IR 05000010/1980020
| ML19351D996 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion  |
| Issue date: | 11/06/1980 |
| From: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19351D993 | List: |
| References | |
| 50-010-80-20, 50-10-80-20, 50-237-80-22, 50-249-80-26, 50-254-80-26, 50-265-80-27, 50-295-80-21, 50-304-80-23, NUDOCS 8011200544 | |
| Download: ML19351D996 (26) | |
Text
V U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-10/80-20; 50-237/80-22; 50-249/80-26; 50-254/80-26; 50-265/80-27; 50-295/80-21; 50-304/80-23 Docket No.50-010; 50-237; 50-249; License No. DPR-2; DPR-19;DPR-25; 50-254; 50-265; DPR-79; DPR-30; 50-295; 50-304 DPR-39; DPR-48 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Units 1,2 and 3 Quad-Cities Muclear Power Station, Units 1 and 2 Zion Nuclear Power Station, Units 1 and 2 Meeting At:
Commonwealth Edison Corporate Offices Meeting Conducted:
October 31, 1980 NRC Personnel Present:
J. G. Keppler, Director, RIII R. F. Heishman, Chief, Reactor Operations and Nuclear Support Branch, RIII R. L. Spessard, Chief, Projects Section No. 1, RIII T. M. Tongue, Resident Inspector, Dresden N. J. Chrissotimos, Senior Resident Inspector, Quao-Cities J. E. Kohler, Senior Resident Inspector, Zion J. R. Waters, Resident Inspector, hion D. C. Boyd, Chief, Projects Section No. 4, RIII R. J. Marabito, Public Affairs, RIII R. B. Bevan, Licensing Project Fbnager, ORB-2, NRR E. A. Reeves, Licensing Project Manager, ORB-1, NRR cj s
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Ad Approved By:
R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch Meeting Summary Management Meeting on October 31, 1980 (R;g' t
'b. 50-10/80-20; 50-237/80-22;
50-249/80-26; 50-254/80-26; 50-265/80-?1 _pi 295/80-21; 50-304/80-23)
Areas Discussed: Management meetin.
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the NRC's request to discuss the regulatory performance of the a..- f._
at Dresden, Quad Cities, and Zion Nuclear Generating Stations as concludoc in the Systematic Assessment j
of Licensee Performance (SALP) program, Results: A summation of the licensee performance evaluation was presented.
Areas of concern were discussed with corporate management.
The performance
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at Dresden, Quad Cities and Zion Nuclear Generating Stations was considered to be adequate.
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l DETAILS l
1.
Attendance CECO Mr. J. O'Connor, President (Part-time)
Mr. B. Lee, Executive Vice President Mr. C.. Teed, Vice President Mr. F. Palmer, Division Vice President - Nuclear Stations Mr. D. Scott, Superintendent Dresden Station Mr. N. Kalivianakis, Superintendent Quad Cities Station Mr. K. Graesser, Superintendent Zion Station Mr. D. Galle, Operations Manager, Nuclear Stations Mr. J. Abel, Director - Nuclear Licensing Mr. W. Stiede, Manager - SNED Mr. J. Danson, Maintenance Manager, Nuclear Stations
}k. J. Bitel, Technical Services Manager, Nuclear Stations Mr.11. Bliss, Director - Nuclear Fuel Services Mr. L. Butterfield, Zion Project Engineer, SNED Mr. E. Zebus, Dresden/ Quad Cities Project Engineer, SNED Mr. R. Janecek, Nuclear Licensing Administrator Mr. L. DelCeorge, F ~ lear Licensing Administrator Mr. T. Rousch, Nucie.r Licensing Administrator Mr. T. Tramm, Nuclear Licensing Administrator Mr.
G. Redman, Staff Assistant to Division Vice President - Nuclear Stations 7_L:E J. G. Keppler, Director, RIII R. F. Heishman, Chief, Reactor Operations and Nuclear Support Branch, RIII R. L. Spessard, Chief, Projects Section No. 1, RIII T. M. Tongue, Resident Inspector, Dresden N. J. Chrissotimos, Senior Resident Inspector, Quad-Cities J. E. Kohler, Senior Resident Inspector, Zion J. R. Waters, Reaident Inspector, Zion D. C. Boyd, Chief, Projects Section No. 4, RIII R. J. Marabito, Public Affairs, RIII R. B. Bevan, Licensing Project Manager, ORB-2. NRR E. A. Reeves, i icensing Project Manager, ORB-1, NRR Observers Ms. B. Cohen, State of Illinois, Attorney General's Office - Environmental Control Ms. J. Dann, McGraw-Hill, Inside NRC-2-
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2.
Areas Discussed a.
A summary of the SALP program was presented, including the development, the basis for evaluation, and its purpose.
b.
The results of the NRC's evaluation of CECO's performance under the SALP program were discussed.
(A copy of the performance evaluation for each station is enclosed).
c.
The results of the appraisal of CECO's licensing performance by NRR's Division of Li % asing were discussed. These results are documented in the performance evaluation for each station which is enclosed.
d.
An analysis of CECO's noncompliance data for the years 1975-1979, the SALP period (7/1/79 - 6/30/80), and the first eight months of 1980 was presented.
Also, a comparison of CECO's non-compliance data with that of the other RIII operating plants for these same periods was presented.
An analysis of the significance of the Licensee Event Reports e.
(LER's) submitted by CECO during the SALP period was presented.
Also, a comparison of the significance of CECO's LER's with those submitted by the other RIII operating plants for this period was presented.
f.
The NRC's new enforcement policy, including its plans for implementation was discussed.
3.
Licensee Comments The licensee commerted during the presentation of each of the areas in paragraph 2.
Additionally, the licensee discussed several matters of concern as follows:
The numerous, new NRC requirements, such as TMI Action Plan items, a.
IE Bulletins and Circulars, Generic NRR letters, SEP items and Zion Confirmatory Order items to mention a few, are havfrg a significant impact on CECO's, as well as other utilities', ability to safely and effectively operate, maintain and manage their nuclear generating stations. The licensee indicated that their efforts, both individually and collectively through the owners groups, to convey this message effectively to the highesc levels of NRC management have been unsuccessful, b.
The response time stipulated in IE Bulletins is too short in many cases and often times the real safety significance of the issue is not clearly defined.
This coupled with a severe work-load (refer to subparagraph a.) often times results in a sub-standard response in order to meet the response time requirement.
The licensee is desireous of being completely factual and responsive. The NRC should provide suf ficient management over-view of these requirements, so that they are properly categorized and defined in terms of their real safety significance and, therefore, require an appropriate response time.
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c.
The NRC's enforcement policy against licensed operators and senior operators is counterproductive to its goals, in that it has a negative impact on their performance. Many operators e
sca: Ed stif f that if they make a human error, the NRC will make an example of them, and this could have severe effects
,their personal welfare due to adverse publicity aspects as all as the attendant enforcement action. This perception has led to a certain reluctance by operators to take independent actions which are within their capabilities and which they may have performed previously. The overall impact is that the job of a licensed operator or senior operator is now less desirable and, therefore, nore dif ficult to staf f.
d.
The NRC's new enforcement policy, and particularly its escalated enforcement options, is not needed to insure licensee compliance with NRC regulations or to encourage improvement of licensee performance. This policy is viewed as strictly punitive in nature.
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DRESDEN UNITS 1, 2, & 3 PERFORMANCE EVALUATION REPORT
REGION III
LICENSEEE PERFORMANCE EVALUATION (OPERATIONS)
FACILITY. Dresden 1, 2, & 3 LICENSEE: Commonwealth Edison Company Unit Identification:
Docket No.
License No./Date of Issuance Unit No.50-010 DPR-2/ September 28, 1959
50-237 DPR-19/Decenber 22, 1959
50-249 DPR-25/ January 12, 1971
Reactor Information:
Unit 1 Unit 2 Unit 3 NSSS General Electric General Electric General Electric MWt 700 2527 2527 Appraisal Period: July 1, 1979 to June 30, 1980 Appraisal Completion Da te: October 7, 1980 Review Board Members:
R. F. Heishman, Chief, Reactor Operations & Nuclear Support Branch R. L. Spessard, Chief, Projects Section 1 K. R. Baker, Chief, Nuclear Support Section 2 W. L. Fisher, Chief, Fuel Facility Projects and Radiation Support Section C. J. Paperiello, Chief, Environmental and Special Projects Section J. F. Donahue, Chief, Security and Investigation Section
- D. H. Danielson, Chief, Engineering Support Section 2
- D. W. Hayes, Chief, Engineering Support Section 1 T. Tongue, Resident Inspector, Dresden M. Jordan, Resident Inspector, Dresden N. J. Chrissotimos, Senior Resident Inspector, Quad Cities J. E. Kohler, Senior Resident Inspector, Zion
- J.
F. Strect(r, Chief, Nuclear Support Section 1 CR. B. Bevan, Licensing Project Manager, ORB-2, NRR
- E. A. Reeves, Licensing Project Manager, ORB-1, NRR CNot present f or board meeting, however, verbal and/or written information was provided for the evaluation.
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A.
Number and Nature of Noncompliance Items.
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Station Noncompliance category:
Unit 1 Unit 2 Unit 3 Site Total Violations
0
0
Infractions
8
2
Deficiencies
0
6
Station Areas of Noncomplianci Unit 1 Unit 2 Unit 3 Site (Points)
(Points)
(Points) (Points)
(Points)
Operations
40
0 112 FFMS
40
6
Safeguards
- 0
0
26 Construction
0
0
Totals
80
32 204 Inspection Reports covered by this review (Report Numbers):
Unit 1 50-10/79-13 through 50-10/80-12 Unit 2 50-237/79-17 through 50-237/80-13 Unit 3 50-249/79-15 through 50-249/80-17 Evaluation on noncompliance items:
Operations - During the SALP period,12 inspections were performed in this area; 11 Infractions and 1 Deficiency were identified.
In several cases these items were repetitive and involved station housekeeping and radiological control practices. This is considered a major weakness at the station and strong management attention is needed to prevent future noncompliance.
The number of noncompliance items was above average, i.e., higher than expected; however, these items were not significant from the standpoint of adversely affecting the health and safety of the public.
The licensee's performance in this area was rated as " average" as compared to the performance of other Region III licensees.
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FFMS
- During the SALP; period, 4 1.
4ctions were performed in this i
xy area; 6 Infractions and 3 P~>1ulencies were identified. None of.these items caused a ha.ord to the public.
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An intensive appraisal of the health physics program' revealed seven significant seaknesses in the. areas of organization and management,- qualification and training, access controls, con -
tamination control, surveillance, instrumentation, and emergency
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response.. The licensee has progressed considerably toward i
correction of these weaknesses.
Similar appraisals were con-
. ducted at Zion and Quad Cities.
In the areas of radiation protection,. radwaste management and radioactive material transportation, the licensee's performance was rated as "below average" as compared to the performance of
.other Region III licensees.
In the areas of confirmatory meas-urements, environmental protection and emergency planning, the
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licensee's performance'was rated as " average" as compared to the performance of other Region III licensees.
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Safeguards - During the SALP period, 1 inspection was performed in this area;.2 Infractions and 3 Deficiencies were identified. These items were not significant in nature, and th;y'have been corrected batisfactorily.
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One problem area was disclosed at Zion related to personnel
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screening practices pertaining to contractor employees and
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an -Immediate Action Letter was initia ted to correct the situa tion.
CECO, recognizing that this problem probably
. existed at Dresden and Quad Cities, audited the contractor records there and proposed corrective action to avoid potential noncompliance.
In this respect, CECO is to be commended for
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taking prompt and definitive action to assure conformity.:ht screening programs at the three sites.
Inspections were conducted recently at all three sites (af ter'
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6/30/80) and indicated an improvement in security plan imple-
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mentation through effective use of security forces and computer access controls of personnel. All sites are still having minor sof tware problems with the computer ~ access control system but are
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correcting problems as they are identified. All sites are also taking steps to further. limit the number of personnel authorized
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vital area access which is difficult to do because the sites
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consider their entire' power block structure to be a vital area.
Nothing short of compartmentalization of vital equipment.will
solve this concern.' This matter is still under Commission j
consideration.
I The licensee's performance in this area was rated as "better than
average"' as compared 'to the performance of other Region III licensees.
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Construction - During the SALP period, 10 inspections were performed in this Y
No items of noncompliance were identified. The licensee's area.
performance in this area was rated as " average" as compared to the performance of other Region III licensees.
Summary
- The noncompliance history, while relatively high in numbers, is not of major regulatory concern. The licensee's overall regulatory performance is acceptable; however, licensee management needs to focus more attention on reduction of thess numbers, including those which were repetitive.
B.
Number and Nature of Licensee Event Reports Type of Events:
Unit 1 Unit 2 Unit 3 Personnel Error
8
Design / Man./Const./ Install.
7
External Cause
0
Defective Procedure
3
Component Failure
14
Other
0
Licensee Event Reports Reviewed (Report Numbers):
Unit 1 LER No. 79-02 through 80-02 Unit 2 LER No. 7c 44 through 80-23 Unit 3 LER No. 79-17 through 80-26 Evaluation of LER's:
During this SALP period, about 13% of the LER's deal with personnel error, 2 of these resulted in noncompliance, and the other 8 were of minimal con-sequences and resulted in no threat to safe operation. The number of per-sonnel errors is not considered excessive for a multiunit station; however, during the SALP period, concerns regarding personnel errors at the Dresden and Quad Cities Stations were discussed during the management conference conducted on January 10, 1980, as described in Paragraph D.
Two-thirds of the LER's were due to component and/or equipment failures, and the remainder for various other reasons. Over 90% of the LER's were on the operating
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units 2 and 3.
Although these numbers do not seen unusual for a multiunit a
station, it is apparent, as plant life increases, that equipment and/or component failures occurrences will increase.
The resulting consequences can only be controlled by increased operator awareness and a flexible, conscientious surveillar.ce/ maintenance program.
C.
Escalated Enf orcement Actions Civil Penalties None frders Confirmatory Order for Dresden Units No. 1, 2, 3 - Installation of a recirculation pump trip, (Unit 1, prior to startup; Unit 2 and 3 by December 31, 1980).
Immediate Action Letters None D.
Management Conferences Held During Past Twelve Months 7/19/79 - Regulatory performance, Iodine and Particular releases, security, revised inspection program and other current topics.
1/10/80 - Regulatory performance, Iodine and Particulate releases, and Investigation of ECCS valve closure.
L.
Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency / Scope (See evaluation sheets)
Radiation Pro tection/Radwaste Operations Increased inspection frequency and scope is warranted in this area due to high nunbers of noncompliance and repeat items of noncompliance associated with radiation protection found during inspections performed by the resident inspectors, to review progress made on significant HP appraisal findings, and to review the Unit I decontamination project.
EMERGENCY PLANNING Increased inspection scope is warranted in this area because of the recent changes in 10 CFR 50, Appendix E.
This is applicable to the other Region Ill licensees.
Training Increased inspection frequency is warranted in this area due to observed
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weaknesses in the General Employee Training program governing entry into (
Dresden and other CECO facilities. The general concensus by several individuals was that the classroom presentation was of poor quality and the -Jore the adequacy of the training received was questionable. Depending on tb 2 findings of a re-inspection of this area, applicability at other CECO sites will be considered.
F.
Other Observations Attitude of Station Personnel Management effort needs to be focused on instilling a sense of pride and professionalism in all station personnel, such that they take an active role in observing plant cond!t iens and equipment and reporting conditions adverse to quality to proper levels of management.
This is especially im-portant in the areas of plant housekeeping and radiation protection practices.
Communica tions Management ef fort should be directed toward better communications not only up and down the managerial ladder, but also horizontally as well; e.g. trade to trade, department to department, etc.
Better communica tions within the organization on identified problems should result in fewer noncompliances, including those which are repetitive.
Affect of NRC Requirements on Licensee Performance Followup on TMI requirements, IE Bulletins, SEP items, and other NRC actions has placed a severe burden on the licensee, particularly in the form of excessive work load on engineering personnel and numerous changes to pro-cedures which require constant upgrading of operator training. The licensee has responded in an excellent manner, and it does not seem to have dis-tracted their attention from plant operations and other saf ety related matters.
Licensee Action on IEB 79-14 Due to IEB 79-14 findings and the apparent lack of seismic restraint provisions for the CRD sys tems, increasing evaluation and followup by the Region III staff in these areas appeared to be warranted.
DOL Appraisal of CECO's Licensing Performance Ceco has responded well to major issues of regulatory interest, such as Emergency Planning, Fire Protection, Qualification of Equipment and Implementation of TMI Lessons Learned.
Their performance in this respect has generally been average or above compared with other licensees.
CECO has been notably consistent, prompt and effective in communicating with the staf f on issues that arise in day-to-day operation at their plants.
In areas where timely, cooperative action f rom CECO and other licensees has been required, in the perception of the staf f, to maintain safe operation of facilities, CECO has performed well,
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O A specific commcr.t should be made on CECO's actions relative to NRC Confirmatory Order, dated Feb. 29, 1980, for the Zion Station.
This Order was issued because of the location of Zion Station in an area of relative high population density. Actions of an immediate nature plus specific actions periodically thereafter have been accomplished in an acceptable manner to date.
However, the final results of this Order and associated studies would be expected to continue during the upcoming year.
In summary, the overall performance of CECO in meeting responsibilities which reside with holders of operating licenses has been good.
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DRESDEN UNITS'1, 2,.& 3
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.g PERFORMANCE EVALUATION Inspection
Frequency and/or Scope FUNCTIONAL AREA Increase No. Change Decrease
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1.
Management Control x
2.
Plant Operations x
3.
Refueling Operations & Activities x
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4.
Maintenance x
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5.
Surveillance & Preoperational Testing x
6.
Training x'
x
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Radiation Protection /Radwaste Operations X
q 8.
Environmental Protection x
,
Emergency Planning x
v.
10. ' Fire Protection X
11.
Security & Safeguards X
12.
Design Changes & Modifications
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Reporting x
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'14 QA Audits x
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. 15.
Committee. Activities x
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16. ' Quality Control x
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Procurement x
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IIcalth Physics Appraisal I
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'R.' F. licishm5, Chief, ROSS Branch I 'l Date-
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ZION UNITS 1 AND 2 PERFORMANCE EVALUATION REPORT
REGION III
LICENSEE PERFORMANCE EVALUATION (OPERATIONS)
Facility:
Zion Units 1 and 2 Licensee: Commonwealth Edison Company Unit Identification:
Docket No.
License No./Date of Issuance Unit 50-295 DPR-39/ April 6,1973
50-304 DPR-48/ November 14, 1973
Reactor Information:
Unit 1 Unit 2 NSSS Westinghouse Westinghouse MW 3250 3250 Appraisal Period: July 1, 1979 to June 30, 1980 Appraisal Completion Date: October 7, 1980 Review Board Members:
K. F. Heishman, Chief, Reactor Operations 6 Nuclear Fupport Branch R. L. Spessard, Chief, Projects Section 1 K. R. Baker, Chief, Nuclear Support Section 2 W. L. Fisher, Chief, Fuel Facility Projects and Radiation Support Section C. J. Paperiello, Chief, Environmental and Special Projects Section J. F. Donahue, Chief, Security and Investigation Section
- D.
H. Danielson, Chief, Engineering Support Section 2
- D. W. Hayes, Chief, Engineering Support Section 1 T. Tongue, Resident Inspector, Dresden M. Jordan, Resident Inspector, Dresden N. J. Chrissotimos, Senior Resident Inspector, Quad Cities J. E. Kohler, Senior Resident Inspector, Zion
- J.
F. Streeter, Chief, Nuclear Support Section 1
- R. B. Bevan, Licensing Project Manager, ORB-2, NRR
- E. A. Reeves, Licensing Proj ect Manager, ORB-1, NRR
- Not present f or board meeting, however, verbal and/or written information was provided for the evaluatio,
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A.
Number and Nature of Noncompliance Items Station Noncompliance category:
Unit 1 Unit 2 Site Total Violations
0
0 Infractions
0
21 Deficiencies ~
0
4 Areas of noncom;11ance:
Station Unit 1
' Unit 2 Site Tota l (Points)
(Points)
(Points)
(Points)
Operation.
20'
42
FFMS
.0
82
Safeguards
~ 0 0-
74 Construction
0
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$
Totals
0 198 218 Inspection reports covered by this review (Report Numbers):
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Unit 1 50-295/79-15 through 50-295/80-14 Unit 2-50-304/79-14 through 50-304/80-14 Evaluation of noncompliance items:
Operations - During the SALP period,12 inspections wcre performed in this
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area; 6 Infractions and 1 Deficiency were identified. These
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items were not significant f rom the standpoint of adversely affecting the health and safety of the public. No trends were
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identified which would show a weakness in any particular opera-
tional area, nor was the total number of noncompliance items considered excessive when compared to other Region III licensees.
The licensee's performance in this area was rated as "better I
than average" as compared to the performance of other Region
Ill licensees.
FFMS'
- During the SALP period, 5 inspections were performed in this area; 8 Infractions and 1 Deficiency were identified. None'of
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these items caused a hazard to the public.
An intensive appraisal of the health physics program revealed eight significant weaknesses in the areas of management support of the health physics program, vandalism, emergency response
~ capability, access control, liquid radwaste, gaseous radwaste, contamination control, and alpha measurement. An inmediate Action Letter (LAL) as described in paragraph C, was issued to correct the more serious - problems.
The licensee has progressed considerably toward correction of these weaknesses.
Similar appraisals were conducted at Dresden and Quad Cities.
In the areas of radiation protection, radwaste manegement and radioactive material transportation, the licensee's performance was rated as "below average" as compared to the performance of other Region III licensees.
In the area of confirmatory meas-urements, the licensee's performance was rated as " average" as compared to the performance of other Region III licensees.
i This represents a substantial improv rment over the previous year's performance.
In the area of nonradiological chemistry the licensee's performance was rated as "below av arage" as compared to the performance of other Region TTI licensees. This is attributed to the 3 items of noncompliance, each involving repetitive excmples that were identified; the prtoary cause of
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these items appears to be the failure of supervisors to review daily work.
In the areas of environmental protection and emergency planning the licensee's ' performance was rated as
" average" as compared to the performance of other Region III
licensees.
Sa feguards
- During the SALP period, 2 inspections were performed in this t
area; 7 Infractions and 2 Deficiencies were identified. This number of noncampliance items was above average, i.e., higher
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than expected. An Immediate Action Letter (IAL) as described in Paragraph C, was issued to correct the more serious problems
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and satisf actory corrective action has been taken. An inspection subsequent to the SALP period indicated that all previous problems had been resolved and no 'new items of noncompliance were identi-fled.
With respect to the problem of personnel screening practices per-taining to contractor employees, discussed in the IAL, CECO recognizing that this problem probably existed at Dresden and Quad Cities, audited the contractor records there and proposed corrective action to avoid potential noncompliance.
In this respect, CECO is to be commended for taking prompt and defini-tive action to assure conformity in screening programs at the
three sites.
Inspections were conducted recently at all three sites (af ter 6/30/80) and indicated an improvement in security plan imple-mentation through effective use of security forces and computer-2-
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I access controls of personnel. All sites are'still having
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minor-software problems with the computer access control
system but are correcting problems as they are identified.
' All sites are also taking steps - to further limit the number of' personnel authorized vital area access which is difficult to do because the sites consider their entire power block structure _to be's vital area. Nothing short of-compartmental-
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izationLof vital equipment vill solve this-concern. This matter is still under Commission consideration.
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The licensee's performance in this area was rated as " average" as compared to the performance of other Region III licensees.
Construction'- During the SALP period, 7 inspections were performed in this
- area. No items of noncompliance were identified. The licensee's performance in this area was rated as " average" as compared
to the performance of other Region III licensees.
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- The noncompliance history, while relatively high in numbers, Summary is not of major regulatory concern, and the licensee's.verall
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regulatocy performance is acceptable. However, licensee I
management needs to focus more attention on reduction of.these
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numbers. This evaluation takes into account the additional
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regulatory requirements that were taposed on Zion by the NRC j
confirmatory order, as described in Pr.ragraph C.
Number and Nature of Licensee Event Reports B.
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Type of Events:
Unit 1 Unit 2 (A) Personnel Error
2 i:
(B) Design
2
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(C) External Cause
1 (D) Defective Procedure
1 (E) Component Failure
20 l
(X) Other
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Licensee Even-Reports Reviewed (Report Numbers):
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Unit 1 i
LER No. 79-48 through 80-29 Unit 2
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.LER No. 79-36'through 80-22
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Evaluation of LER's :
I The licensee submitted 89 LER's during the SALP period. The majority (63%) of the LER's deal with component failure and instrument drif t and prompt corrective action was taken. Approximately 9% cf the LLA's deal with personnel error, and this number is. 't considered excessive for a dual unit station. Of the 8 personnel errors, 1 involved noncompliance, the remaining 7 were of minimal consequences and resulted in no threat to safe operation.
C.
Escalated Enf orcement Actions Civil Penalties None Orders Confirmatory order February 29, 1980 regarding Zion Stotion and high contiguous population.
Immediate Action Letters (1) May 23, 1980 Safeguards Inspection (2) May 14, 1980 Health Physics Appraisal Program Inspection D.
Mana gement Conference held during last Twelve Months July 19, 1979 - Regulatory perf ormance, security, revised inspection program, and other current topics.
E.
Justification of Evaluation of Functional Areas Categorized as Requiring An increase in Inspection Frequency / Scope EMERGENCY PLANNING Increased inspection scope is warranted in this area because of the recent changes in 10 CFR 50, Appendix E.
This is applicable to the other Region III licensees.
HEALTH PHYSICS Increased inspection scope is warranted in this area to review progress on significant HP appraisal findings.
F.
Other Observations Licensee Responsiveness The licensee's strong point is considered to be their responsiveness to NRC regulatory requirements and concerns which have required additional resources to be directed to new areas.
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Nuclear Operator Licensing Program
This program for new operators has received commendation from the. licensing
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branch of the NRC on the quality of operators taking the Reactor Operator and Senior Reactor. Operator. certifying examinations.
Affect of NRC Imposed Requirements on Licens.'s Regulatory Performance With regard to the imposition of numerous new regulatory requirements as related to Three Mile Island accident, manzgement has responded in the highest professional manner. The dedication and efforts put-forward to
meet requirements were excellent. This dedicated ef fort has detracted
_ relatively little from normal operations. However, it has had some
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impact an Regulatory performance.
DOL Appraisal of CECu's Licensing Performance CECO has responded well to major issues of regulatory interest, such as
- Emergency Planning, Fire Protection, Qualification of Equipment and Implementation' of TMI Lessons Learned. Their performance in this respect-has generally been average or above compared with other licensees.
Ceco has been' notably consistent, prompt and effective in communicating with the staff on issues that arise in day-to-day operation at their pla nts. In areas where timely, cooperative action from CECO and other-licensees has been required, in -the perception of the staff, to maintain safe operation of f acilities, Ceco has performed well.
A specific comment should be made on CECO's actions relative to NRC
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Confirmatory Order, dated Feb. 29, 1980, for the Zion Station.
This Order was issued because of the location of Zion Station in an area of relative high' population density. Actions of an immediate na ture plus specific actions periodically thereaf ter have been accomplished in an acceptable manner to date. However, the final results of this I
Order and associated studies would be expected to continue during the l
upcoming year.
In summary, the overall performance of CECO in meeting respcasibilities
which reside with holders of operating licenses has been good.
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ZION UNITS 1 AND 2
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PERFORMANCE EVALUATION
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Inspection Frequency and/or Scope FUNCTIONAL AREA Increase No. Change Decrease
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1.
Management control x
2.
Plant Operations x
3.
Refueling Operations & Activities x
4.
Maintenance x
5.
Surveillance C-Preoperational Testing x
6.
Training x
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o 7 Radiation Protection /Radwaste Operations X
8.
Environmental Protection x
9.
Emergency Planning x
10.
Fire Protection x
11.
Security & Safeguards y
12.
Design Changes & Modifications x
13.
Reporting x
14.
QA Audits x
15.
Committee Activities x
16.
Quality control x
17.
Procurement x
- Has been inspected under Health Physics Appraisal
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Y F. Heishman, Chief, RONS Branch nH./fc Date
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QUAD CITIES UNITS 1 & 2 PERFORMANCE EVALUATION REPORT
REGION III
LICENSEE PERFORMANCE EVALUATION (OPERATIONS)
' Facility: Quad Cities 1 and 2 Licensee: Commonwealth Edison Company Unit Identification:
Docket No.
License No./Date of Issuance UNIT No.
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50-254 DPR-29/ October 1, 1971
50-265 DP.4 30/ March 21, 1972
Reactor Information:
Unit 1 Unit 2 NSSS General Electric General Electric MWT 2511 2511 Appraisal Period: July 1,1979 to June 30, 1980 I
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Appraisal Completion Date:
October 7, 1980 Review Board Members:
R. F. Heishman, Chief, Reactor Operations & Nuclear Support Branch R. L. Spessard, Chief, Projects Section 1 K. R. Baker, Chief, Nuclear Support Section 2 L. Fisher, Chief, Fuel Facility Projects and Radiation Support Section W.
C. J. Paperiello, Chief, Environmental and Special Projects Section J. F. Donahue, Chief Security and Investigation Section 4D. H. Danielson, Chief, Engineering Support Section 2 4). W. Hayes, Chief, Engineering Support Section'l T. Tongue, Resident Inspector, Dresden i
M. Jordan, Resident Inspector, Dresden N. J. Chrissotimos, Senior Resident Inspector, Quad Cities J. E. Kohler, Senior Resident Inspector, Zion
- J. F. Streeter, Chief, Nuclear Support Section 1
- R. B. Bevan, Licensing Project Manager, ORB-4 NRR
- E. A. Reeves, Licensing Project Manager, ORB-1, NRR
- Not present for board meeting. however, verbal and/or written information
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was provided for the evaluation.
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A.
Number and Nature of Noncompliance Items Station Noncompliance category:
Unit 1 Unit 2 Site Total Violations
0
1
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Infractions
3
11 Deficiencies
2
3 Station
. Areas of noncompliance:
Unit 1 Unit 2 Site Total (Points)
(Points)
(Points)
(Points)
Operations
12
44 FFMS
20 130 150 Safeguards
2
22
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Construction
0
0 Totals
34 162 216
Inspection reports covered by this review (Report Numbers):
Unit 1 50-254/79-15 th rough 50-254/80-15, 17 and 20
Unit 2 50-265/79-13 through 50-265/80-19 and 22 l
Evaluation of noncompliance items:
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Operations - During the SALP period 14 inspections were performed in this area; 4 Infractions and 2 Deficiencies were identified. These items were not significant in nature.
However, the access con-
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l trol noncompliance was a result of the excessive numbers of
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nonessential personnel in the control room.
The number of
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personnel present during operational evolutions is excessive and management effort should be directed toward resolving i
this situation.
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The licensee's performance in this area was rated as "better than average" as compared to the perf ormance of other Region III licensees.
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FFMS
- During the SALP period 9 inspections were performed in this
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area; 1 Violation and 5 Infractions were identified. None of i
these items caused a hazard to the public. A transportation inspection revealed an excessive radiation level beneath the truck (Violation), resulting in the issuance of the civil penalty described in paragraph C.
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An intensive appraisal of the health physics program revealed six significant weaknesses in the areas of training, exposure control, access controls, contamination controls, instruments, and. facilities. The licensee has progressed considerably toward correction of these weaknesses.
Similar appraisals
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were conducted at Dresden and Zion.
In the areas of radiation protection, radvaste managen ent and radioactive material transportation, the licensee's
- performance was rated as " average" as compared to the performance of other Region III licensees.
In the areas of confirmatory measurements, environmental protection and
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emergency planning, the licensee's perfor.ance was rated a "better than average" as compared to the performance of other Region III licensees.
j Safeguards - During the SALP period 2 inspections were performed in this area; 2 Infractions and 1 Deficiency were identified. These
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items were not significant in nature, and they have been
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corrected satisfactorily, a
One problem area was disclosed at Zion related to personnel
j screening practices pertaining to contractor employees and an Immediate Action Letter was initiated to correct the
situation.
CECO, recognizing that this problem probably existed at Dresden and Quad Cities, audited the contractor records there and proposed corrective action to avoid potential noncompliance.
In this respect, CECO is to be commended for
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taking prompt and definitive action to assure conformity in
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screening programs at the three sites.
Inspections were conducted recently at all three sites (af ter 6/30/80) and indicated an improven:ent in security plan im-j plementation through effective use of security forces and
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computer access controls of personnel. All sites are still
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having minor sof tware problems with the computer access con-trol system but are correcting problems as they are identified.
All sites are also taking steps to further limit the number of I
personnel authorized vital area accesa which is difficult to do because the sites consider their entire power block structure to be a vital area. Nothing short of compartmentalization of vital equipment will solve this concern. This matter is still under Commission consideration.
The licensee's performance in this area was rated as " average" as compared to the performance of other Region III licensees.
Construction - During the SALP period, 9 inspections were performed in this area. No items of noncompliance were identified. The licensee's performance in thi; area was rated as "better than average" as compared to the performance of other Region III licensees.
i Summary - The noncompliance history is not of regulatory concern, and the licensee's overall regulatory performance is acceptable.
B.
Number and Nature of Licensee Event Reports
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Type of Events:
Unit 1 Unit 2
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Personnel Error
0 Component Failure
30 Design / Fabrication / Analysis
0 Error Defective Procedures
0 Other
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Licensee Everit Reports Reviewed (Report Nos.):
i Unit 1
LER No. 79-22 through 80-16 Unit 2 LER No. 79-13 through 80-13
Evaluation of LER's:
Of the 4 personnel errors, only one involved a noncompliance, the remaining three were of minimal consequences and resulted in no threat to safe operation.
For the history reviewed, the number of personnel errors does not represent a regulatory concern.
However, during the SALP period, concerns regarding per-j.
sonnel errors at the Quad Cities and Dresden Stations were discussed during the management conference cenducted on January 10, 1980, as described in paragraph D.
Of the 53 component f ailures, 40% were setpoint drif t events which are unavoidable, and the reporting of these, obscures the significance j
of LER's.
The other events were within the constraints of expected failures.
C.
Escalated Enforcement Actions
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Civil Penalties
$4,000 June, 1980 Inspection Report No. 50-254/80-13; 50-265/80-16, violation level item of noncompliance associated with shipment of LSA material on January 31, 1980, to Richland, Washington, in which radiation levels underneath trailer exceeded DOT limits by 500 MR/HR.
Orders (1) Confirmatory ors e issued February 21, 1980, to confirm Quad Cities commitment to install a recirculation pump trip for both units prior to operation in calendar year 1981.
Immediate Action Letters None D.
Management Conferences Held During Past Twelve Months 7/19/79 - Regulatory performance, Iodine and Particular releases, security, revised inspection program and other current topics.
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1/10/80 - Regulatory performance, Iodine and Particulate releases, and Investigation of ECCS valve closure.
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Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency / Scope (See evaluation sheets)
SECURITY AND SAFEGUARDS An increased insnection scope was recommended in this area because of intense interest in the aJequacy of security by local residents and news media as a result of the recent release of the 1977 Security Inspection Report and trial of Commonwealth Edison. An inspection was performed in July 1980, and based on these fitiings, no change in inspection frequency or scope was considered necessary.
FIRE PROTECTION Increased inspection frequency is warranted in this area because initial operational status will be est ablished by November 1,1980.
EMERCENCY PLANNING Increased inspection scope is warranted in this area because of the recent changes in 10 CFR 50, Appendix E.
This is applicable to the other Region III licensees.
HEALTH PHYSICS Increased inspection scope is warranted in this area to review progress on significant HP appraisal findings and to assess the significant HP staf fing changes made subse-quent to the HP appraisal, e.g., loss of two experienced HP's and their replacement with inexperienced HT's, and temporary assignment (several months) of lead HP to training with his role being filled by the Radchem Supervisor.
F.
Other Observations
Communica tions Management ef forts should be aimed at enhancing downward communications to employees and focus on the promulgation of broader responsibilities to all employees. These efforts would provide a higher level of performance in regards to noncompliance and personnel errors.
Affect of NRC Imposed Requirements on Licensee's Regulatory Performance With regard to the imposition of numerous new regulatory requirements as related to Three Mile Island accident, management has responded in the
!
highest professional manner. The dedication and efforts put forward to meet requirements were excellent. This dedicated effort has detracted relatively little from normal operations. However, it has had some impact on Regulatory performance.
.
DOL Appraisal of CECO's Licensing Performance CECO has responded well to major issues of regulatory interest, such as Emergency ' Planning, Fire Protection, Qualification of Equipment and Lnplementation of TMI Lessons Learned.
Their performance in this respect has generally been-average or above compared with other licensees.
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I CECO has been notably consistent, prompt and effective in communicating with.the staff on issues that arise in day-to-day ' operation at their plants.
In areas where timely, cooperative action from Ceco and-other licensees has been required, in the perception of the staff, to maintain
- safe operation of facilities, CECO has performed well.
,
~ A' specific comment should 'oe made on CECO's actions relative to NRC Confirmatory Order, date; Feb. 29, 1980, for the Zion Station. This Order was issued because if the location of Zion Station in an area of relative high population density. Actions of an immediate nature plus specific actions periodically thereaf ter have been accomplished in an acceptable manner to date.
However, the final results of this
,
Order and associated: studies would be expected to continue during the l
upcoming year.
,
i In summary, the overall pc-formance of CECO in meeting responsibilities which reside with holders of operating licenses has been good.
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QUAD CITIES UNITS 1 & 2
'g PERFORMANCE EVALUATION Inspection Frequency and/or Scope FUNCTIONAL AREA Increase No. Change Decrease 1.
Management Control x
2.
Plant Operations x
3.
Refueling Operations & Activities x
4.
Maintenance x
5.
Surveillance & Preoperational Testing x
6.
Training x
7.
Radiation Protection /Radwaste 0,perations X
8.
Environmental Protection x
0.
Emergency Planning x
l 10.
Fire Protection x
11.
Security & Safeguards y
12. Design Changes & Modifications x
13.
Reporting x
14.
QA Audits x
15.
Committee Activities x
16.
Quality Control x
17.
Procurement x
- Has been inspected under Health Physics Appraisal o
R. F. Heishman, Chief, RONS Branch ti/USo Date
.