IR 05000010/1997011
| ML20212F893 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212F887 | List: |
| References | |
| 50-010-97-11, 50-10-97-11, 50-237-97-11, 50-249-97-11, NUDOCS 9711050140 | |
| Download: ML20212F893 (2) | |
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Obaarvations and Findings gy w s
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- QAS 12-96-10 was conducted by a multi disciplined team, which included members
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- from other. Commonwealth Edison sites.; This approach provided an independent
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viewpoint which added to the overall quality of the assessment. The assessment
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W iwas thorough and identified issues across a wide range of MR implementation
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, aspects. '.The inspectors considered the findings iri the " Deficiencies" and
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" Recommendations" sections to be especially vduable.j Of particular note were the
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- concems expressed regarding action plans and goal setting for (a)(1) SSCs and
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f scoping errors.
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J LOAA 12 97-17.was conducted by the Dresden Site Quality Verification group with
,3 the_' assistance of an independent consultant. The audit was comprehensive, both D~;
i horizontally.and ' vertically, and identified substantive issues in several aspects of MR
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-implementation. Key findings w'ere in the areas of scoping,. weaknesses in the
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- Delphi process of risk significance determination, performance criteria, and -
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- performance monitoring.: During the inspection, the inspectors confirmed the
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! findings of.the audit as well as identifying other deficiencies. These were discussed '
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(in earlierportions of this report, iThe licensee took significant s_teps in correcting the
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i findings of jhe audit including,' hiring a Maintenance Rule Improvement Project.
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- Manager, assigned a new SMRO, issuing CAR 12 9717, developing the Dresden
.:J Mn improvement Plan,'and establishing a tracking system for the corrective actions a with assigned personnel and due dates.? The inspectors reviewed the licensee's-y
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" corrective. action'documentsireviewed 'some of the actions that had already been
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(accomplished, and considered the corrective action plans appropriate. Becausc the
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' saudit findings list'ed above could be characterized as violations of the MR, the
,, ginspectors considered thsiddit findings as an unresolved item pending a future
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i Mview of corrective action ~statusjURI 50-010/237/249/9701103).
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L c'.y Conclualons
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(The inspectors conclu ed that the licensee's self assessment activities were
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(appropriately conducted and identified worthwhile issues. Use of independent
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personnel lwas considered a strength. of both self-assessments. The inspectors e
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^ fuither concluded that the licensee's corrective actions for QAA 12-97-17 were ~
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- ' appropriate.1 The audit findings were considered an ' unresolved item pending future
.S E,g 1reyiew of completed corrective actions.-
- g sN M82 ' Mlacellaneous Maintenance issues (92902)
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! M8.1 10panlMBl.5bO10/97008i-11 tDRSl: 1 Unit 1 MR program.. This item was identified o'
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>during'the 1996 ISI discussed in Scction M1. The licensee had established a
- p'} pi yh gmonitoring program for the safe storage of the fuel in Unit 1. ' This program was K'
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Postablished as a result of an event in November 1994 which resulted Ire the draining
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. of approximately 50,000 gallons of service water into the Unit 1 reactor building.
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EThis Was caused by the freezing and breaking of a pipe and some valves. During ithe"lSI, the_ inspector discussed this program with the Unit 1 station manager and m
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L reviewed some of the surveillance procedures that had been established or revised lfor monitoring Unit 1.: These procedures included DAP 03 25, " Administrative Controls For Use Of Unit 1 Fuel Building (W 1)," DRS 2000-03, Revision 05, "SPING Effluent Monitor Calibration," DAP 07.35, " Foreign Material Exclusion," DMS 5800-01, Revision.1, Overhead Gantry Cranes, Monthly inspection and Preventive
' Maintenance," DlS 1800-01, " Unit 1 Fuel Building Area Radiation Monitor -
Calibration,"_ DRS 2000-06, "SPING Effluent Monitor Quarterly Functional Test," and DlS 1900-01, " Unit 1 Spent Fuel Pool Levei!nst ument Functional Check." The inspector also reviewed records for some of the completed surveillance and maintenance activities and wified that they were being performed. The inspector noted that the spent fuel water level was being maintained and monitored by Unit 2/3 operators, the HVAC system was being maintained to ensure that temperature was maintained above freezing, and that radiation and effluent alarms were in working order. Based on these reviews the inspector concluded that the types of monitoring that were being performed could be taken credit for under the MR.
However, the inspector determined that, the licensee had not conducted scoping reviews, had not conducted risk significance determinatons, and had not established appropriate goals or performance criteria for those SSCs.
During this inspection, the inspectors reviewed Dresden Decommissioning Procedure
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(DDP) - 08, z"Dresden Unit 1 Compliance with the Maintenance Rule," dated 1 November 1,1996. The inspectors noted that DDP-08 closely paralleled the Unit 12/3 procedure, DAP 1418. The procedure established all of the attributes of a MR
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program consistent with NUMARC 93 01 including scoping, expert panel, risk determinations,' performance criteria and goals, monitoring, and periodic 7,
effectiveness reviews. The inspectors met with the Unit 1 station manager to discuss the ISI fmdings and the status of implementation of the DDP-08 program.
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The inspectors determined that this unresolved item will remain open pending a.
review of the licensee's scoping, risk significance determinations, performance
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criteria and goals, and performance monitoring, 111. Engineering
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E2 Engineering Support of Facilities and Equipment
E2.1' / Review of Undated Final Safety Analysis Reoort (UFSAR) Commitments
- The discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares c plant practices, procedures and/or parameters to the UFSAR descriptions. While f p'erforming the inspections discussed in this report, the team reviewed the
- applicable portions of the UFSAR that related to the areas inspected. The team
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verified that the UFSAR wording was consistent with the observed plant practices, 1 procedures and/or parameters.
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