IR 05000010/1985001
| ML20136F718 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/03/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20136F717 | List: |
| References | |
| 50-010-85-01, 50-10-85-1, 50-101-85-1, 50-237-85-01, 50-237-85-1, 50-249-85-01, 50-249-85-1, NUDOCS 8601070477 | |
| Download: ML20136F718 (38) | |
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SALP 5 SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE t SG-10/85001; 50-237/85001; 50-249/85001
Inspection Report
Comonwealth Edison Company Name of Licensee Dresden Nuclear Power Station i Name of Facility l
June 1, 1984 through September 30, 1985 Assessment Period i !
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. . INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this informatio SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio A NRC SALP Board, composed of staff members listed below, met on November 19, 1985, to review the collection of performance observations and data to assess the licensee's performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety perforu nce at the Dresden Nuclear Power Station for the period June 1, 1984 thrcJgh
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September 30, 198 SALP Board for Dresden Nuclear Power Station:
Name Title J. A. Hind Director, Division of Radiological Safety and Safeguards C. E. Norelius Director, Division of Reactor Projects C. J. Paperiello Director, Division of Reactor Safety E. G. Greenman Deputy Director, Division of Reactor Projects N. J. Chrissotimos Chief, Reactor Projects Branch 2 L. A. Reyes Chief, Operations Branch G. C. Wright Chief, Reactor Projects Section 2C E. R. Schweibinz Chief, Technical Support Section D. H. Danielson Chief, Materials and Processes Section F. Hawkins Chief, Quality Assurance Programs Section R. L. Gregor Chief, Facilities Radiation Protection Section M. C. Schumacher Chief, Indepentent Measurements and Environmental Protection Section J. R. Creed Chief, Safeguards Section R. A. Gilbert Licensing Project Manager, NRR T. M. Tongue Senior Resident Inspector, Braidwood L. McGregor Senior Resident Inspector, Dresden R. B. Landsman ProjectManager,ReactorProjects Section 2C P. R. Rescheske Reactor Inspector D. Miller Senior Radiation Specialist
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II. CRITERIA The licensee's performance is assessed in selected functional areas depending on whether the facility is in a construction, preoperational, or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each functional area: Management involvement in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Reporting and analysis of reportable event . Staffing (including management). Training effectiveness and qualificatio However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the 5 ALP Board's assessment, each functional area evaluated is classified into one of three performance categorie The definition of these performance categories is:
Category 1: Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety. Licensee resources are ample and effectively used so that a high level of perform 1nce with respect to operational safety or construction is being achieve Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and management is concerned with nuclear safety. Licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
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Category 3: Both NRC and licensee attention should be increased. Licensee management attention and involvement is acceptable and considers nuclear r
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Trend: The SALP Board has also categorized the performance trend in each functional area rated over the course of the SALP assessment period. The categorization describes the general or prevailing tendency (the perfor-mance gradient) during the SALP perio The performance trends are defined as follows:
Improved: Licenseeperformancehasgenerallyimprovedoverthecourse
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of the SALP assessment perio Same:- Licensee performance has remained essentially constant over the course of the SALP assessment perio Declined: Licensee performance has generally declined over the course of the SALP assessment period.
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III. SUfMARY OF RESULTS The overall regulatory performance of your facility has improved during the current SALP period. We are encouraged by the improved performance ,
in the areas of radiological controls, maintenance / modifications, t security, and licensing activitie However, performance in the areas of surveillance and inservice testing declined from a Category 1 to a Category 2 and the performance trend in the areas of plant operations and fire protection / housekeeping also declined. Your performance in these areas will be monitored and discussed in the next SALP Board assessment for your facilit Rating Last Rating This Functional Area Period Period Trend
' Plant Operations 2 2 Declining Radiological Controls 3 2 Improving Maintenance /
Modifications 3 2 Improving Surveillance and Inservice Testing 1 2 Same Fire Protection /
Housekeeping 2 2 Declining Emergency Preparedness 1 1 Same Security 2 2 Improving Refueling 1 1 Same Quality Programs and Administrative Controls 2 2 Same
' Licensing Activities 2 1 Improving
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i IV. PERFORMANCE ANALYSIS Plant Operations Analysis This functional area was routinely inspected by the resident inspectors throughout the evaluation period. One special inspection was conducted by the resident inspectors related to three personnel errors that occurred in a short period of tim Six violations were identified as follows: SeverityLevehIV-Inadequatecorrectiveactionsresulting in a second occurrence where the corner room submarine doors were.found open and unattended (237/84012-03).
3 Severity Level V - Failure to investigate and evaluate multiple alarms and indications in the control room where secondary containment was in question (237/84016-01; 249/84015-01). Severity Level V - Failure to report scrams in accordance with 10 CFR 50.73 (249/84021-01). -
. Severity Level IV - High Pressure Coolant Injection (HPCI)
room cooler service water found valved-out resulting in HPCI being inoperable (249/85009-01). Severity Level IV - Loss of undervoltage protection on Emergency diesel bus 34-1 for about four and one-half minutes (249/85009-03). Severity Level IV - Suppression pool water sample line found open allowing water to flow from the suppression pool in containment to the secondary containment (249/85009-02).
The violations did not appear to be programmatic or to have generic implications to the plant. Although the licensee's response to all of the violations was generally prompt and effective with consideration given to longterm corrective actions, the responses to d, e, and f above were exceptionally good. The number of violations issued during this assessment period was comparable to the number issued during the last assessment perio During the SALP 5 period, the licensee experienced 35 unscheduled reactor scrams (21 on Unit 2 and 14 on Unit 3).
Fourteen of the scrams occurred while the reactors were in a shutdown condition with all rods fully inserted. Nine scrams resulted directly from personnel errors, of which
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one was caused by a nonlicensed operator, five by licensed operators, and the remaining three by maintenance or other personnel. Three scrams during SALP 5 were due to defective procedures, with the balance of the scrams attributed to component failures. During the later portion of the assessment period, recognizing that the number of scrams being experienced were becoming excessive, the licensee formed a scram reduction committee chaired by the assistant superintendent for operation The committee's function was to perform indepth reviews of every scram and provide feedback of the analyses to the appropriate personnel with the intention of preventing similar scrams. Due to the short time the committee has been in place, a determina-tion of its effectiveness could not be made at the time of this repor As discussed in Section V.F.1, LER data indicates that the number of personnel errors during the present assessment period have substantially increased from the last assessment period. Of the 93 LERs submitted this period 38 involved personnel errors, of which 20 were attributable to the operations department. This is a significant increase over the SALP 4 data where, although 121 LERs were submitted, only 21 involved personnel errors and only three of these were directly attributable to the operations departmen During the assessment period, the licensee exhibited adequate control over plant work activities as evidenced by well planned daily assignments of priorities, use of followup and tracking mechanisms to ensure required work was completed in a timely manner, and adequately stated policies that insured appropriate levels of station management review was involved when decisions towards safety were made. During daily (morning and afternoon)
planning meetings, operations personnel interfaced closely with maintenance, health physics, and other station personnel to set up work projects for the day and night shifts respectively with emphasis given to determination of prioritie Staffing was adequate during the period and vacancies were generally filled quickly with qualified and motivsted personne Overall, operators were attentive to their duties and ack-nowledged and analyzed alarm conditions promptly and thoroughl On many occasions, the inspectors noted a seemingly large number of annunciators "up" (acknowledged) in the control room. Upon questioning of the operators, it was generally found that the causes for the annunciators were known or that equipment trouble-shooting was underway to determine the cause. Distractions, such as. radios, televisions, or non-job related reading material are not allowed in the control roo .
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During the SALP period, the licensee completed construction of a new shift supervisor's office / locker room area. The original plant design had resulted in a.high personnel traffic flow through the control room for access between the shift super-visor's office and the plant. The newly constructed additions have considerably reduced this proble The Regulatory Performance Improvement Plan (RPIP) as described in the previous SALP 4 report has resulted in supervisors and union personnel being more aware of the need for attention to detail. This has been accomplished through the use of weekly meetings dealing with timely subjects and how they relate to Dresden and by a greater onsite presence by station and corporate management during both normal and off-normal work hour The licensee identified and presented to the NRC, in a March 25, 1985 enforcement conference, a recurring problem involving an overall increase in personnel errors that rince 1984 has accompanied the restart of each Dresden uni following its respective refuel outage. In recognition c.' this, and to help correct it, the licensee has assigned additional personnel on shift for operations, health physics, and quality assurance during the Unit 3 refueling and recirculation piping replacement project. These personnel will aid in the outage work and their experience and expertise should help to reduce personnel errors, thus providing a smoother restart following completion of the outag During the assessment period,12 Reactor Operator (RO) and 12 Senior Reactor Operator (SRO) examinations were administered to Dresden personnel. Two of the SR0 candidates were re-applications. The overall pass rate was 79%, which is very close to the national average. Requalification examinations were not administered by Region III at Dresden during this perio . Conclusion The licensee is rated Category 2. Although the category rating is the same given in the last SALP, due to the number of l personnel errors and reactor scrams, the trend in this area is l declining. This is a significant change from the previous SALP rating which judged the trend to be improvin . Board Recommendations The Board recommends that increased management attention should be given to this area to reverse the declining tren l J
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O B. Radiological Controls Analysis Seven inspections were performed during the assessment period by regional specialists. The inspections included outage radiation protection, radwaste management, operational radiation protec-tion, and confirmatory measurements. The resident inspectors also inspected in this are The following violations were identified: Severity Level IV - Uncontrolled liquid radioactive waste release exceeded gross beta technical specification concentration in Unit 1 discharge canal (10/84011-03).
- Severity Level IV - Failure to adhere to radiation control procedures for: (1) location of personal film badges on body, (2) performing required personal frisking, (3)
reporting out-of-specification radiochemistry results to the Radiation / Chemistry Supervisor and Shift Engineer, and (4) service water sampling requirements to confirm high monitor readings (10/84011-01,02,04,05); 237/84013-01,02; 249/84012-01,02). Severity Level IV - Inadequate procedure for filling the floor drain surge tank. Procedures did not caution that the level indicator was inaccurate, thereby causing a liquid spill (237/84013-03; 249/84012-03). Severity Level IV - Transfer of contaminated gas cylinders to persons not licensed to receive or possess radioactive material (10/85002-03; 237/85005-05; 249/85004-05). Severity Level V - Failure to specify Tc-99, I-129, H-3, and C-14 on shipment manifests as required by 10 CFR 20.311(b) (237/85021-01; 249/85017-01).
The Severity Level IV violations were indicative of minor programmatic breakdown Licensee corrective actions were generally timely and effective but some procedural adherence problems still exist. The Severity Level V violation resulted from an inappropriate instruction from the corporate offic Corrective action was again timely and effective. Overall, licensee enforcement history improved from the previous SALP rating perio Both the extent and severity of violations has diminished from previous SALP evaluation Staffing in this functional area remains adequate. Vacant positions are usually filled within a reasonable tim Significant management changes, including replacement of the -
Rad / Chem Supervisor, Lead Health Physicist, and Lead Chemist occurred during the perio .
Other staffing changes, including several new staff reporting to the Lead Chemist, have also occurred. Sufficient staffing continuity appears to have been maintained. The changes should result in a net strengthening of the licensee's progra Radiation protection support has also increased with appointment of additional Radiation / Chemistry Foremen and technicians and the addition of a new ALARA Section. This new section consists of a Lead Radiological Engineer, ALARA Coordinator, and ALARA Decon Foreman and has resulted in improved pre-job planning, job coverage, and post-job reviews. However, several health physics and engineering assistant positions are vacant owing to promotions and transfers. The licensee's policy of rotating Radiation / Chemistry technicians (RCTs) between health physics and laboratory assignments results in long intervals between successive laboratory assignments. This could limit RCT proficiency in the laboratory. Management oversight appeared adequate during this period but the quality of the laboratory program would be vulnerable to inappropriate management change The licensee's management involvement has been pervasive. Audits are generally thorough and comprehensive; responses and correc-tive actions are generally good and timely. Health physics, chemistry, and radwaste expertise is represented on both the station and corporate QA audit teams. Audit findings included radwaste transport vehicle problems, records retrievability problems, and isolated technical specification surveillance problems. In the radiological protection area, improvements have been made in job-specific surveys, personal contamination reports, solid radwaste handling, and supervisory overview of ongoing work in radiologically significant areas. Personal monitoring equipment, personal decontamination facilities, and respirator cleaning facilities and equipment have been improve Also, the management decisions to conduct chemical cleaning of Unit 2 recirculating system piping before performance of Inservice Inspection and Induction Heating Stress Improvement work resulted in a significant reduction in total dose to workers (ALARA). However, it was noted during inspections that administrative duties assigned the Radiation / Chemistry Foremen occasionally hindered their timely response to radiological technical matter The licensee's responsiveness to NRC initiatives in the radiation protection area has been good during this assessment period as evidenced by improvements in self-identification and correction of radiation protection problems, management support for implementation of radiation protection procedures, contamination controls, and health physics coverage of radiologically signifi-cantjobs. Evidence of these improvements is noted by more thorough licensee review of Radiological Occurrence Report and personnel contamination events, stronger disciplinary actions for offenders of radiation protection procedures, a reduction
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in dose at the station, and a dramatic reduction in the extent of contaminated areas. Also improved was ALARA pre-job planning, job coverage, and post-job reviews. The licensee's approach to resolution of these issues has been technically sound and thoroug The training and qualification program contributes to an adequate understanding of work and fair adherence to procedures with a modest number of personnel errors. The policy of rotating RCTs between health physics and laboratory assignments results in a long interval between successive laboratory assignments and requires a high degree of oversight and supervision. However, retraining has been enhanced by increasing scheduled formal training sessions and broadening the scope of retraining to include refresher training. Insufficient time has elapsed to assess effectiveness of the enhanced retrainin The licensee's approach to resolution of technical issues generally results in sound and timely resolutions with appropriate emphasis on radiological safety. Effectiveness of the ALARA program has continued to improve during this assessment period. Increased ALARA awareness by the station staff, addition of appropriate manpower to support the ALARA organization, and greater management support have resulted in more extensive pre-job planning, engineering controls, and post-job review Total worker doses during this assessment period, about 890 person-rem per reactor in 1984 and estimated to be approximately the same for 1985, represent significant decreases (30 to 35 percent) over the licensee's recent five year dose averages and are about 20 percent below the national average for U.S. boiling water reactors. A further reduction for 1985 was not projected because of Unit 3 recirculating system piping replacement scheduled to begin during the fourth calendar quarte The licensee's radiological effluents continue to be about average for U.S. boiling water reactors. One unplanned liquid l release above technical specification limits and one unplanned release below technical specification limits occurred during the assessment period. There were no transportation incident Laboratory performance continued to be satisfactory during this period. Instrument QC programs were satisfactory and analytical instruments were operable and calibrated. An ion chromatograph obtained during the period-is expected to be put into use by early 1986. Laboratory procedures appeared satisfactory. The licensee has implemented a program to check RCT analyses of blind samples for conductivity, silica, chlorides, and pH prior to their starting a three-week laboratory assignment. The station
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also analyzed fluid samples provided by the corporate laborator These programs should be strengthened and expanded to include radiological samples to better check laboratory and individual analyst performanc Laboratory performance in confirmatory measurements continued
.to be very good with 28 agreements in 29 comparisons made during the period. Problems noted in the past with the Automated Analytical Instrumentation Systems (AAIS) appeared to have been resolved. An experienced radiochemist with experience at the plant provides good oversight for gamma spectroscop . Conclusion The licensee is rated Category 2 in this are This is an improvement over the Category 3 achieved in SALP . Board Recommendations Non Maintenance / Modifications Analysis This functional area was inspected routinely throughout the assessment period by both resident and regional inspector In addition, six special inspections were conducted by regional personnel. The following violations were identified: Severity Level V - Hold points and work request forms were not completed in accordance with approved procedures (237/85008-01; 249/85007-01). Severity Level V - Failure of the control rod scram surveillance procedure to provide for the review and approval of test results (237/85032-03; 249/85028-03). Severity Level IV - Failure to perform adequate QC inspection for piping suspension system n.odifications to assure conformance to design documentation (237/84027-01; 249/85013-01). Severity Level IV - Failure of the Architect Engineer (AE) to conduct an adequate transient operability analysis for the LPCI system snubber failure (237/84027-04). Severity Level IV - Failure to have prescribed standards and procedures for Class IE cable splicing (237/85014-04a). Severity Level IV - Failure to assure that design basis requirements are translated into specifications, drawings, procedures, and instructions (237/85014-05b).
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One of_the special inspections conducted in this area was performed.to provide for an indepth' review and evaluation of the maintenance program and its implementation. This was the first in a planned series'of inspections of this type and was prompted by the Category 3 -rating received in this func-
'tional area during the last assessment pericd (SALP 4). As part of the review an extensive sampling of work packages was inspected, of which approximately 25% were found to have work request forms not completed in accordance with approved procedures. This resulted in the issuance of violation a. as described above. Other concerns noted included:
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A relatively large work request package backlog and the inadequate storage of incomplete package The inability of Quality Control to support maintenance acti'/itics during periods when the workload is hig Some craft personnel were not aware that maintenance procedures were required to be at the job sit It should be noted that although violation a. above did not i involve a significant' safety issue, the fact that such a'large
. proportion (25%) of the work packages were incomplete. reflects poorly on the licensee's ability to control and evaluate work activities. The licensee agreed that plant performance in regard to the items identified required improvemen l Another inspection in this functional area was conducted to I determine the adequacy of the licensee's program to meet the requirements of Generic Letter 83-28, Required Actions Based
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on Generic Implications of Salem ATWS Events". The inspection addressed' equipment classification, vendor. interface, post-maintenance testing,'and reactor trip system reliabilit Violation b. was issued as a result of this inspection; however, l in' general the licensee's program adequately met the requirements of Generic Letter 83-28 as ascertained from the areas inspecte Inspections were conducted to examine the inservice inspection program including review of activities related to: (1) the licensee's actions to satisfy requirements of NRC Generic Letter 84-11; (2) the licensee's actions related to-the Unit 2 Main Steamline-(MS) and Low Pressure Coolant Injection (LPCI)
piping snubber failures, including an independent review to determine the cause of failure, and followup of Confirmatory Action Letter 85-04; (3) the replacement of the Unit 2 Reactor Water Cleanup System piping, including a review of procedures, welder qualifications, radiographs, and other related documenta-tion, and observations of piping spool fabrication and inprocess welding; and (4) the licensee's actions to evaluate the effects
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of upgrading safety-related piping system supports that meet IE Bulletin 79-14 location verification requirements. As a result of these inspections, violations c. and d. were identified. The violations were not repetitive of any identified during the previous assessment period, and do not appear to have generic or programmatic implications. A significant causal factor in the inspection discrepancies was the failure of personnel to adhere to field change procedure Two inspections were conducted during the assessment period to evaluate the Unit 2 125V DC system modification performed to replace the degraded Unit 2 battery with the Unit 1 High Pressure Coolant Injection Battery. Two violations (e) and (f)
were identified to have occurred during the modificatio In summary, the licensee has shown overall improvement in this functional area since the last assessment (SALP 4) as evidenced by a significant reduction in the number of LERs issued as a result of personnel errors by maintenance / modification work groups (14 in SALP 4 as compared to 4 this period) and in a reduction of NRC violations issued (11 violations in SALP 4 as compared to 6 violations this SALP period). However, further improvements are required in the area of program implementatio The licensee has dedicated additional resources to this area in the form of management attention, training, and better communica-tions with workers and first-line supervisors to create a greater awareness of maintenance activitie The licensee has continued to develop new procedures as necessary and to use an extensive system of maintenance manuals (as outlined in previous SALP reports) to aid maintenance activities onsite. Response to NRC initiatives is generally timely with few longstanding issues attributable to the licensee. Resolution of technical issues from a safety perspective has been generally conservative, sound, and thoroug Maintenance records were generally complete, well maintained, and available. Maintenance personnel were adequately trained and direct observations of work activities indicate the work force has an adequate understanding of work practices and procedure The inadequacy in the Architect Engineer's operability analysis performed for the LPCI system snubber failure and the failure of quality control to adequately inspect modifications to assure conformance to the design documentation indcate that, although there is an overall improvement in license- ( %rmance in this functional area, a decline in performance .s % rent in this one narrow are . - . _ . . Conclusion The licensee is rated Category 2 in this are This is an improvement over the Category 3 received in SALP . Board Recommendations Non Surveillance and Inservice Testing Analysis During the assessment period, the resident and regional inspectors routinely inspected this area, concentrating on implementation of procedures. The inspectors also verified that procedures were adequate, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components was accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne During these inspections the following six violations were identified: Severity Level V - Inadequate procedures resulting in no '
precaution to operators on SBGTS flow and passive supports for batteries being left off after maintenance (237/84018-02A,'2B; 249/84017-02A, 28). Severity Level V - A number of examples of failure to adhere to surveillance procedures (237/85016-01). Severity Level V - A number of examples of failure to implement Quality Assurance procedures (237/85016-02). Severity Level IV - Failure to trend and evaluate valve inservice testing data for Unit 3 during 1984 (249/
85005-07). Severity Level V - Failure to use calibrated measuring and test equipment during surveillance testing (237/85006-06; 249/85005-06). Severity Level V - Failure to verify remote position indicators for accessible valves and to measure pump i suction pressure with an idle pump as required by Section XI of the ASME Code (237/85006-01; 249/85005-01).
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This'is aLsignificant increase from.the previous assessment-period when there were no violations and may be indicative of a relaxed attitude and inattention to detail.' Furthermore, there were several examples for two of the violations indicating that there were more than six events. Additionally, the events are not limited to any specific functional area.but rather involve diverse areas such as operational-surveillance, core performance testing and inservice testing. This may be indicative of a -
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programmatic weakness in surveillance testin .During inspection of core performance testing and startup related activities it became evident that improvements ar needed in the quality of surveillance records and implementation of surveillance procedures (violations b. and c.). While evidence of management involvement exists, violations b. and and.the necessary supplemental responses indicate increased attention is required to not'only assure proper implementation of procedures but to ensure timely and thorough evaluation and response to identified concern ~The inspections relating to the inservice inspection (ISI) of piping systems and the. functional testing of snubbers included a review of the ISI program, procedures and drawings, equipment and material certifications, personnel qualifications, records and associated documentation for completed work, and selected records'of nondestructive examinations performed during the October 1984 to April 1985 refueling outage for Unit 2. The completeness, availability, and quality of the documentation indicated the appropriate levels of management overview were-being applie Except for violations (d), (e) and (f), the licensee had fully implemented the inservice testing program f~ ?" ps and valves and was conducting Letting in accordance with appropriate schedules and approved test procedures. Pump testing was generally well defined and determination of operability was made in a timely manner. In addition to violation d., the licensee was unable to verify or retrieve the valve test results during the inspection.-
The licensee continues to show managerial involvement and the approach to technical and NRC issues is appropriate and timel The licensee's responsiveness to inspection related concerns was deemed very good. The ifcensee submitted the required reports and associated analyses within the time constraints imposed.'
The. licensee's training, staffing, and qualifications were adequat Management control systems were effective in that activities received prior planning and priorities had been s
assigned. Activities were controlled through the use of well stated and defined procedures. As stated previously, although
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the licensee was unable to retrieve valve test results during an inspection, overal records were found to be generally well maintained and available. The records also indicated that equipment and material certifications were current and complete and that personnel were trained and certifie . Conclusion The licensee is rated Category 2 in this area. This is a reduction from the rating received in the last SALP perio This is primarily due to the increase in violations and the apparent programmatic weaknesses indicate . Board Recommendations Non E. Fire Protection / Housekeeping Analysis Throughout the assessment period, the resident inspectors observed the implementation of the licensee's fire protection program. One inspection involving a region based inspector was also conducted to review the circumstances leading to Licensee Event Report (LER) No. 85-029-0 and the corrective actions related to the event. Two violations were issued as follows: Severity Level IV - Failure to establish a continuous fire watch in a timely manner (237/85028-01; 249/85023-01). Severity Level IV - Failure to test the automatic actuation of the Master Cardox system valve (237/84011-02);
249/84010-02).
The first violation was identified as a result of a special surveillance test in which three of five fire dampers failed in the open position. A major factor contributing to this event was a lack of understanding of the Technical Specification requirements for inoperable fire dampers on the part of the Station Fire Marshall. This resulted in a delay in notifying the Operations Department of the failed dampers. This is viewed as a training deficiency. The Operations Department promptly established the required fire watches upon notification of the inoperable dampers. Thus, the technical issues were properly addressed once identified. The LER itself was submitted in a timely manner and contained the required information. The licensee was very cooperative in resolving the issues identified in the LER. No other violations or open items were identifie . .
m Housekeeping and plant appearance have improved throughout the SALP period. The licensee has established a special crew for this purpose, supervised by an ex-shift foreman who holds an SR0 license. Along with general cleaning, the crew has the responsibility of reducing the contaminated areas in the plant, painting and generally improving appearances. This has resulted in. improved appearance in numerous areas in the plant and in a number of areas that were made accessible without protective clothing. In spite of the foregoing, housekeeping at Dresden remains a problem with craft personnel not picking up after completion of a job and areas becoming recontaminated during maintenance work. In addition, it is common to see numerous cigarette butts and loose trash in non-safety /non-health physics controlled areas reflecting poor attitudes on the part of the work forc Station management has acknowledged this situatio 'Although housekeeping is an important factor in fire prevention, the board also recognizes the necessity of maintaining the plant as clean as reasonably possible to prevent dirt, dust, etc. from intruding into safety-related systems and components since their presence can ultimately challenge the reliability of system operabilit The licensee should take steps to correct the attitudes that have resulted in the poor housekeeping habits, especially at the worker and f;irst line supervisor level .c \
With regard to final implemer.tation of the fire protection
, requirements of 10 CFR 50 Appendix R, as they apply to Dresden, there are a numtier of outstanding issues. Thesd issues are the
. subject of ongoing discussion between the licensee and the NR '
2.' Co'nclusion The licensee is rated Category 2 in this area. The trend was improving early in.the SALP perio'd and has shifted to declining-later in the period.- Board Recommendations s
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The board noted that shortly after the close of the} SALP 5 period, a fire protection inspection was conducted which indi-cated potentially significant weaknesses in the implementation of existing. fire protection requirements. These weaknesses,
- some of which were. identified by the licensee, are currently D under review by the licensee in an effort to improve the progra ,. - ;This effort will be closely monitored by . Region II . A 1 ,_ , [ !
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- F. .- Emergency Preparedness- < Analysis
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Three inspections were conducted during the. period to evaluate the.following aspects of the. licensee's emergency preparedness program: (1) emergency detection and classification, (2) protective. action decision' making,-(3) emergency notifications, (4) emergency communications' systems, (5) shift augmentation provisions, (6) emergency preparedness training, (7) independent audits of emergency preparedness, and (8) implementation of
_
changes to the emergency-preparedness program. Two of these
. inspections were observations-of annual emergency exercises. No violations or deviations from commitments were identified during the perio ~Manag' e ment involvement in the emergency preparedness program has been adequate with evidence of assignment of prioritics and
, s explicit procedures for control of activitie Independent audits of:the emergency preparedness program were thorough, being adequate.in scope, depth, and frequency. Audit records were complete, well-maintained, and readily available. During the period'the. licensee has improved its capability to monitor corrective actions by utilizing effective tracking system Administrative procedures were adhered to regarding the prepara-
' tion, review, and distribution of the emergency plan and its
~
implementing-procedures. Plan'and procedure revisions were consistent and did not decrease their effectiveness. Training recordkeeping improved during the period; however, updating of records, with training performed,_in a timely manner remains as a problem are Management involvement and control in assuring quality of the emergency preparedness program is further evidenced by the licensee's corrective action system, which promptly recognized and addressed several nonreportable concerns. .For example, a Quality Assurance. Surveillance of.a Health Physics Drill iden-tified the need for a timing device and a lack of heating where low temperatures could cause adverse affects. These items were-brought to management attention and both were resolved in~a timely manne The licensee's responsiveness to NRC initiatives has been l timely, with technically sound and thorough responses in almost all. cases. Whenever the-licensee was required to formally-
, respond-to-exercise weaknesses, they responded weil before the
. due dates. All proposed corrective actions were acceptable,
- including the~ proposed completion schedules. Effective
corrective _ actions on the majority of the previously identified
.open items were completed during the period.
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% o y v v e , e--,e- - -. er , un, --e.s-w e e.~ ~ ,e - - , - -,m
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Records of eight activations of the emergency plan were evaluated during the SALP period. All emergency conditions were properly classifie Initial notifications to the NRC and State of Illinois were completed in a timely manner following each emergency declaratio The licensee has maintained a prioritized roster of sufficient numbers of qualified personnel to fill well-defined key positions in the emergency organization. Augmentation capabilities have been adequately demonstrated by periodic drills. The licensee has involved both primary and alternate persons assigned to key positions in emergency drills and exercise The licensee's training and qualification program contributes to an adequate understanding of emergency responsibilities with only a modest number of personnel errors, as evidenced by exercise and walkthrough performances. However, some areas were identified which indicated a decrease in training emphasi In the Operational Support Center, the lack of adequate briefings of teams has been identified in the last two exercise inspection Additionally, some radiological control personnel exhibited insufficient knowledge of various tasks and associated procedures during both exercise . Conclusion-The licensee is rated Category 1 in this area, with the trend being essentially the same throughout the perio . Board Recommendations Non G. Security Analysis Two routine security inspections were conducted by region based physical security inspectors during the assessment period. In addition, the resident inspectors routinely conducted observations of security activitie Two violations were identified relative to the security program as follows: Severity Level IV - The licensee failed to adequately implement a section of the background screening program for contractor employees (10/85003-04; 237/85007-04; 249/85006-04). Severity Level V - The licensee failed to implement an adequate compensatory measure (10/85003-02; 237/85007-02; 249/85006-02).
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In addition to the two violations, a concern was identified regarding an ineffective maintenance program for some security related equipmen Further, an anonymously written allegation was received by Region III that dealt with an individual working onsite while under the influence of alcohol and that he had been terminated from other nuclear sites for alcohol and drug abuse. The inspectors determined that the licensee took adequate and immediate followup action after receiving the informatio The allegation was not substantiated and no enforcement action was require Regarding the compensatory measure violation, the implementation of the compensatory measures for the failure of a perimeter intrusion alarm zone was not effective, in that the CCTV being used to monitor the affected zones was out of focus. Therefore, the guard posted to observe and monitor could not adequately assess activities in the alarm zone. The significance of this violation was increased due to the fact that: (1) a work-request had apparently been written but not acted on for a long time;'(2) guards apparently had become complacent and used a less effective system; and (3) the importance of complete implementation of compensatory measures should have-been recognized as critical, based on the Severity Level III violation cited in the last SALP perio The violations identified were early in the assessment period, were minor, and were corrected in a timely manne The item of concern identified the lack of timely action by the electrical maintenance department to repair security-related equipmy Individually, none of the outstanding maintenance items represented a significant failure of the security program; however, the volume of items appeared to indicate a lack of management action in assuring those items were corrected in a timely manner. Additionally, the licensee's preventative maintenance program for the CCTV and protected area intrusion alarm system was discontinued approximately two years ago due to manpower shortage Based en this finding, the licensee was requested to respond to the concern describing their short and long range program for reducing the backlog of outstanding electrical maintenance requests. Additionally, the licensee was requested to immediately re-establish a preventive maintenance program for security-related electrical items and to keep the Region informed of progress in the area. The licensee responded to this concern in a timely manner and the corrective actions taken appaar to be adequat l
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There were no technical. issues involving physical security, from a safety aspect, which required resolution during this assessment perio The licensee has provided a technically sound and thorough response to NRC initiatives such as the development of a security drill program to address all of the contingency events identified in the Safeguards Contingency pla . Events reported under 10 CFR 73.71 were accurately identified and reported in a timely manner. The number of reportable events-decreased significantly in this assessment period which was attributed to improvements made to the security compute Positions within the security organization are identified and responsibilities are defined. The staffing levels for the uniformed security force appeared adequate. There is good communication between the licensee and the contract guard forc The training effectiveness and qualification of the guard force is adequate. This was demonstrated during the alert that occurred during the assessment period, when the guards performed their duties adequately and in a professional manne Corporate security involvement has increased during this assessment period and has provided excellent support to site security operations. The licensee promoted from within to fill vacancies at the corporate (Senior Nuclear Security Adminis-trator) and site (Station Security Administrator) level Both individuals are knowledgeable of past and current security practices at Dresden. Due to his vast experience, the promotion of the Station Security Administrator to a corporate security level position should further enhance corporate involvement with the sit Good communication exists among corporate, site security, and Region III NR Except for the maintenance concern, senior management support of security operations was made evident by the upgrading of the security computer, the purchasing of new explosive detectors, closed circuit television cameras, and the construction of new nuclear security training facilities which include both administrative offices and classroom In summary, the contract security performance and corporate security involvement in site activities has been strong and consistent except in the electrical maintenance backlog of
. security equipmen __
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1 Conclusion The licensee is rated Category 2 in this area, which is the same SALP rating given in the previous assessment perio A positive trend has been identified during this assessment period in that the licensee continues to increase its efforts in upgrading securit . Board Recommendations Non H. Refueling Analysis Refueling activities we're inspected by the resident inspectors during the refueling outage on Unit 2, and the return to power on Unit 3. The licensee continues to maintain their high level of performance. Personnel involved are well trained and staffing is ample. The licensee completed the remaining shipments of Unit 1 spent fuel from West Valley, New York to Dresden without inciden One inspection of core physics and refueling was performed by a Region III specialis No violations were identified. The inspection activities included a review of training records, fuel handling equipment check out procedures, fuel handling and surveillance test procedures, results of fuel reuse inspections and fuel sipping operations, and several shifts of core alterations for Unit The licensee continues to use a permanently assigned refueling group that demonstrated the qualities of a well managed and proficient fuel handling team. There was evidence of prior management attention and planning as the fuel movements were handled safely and efficiently. There was good coordination and communication among the various licensee work groups that support fuel handling. Problems encountered were handled effectively with minimal loss of time. Personnel were knowledgeable of their duties and staffing was adequate to support all fuel handling evolution . Conclusion The licensee continues to be rated Category 1 in this are . Board Recommendations Non .
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I. ~ Quality Programs and Admir.istrative Controls . Analysis Routine observations by resident inspectors were made in this area. . This functional area was also examined.by four region based inspectors during two inspections within the assessment
- period. These inspections were performed to determine the adequacy of procurement, calibration, tests and experiments, Lquality program control, records, and offsite review committee and support staff activitie The following violations were identified: Severity Level IV'- Failure to evalu-te a possible discrepancy for disposition in a timely manner (237/84026-01; 249/84023-01).
- Severity Level IV - Three examples of failure to follow
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procedures (237/84015-07; 249/84014-07). Severity Level V - Failure to perforr a seismic evaluation on a substitute motor for the HPCI aue.iliary oil pump (237/84015-08; 249/85014-08).
' Severity. Level V - Failure to provide training on QA program changes within the time frame specified by the QA program (237/85029-02; 249/85024-02).
The-procurement inspection was a special inspection of the Ceco procurement program and its implementation at all operating site During this inspection violations b. and c. specific to Dresden were disclose With. regard to violation-b., the examples involved purchase orders failing to impose'a. review for suitability of application on-the vendor as required by the Ceco procurement progra While the individual examples had minor safety significance, the multiple examples of the failure to impose programmatic requirements indicated the need for added management attention in this' area. 'With regard to violation c., the motor is currently in a hold status pending a licensee decision on its disposition. The licensee has implemented procedure changes for both items,.which should preclude recurrenc _InadditiontotheDresdenspecific.itemsaddressedabove,six
_ other items.were disclosed relating to the Ceco corporate procurement program which apply to Dresden as well as the other operating sites. .These items were of~ concern, in that they represented programmatic' weaknesses that provided a potential c
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for the procurement, installation, and use of unqualified item The licensee's proposed action re' eating to these unresolved items' appears to mitigate some of the weaknesses; however,
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further NRC review is required before these items can be dispositioned.
With regard to violation d.on training, the licensee had a commitment to train all appropriate personnel on changes to the nuclear Quality Assurance Manual within 60 days of the date of i
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revisions so that the changes would be effectively implemente On one recent revision, there were over 20 job classifications
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l-of site personnel who were not given the required training '
within the specified' time period. This failure was of concern
. because.of the number of personnel who did not receive the training in a timely manner. Some of the changes were administrative in nature without direct safety applications, so the overall_ impact'of this' violation was_of limited safety significance.
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- The. licensee's performance in the functional areas of Calibration, Records, Offsite Review and Support Staff was -
a found to be satisfactory. No_ items of concern were identified requiring further action by the licensee or the NRC in these
{ three areas.
. In-' summary, the procurement area was controlled by a sometimes
.poorly stated program containing some weaknesses. Weaknesses in program implementation indicated.the lack of management
. attention in this area and the need for more effective staff-
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training. The failure to provide training in QA program
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changes also supported the need for more management attentio The licensee has initiated corrective action to address these ,
issue The other area of inspection disclosed one minor item of concern-in the functional area of Tests and Experiments. The licensee.
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will be conducting a special sampling review of completed modification and maintenance work packages to verify that the required technical evaluation had been completed on replacement
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parts used in safety-related components.
, Conclusion
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The licensee is-rated a Category 2 in this are ,
' Board Recommendations None.
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. . Licensing Activities
~ Analysis Methodology The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period. .These actions, consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, including the following specific items:
(1)_ Multiplant Action Items (MPAs) completed or having a significant level of review action completed include:
- NUREG-0737 Item (six items closed for D2 and D3, one item (I.A.2.1) near closure for both units)
- NUREG-0737 Technical Specifications - GL 83-3 Completed except for Post Accident Sampling and Control Room Habitability for the station
- NUREG-0737 Supplement 1 Items:
SPDS in progress review, station DCRDR in progress review, Final Summary Report submitted Procedures Generation Package (PGP)
for E0Ps. RAI sent
- Response to GL 81-04, NUREG-0313, completed
- Control of Heavy Loads, Phase II, completed
- Mark I Long Term Program, completed
- Environmental Qualification Schedular Extension, completed
- Radiological Effluents T.S. (RETS), completed
- IST (2nd ten years) Relief Requests approved
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- B-24, Containment Isolation Depenjability by Demonstration of Purge and Vent Vilve Operability, near closure
- Response to GL 84-11, completed
- Appendix R Schedular Exemptions - RAI sent, near closure (2) Plant Specific Action Items completed or having a significant level of review include:
.
- Reformatting of entire Technical Specification for D2 and 03, completed
- Emergency Preparedness Exercise Exemption, issued
- Transfer of Dresden 1 Spent Fuel from West Valley to Dresden Station, completed
- -Decontamination of Dresden 1, completed except for disposal s
- T.S. change relating to extension of MAPLHGR Curves, D3,_ completed
- T.S. for Cycle 10 Restart, D2, completed
- Installation of Liquid H2 Storaga Tank at Dresden, near completion
- T.S. relating to Administrative Controls, D2 and D3, completed
,
- T.S. relating to SEP Topics VI-7.C.1 and XV-iS, D2 and D3, completed
- T.S. relating to Revision of T.S. Table 3.7.1, D2 and D3, completed
- T.S. relating to Economic Generation Control, D2 and D3, completed
- SEP Item - Thermal Overload Protection of M0Vs, 02, completed
- T.S. - Deletion of Recirculation Equalizer Valves, 03, completed
, * Appendix J Exemptions, 03, completed
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b. -Management Involvement and Control in Assuring' Qualit Commonwealth Edison management has an awareness of the various licensing issues by virtue of-its extensive experience in the. industry, technical expertise, and active participation in Owners Group and professional organization
, activitie Commonwealth management takes actions in a timely manner to ensure safety issues are properly addresse These actions include. frequent. visits to NRC Headquarters by the Director of Nuclear Licensing to discuss progress in
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general on resolution of outstanding _ issues. Specific examples of this attribute in the report period are: (1)
the involvement of management all through the period relative'to the req'uirements of Generic Letter 84-11 which relates to the inspections of BWR stainless steel pipin Because of management _ involvement with this issue, Commonwealth's response to GL 84-11 was such that the staff considered them acceptable relative to current IGSCC concerns; (2) the response to NRC's need for effective action and/or information regarding the loss of offsite power event at Dresden 2 on August 16, 1985; and (3) the care that Commonwealth took in evaluating the September 19, 1985 event where leaking scram solenoid valves caused reactor: coolant to leak into the Reactor Building via the vent and drain valve Approach to Resolution of Technical Issues from a Safety Standpoint Commonwealth's responses to most technical issues are su:h that few reviewer Request' for Additional Information (RAIs)
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are needed. When RAIs are issued, Commonwealth's responses are timely and technically accurate. The need for conference calls to resolve issues are rare and, when~ conference calls are made, Commonwealth has the proper technical expertise available to respond to remaining staff concerns. They have a well qualified engineering staff and even a recent licensing contact change did not interrupt the flow of information to continue adequate review of outstanding issues. .This is an indication of the depth of quality of Commonwealth's staff. They also make appropriate use of contractors when neede The resolution of the large number of multiplant issues demonstrates that Commonw2alth's staff understands complex technical issues in terms of' plant safety, plant operation, and responsiveness to regulatory concern . .
During the report psiod several issues were identified for which prompt and effective action was appropriate. In each case, the licensee promptly evaluated the problem and took action to provide interim repairs or other appropriate actions to satisfactorily resolve the issue from a safety standpoint. In each case Commonwealth Edison furnished the staff promptly with the information required to evaluate the possible safety concerns. In addition, as required for staff licensing actions, the necessary docu-mentation was made available so that licensing deadlines could be met without straining staff resource d. Responsiveness to NRC Initiatives Communication between NRC and Commonwealth generally occurs between the respective licensing staffs. However, on the occasions where the need for information directly from Dresden occurs, appropriate and technically competent personnel have responded to staff concern All technical specification requests are initiated by the station and the cooperation in satisfying staff documentation needs during TS processing has been excellen This cooperation, in fact, was extremely important during the reformatting of the entire D2 and D3 Technical Specifications during the evaluation perio While Commonwealth responds to most staff concerns promptly and is very cooperative when urgent safety issues appear, they are much slower to respond to concerns that do not effect them in an immediate way. This causes reviews of such concerns to remain outstanding longer than the staff believes necessary. Three specific items of this type are: (1) the closure of SEP items which will lead to the Provisional Operating License-Full Term Operating Licensee conversion for Dresden 2; (2) the licensing issues relating to the use of the Mobile Volume Reduction System; and (3)
the approval of the use of the Liquid Hydrogen Storage Tan Resolution of these issues should be expedited during the next rating perio e. Housekeeping The NRR Project Manager has visited the site on numerous occasions. However, during the evaluation period the visits involved issues which did not require an extensive site tour. Visits to the Control Room were made in March and June 1985. The Control Room appeared to be well maintained and operated in a professional manner. There was no evidence of food and drink containers and all reading material appeared related to operational needs. In earlier discussions with the Dresden Senior Resident
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Inspector, a concern was expressed by him of housekeeping problems at Dresden. However, more recent contacts indicated that these concerns were being reduce Fire Protection Nearly all ~ plant modifications resulting from the NRC staff fire protection review have been completed, and exemptions were issued where appropriate.-
In late 1983, NRC issued a clarification of the requirements of Appendix In response to the NRC clarification, the licensee then initiated an independent review of their fire protection program, and additional exemptions were requested beyond those resulting from the original NRC fire protection review. These are currently under NRC staff revie . Conclusion The licensee is rated Category 1 in this are This is an improvement from last years Category 2 and is due to improve-ments in timeliness and resolution of licensing activitie . Board Recommendations Non V. SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 1 was officially declared " Retired in Place" on August 31, 198 Presently, the licensee is deliberating the disposition of the uni "
Chemical cleaning commenced on September 12, 198 Units 2 and 3 engaged in routine power operation throughout most of SALP 5. A major scheduled Unit 2 outage for plant refueling, modification, and maintenance began on October 5, 1984 and was completed on April 13, 1985. A major unscheduled outage for turbine repair was in progress at the beginning of the assessment period for Unit 3 and was completed on July 21, 198 The remaining outages throughout the period are summarized below:
_U__ nit 2 June 21 to July 1, 1984 Repair 2A feed regulator valve June 9 to June 13, 1985 Repair 2B MG set June 18 to June 20, 1985 Repair EHC
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August 2 to August 6, 1985 Repair turbine oil reservoir tank August 16 to August 22, 1985 Repair auxiliary transformer August 22 to August 25, 1985 Repair 2B feed pump September 29 to October 10, 1985 Inspect snubbers
Unit 3 August 21 to August 22, 1984 Repair 3A feedwater valve September 11, 1984 Repair EHC oil leak September 25 to October 1, 1984 Repair main condenser leak October 1 to October 4, 1984 Repair feedwater regulator valve October 4 to October 5, 1984 Repair EHC oil leak October 20 to October 23, 1984 Feedwater regulator valve problems October 26 to November 2, 1984 Routine maintenance January 12 to January 14, 1985 Oil trip solenoid valve on turbine April 26 to May 3, 1985 Repair feedwater heaters and take measurements of recircula-tion piping Unit 2 scrammed twenty-one times (ten occurred while shutdown) and Unit 3 fourteen times (four occurred while shutdown). Fourteen of the Unit 2 scrams and none of the Unit 3 scrams were attributed to equipment malfunctions and required minor maintenance prior to returning the units to service. Two scrams occurred at power for Unit 2 which were attributable to personnel error. Three scrams occurred at power for Unit 3 which were attributable to personnel error. While both units were shut down, four scrams were attributed to personnel error. Three scrams during SALP 5 were due to defective procedure The licensee formed a scram reduction committee late in this SALP period because the number of scrams have approximately doubled each of the last two SALP periods. The purpose of this committee is to review each scram and provide feedback to all appropriate site personnel to prevent similar scrams from occurring in the futur _ _ _ - _ _ _ _ - _ - - - __
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B. Inspection Activities A special NRC HQ's trial outage team inspection was begun on September 5-6, 1985, to assess the stations' performance during the Unit 3 recirculation pipe replacement. This is the second of two NRC inspections to be performed on plants that will have extended outages. The inspection is being conducted in accordance with a proposed NRC procedure to analyze details of new designs /
modifications for older site Violation data for Dresden is presented in Table 1, which includes Inspection Reports 84009 through 85014 for Unit 1, 84010 through 85032 for Unit 2, and 84009 through 85028 for Unit TABLE 1 INSPECTION ACTIVITY AND ENFORCEMENT No. of Violations in Each Severity Level Functional Unit 1 Unit 2 Unit 3 Site Areas III IV V III IV V III IV V III IV V A. Plant Operations 1 1 3 2 4 2 B. Radiological Controls 3 3 1 3 1 4 1 C. Maintenance /
Modifications 4 2 1 2 4 2 D. Surveillance and Inservice Testing 5 1 3 1 5 E. Fire Protection 2 2 2 F. Emergency Preparedness G. Security 1 1 1 1 1 1 1 1 H. Refueling I. Quality Programs and Administrative Controls 2 2 2 2 2 2 J. Licensing Activities TOTALS 4 1 13 12 13 11 18 13
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C. Investigations and Allegations Review During a safeguards inspection, reviews were made as followups to three anonymous allegations received on December 4, 1985 by the Senior Resident Inspector. The allegations concerned: (1) DNI-Radman suspected of alcohol use, (2) Commonwealth Edison Company was told of the problem and did nothing,'and (3) Commonwealth Edison Company needs a quality screening program. The inspectors determined that the licensee took adequate and immediate action after receiving the information. No violations of regulatory requirements were identified and the allegation was not substantiate On January 7,1985, a NRC contractor employee contacted the NRC with concerns about an incident that occurred four years ago when control rod drive pressure was too high, went offscale, and a rod moved more than 1 notch. A review of the incident determined that the licensee reported.this in an LER which was followed by the residents and closed in a routine inspection. No violations of regulatory requirements were identifie D. Escalated Enforcement Actions There were no escalated enforcement actions during the assessment period. However, an Order imposing civil penalties in the cumulative amount of $130,000 was issued in 1985 for violations occurring during SALP E. Management Conferences Held During Appraisal Period Confirmatory Action Letters (CAL)
A CAL was issued April 15, 1985 to confirm licensee action regarding monitoring and surveillance actions required as a-result of the damage sustained by several main steam piping mechanical snubbers at Unit . Management Conferences September 7, 1984 (Glen Ellyn, Illinois)
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Meeting to discuss licensee performance in regards to their Regulatory Performance Improvement Plan (RPIP). . September 17, 1984 (Glen Ellyn, Illinois)
Management meeting to review Systematic Assessment of Licensee Performance (SALP 4).
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9 * March 7, 1985 (Glen Ellyn, Illinois)
Meeting to discuss licensee performance in regard to their RPI June 24. 1985 (LaSalle County Station)
Meeting to discuss licensee performance in regard to their RPI July 16, 1985 (Glen Ellyn, Illinois)
Meeting to discuss additional aspects of the licensee's RPI . Enforcement Conferences March 25, 1985 (Glen Ellyn, Illinois)
Meeting to discuss the increase in personnel errors and HPCI inoperabilit F. Review of Licensee Event Reports and 10 CFR 21 Reports Licensee Event Reports (LERs)
LER's issued during the 16 month SALP 5 period are presented below:
Unit 2 Unit 3 LERs N LERs N through 84-25 84-05 through 84-23 85-01 through 85-34 85-01 through 85-16 Proximate Cause Code * Number During Salp 5 Personnel Error (A) 38 Design Manufacturing, Construction / Installation (B) 3 Defective Procedures (D) 7 Others (X) 45 Total - TJ
- Proximate cause is the cause assigned by the licensee according to NUREG-1022, " Licensee Event Report System."
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During the SALP 5 period, 93 Licensee Event Reports (LERs) which were required by 10 CFR 50.73 were submitted . Of these, two-addressed occurrences on Unit 1, 56 were associated with Unit 2, and 35 LERs were submitted relating to Unit 3. In most cases, the LERs were submitted in a timely manner and in accordance with NUREG-1022, " Licensee Event Report System." However, in four cases, LERs were submitted which exceeded the 30 day time limi This was due, in part, to some initial confusion on the part of the licensee as to what specifically constituted a reportable occurrence following the change of the NRC reporting requirements in January 1984. The licensee conducted a review of station deviation reports (DVRs) in the Fall of 1984 to ascertain if all reportable items were issued as LERs and found that some had been overlooked. These were then subsequently made into LERs and submitted. During subsequent reviews, no further problems in this area have been identified to dat Because of the change in reporting requirements that occurred in January 1984, a detailed comparison of LERs submitted during SALP 4 and SALP 5 could not be mad However, tha number of LERs as a result of personnel errors have increased signifi-cantly. A portion of an enforcement conference discussed this increase. The number of component failures that were reportable decreased during the last SALP period. This is indicative of the licensee's increased management attention in this are Of the 93 LER's submitted by the licensee during the SALP 5 period, 35 were due to unscheduled scrams or RPS actuation which are discussed in this report under the Operations Functional Area. A review of the LERs identified that the licensee has reported a number of ESF events even though the actuation was anticipated and would therefore not be reportabl During the SALP 5 period, where events are caused by personnel error, and the licensee's investigation reveals that it was carelessness or disregard by an individual, the licensee has exercised stronger actions against the individuals who caused the event. This has been part of the effort to improve attitudes and achieve a better sense of accountability to perconnel working in the plan Notwithstanding the positive aspects of the licensee's reporting system, an assessment by the Office for Analysis and Evaluation of Operational Data (AEOD) of the quality of LERs submitted found that the LERs were of barely acceptable quality based on the requirements contained in 10 CFR 50.73. The most significant areas that need improvement are: root cause discussions, personnel error discussions, corrective actions to prevent
< recurrence, safety assessment information, manufacturer and model number information, date and time information, text presentation consistency, text readability, and abstracts and
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titles need to be written such that they better describe the essence of the even A copy of the AE0D report has been provided to the licensee so that the specific deficiencies noted can be corrected in future LER . 10 CFR 21 Reports No 10 CFR 21 reports were submitted during the assessment perio G. Licensing Actions 1.- NRR Site and Corporate Office Visits March 17-20, 1985 - Site Visit, add RETS to Technical Specifications and prepare an official version of the reformatted Technical Specifications for Dresden 2 and June 9-11, 1985 - Corporate office visit on June 19, 1985, to accompany J. Zwolinski and C. Jamerson on "get acquainted" tour. Talked with corporate and technical personnel to ensure that current regulatory requirements were well understoo Site Visit on morning of June 11, 198 J. Zwolinski and C. Jamerson met with station management, visited TSC, Control Room, HRSS, and areas where MVRS is proposed to be placed and where H2 Storage Tank is placed, but not approved for us J. Zwolinski and C. Jamerson also visited Commonwealth's Training Center at Braidwoo . Commission Briefing Non . Schedular Extension Granted January 3, 1985, Equipment Qualification, Dresden Unit . Relief Granted March 5, 1985 IST Program - Second 10 Year Interva . Exemptions Granted August 14, 1984, - Emergency Preparedness Exercise Exemption, 02 and D September 26, 1985 - Schedular Exemption from Requirements of Appendix J, D . License Amendments Issued i 36 t
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' Amendment-No. 82, issued August-6, 1984, Reformatted Technical
- Specification Amendment No. 83, issued November 16, 1984, Radiological
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Effluent Technical Specification ~
Amendment No 84, issued January 17, 1985, Technical Specifica-tion changes relating to the Cycle 10 Reloa Amendment No. 85, issued February 27, 1985, Technical Specification changes relating to Snubbers and Reflecting
- the_ guidance of Generic Letter 84-1 Amendment No. 86,_ issued March 20, 1985,- -Technical Specification changes Relating to Administrative Control and Reportabilit Amendment No.- 87, issued May 30, 1985, Technical Specification Amendments Resolving-SEP Topics-VI-7.C.1 and XV-1 Amendment No. 88, issued May 30, 1985, Technical Specification changes to Revise Table 3. Amendment No. 89,. issued May 30, 1985, Technical Specifications:
Relating to Economic Generation Contro Amendment No. 90, issued June 24, 1985, Technical Specifications Relating to TMI Action Items Covered by Generic Letter 83-3 Unit'3 Amendment No. 75, issued August 6, 1984, Reformatted Technical Specification Amendment No. 76, issued September 14, 1984, Technical Specification changes Relating to the Extension of Certain MAPLHGR Curve Amendment No. 77, issued November 16, 1984, Radiological Effluent Technical Specification Amendment No. 78, issued February 27, 1985, Technical Specification changes Relating to Snubbers and Reflecting the Guidance of Generic Letter 84-1 Amendment No. 19, issued March 20, 1985, Technical Specification changes Relating to Administrative Control
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and Reportabilit cr
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Amendment-No. 80, issued May 30, 1985, Technical Specification Amendments Resolving SE0 Topics VI-7.C.1 and SV-1 Amendment No. 81, issued May 30, 1985, Technical Specification changes to Revise Table 3. Amendment No. 82,' issued May 30, 1985,-Technical Specifications Relating to Econmic Generation Contro Amendment No. 83, issued' June 24, 1985, Technical Specifications Relating.to TMI Action Items Covered by Generic Letter 83-3 Amendment No. 84, issued September 17, 1985, Technical Specification and License changes Relating to Deletion of Recirculation Equalizer Valve . Emergency / Exigent Technical Specification Emergency Technical Specification for Dresden 3 on LPCI-Loop A -
Extension of LC0 was completed, (but not issued when Licensee was able to complete the required repairs within the seven day period specified in the existing Technical Specifications), for issuanc by 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />,- August 4, 198 . Orders Issued A document entitled " Issuance of Order Confirming Licensee Commitment on Emergency Response Capability" was issued on June 12, 198 . NRR/ Licensee Management Conference Conference in Bethesda on July 23, 1985 regarding the details of Commonwealth's program for reactor coolant system piping replacement during the next refueling outage scheduled to start October 26, 198 ,
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