errors The response to this deficiency indicated the licensee was aware of problems in the area of test activities at Dresde The specific proce-dure errors identified in the SSOMI report have been corrected and a *

Modification Test Review Corm1ittee has been formed to review test proce-dures for accuracy and practicalit On the basis of this information, this item is close.2.7 Oeficienc 2.7-2 50-249 86012-59 : Test Procedure Verification Ste s:

This e c1ency concerns rec rcu at1on pipe rep acement test proce ures which did not contain steps to verify the test or to document verifica-tion of specific equipment on the applicable test procedure appendice The licensee's response indicated that startup test engineers (STEs) have been instructed to complete Appendices 10.7 and 10.8 of the subject procedures before performing the tests in order to support pre-test verification of equipmen ~ '

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With regard to the specific RPR tests referenced, the SSOMI followup inspection team reviewed Appendices 10.7 and 10.8 and found they con-tained appropriate STE signature No evidence of adverse impact upon test results was observe Consequently, this item is close.2.8 Unresolved Item 2.7-4 50-249/86012-64):

Chan e in Test Procedure Intent:

e R S

Insta at1on an Test report ocumente t at during performance of SP 86-1-9, *iReactor Recirculation System Preopera-tional Testing Test," a TCR was issued which changed the method of testing a temperature detector channel from a functional test of the channel to a continuity test using a signal injector. At the time of the test, test personnel explained that the original intent was to perform a wiring test rather than a functional test. The SSOMI team noted that the

• reviewed and approved test procedure was the basis for testing and that field interpretation of "original intent," if it is different from the approved procedure, was not allowable under station pro~edures~. *

The licensee's response to this unresolved item indicated that an addi-tional special procedure, SP 86-8-11, which monitored the thermocouple response during heatup, was written and performed to ensure proper response to temperature, and the use of TCRs was discussed with the RPR test group and its superviso The SSOMI followup team reviewed the additional special test and concluded that the tech~ical aspects of this issue have been adequately addresse This item is close.2.9 Observation 2.8-1 50-249 86012-68 : Documentin Calibration Checks:

The SS M nsta at1on an est report eta1 e concerns t at ur1ng testing for the core spray instrument modification M12-3-83-37, the hydrostatic test pressure had been increased with no procedure change or TCR provided, and that subsequent calibration checks were not documented properl The licensee responded to the observation that station personnel were reminded of the necessity for adherence to procedures and indicated that the requfrements for review of modification testing had been strength-ene SSOMI followup inspectors reviewed OAP 5-1, "Plant Modification

• Program," Rev. 16 and OAP 15-1, "Work Requests," Rev. 19 and concluded that the revised procedures would result in improved control of modifica-tion and testing if they were properly followe Draft procedures resulting from Dresden's procedure upgrade program that would have an impact on procedure adherence, procedure preparation, and procedure approval were also reviewe The draft procedures, if implemented as written, would provide additional improvement to station procedures and would assist in reducing recurrence of this type of proble The SSOMI followup team reviewed the modification package and verified that the calibration checks have been properly documented. Therefore, this item is close.2.10 Observation 2.8-2 50-249 86012-69 : Correction of Procedure Error:

The S team a een concerne t at t e o Ject ve o proce ure-86-1-6, "Core Spray Preoperational Test," had not been achieved since the A and B train instruments had been reverse The "Test Objectives" section-21-

of the procedure specifically stated_ that the procedure sought to verify proper indication of the core spray header differential pressure instru-mentatio During the original installation of the header differential pressure transmitters, instrument dPI 3-1467A was installed on the B core spray line and instrument dPI 3-14678 was installed on the A core spray lin Test Procedure SP-86-1-6, however, erroneously referred to the A instru-ment on the A core spray line and the B instrument on the B core spray.

line. While witnessing the performance of the test during the original SSOMI, it was apparent to the team that the test personnel were aware of the problem but were not correcting the procedure or making special note of the proble Thus, it was not clear that one of the test objectives, that of verifying proper operation of this instrumentation, was achieve The licensee responded that the instruments' lines had been reversed from the time of initial construction of the plan On August 11, 1986 the licensee evaluated the test results and properly noted the proble At that time it was determined that, although the lines were reversed, the instruments performed as expected since plant personnel were aware of this proble In addition, the licensee reversed the sensing lines

{plant modification M12-3-86-36) so that the instruments were correctly aligne All technical issues with respect to the adequacy of the preoperational testing or the material condition of the core spray instruments have been adequately resolved, and this item is close.2.11 Deficienc 2.8.2 50-249/86012-70 : Documentin Test Failures:

During t e per ormance o

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ow ressure oo ant nJection Preoperational Test, 11 the SSOMI team identified several items as examples of inadequate test control and documentation practices. These included the following:

o Inadequate documentation of the prerequisite to maintain reactor water temperature at or below 150 degrees o Double entry of stroke time data for valves M0-1501-22A and M0-1501-228 without any explanatio o Conducting fuel loading operations, for which this procedure was a prerequisite, without properly dispositioning the problem associated with the failure of the LPCI pump discharge pressures to meet the stated acceptance criteri o * Unauthorized and unclear changes to the procedure with respect to the instrumentation used to measure LPCI system flowrate during the tes The licensee responded to the deficiency, resolving the technical issues as follows:

o Since the reactor was in cold shutdown and defuel~d, the prerequi-site for maintaining reactor water temperature at or below 150-22-

t *

degrees F was satisfied at the start of the test, and it was not deemed necessary to document the temperature mainter.ance throughout the procedure since there was no capability to heat up during the performance of the tes '

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o The double entry of stroke times occurred because the original stopwatch data were misplaced and the test was performed agai The reason for the double entry was subsequently annotated on the test evaluation documen o Not meeting the test's criteria for the LPCI pump discharge pres-sures was attributed to the reading being taken at a flowrate of approximately 16,100 gallons per minute {gpm).

The pressure require-ment to prove technical specification operability required a flow-rate of 14,500 gp Pressure was not a direct requirement of RPR activities but had been included for completenes It was not possible to throttle the flow during the test since vibration measurements and cavity fill rate limitations required steady flows and minimal injection periods. A second test was performed the following day to verify pressure at the required flowrate of 14,500 gp This test was successfully completed and was used as a basis for concluding that LPCI could develop the required pressure at a 14,500-gpm flowrate and fuel load was pennitte At the time of the SSOMI, a detailed evaluation was not complete; however, on the basis of the data from the two tests, LPCI was considered operable. The test evaluation was subsequently completed and the importance of completing timely reviews was emphasized to test personne o-During the licensee's final review and evaluation of the test, the licensee resolved the questions regarding the source of data for_

measuring the LPCI flowrat This item is close Documentin LPCI Flow Test e c enc es in t e procedure and perfonnance of LPCI test SP-86-5-9 The test procedure was developed in response to IE Bulletin 86-01 and was designed to prove that a LPCI flow of 14,500 gpm could be obtained with a pump discharge pres-sure of 125 psig. During the perfonnance of the test, the discharg~

pressures of the three pumps operating at 14,500 gpm flowrate were in excess of 155 psig and no discrepancy report was filed in respons In addition, the test procedure was deficient in several other areas including:

o Lack of provisions on the data sheets for recording the name of the person responsible for perfonning the tes o Omission of records to indicate the date or period when the test was perfonne o Lack of provision for recording the LPCI flowrate, and for collecting the required data.

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The licensee responded that although the test format and documentation were not consistent with standard station pr6cedures, the intent of the procedure was to verify LPCI operability based on the technical specifi-cation requirement The technical specifications require a system flow of 14,500 gpm with three pumps operating and a minimum of 125 psig discharge pressure. Since the discharge pressures were above this value and consistent with discharge pressures recorded during previous surveil-lances, no discrepancy report was necessar,

Although the licensee was able to resolve the issue, its written response was considered inadequate since it did not address all the concerns regarding the inadequacies of the test procedur However, in discus-sions with the licensee's representatives, the team detennined that this procedure was performed for information only and the test data therein derived were not used for detennining LPCI operabilit The draft

• version of OAP 9-3 was also reviewed by the SSOMI followup team and, if followed, should prevent future occurrence of this type of test procedure deficienc *

The technical issues of this deficiency have been resolved and the item is close.2.13 Deficienc 2.8-5 50-249/86012-74 : Documentin Lo ic Test Defi-diency: Te SS MI team i ent1 ie a ev1at on rom test instruct ons ur ng performance of the LPCI and containment cooling service water (CCSW) logic tes In order to obtain a relay actuation time, the test technician acted outside the scope of the appropriate test procedur Additionally, this deficiency was not documented by test personne The licensee responded that the actions taken by the technician did not invalidate the test activity or subsequent results. The licensee further acknowledged that problems in the area of test performance did exist at Dresden and programs are being developed that should prevent similar occurrence in the futur *With regard to the specific LPCI/CCSW test referenced in the SSOMI report, the SSOMI followup inspectors confirmed by review of DIS 1500-5 test data sheets, that the actions taken by the technician had not degraded test performance or results. Consequently the technical aspects of this deficiency have been resolved, and the item is close.2.14 Deficienc 2.8-7 50-249 86012-76, Deficiency 2.8-8 (50-249/86012-77),

and servat on

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50-2 9 86 2-78 : Conduct of Erner enc Diesel Generator ests: T e two e c enc1es an one observation resu te rom the NRC SSOMI team's observation of DOS 6600-3 and DOS 6600-4, the bus undervoltage and ECCS integrated functional tests for Dresden's diesel generator The SSOMI report detailed many findings relating to the conduct of this testing. All issues for these items could be condensed into three functional issues:

inadeq~ate procedural adherence by test personnel, test stipervisors, and shift personnel; inadequate test control; and inadequate procedure The SSOMI followup team reviewed all discrepancies for both deficiencies and the observation with Dresden staff and found that all procedural-24-

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deficiencies had been corrected in draft copies of DOS 6600-3 and DOS 6600- The revisions to the draft procedures corrected technical inadequacies in procedure, added locations for breakers and switches where the locations were previously unspecified, and deleted incorrect step The many cases of "failure to follow procedures" noted during the test should be diminished by the deletion of incorrect steps, addition of selected verification steps, and clarification of specific actions through implementing the draft revision Since these procedures are only used during outages, the licensee has co11111itted in writing in the Dresden response to the SSOMI report to issuing the revisions before the procedures are performed agai The technical issues associated with this item are adequately resolve These items are close.2.15 Deficienc 2.8.4 50-249 86012-72 Evaluation The team note t at ur1ng t e per onnance o

- 6- -1,

eactor Water Cleanup (RWCU) Preoperational Test," which required verification of proper operation of several RWCU system valves, the computer point position indication for valve M0-1201-2 failed to functio The SSOMI team was c*oncerned that this prob 1 em had not been re so 1 ved before the steps of Section 6.2 of the procedure had.been perfonned; satisfactory completion of the valve position indication test was a prerequisite to perfonning the steps of Section CECO's response to the notice of violation indicated that the malfunction did not affect the test since the valve position was verified locally and on the ~ontrol room panels at the appropriate step and, at the time of the SSOMI, the final test evaluation had not yet been perfonne The computer point indicator was subsequently repaired under modification Ml2-2/3-80-06 and retested. *The anomaly had been documented on the test*

evaluation found with the procedur The SSOMI followup team's review found the licensee's response to be adequate with respect to the technical issue related to the operability of the RWCU system. This item is close.3 Items Remaining Open After the Inspection 2.3.1 Unresolved Item 2.1-3 50-249 86009-2 and Deficiency 2.1-4 50-2 8 0 -

C stem ea etection: The scope of these items, use of ea - e ore-rea concept or equ pment qualification and concerns regarding the leak-before-break analysis perfonned for the reactor water cleanup system, was outside the resources available to this inspectio The items were therefore referred to NRR Projects Division for resolution subsequent to this inspectio These items remain ope.3.2 Deficienc 4.1-7 50-249/86009-18 Documentin Safet Evaluations:

There were two concerns state in t e S es1gn report or t is deficiency regarding inadequate 10 CFR 50.59 evaluations: For the.

. modifications addressed, the safety evaluations tended to be brief, containing no detailed bases for the scenarios evaluated or for the.

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conclusions reached; and for five modifications performed on the analog trip system, there was no documented evidence that the impacts of changed system response times, interface with new power supplies, and loss of channel separation had been considered..

Although not documented in its response to the notice of violation, the licensee had generated a safety evaluation guidelines procedure, SNED procedure This procedure does require detailed, documented 10 CFR SQ.59 reviews for all modification New safety evaluations were perfonned to the requirements of SNED procedure Q.6 for the five modifications identified in the original SSOMI report. These evaluations were much more detailed than the original safety evaluations, and they did address new power supplies, channel separation, and the impacts of changed system response time These aspects of the deficiency are adequately resolve The SSOMI followup team's review of the new detailed safety evaluations identified a new concer The safety evaluations for all five modifica-tions stated that the minimum required voltage for the Rosemount instru-mentation is 19.8 V de, and the worst-case voltage drop is 4.4 Therefore, "Under abnonnal conditions with the 24V battery charger unavailable, which puts the plant in an LCO, there is potential for a low voltage condition at the analog trip cabinets."

No resolution of this apparent problem was presented in the safety evaluation When ques-tioned on this point, the licensee presented a calculation performed subsequent to the safety evaluations which showed that the voltage at the cabinets would be 20.9 V at the end of the design-basis 4-hour battery discharge period following an accident. Test results from a test per-formed in March 1986 were also presented which showed that with currents higher than those assumed in the calculation and with a 7 1/2-hour discharge period, the voltage at the cabinets was 20.l volt On the basis of this information, the technical concern regarding low voltage conditions to the trip cabinets has been resolve However, a progranunatic concern remains about how these new safety evaluations were approved although unresolved statements existed within the safety analyses that indicated a concern with low voltage at the trip cabinet under certain conditions. Therefore, this item remains open pending the following actions:

o Incorporation of the resolution of the low voltage concern into the safety analyse *

o A determination of why this concern was not identified and resolved with the plant in an operational statu o A description of the corrective actions that are being instituted to prevent recurrence of such oversights *

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No procedure existed to govern the calculation of safety-related set points. Set-point margiri was being added by personnel at the site without a documented basi o Safety impact evaluations of set-point changes were not being per-formed as required by CECo procedure OAP 11-1 o A number of set points could not be correlated to the system's design basis requirement (1)

Although the NRC followup team considered the licensee's response to be inadequate with regard to the response's interpretation of IEEE proposed standard 279-1968 and its relationship to set point docu-mentation, the licensee took actions to resolve this issue. Several procedural enhancements, which were not addressed in the licensee's response, had been made in the set-point progra Nuclear station directive NSDD-MlO, "Setpoint Change Control Programs,"

Rev. 0, dated May 1, 1987, had been generated; CECo's Architect-Engineer Guidebook had been revised with respect to set-point requirements; and one of CECo's most frequent consultants, NUTECH, had revised its training program to require providing the necessary set-point documentatio However, even though these procedures impose some controls that were previously nonexistent, they still fell short of the level of control that design modifications requir Both of the CECo procedures were deficient in this respect as follows:

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Both NSDD-MlO and the revised Architect-Engineer Guidebook had

"should" statements where "shall" statements would be appropri-ate, making the subject control measure optional when it should be mandator Examples included Section 5.2, "Applicability" of NSDD-MlO; and Item 3 of Exhibit 4-7, "Setpoint Justification," and Section 4.10 of the Architect-Engineer Guideboo Although NSDD-MlO acknowledged in two places (Sections 3.1 and 5.1) that set-point changes were changes to the design, they were not treated as such in that there was no stated requirement that the design basis for the setpoint change be identifie The Architect~Engineer Guidebook revision added approximately 45 instrument data sheets to be completed by contractors performing setpoint changes for CEC However, the sheets were not identified as to the type of instrument each was to be

.used for, and no guidance was provided on how to complete the sheet This aspect of the deficiency therefore remains open pending the following actions by the licensee:

Change the "should" statements to "shall" statements in NSDD-MlO and the Architect-Engineer Guideboo...

0 Change NSOD-MlO to require that the design basis for set-point changes be identified.

Add descriptive titles to each of the instrument data she~ts in the Architect-Engineer Guidebook, and add instructions for their use in the body of the documen (2)

The licensee also maintained that safety impact evaluations of the two set-point changes reviewed by the SSOMI team were not required since the procedure cited in the report, OAP 11-11, Rev. 6, does not apply to set-point changes in modification package However, the licensee did in fact perform safety evaluations for the modifica-tions and they were reviewed by the SSOMI followup tea The adequacy of these evaluations is addressed in the discussion of deficiency 50-249/86009-18 in Section 2.3.2 abov Therefore, this aspect of the item is resolve (3)

A substantial volume of new information was provided to the SSOMI followup team to show the bases for the set-point change The team's review of this information and subsequent conversations with the licensee resolved all of the original concerns except for high-pressure coolant injection (HPCI) steamline high flow instru-

. ments dPT-2352 and dPT-235 This exception is discussed as new unresolved item 2.4-1 in Section 2.4.1 of this report. Therefore this aspect of the deficiency is resolve.3.4 Deficienc 5.3~1 50-249 86009-34 :

MOV Overload Heater Selections:

The origina SS MI es1gn team a t e o owing concerns regar ng development of MOV overload heater selection:

o An unreviewed, unapproved procedure was being used to establish overload heater sizes for safety-related motor-operated valve o No procedure was available for selecting de overload heater o There was no documented evidence that overload heaters had been reviewed for any of the safety-related valves in the plant except for the few that had been reviewed by the station electrical engineering department (SEED} per the unapproved procedure described abov o The plus or minus 15 percent adjustment dial on the GE 124 K relays was not addressed in the draft procedure or in the set-point recornnendation from SEE o MOY 1501-JA locked rotor current used by SEED did not agree with the motor nameplate dat o No backup calculation existed for the heater sizes reconmended by SEE o The SSOMI team could not duplicate the licensee's selection of heaters utilizing the licensee's procedure described abov..

The licensee present~d a number o& documents which resolved most of the original concerns; however, one concern ~emains open pending additional action by the licensee. A new concern regarding control of heater selections and installations was identified and is discussed in Section 2.4.3 which follow (1)

The licensee had issued a reviewed and approved design guide, R. Guide No. 06, foi the sizing of overload heaters for MOVs in nuclear stations. The licensee alsQ pointed out that there had been no MOV failures due to improperly sized heaters over an 8-year period following a heater resizing progra The new overload sizing guide was reviewed-and found to address de as well as ac MOVs, and to contain specific guidance for setting the adjustment dial on GE 124 K relays to 100 percen The licensee stated that the motor locked-rotor nameplate data had been determined to be correct for MOV 1501-3A, and the heater sizing calculation had therefore been redon The effect was negligible, not requiring a change in the heater size. The locked rotor current discrepancy was corrected also on the station data sheet for DMP 040-6, Revision The backup calculations to a review of the safety-related MOV heater sizes performed by S&L were performed, reviewed, approved, and filed in their offices in accordance with their QA progra The S&L backup calculation for MOV 1501-3A was reviewed by this inspection team against the ~pproved sizing guid The heater size selected in the calculation was duplicate These aspects of the deficiency are close (2) The team was provided with a copy of a review performed by S&L of the safety-related MOV overload heaters (480-V ac, 460-V ac, 440-V ac, 208-V ac, 250-V de, and 230-V de). This review was performed in

.accordance with the approved guide described abov The heater sizes thus obtained were compared with the installed heaters, and a list was generated of the valves for which heaters had to be replaced. This infonnation was convnunicated to the site by a letter dated August 4, 1987, with the request that these heaters be change The licensee stated that the incorrect heaters would be replaced during the upcoming unit outage or that they would be analyzed to show that they comply with current NRC guideline This item remains open pending completion of these action.3.5 Deficienc 2.2-7 50-249/86012-09): Safet Evaluations of Procedure Changes:

e nsta at1on an est report 1 ent1 ie t at s

written for station procedures to test modifications had inadequate safety review Many of the safety reviews were.found to repeat the safety review done for the modification package or just to reference the modification package safety revie CECo responded that to ensure meaningful and accurate safety evalua-tions, extensive training material was disseminate The NRC SSOMI-29-

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~ I followup team reviewed a training material package that was presented for review and discussed the issue with Dresden staff. The interim docu-mentation and training that was provided to key personnel was promulgated by a guidance letter issued by the station manage The guidance letter included the SNED-approv~d safety evaluation guideline checklists, a procedures list from the FSAR, design-basis-accident information, and a safety evaluation lesson pla The interim guidance was to be supple-mented by new procedure OAP 9-9, "Safety Evaluations," which was planned to be used for safety evaluation of procedure changes only. Discussions with Dresden staff indicated that several different guidance documents existed for safety reviews which included SNED procedures for modifica-tions prepared by SNED, and four separate Dresden administrative proce-dure The NRC review team was concerned that several documents addressed safety evaluations and that it appeared a consistency review of all guidance *had not been conducte Because of this multiplicity of guid-ance and the significant number of deficiencies noted during the SSOMI and this followup inspection, the NRC team continued to be concerned about the adequacy of Dresden's 10 CFR 50.59 progra The NRC SSOMI followup team reviewed the draft-OAP 9-9 and concluded that, if promulgated and implemented as written, it would provide improved guidance for conducting safety evaluations on procedure change However, Dresden staff elected during this inspection, to incorporate all station 10 CFR 50.59 guidance into a new safety evaluation instruction, OAP 10-2, to consolidate information and guidance from the several instructions, because of both Dresden and NRC concerns. This item remains open pending generic corrective action for safety evaluation Specific action necessary to close this item includes:

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Issuing the new safety evaluation procedur o Training all personnel who prepare, review, or approve safety evaluations on its contents~

o Conducting a review or sampling of past safety evaluations for adequac.3.6 Deficienc 2.4-1 50-249 86012-21 : Modification and Test Acee tance Criteria:

e SS team was concerne t at a equate acceptance criteria had not been provided in a number of tests and modification package The SSOMI report discussed eight separate example The licenseeis response identified changes to various procedures and documents that resolved many of the specific example One example not addressed in the response was resolved through discussions with the licensee which identified procedure changes that resolved the exampl The SSOMI followup inspection team reviewed those documents to determine that adequate acceptance criteria had been included where required and program changes were made to prevent recurrence and in most cases concurred in the licensee's conclusion. These documents included electrical construction test procedure (ECTP) 1, Rev. O; Bechtel Power Company letter Chron 11313, June 6, 1986; DIS 1700-5; DCP 2700-1; DCP 3000-T70; SP-86-1-9; OAP 5-1; and OAP 15-1 *

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However, the initial corrective action for one example was found to be unacceptable, and two other examples remain unresolve (1) Jhe CECo response indicated that seismic requirements for the modification to the diesel generator's cooling water pump were evaluated during the performance of the 10 CFR 50.59 safety evalua-tion (although not documented).

However, the CECo response did not address why there had been no documented seismic analysis, and did not address the lack of construction controls for piping length to prevent overstress conditions. Subsequent to the SSOMI, CECo perfonned a separate seismic calculation documenting the accept-ability of the installation which was presented to the SSOMI followup tea The followup team's review found this calculation unacceptable since it was unsigned, unchecked, unapproved, and did not even reference the piping line or modification being evaluate However, the inadequate seismic calculation had been ident~fied by CECo during a QA department safety system functional inspection in late 1987 and a formal calculation was issued February 9, 198 The proper seismic analysis and development of an as-built drawing of the installation, which were reviewed by the SSOMI followup team, resolved this SSOMI example; improvements to the modification program in OAP 5-1 should minimize deficiencies of this type in the futur (2)

The following two examples within the deficiency were not resolved and remain.open:

The licensee's response to incomplete work instructions for WR 46639 indicated that inclusion of the repair manual 12-MM-2 as a reference in the work package did not necessarily mandate that all instruc-tions in the manual were applicable for this specific work reques It was intended to be used as a reference by craft personnel to help them complete the tasks specified under the work instruction Although the station believed the work performed under this work request was of an acceptable quality, in the future the station will require a more detailed collection of instructions to reduce reliance on craft capabilit The licensee's response was incomplet OAP 15-1 required that detailed procedures or instructions be provided or referenced on work packages that require specific approva The work request in question failed to meet the requirement of this procedur The licensee appeared to have taken no corrective steps to emphasize the need to comply with the requirements of OAP 15-1 with respect to increasing the level of detail in work instruction The licensee needs to demonstrate that the level of detail in work requests currently being utilized is consistent with the requirements of OAP 15-.

CECo's actions in response to the SSOMI concerns regarding HPCI pipe whip restraints included issuing a design change after the SSOMI and again modifying restraint PWHP-1, adding the hot and cold position pipe-to-restraint design clearances to the installation drawings,

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and issuing a procedure by means of which the field engineei visu-ally verified that the restraints conform to design drawing However, CECo's written response to the notice of violation did not address the failure to identify the design error before completion of work, and the inability of the inspection criteria and requirements to detect the erro In addition, the response stated that the installers had field marked the existing position of a U-bolt on PWHP-1 disassembl During the SSOMI, NRC inspectors were not able to identify any field markings and the installers were unable to show how or where such marking was don Replacement of this U-bolt to the as-found condition was a critical requirement because CECo had determined that inspection of final hot position clearances were not necessar The NRC followup inspector reviewed the revised drawings, proce-dures_, completed documentation, and supporting engineering informa-tion, and discussed this issue with responsible engineering personne Several additional discrepancies were identifie o For PWHP-1, the addition of the predicted thermal growth to the specified maximum installation cold clearance (with the instal-lation tolerance) places the pipe slightly (1/16 inch) outside the design maximum clearance. Although this was addressed in the calculation that reworked this restraint after the SSOMI and was determined to be acceptable, it imparts another item of uncertainty concerning the design and installation of this modification; tolerances were allowed that could result in a final installation outside of design requirements.

. o The NRC followup team noted that during the Impell hot walkdown inspection no clearance was found between the bottom of the pipe and the restraint on jet impingement restraint (JIHP) 3 on the same HPCI line. The results of this walkdown inspection of the as-built condition was the basis for the modifications to these restraints. If no clearanc~ existed, then the pipe could well have been restrained and thus the recorded clearance measurements on adjacent restraints may not have been accurat o The cold position walkdown, performed by Dresden personnel after the SSOMI, revealed that a small gap existed between the bottom of the pipe and JIHP-However, although Impell predicted thermal growth would be in an upward direction, the Impell hot position inspection showed no clearance between the bottom of the pipe and the restraint. Therefore, it appears that either the pipe moved in a direction opposite to that predicted or one of the walkdown inspections was in erro These attributes are the basis upon which the design changes were mad The lack of a hot position clearance indicated that during a-seismic event there would be interference between the pipe and restraint JIHP-No modification was performed on JIHP-3 to provide the necessary clearance. A cold position walkdown comparison worksheet (performed after the SSOMI) provided by-32-

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CECo contained an inadequate ju$tification for the acceptability of this predicted interferenc Individually, all of the above-listed new concerns for the HPCI pipe restraint modification were mino However, when these discrepan-cies were coupled with the original design error, the lack of tight construction controls and inspections, the failure to verify that the modified conditions met the design intent, and the inadequacy of the written CECo response to this item, it raised a concern regarding the overall design effort for these change The NRC followup inspection team considered that additional licensee action was necessary to perform a comprehensive review of all aspects of this design change, from inception to completion, to ensure that the as-built condition of this HPCI line and its supports and restraints are technically acceptable and will perform their design functio CECo should also address the long-term corrective action to prevent the recurrence of similar design error.3.7 Unresolved Item 2.4-2 50-249 86012-30 : Seismic ualification of LPCI Room Coo er Motors:

is unreso ve item concerne t e a equacy of seismic qualification for Westinghouse motors used for operation of the LPCI room cooler In question was the application of the rigid mount criteria used in the original seismic qualification to the flexible motor mount in the field installatio The licensee's response to this unresolved item was based upon a Westing-house analysis which had determined that the motors in question have

"sufficient strength and stiffness t~ withstand the conservative static coefficient analysis approach and subsequently, a dynamic analysis does not appear justified."

The SSOMI followup team reviewed the Westinghouse qualification report and additional information provided by the licensee, and determined that the licensee's statement was in part factual but did not provide details sufficient to close this issue. The Westinghouse seismic qualification was based upon an assumption that the motors would be rigidly mounted to their base As indicated in the SSOMI report, the actual installation of these motors was a non-rigid mounting.. Consequently, the licensee's response did not address the additional accelerations the motors may

experience as a result of their installed configuratio This item remains open until the licensee provides details sufficient to demonstrate that "as-1nstalledn conditions were considered during orig-inal qualification analysis, or until the licensee performs and documents additional analysis or evaluation which would demonstrate acceptability of the present installatio.3.8 Observation 2.5-4 50-249 86012-48 : Use of Grease on Sealin Surfaces:

The SSO team was concerne t at grease was eing use on numerous sealing surfaces that form boundaries subject to containment leak rate testing. Dresden routinely specifies the application of a "thin coating" or "light film" of heavy silicone grease on rubber seals on valve stems, bonnets and seats, and personnel hatche The NRC had issued a-33-

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confirmatory action letter (CAL) in 1983 because CECo had been. using grease on the valve seats to enable valves to pass leak test CEC0 1 s written response to the notice of violation stated that in keeping with their response to the CAL, Dresden restricts the use of lubricants on valve seating surfaces in accordance with vendor recommendation The SSOMI foll6wup team interviewed site maintenance, QC, and training personnel; reviewed maintenance and test procedures and work requests; and viewed a training video tape titled 11Lubricants, Sealants and Solvents.

The video tape adequately described the application of a 11thin coating 11 and warns personnel against using lubricants on valve seats. However, this video tape was not part of training for QC personne QC requirements consisted of site procedures and QC hold-points in maintenance requests to verify the absence of foreign materia In addition, the NRC SSOMI followup team noted that.a vendor report on a visit to CEC0 1 s Quad Cities plant in August 1984 stated that

11when va 1 ve 1 eak tests exceed the 1 imi ts maintenance personne 1 perform adjustments to the valve such as... lubricating the seat....

The NRC review team believed that the use of grease on numerous rubber seals subject to containment leak rate testing required more technical justification, more formal training (including QC personnel), and more specific controls on its application and inspectio The technical justification should provide assurance that the use of grease does not affect the results of leak rate testing. It should also address the changes in the grease (seal) condition due to aging, environmental condi-tions such as heat and radiation, and the effect of movement of component parts or fluids over the full time interval between leak tests. That is, it should detennine the long-term effect changes in the grease may have on the ability of the seal to perfonn its.functio This item remains open until the above concerns are resolved by the license.3.9 Unresolved 2.7-2 50-249/86012-62 :

LLRT Valve Lineu : The SSOMI team a been concerne t at DTS 1600-1, Loca Lea Rate Testing (LLRT)

of Primary Containment Isolation Valves, 11 had no specific valve lineup for perfonning the leak rate tes In addition, there were no plans or schedules for routine surveillance of leak rate test activities by either the QA or QC organization The licensee*s response and discussions between the NRC followup team and site QA representatives indicated that the site QC organization only verified a percentage of local leak rate test QC involvement usually took the form of witnessing the test on equipment after required maintenance had been performe The licensee*s response was not considered to be adequate by the SSOMI followup tea This item remains open pending the following correct~ve action by the licensee:

Surveillance test procedure DTS 1600-1 and other test procedures

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related to leak rate testing of containment isolation valves should-34-

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be changed, as required, to provide appropriate valve lineups needed for perfonning the test o QA or QC surveillance schedules should be augmented to provide for routine monitoring of leak testing activitie.3.10 Deficienc 2.7-3 50-249/86012-60):

The SSO team 1 ent1 1e e icienc1es wit test proce ures re ated to modification packages that were found to have a variety of shortcomings, omissions, and questionable documentation practices including:

o Lack of acknowledgement of prerequisite o No initial when "N/A" is use o No notation made when field personnel verify procedure step o Ineffective use of temporary change documentatio o No formal mechanism for releasing a test to be perfonne o No apparent mechanism for attesting to test completion or acceptabilit The licensee's response to the notice of violation indicated that since the SSOMI report did not identify the specific test procedures, it was not possible to take specific corrective actions for acknowledgment of prerequisites or lack of initials. The response did indicate that the modification program procedure, OAP 5-1, had been changed to improve the writing and reviewing of modification tests, including the institution of a modification test conunitte In addition, plant personnel were re-minded (through infonnal "tailgate" training and a station directive)

about the proper method for signing and initialing the steps of test procedure The response also stated that it is "general practice at the station" to annotate temporary changes in the affected procedur The response further stated that operations approval for starting tests is a requirement for prerequisites or first test step, and surveillance procedures include documented review of results on a cover pag The SSOMI followup team considered the response inadequate. Reliance on a ngeneral practicea which had been shown to be ineffective, and informal training to reinforce personnel adherence to procedures did not fully address the issue of test control. Further discussions with licensee personnel indicated that new procedures were being written to address control of procedures in general and special test procedures specificall Since the general issue of procedure adherence will be followed through an open item in Section 2.4-2, and improvements in the temporary proce-dure change process were verified in Section 2.2.2 above, these elements of the deficiency can be considered closed. However, this deficiency remains open until the licensee issues new administrative procedures and demonstrates that it adequately controls test prerequisites, ambiguous test step signoffs, and late test result review and approva..

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2.3.11 Deficienc 2.7-4 50-249/86012-65):

Consistanc* in Identif in Iso ation Va ves:

Discrepancies were identified by the SSOMI team between the technical specifications, the updated final safety analysis report (UFSAR), and the surveillance test procedure with respect to the identification and testing requirements of primary containment isolation valve In the case of the surveillance test inconsistencies, identifi-cation of containment isolation valves in test procedures DOS 1600-1,

"Quarterly Valve Timing," and DOS 1600-18, "Cold Shutdown Valve Testing,"

did not agree with that of Table 3.7.1 of the Dresden technical specifi-cation The licensee responded by revising the UFSAR as part of the annual update to accurately reflect the correct containment isolation valves as required by the technical specifications. The licensee had changed the UFSAR, and the UFSAR now agrees with the technical specification with respect to identification of primary containment isolation valve The licensee did not, however, address the problems associated with the surveillance test procedure This item remains open pending the following actions by the licensee:

o All differences between the valves identified in the technical specifications as containment isolation valves and those so noted *in surveillance test procedures DOS 1600-1 and DOS 1600-18 should be reconcile The licensee should verify that all containment isolation valves listed in Table 3.7.1 of the technical specifications are subject to appropriate stroke testing as required by the technical specifica-tions and ASME Inservice Testing (IST} Progra.3.12 Deficienc 2.7-5 50-249 86012-66 : Valve Stroke Time Verification:

This SS M efic1ency nvo ve rep ac ng t e operating so eno1 va ves on the reactor building vacuum breaker valves without testing to establish thatthe vacuum breaker valves operated within a specified maximum stroke time requiremen The ASME Code,Section XI, Sub.section IWV-3410, specifies that* "the limiting value of full stroke time of each power operated valve shall be specified by the owner."

• CECo written response to the notice of violation stated that the modifi-cation test was revised to incorporate valve stroke times in accordance with Section XI of the ASME Cod The response further stated that Dresden instrumentation surveillance (DIS) and Dresden operating surveil-lance (DOS) procedures, performed after repairs and before start-up, included-proper stroke time The SSOMI followup team found that this response was in erro At the time of this inspection, Dresden* still had not established a maximum stroke time for these valves and the applicable DIS and DOS procedures did not specify stroke time However, Dresden is currently performing a major upgrading of itsSection XI IST Program. * CECO needs to complete the following actions in order to resolve of this item:

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• o Issue and implement OAP 11-21 (new procedure) providing administra-tive guidelines for the IST Progra o Revise surveillance procedures to specify maximum allowable stroke times for power-operated valves as is required by the ASME Cod o Provide procedure requirements to ensure that maintenance and modification activities affecting IST Program components (governed by OAP 5-1 and OAP 15-1) are always reviewed by personnel responsible for the IST Program to ensure that ASME Code requirements are me.3.13 Deficienc 2.8-1 50-249/86012-67 : Documentin Lo ic Test Failures:

This SS e ic1ency invo ve test an component a1 ures that occurred during testing of the core spray system and the LPCI/CCSW logic. Defi-ciencies identified in the SSOMI report included _system relay failures which were not evaluated by the license The licensee's formal response to this deficiency stated that while it was recognized that test performance and documentation need improvement,

"none of the test discrepancies identified by the inspection team invalidated any test procedure."

On the basis of the SSOMI followup team's review of this response, and additional information provided by the licensee, it was determined that the licensee had not documented the deficiencies identified in the SSOMI report, and had not evaluated component failures or their effect upon

• system test and performance. This deficiency will remain open pending resolution of the following:

o The licensee's response does not provide objective evidence to support the conclusion that test activities were not invalidated by the identified deficiencies. Specifically, the component failures were not evaluated or analyzed for their effect upon the system test and its performanc o The licensee did not provide evidence to indicate that the deficien-cies encountered during performance of the tests have been properly documente A review of the original test data sheets disclosed no reference to the relay failures identified in the SSOMI report, nor.

were deficiency reports (DRs) written for these items. Additionally, the only documented evidence of a retest of these systems was the presence of a second date in the ipace on the data sheets for test step verificatio.4 New Items Identified During the Inspection 2.4.1 Unresolved Item 2.4-1: HPCI Hi h Flow Set oint Basis:

During the SSOMI fo owup team s rev ew o ns rumen set-po n asis or deficiency 2.3-3 86009-19 (Section 2.2.2 above), NUTECH calculation XNC-01.0201 was originally presented to the team as the basis for the HPCI high-flow instrument (dPT-2352 and dPT-2353) set point corresponding to three times the maximum expected steam flo The maximum expected steam flow was determined to be 125,000 pounds per hour at 1125 psia, the maximum rated-37-

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pressure for the HPCI turbin These values were taken from GEK-78 which is a General Electric (GE), Dresden-specific system document for the HPCI system, dated 197 According to this calculation, at this flow condition, the differential pressure would be 141.74 inches of wate The set point provided for the instruments corresponded to 145.5 inches of water. Therefore, at 300-percent flow, according to this calculation, the setpoint would not be reached, making this a nonconservative set poin When this discrepancy was pointed out to the licensee, a GE document, GEK-26901, was presented that was described as the design basis rather than the calculation that had been provided originally. This document showed a set point of 150 inches of wate The set point being used, it was maintained, was conservative with respect to this design basi Also presented was a GE design specification, 257HA353AC (later deter-mined to be the design specification for the Quad Cities plant.. The Dresden specification, 257HA353AB, contains the same flow vs. pressure values). Specification 257HA353AC showed the maximum expected flow to be 145,000 pounds per hour at 1125 psia, and a new calculation was presented which showed that for a steamline break, the resultant differential pressure would be well above the current set poin The first calcula-tion had been cancelled. The team responded that had the first calcula-tion not been originally presented as the basis, there would have been no reason to question the GE documen However, given this conflicting document, the GE design specification was considered questionabl The licensee then responded that because the elbow tap flow instruments were inaccurate, calculations of flow versus differential pressure could not be relied upon, but rather that startup test data which showed actual flow vs. differential pressure should be used instea The team agreed and asked that if the set point was indeed based upon such data, the data be provide The licensee then conceded that it had not actually been so based. Another basis, from FSAR question and answer 5.3, of 3000 gpm of saturated water was also presented as the basis for the set point, but no correlation could be shown between this value and the set poin At the end of this inspection, there was no serious concern that the instruments would fail to isolate the HPCI steamline for a break as required because the results of the break calculation show that a dif-ferential pressure well above the existing set point would occu However, there was still no analysis that correlates the existing set point to 300-percent of the maximum expected flow as stated in the FSAR, i.e., no analysis which determines the differential pressure for 300-percent of 145,000 pounds per hou Additionally, because of the con-flicting documentation, _a* concern had been -raised about the validity of the 145,000 pounds per hour as the maximum expected flo This item remains open pending the following actions by the licensee:

o Verify the actual maximum expected flow (as-delivered as opposed to as-specified) for the HPCI turbin o Perform an analysis that determines the differential pressure expected for 300-percent of this flo.

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Change the set point of the instruments in the plant to reasonably correspond to the differential pressure thus determine o Or alternatively, change the FSAR and other plant documents to indicate the percent flow that the existing set point corresponds to with respect to the actual as-built HPCI turbine maximum expected flow, and show how this change to the design basis does not reduce the margin of safety for the plan.4.2 Open Item 2.4-1: Corrective Actions Relative to Adherence to Procedures:

During the SSOMI, the team found many issues that were cited as violations or deficiencie When those issues were reviewed by both the NRC and CECo, it became clear that a major root cause contributing to the problems was failure to adhere to existing procedure The Dresden response to the SSOMI reports, although acknowledging and responding to technical concerns, did not specifically address timely formal corrective action to ensure that procedures are either followed or that an.approved procedural change method is use During the SSOMI followup, the team requested formal training records, lesson plans, policy statements, QA surveillances specific to procedure adherence, revised procedures, or other documentation to indicate specific corrective action and*recurrence control for this root cause. The documentation provided and the licen-see's response to the notice of violation, which used words such as

"station personnel meetings have occurred to emphasize the requirement of adhering to approved procedures" and "station personnel have been re-minded of the necessity to adhere to all procedural requirements," raised concern about the adequacy of corrective action taken in this are During discussions with Dresden staff, Dresden management personnel indicated that a quality assurance trending report for 1987 indicated poor adherence to procedures and the SSOMI followup team's review of about 65 discrepancy reports for the last half of 1987 raised similar concerns. This concern, which apparently still exists, requires prompt management attentio A review of nuclear station directive NSDD-A09, "Conduct of Operations,"

Rev. 7 indicated that a general requirement to follow procedures was applicable only to operations department personnel and procedure It appeared that no corporate policy applicable to all departments and personnel existed. During the inspection, Dresden management personnel con111itted to incorporating the guidance on procedure adherence stated by the Institute for Nuclear Power Operations (INPO) into corporate and station procedures and training personnel on its content The following action is necessary to close this issu o Establish a corporate policy regarding proper adherence to all procedures and clearly document this polic o Implement this policy at Dresden for all procedures and all personne o Train station personnel on the policy, on the implementing procedures, and on allowable interpretation t *

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~ 2.4.3 0 en Item 2.4-2: Control of MOV Overload Heater Chan es:

The SSOMI fo owup team i ent1 ie an a it1ona concern ur1ng its review of changes in CECo's program for selecting MOV overload heater The team was concerned that even with the newly instituted design guidance for MOV heater selection, replacement of heaters was still not receiving the same level of control as other similar changes, such as instrument set point changes, which are considered alterations to the plant desig For example, heaters may currently be replaced by site personnel without consultation with design engineering personnel, without adhering to the new selection guide for heaters, and without performing a 10 CFR 50.59 safety evaluatio The licensee responded to this concern by stating that the site procedures would be changed to require that all heater changes and changes to MOV torque switches would be coordinated by the design engineering group. This item requires procedure changes adequate to control MOV overload heater changes performed by site organization CONCLUSIONS The reviews and improvement programs undertaken by the licensee as a result of the SSOMis and subsequent inspections by NRC Region III and headquarters personnel are extensive and far reachin However, the written response to the NRC's notice of violation was in many cases incomplete or did not address the concern described in the inspection report Examples include the failure of the response to (1) address SSOMI concerns regarding inadequate 10 CFR 50.59 safety reviews and (2) evaluate and detail corrective actions relating to deficiencies that occurred during modification testing. The team was able to close items based on information and actions the team obtained from the licensee's representative For example, the team's questioning on several deficient 10 CFR 50.59 issues revealed that CECo's reevaluation performed after the SSOMI had also been deficient, and additional evaluations had to be performed during this inspection to resolve the original problem Discus-sions with the licensee on the individual items also revealed in some cases that, although not discussed in the official response to the notice of viola-tion, actions had been taken that resolved the item At the time of the followup inspection, the licensee had not implemented all of its program improvements and procedure revisions to address long-term corrective actions in several areas. This inaction prevented full closure of a number of open items and resulted in the grouping of others into a new co1T1Tion open item. This new item deals with corrective actions to prevent failure to follow procedures. Although failure to follow procedures was a root cause revealed by the SSOMI and subsequent CECo modification program task force, the followup team did *not see the objective evidence that a management philosophy of strict procedural adherence had been adequately co1T1Tiunicated to all working levels at the site. The current corporate policy on procedure adherence published in NSDD-A09 only applies to the operations departmen Discussions with Dresden management on this issue elicited verbal assurances that the policy in NSDD-A09 would be generalized to encompass all site staff and would be included in proposed revisions to administrative procedures currently being prepare MANAGEMENT MEETING Utility and plant management met with the NRC staff on March 11, 198 The objectives of the inspection were restated and the inspection results and-40-

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conclusions were summarize The discussion included the reasons why some items remained open and why three new items had been opened as a result of this inspectio PERSONS CONTACTED The following list identifies the key people contacted b~ the team during this inspection. Those persons indicated with an asterisk (*) were present at the exit meeting conducted on March 11, 198 *E. Armstrong

• E. Netzel

• S. Kuczynski

• B. Christel

• R. Dyer

• E. Eenigenburg

• J. Wujciga

• J. Brunner

• R. Meadows

• R. Geier

• J. Silady

• G. Frizzell

• M. Reed

• B. Viehl N. Smith J. Gelston G. Milligan J. Atwood 6 DOCUMENTS REVIEWED Regulatory Assurance Supervisor Quality Assurance Superintendent Technical Staff Modification Group Leader Assistant Modification Group Leader Dresden Station Manager Production Superintendent Assistant Superintendent Technical Services Maintenance Staff Supervisor Quality Control Supervisor Nuclear Licensing Administrator BWR Engineering BWR Engineering Site Supervisor BWR Engineering Nuclear Licensing Supervisor NUTECH Engineers NUTECH Engineers NUTECH Engineers Dresden Administrative Procedure {OAP) 2-8, 0 Deviation Reporting" OAP 3-11, "Station Material Condition and Housekeeping Program" OAP 4-10, "Post Maintenance Review and Trending of Nuclear Work Requests" OAP 5-1, "Plant Modification Program0 OAP 7-2, °Conduct of Shift Operations" OAP 7-3, aoperat1ng Orders" OAP 7-4, °Contro1 of Temporary System Alterations" OAP 8-1, "Training Department Organization" OAP 8-2, "Personnel Training

OAP 9-1, "Station Procedures

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OAP 9-2, "Procedure Preparation"

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OAP 9-3, "Procedure Review and Writing" OAP 9-5, "Review and Approval of Non-Station Work Group Procedures" OAP 11-11, "Control of Setpoint Changes" OAP 12-12, "Installation and Control of Temporary Shielding" OAP 15-1, "Work Requests" OAP 15-3, "Preparation of Safety Related, Regulatory Related, or Reliability Related Work Packages Off Shifts" Dresden Maintenance Procedure (DMP) 040-6, "Safety Related MDV Data and Settings"

UMP 200-30, "Units 2/3 6-Inch Safety Valve Overhaul and Test Procedure" DMP 7300-5, "Inspection and Maintenance of 480V.MCC Breakers/Contactors and 208V Contactors" Dresden Operating Procedure (DOP) 1600 Ml/El, MPressure Suppression Checklist Prestartup" DOP 6900-1, "250 VDC Electrical System Operating Procedure" DOP 6900-2, 11 125 VDC Electrical System Operating *Procedure," and Procedure Change Request 88-2-121 Dresden Operating Surveillance Procedure (DOS) 10-6, "Surveillance of Units 1, 2, and 3 Temporary System Alteration Logs" DOS 6600-5, "Bus Undervoltage and ECCS Integrated Function Test for 2 (3)

Diesel Generator" Nuclear Station Work Procedure (NSWP) G-1, "Preparation and Processing of Work Packages" NSWP M-5, "Pressure Testingn Quality Procedure {QP) 3-51, "Design Control for Operations - Plant Modification" QP 11-1, "Development, Perfonnance, Documentation, and Evaluation of Con~truction Tests" Station Nuclear Engineering Department (SNED) Procedure Q.6, "Modifications Originated by Station Technical Staff"

Nuclear Station Quality Control Procedure (NSQCP) 1, "Nuclear Station Quality Control Inspector Qualification and Certification" Nuclear Station Directive (NSD) NSDD-MlO, "Setpoint Change Control Program"

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Dresden Report, "Dresden Safety Valve Analysis - Conclusions from Six Months of Investigations Into Causes of Premature Safety Valve Actuations" CECo Report M-944-72, "Operational Analysis Department Report on Safety Valve Springs from Nuclear Stations" NUTECH Calulation XCE004.0300.0137, "Over Voltage at Analog Trip System Cabinets" NUTECH Calculation CWE-44!0200, "HPCI High Steamline Flows" NUTECH Calculation XNC-01.0201, "HPCI High Steamline Flow" NUTECH Calculation XNC-01.0203, "Core Spray Minimum Flow Setpoints" NUTECH Calculation XCE004.0300.0143, "Setpoint Conversions" Sargent & Lundy Engineers (S&L) Calculation 7927-12-19-1, "MOY Overload Heater Review" General Electric Comapany (GE) Design Cri.teria 22A2501, January 28, 1969,

"Separation Requirements for Reactor Safety and Engineered Safeguards Systems" GE Design Specification 257HA353AC, "High Pressure Coolant Injection System"

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ac ASME CAL CE Co ccsw OAP de DIS DMP DOP DOS DR DTS ECCS ECTP EQ FSAR gpm HPCI HVAC IE IEEE INPO ISA IST LLRT LPCI MOV N/A NRC NRR NSO NSQCP NSWP OJT QA QC QP RPR RWCU S&L

• scRE SEP SEED SSOMI SNED SP STE TCR UFSAR v

WR ABBREVIATIONS alternating current American Society of Mechanical Engineers NRC Confirmatory Action Letter Commonwealth Edison Company containment cooling service water Dresden administrative procedure direct current Dresden instrumentation surveillance (procedure)

Dresden maintenance procedure Dresden operating procedure Dresden operating surveillance (procedure)

deficiency report Dresden technical surveillance {procedure)

emergency core cooling system electrical construction test procedure environmental qualification final safety analysis report gallons per minute high-pressure coolant injection heating, ventilation, and air conditioning NRC Office of Inspection and Enforcement (superseded)

Institute of Electrical and Electronics Engineers Institute for Nuclear Power* Operations Instrument Society of America inservice testing local leak rate test low-pressure coolant injection motor-operated valve not applicable Nuclear Regulatory Commission (NRC Office of) Nuclear Reactor Regulation nuclear station directiv~

nuclear station quality control procedure nuclear station work procedure on-the-job training quality assurance quality control quality procedure recirculation pipe replacement reactor water cleanup Sargent & Lundy Engineers shift control room engineer Systematic Evaluation Program station electrical engineering department NRC safety systems outage modifications inspection station nuclear engineering department special procedure startup test engineer temporary change request updated final safety analysis report volt{s)

work request-44-