IR 05000237/1988001

SALP Repts 50-237/88-01 & 50-249/88-01 for Jan 1987 - Jan 1988

ML17201K164
Person / Time
Site:	Dresden
Issue date:	04/20/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17201K124	List: IR 05000237/1988001 ML17201K066
References
50-237-88-01-01, 50-237-88-1-1, 50-249-88-01, 50-249-88-1, NUDOCS 8809140183
Download: ML17201K164 (44)

Text

SALP BOARD REPORT U.S. NUCLEAR REGULATORY.COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-237/88001; 50-249/88001 Inspection Report N Commonwealth Edison Company Name of Licensee Dresden Station Name of Facility January l, 1987 through January 31, 1988 Assessment Period SALP 7

SUMMARY OF RESULTS Overall, the licensee's performance was found to be acceptable and improved since the last SALP assessment perio Of the 10 functional areas rated during this assessment period, licensee perfonnance in one area (Quality Programs and Administrative Controls Affecting Quality)

improved from a Category 3 to a Category License perfonnance in one area (Licensing Activities) declined from a Category 1 to a Category In addition, while the area of Plant Operations sustained a Category 2 rating, the trend was noted as improving at the end of the assessment period, as opposed to a declining trend noted at the end of SALP All of the remaining functional areas which were rated sustained Category 2 ratings with an improving trend noted at the end of the assessment period in the area of Emergency Preparednes The functional areas of fire Protection/~ousekeeping and Outages were not rated this assessment perio Functional Area Plant Operations Radiological Controls Maintenance Surveillance

• Fire Protection/Housekeeping F:

Emergency Preparedness Security Outages Quality Programs and Administrative Controls Affecting Quality Engineering/Technical

• Support Licensing Activities Training and Qualification Effectiveness 0 NR = Not Rated Rating Last Period (SALP 6)

2

2

2

2

1

• Rating-changed by Regional Administrator

Rating This Period (SALP 7)

2

,r3*

0 NR

2 0 NR

2

.2

I PERFORMANCE ANALYSIS Plant Operations

• Analysis Evaluation of this functional area was based on the results of routine and special inspections conducted by resident inspectors; regional inspectors. an Augmented Inspection Team. and the NRC D~agnostic Evaluation Team (DET).

Excluding a 4-month period for a scheduled refueling outag Unit 2 was available 78.1% of the tim Unit 3. excl~ding a two-month period for feedwater system testing. was available 76.6% of the tim The enforcement history in this area indicated several significant problems during the first quarter of this SALP period. Three violations (two Severity Level IV and one Severity Level III). one resulting in escalated enforcemen were identifie The Severity Level III violation was issued for a personnel error that resulted in an inadvertent heatup of the Unit 3,

reactor vessel while shutdow In all cases. prompt corrective actions were initiated by licensee managemen In the are of personnel errors. the corrective actions were effectiv resulting in a low percentage (9%) of events caused by personnel errors (combination of all Deviation Reports and Licensee Event Reports).

However, these efforts were not totally effective in that after the close of the as~essment period. a personnel error resulted in a repeat violation involving the IRM and APRM neutron monitoring system Operational events that occurred during this SALP period indicated below-average performance during the first half of the assessment period with improving trends throughout the remainder of the period. These efforts resulted in a 101-day continuous dual-unit op~ration during the last ~uarter. The previous best continuous dual-unit operation at Dresden was 76 days in 1978. Subsequent to the SALP period. Dresden extended this run to over 155 day During the assessment period. 15 unscheduled reactor scrams (10 at power) occurred during the first three quarters with no reactor scrams during the last 103 days of the assessment period. Although this does not indicate any improvement over that reported during SALP 6 (16 total reactor scrams). it does indicate an improvement trend that should continue into the next assessment perio **

Management involvement was effective compared with that reported during the SALP 6 period, in that only 4 of the reactor scrams were due to personnel errors (there were 10 during the SALP 6 period) and none were caused by licensed operators. Of the 15 scrams during this assessment period, 5 occurred under shutdown conditions involving no control rod movement, and two of the scrams at power were manual scrams by operators in response to deteriorating plant conditions. This is an improving trend, in that the operators and shift management are taking effective action before (i.e. not depending on) the automatic response of the reactor protection system. This is also indicative of improving management involvement and operator trainin During this SALP period, 58 licensee event reports (LERs)

were issued; of these, 5 documented events that had occurred during the last month of the SALP 6 period (72 LERs were issued during the SALP 6 period) and 14 were caused by personnel error (41 during the SALP 6 period). Of the LERs, 7 were attributable to personnel errors by the Operations Department (18 during the SALP 6 period). The licensee continues to be conservative when

_deciding which events are to be reporte The LER analyses are carefully done and thorough; the Office of Analysis and Evaluation of Operational Data (AEOD) noted a significant improvement in the quality of Dresden LER The effectiveness of management's involvement in reducing personnel errors is indicated by the decrease in the percentage O*f a 11 events (combination of deviation reports and LERs) caused by personnel error from 22% (SALP 6) to 9% (SALP 7) and the reduction of LERs attributable to personnel errors from 56% to 24%. *

Conduct in the control room was businesslike and professiona During this assessment period an improving trend was noted in the enforcement or restriction of personnel access to the control room and the operating controls areas. Additionally, management's involvement has resulted in the removal of some administrative f~nctions related to operations from the control room; the performance of these functions from the control room was an identified contributor to the inadvertent reactor vessel heatup that occurred earlier in the assessment period. Other indications of management's involvement include the establishment of the crew concept to improve teamwork within the operational shift, the use of extra operators during the day shift to minimize_ possible operator distractions due to scheduled work and testing activities, and improvement in teamwork between the Operations Department and other department The DET noted that the lack of effective teamwork contributed, in part, to the generally low morale and operational performanc at Dresde During the last three months of this assessment, morale and operational performance improved significantly with the establishment of.~epartmental teamwor Teamwork between departments resulted in the licensee being able to resolve

several system and equipment conditions without undergoing forced outages. Additionally, the DET observed control room operations and found that the shift turnover procedures were being implemented* efficiently by the operators with minimal disruption of plant operation. The nuclear station operators (NSOs) also responded well to alarm conditions in accordance with procedures and were attentive to the operating conditions of the*

plan To correct the apparent weakness of the operating shift *

supervision during the inadvertent heatup event, improvements were made and have resulted in an improvement in the overall quality of operations during the last three months of the assessment. perio The Augmented Inspection Team (All),

conducted in response to a feedwater transient in August, found that operations personnel performed in a professional and responsible manner and demonstrated good recognition of the symptoms of the even *

The licensee is also remodeling the control room to correct the poor lighting and high background noise that were identified during previous SALP However, this has not been a timely effort and additional efforts on the part of corporate management are still needed to complete the remodelin The licensee was responsive to NRC initiatives during the assessment period. Monthly meetings of the licensee and NRC management have been held to review plant improvement programs and operating performanc During these meetings, licensee management continued to exhibit an understanding of.the high level.of performance that must be achieved and maintained in this functional are The licensee issued monthly performance reports that provided statistical data and trends for 78 parameters covering all aspects of plant operatio The reports were a valuable management tool and largely were the basis for discussions during these meetings. Additionally, a weekly

.

status report was provided to monitor weekly, monthly, and annual progress in reducing scrams, LERs, engineered safety features actuations, personnel errors, and personnel contamination. This report proved to be valuable as a management tool to provide mid-course adjustments to the various improvement program The Operations Department staffing was stable throughout the perio The licensee transferred personnel to improve management skills and to increase the knowledge levels of the Operations Department and other department Most notable of these was the transfer of operations personnel to strengthen the position of *

the Fire Marshall and the technical and training staffs. In addition, one member of the training staff was transferred into the Operations Department. All of these transfers are considered as overa 11 p 1 ant improvement Currently, the 11 censee 1s establishing an operations staff to* assist the Operations Department in implementing administrative and technical improvement This effort is perceived as an improvement, but ~dditional attention

• at the station and corporate levels is needed to complete the staffing effor Management involvement to ensure quality operation, although not totally effective in red~cing ~nscheduled scrams, improved significantly in the last quarter of the assessment period, as demonstrated by the significant reduction in personnel errors, the achievement of 155 days of continuous operation, and the ability to resolve several system and equipment condition However, additional efforts on the part of corporate *nd site staff are still needed to achieve a level of excellent performanc.

Conclusion The licensee's performance is rated Category 2 and improving in this are During the previous assessment period, the licensee's performance was rated Category 2 and showed a declining tren Board Recommendation None Radiological Controls An a 1 y s i s *

Evaluation of this functional area was based on the results of

• four inspections by re.gional specialists, observations by the resident inspectors, observations from the All, and findings from a DET assessment of licensee performanc Enforcement history improved somewhat during this assessment period with two potential violations identified: The tw violations concerned an unmonitored release of liquid radwaste and failure to follow procedural requirement Enforcement action is still pending for these violations. Five violations (one Severity Level III; two Severity Level IV; and two Severity Level V) were identified during the previous assessment perio Staffing, in general, remained adequat However, the stability of the professional staff was poor; two rad/chem supervisors, the lead chemist, and several staff health physicists and chemists were replaced during this assessment perio On the other hand, the stability of the technical staff improved, and overall professional and technician staffing levels were goo The chemistry.group was strengthened because of a reorganization and the addition of another laboratory forema The chemistry staff appears to be adequate to perform the chemical analyses required for plant operatio Initiatives to separate radiation protection and chemistry functions at the technician level and establish a progress.ion ladder of multi-tier technicians are potentially significant improvement Management's involvement in ensuring quality appears goo Audits and associated licensee responses have generally been satisfactory. Several programmatic improvement initiatives were implemented in response to audit findi~gs. Corporate radiological support has evolved over the past several years to provide timely and knowledgeable assistance for the generic and special technical aspects of the progra The licensee has developed a good water quality control program that conforms to the Electric Power Research Institute BWR Owners Guideline It includes an extensive program of measurement and trending of water chemistry parameters and, in Unit 2, hydrogen addition to maintain the dissolved oxygen at very low level The licensee's responsive~ess to NRC initiatives was generall goo Initiatives concerning reduction of contaminated areas, site housekeeping and refurbishment, reduction of personnel errors, and enhanced high radiation area (HRA) access controls have resulted in measurable improvements 1n these areas. Ongoing initiatives concerning improvement of the respiratory protection program, the separation of radiation protection and chemistry functions at the technician level, establishment of a progression ladder of multi-tier technici~ns~ better use of* foremen, hot-particle identification and control, communications, formalization of programs, and reduction of incidents involving personnel contamination are progressin The analytical capabilities of the chemistry laboratory.have been improved with state-of-the-art instrumentation, an improving quality assurance/qua 1 ity contro 1 program,.and better staffin The licensee's approach to resolving technical issues generally resulted in sound timely resolutions with appropriate emphasis on radiological safet The total station dose for 1987 was about 1145 ~erson-rem. This dose represents generally sound performance and constitutes a significant improvement over*

previous licensee histor An initiative to improve the ALARA (as low as is reasonably achievable) program places greater emphasis than before on the participation of all plant departments in the ALARA program; this initiative is in the early implementation stages and should enhance the existing ALARA progra However, adequate notice of planned maintenance activities was not always provided to ALARA coordination personnel; therefore, the extent of ALARA reviews were sometimes limited in scop Personnel contamination and the extent of contaminated areas have decreased significantly; this reflects a concerted licensee effort to improve 1n this *re Acti~ns by HP personnel, in response to the August 1987 feedwater line break even~, were prompt and thorough, thereby limiting the number of plant personnel becoming contaminate The results of the confirmatory measurements program were goo Only 3 of 27 nonradiological analysis comparisons were in disagreement with NRC values, and these were later resolve Despite agreement, analyses on the AA spectroprotometer showed persistent biases that indicate the need for further development of the quality assurance progra The r*esults of the radiological confirmatory measurements also were good; of 63 comparisons, 59 showed agreemen The plant in-line monitoring systems are being upgraded with state-of-the-art instrumentatio~ that is more accurate, reliable, and easy to maintai The licensee reduced corrosive-agent levels in the plant by actively pursuing a chemical control program that regulates and limits the entry and usage of materials in the plant. This program appears to be responsible for improved conductivity levels in the reactor coolan *

No unplanned liquid or gaseous releases were reporte As noted, one planned liquid release was made without proper release monitorin The volume of radwaste shipped was high because of site cleanup, the replacement of Unit 3 recirculating system piping, and Unit 1 decontaminatio The licensee has greatly

. improved the solid _radwaste solidification facilitie.

Con cl usi on The licensee's performance is rated Category 2 'in this are During the previous assessment period, the licensee's performance was rated Category.

Board Recommendation None.

• Maintenance Analysis*

Evaluation of this functional area was based.on the results of six routine and two special inspections conducted by NRC headquarters, regional, and resident inspector Enforcement history in this area showed improvement in licensee performance since the previous assessment pe~io No violations wereidentified compared with three violations (one Severity Level IV and two Severity Level V) identified in the area of

.maintenance during the previous SALP period. Additionally, some improvements were demonstrated in the area of personnel errors; 4 were identified during this assessment period compared with 18 during the previous assessment perio Although only 4 of the total 24 personnel errors at the station were attributable to the Maintenance Department, 2 of these re~ulted*tn ~~actor scrams.~*

Although no violations of NRC requirements were identified during this assessment period, weaknesses were identified by both the DET and the Region III task. force reviews of equipment performanc These weaknesses included the lack. of a systematic and comprehensive preventive maintenance program (particularly of motor-operated valves); the root cau~e and failure analysis of the component/equipment failures trending program needs

_

improvement so that it will include similar component failures; -

the lubrication and oil analysis trending program needs to be upgraded; and the maintenance staff was insufficient during mid SALP to adequately perform all department function Operational events attributable to th1s area indicated weaknesses in the licensee's preventive maintenance program as evidenced by the failures associated with balance-of-plant (BOP) event BOP events that ~ccurred during this assessment period included the loss of all three shutdown cooling pu~ps at Unit 3 (as previously noted in the SALP 6 report), failure of the 2A feedwater regulating valve stem resulting in a reactor scram, failure of the JC condensate booster pump motor resulting in a reactor scram, and malfunctions of the 3A feedwater regulating valve that resulted in two reactor scram The trending*of LERs also revealed that the high pressure coolant injection (HPCI) system was inoperable at least sh times during this assessment period as a result of equipment degradation, historically recurring problems, and insufficient preventive maintenance activities. These technical issues generally were approached from a conservative safety standpoint as evidenced by the licensee's selection of the HPCI system as the first model system and its improvement of the BOP preventive maintenance progra The program is being designed to anticipate and prevent BOP equipment failure and degradation by enhancing the trending of equipment performanc The need for programmatic improvements in the maintenance area was further heightened as a result of a CECo maintenance self-assessment and other maintenance reviews conducted during this SALP period. These assessments were indications of an increasing involvement by management to improve the qualtty of the maintenance program Following these reviews and evaluations, the licensee developed a comprehensive maintenance improvement program in response to the deficiencies identified fro~ these evaluation The maintenance improvement program includes strengthening of the maintenance staff and management organization, general upgrading of maintenance procedures, overhaul and lubrication of motor-operated valves to ensure operability, development of a trending program for use in predictive maintenance, development of a lubrication and oil analysis trending program,. and development of a post-maintenance testing progra Results of these recent improvement initiatives have not been completely evaluated for their effectiveness in improving equipment reliability because most were just being developed or implemented toward the end of thi~ SALP period,.

however, initial indications have shown a reduction in equipment out of servic Staffing in the maintenance area has been improved by the strengthening of the management organization responsible for maintenance activities. This was accomplished by transferring the Assistant Superintendent of Maintenance at Quad Cites to

. this position at Dresden and by the creation of new position within the maintenance organization. These positions -.

Maintenance Improvement Coordinator, Preventive Maintenance Coordinator, and the Motor Operator Valve Coordinator - were designed to enhance specific elements of the maintenance organizatio In addition, the staff was also increased to provide support for the various elements of the maintenance improvement program by the addition of two writers of procedures and seven work analysts. The Technical Staff system-engineer concept also was implemented to provide additional support to the maintenance improvement effort and enhance the monitoring of system performance and the effectiveness of preventive maintenanc Management's involvement in ensu.ring quality in this functional area was demonstrated by the strengthening of the maintenance

.management organization with the staffing changes denoted in the previous paragraph Additionally, three new Maintenance Department heads wer~ assigned during this assessment perio The new master mechanic and master instrument mechanic were transferred from other Dresden departments*, and the new master electrician was ~reviously the ~aster instrument mechani These management chang~s were well.received by the technicians..

Management was responsive to NRC initiatives and concerns during this SALP period as evidenced by the development of a maintenance improvement program establish~d to develop action

• plans, schedules, tracking ~nd assessment methods, and progress rep~rts to monitor corrective, preventive, and predictive maintenanc However, as noted in the SALP 6 cover letter and DET observations, considerable NRC and licensee attention was necessary in this area. Additionally, during this assessment period, management developed a model system concep The licensee evaluated model space concepts 1n use at several other facilities and INPO guidance and adopted a program that would incorporate all of the plant and system improvement programs into a single model system concep The concept is planned to be fully implemented on the high pressure coolant injection (HPCI) system late in the SALP 8 period. The HPCI system was selected as the model system because of its historical problems and safety significanc The concept will include incorporating a comprehensive preventive maintenance program for all equipment in the system, a complete upgrading of maintenance procedures associated with the HPCI system, upgrading of component labeling, and a complete up-grading of the appearance of and lighting in the area where the HPCI system is located. The concept also provides for implementing the various elements of the program in the enti.re station. These efforts will provide a mechanism to upgrade a 11 improvement programs, s*uch as the station modification program, by implementing, revising, and evaluating the programs against the performance of the HPCI mJdel syste The licensee's response to NRC initiatives was further demonstrated by the following corrective actions: refurbishment of the reactor feed pumps (four of the six pumps were refurbished during the assessment period and a fifth after the end of the period), cleaning of the condensate storage tanks, construction of a new makeup demineralizer, replacement of 20 control rod drive hydraulic control unit accumulators (resulting in a decrease in control room alarms), development of an overhaul and inspection program for all safety-related valve operators, and development of a preventive maintenance program for the 4-kV switchgear. These programs are expected to enhance equipment reliability and improve overall plant performanc Some improvement initiatives, such as refurbishment of the reactor feed pump, replacement/repair of the shutdown cooling pump motors, upgrading of the feedwater regulating valve operator, modification of the main steamline low pressure switch vibration isolator, and modification of isolation condenser logic, have resulted in the resolution of some longstanding Dresden problems, and improved plant performance during the last 3 months of this assessment perio These actions helped reduce LERs to a rate of 2.5 per month for the last 3 months compared with the 1987 monthly average of 4. 4, and contr1 buted to the cont 1 nuo.us dual-unit operation for over 100 days at the end of the assessment perio.

Conclusion The licensee's performance was rated Category 2 3* in this are During the previous assessment period, the licensee's performance was rated a Category.

Board Recommendation While the SALP 6 rating was a 2, as noted 1n the regional administrator's cover letter, that rating may have been too hig The Board believes there has been substantial improvement in maintenance, however, because of the magnitude and scope of the problems and resultant improvement programs, continued NRC and licensee attention is warrante Surveillance Analysis Evaluation of this functional area was based on the results of four inspections conducted by regional inspectors and observations by the resident inspectors. During these inspections, the inspectors examined inservice inspections, snubber functional t~sts, the containment integrated leak rate test, and the li cense.e 1 s responses to Generic Letter 84-11 and Information Notice 86-10 *

Rating changed by the Regional Administrator to a Category 3 with an improving trend

Enforcement history in this functional area is considered to be good* in that no violations were identified during this assessment period or the previous assessment perio One potential violation was identified during this assessment period pertaining to missed Appendix J surveillance In addition, one deviation from a commitment was issued during this perio Generally, the licensee's performance showed continued significant improvement compared with the performance during the SALP S period when six violati~ns were identified; The licensee issued eight LERs related to the implementation of the surveillance progra Of these, seven were attributable to personnel error during the performance of surveillance **

testing. One LER was issued because of a procedural deficienc The personnel errors appeared to be unrelated, had no major safety significance, and were* adequately addresse The procedural deficiency was corrected in a timely manner, thereby preventing other occurrence Two of the personnel errors and the procedural deficiency resulted in missed surveillances (three during the SALP 6 period). Although the number of LERs and personnel errors has decreased as compared with the number during the SALP 6 period, the number of surveillance related events indicates that further improvements are still warrante The lice~see responded adequately to technical issues and NRC initiatives. The licensee's actions in response to IE

. Informati6n Notice 86-106 and Generic Letter 84-11 were timely and thoroug The licensee's resolution of technical issues routinely exhibited adequate conservatis In most cases, the approaches were technically sound and sufficiently thoroug Piping and thickness measurements made before the issuance o the response to the information notice pertaining to the pipe wall thinning issue demonstrated overall concern for plant safet Management's involvement in this functional area was adequate and indicated a general improving tren Management demonstrated gqod planning and established appropriate priorities for the inservice inspection activities and snubber functional test progra However, some improvements are still warranted in regard to the containment integrated leak rate testing, specifically the data acquisition equipment~

Staffing in this area was adequat None of the operating events, including missed surveillances, were the result of inadequate staffing. Personnel functions, responsibilities, and authorities were clearly specified and implemente Utilization of outside consultants was at the appropriate level with proper oversigh.

Conclusions The licensee's performance is rated Category 2 in this are During the previous assessment period, the licensee's performance was rated Category 2 overal.

Board Recommendations Non FIRE PROTECTION/HOUSEKEEPING Analysis Evaluation of this functional area was based on the results of routine inspections by resident inspectors and site visits by th* project manager:

In ~ddition, the evaluation was primarily directed at housekeeping practice During this assessment period, the licensee initiated and implemented four improvement programs; reduced combustible debris in the general access area, reduced contaminated areas in the whole plant, improved the appearance of the turbine and reactor buildings, and removed all outside storage of radioactive waste material. All four-programs were determined_

to be successful, producing noteworthy improvements in the overall plant appearanc A particularly notable change was the cleanliness of the crib hous On the first visit, by the licensing project manager, it was not acceptable, but, by the second visit, it had been completely cleaned and painte.

Conclusion The licensee was not rated in this area because of an incomplete assessment of all of the elements within this are However, improvements were noted in the general housekeeping practices. During the previous assessment period, the licensee's performance was rated Category 3.

. Board Recommendation The Board recommends that the NRC staff assure prompt issuance of the Fire Protection SER and perform subsequent inspections to assess licensee performanc~ in this are~. Emergency Preparedness Analysis Evaluation of this functional area was based on three inspections conducted by regional inspectors, two routine resident inspections, and observation of an exercis is

Enforcement history declined slightly during this perio One Severity Level IV violation was identified, compared with none during the previous assessment period. The violation resulted from the untimely filing of controlled documents at the

. Emergency Operations Facility. The licensee's corrective actions were effectiv Management's involvement in ensuring quality has generally been goo Several audits and multiple surveillances were thorough and well documente Periodic drills, communications tests, and supply inventories were completed on schedule and ade~uately documente Tracking systems were effectively used to track progress on NRC and self-identified items. The overall performance during the 1987 exercise was an improvement compared with that during the previous exercise. Corrective actions for four items identified during the last exercise were satisfactorily demonstrated; only one item requiring corrective action was

• identified during.the 1987 exercise.. However, exercise performance still demonstrated the need for improved logkeeping in th~ c~ntrol room and ~ore consistent use of contamination and exposure control provisions for in-plant team The licensee's approach to resolving technical 1ssues from a safety standpoint improved during the period, as evidenced by *

the adequate correction of four procedural and training program discrepancies identified by the inspectors during a routine inspection. Corrective actions were completed by the end of the inspection. A relatively longstanding issue has been the licensee's failure to revise an emergency action level (EAL)

to better ensure timely notification of the NRC and the State agencies in the event of a significant onsite fire. The licensee planned to submit a substantially revised set of EALs in the Spring of 1988 and indicated that this regulatory concern would be adequately addres.sed by the upgraded EAL *

Through September of this assessment period, the licensee correctly classified and promptly notified NRC and State officials of all classifiable emergencies. The emergency planning coordinator's evaluations of these emergency declarations became more thorough during the assessment perio Provisions for staffing the onsite emergency organization remained adequat Revisions of callout procedures were issued in a timely manne The capability to augment onshift personnel with emergency responders was satisfactorily demonstrated through quar~erly off-hour drills. Late in the assessment period, management quickly appointed a qualified individual as interim emergency planning coordinator because the current coordinator needed a lengthy recovery from an illnes The onsite emergency preparedness training program was adequately defined and consisted of approved training modules, reading of relevant procedures, and examination On the basis of walkthroughs, records review, and overall exercise performance, it was determined that the onsite emergency organization has been adequately traine.

Conclusion The licensee's performance is rated Category 2 and improving in this area. The licensee's performance was rated Category 2 for the last assessment perio The capabilities of the emergency organization have impro~ed, as evid~nt from trainihg program refinements and improved exercise performance since 198 Adequate resolution of technical issues has generally become more timel.

Board Recommendation None Security An a 1 y s i s.

Evaluation of this functional area ~as based on the results of three routine and three reactive inspections conducted by regional physical security inspectors and the inspections conducted by the resident inspectors to routinely observe security activities.

. Enforcement history represented a slight reduction in the licensee's performanc Three violations were noted in this functional area:

two Severity Level IV violations and one Severity Level III violation that was noted early in the assessment period, for which a civil penalty was assesse This last violation has existed since the plant was constructed and, because of the location where it occurred, was not identified previously by the licensee or the NR This violation did not represent a significant program breakdown but did represent a specific security breakdow During the previous assessment period, four Severity Level IV violations were note Corporate support of the Security Department continues to be effective. The corporate Nuclear Security Administrator actively participates in resolving issues and maintains close liaison with site security managemen The licensee's staffing levels amply fulfilled security plan commitment Positions and responsibilities.were well defined. Training policies and procedures ensured that all personnel were well trained and qualified to perform assigned security-related tasks or dutie Administrative.support for licensing issues was timely and technically correct. Effective communications were maintained with the NR Effectiveness of training and qualification of the security force are acceptable. Procedural guidance 1s generally adequate, and day-to-day supervision of the security force performance is.

adequate. Maintenance of security equipment has been generally -

effective and acceptabl The licensee's quality assurance security audits were very basic and repetitive. They generally consisted of only a paperwork review that verified only that system components existe They did not verify the functional adequacy of the security program, which management could have used to identify potential problems and solution *

Licensee security event reports (SERs) reported under 10 CFR 73.7l(c) were significantly reduce During this assessment period, 8 SERs were submitted compared with 12 SERs submitted during the previous assessment perio Seven of the SERs were equipment related, and one SER pertained to equipment tamperin None of the SERs were of a repetitive natur The reports were submitted in a timely manner and corrective actions were

• effective and technically sound..

The licensee's response to NRC initiatives was goo When concerns were identified, corrective actions were taken *in a prompt and effective manne The licensee's review of I Information Notice 86-91 (Limiting Access Authorization) was acceptabl * Conclusion The licensee's performance is rated Category 2 in this are During the previous assessment period, the licensee's performance was rated Category.

Board Recommendations None Outages Analysis This functional area is limited to refueling and reactive activities in the area of outages. Modifications are addressed in the Engineering/Technical Support section. This area's

.

evaluation was based on limited inspections conducted by resident inspectors and one limited regional inspection to evaluate core performance testing during the last three months of the Unit 2

. refueling* outag Because of this 'limited-assessment, the*

overall evaluation of this functional area 1s determined to be incomplet The enforcement history in this area showed an improvement in licensee performance since the previous assessment perio During tnis assessment period~ no violations or deviations were identified, which represents licensee performance that conforms to NRC regulations. During the previous assessment period numerous violations were identified in this functional area by Safety Systems Outage Modification Inspection (SSOMI) on Unit 3 and were pending escalated enforcement action. Results of the escalated enforcement SSOMI findings are discussed under the Quality Programs and Administrative Controls section of this SALP report. *

Operational events associated with the Unit 2 refueling outage, although not resulting in violations, indicate improvements are needed in this area to obtain more effective outage modification planning and execution organization.* The Unit 2 refueling outage was initially scheduled to be accomplished in approximately 110 days; however, because of several problems experienced during the outage, the actual duration was 154 day These problems were mostly attributed to slower than expected progress with plant outage modifications in addition to drywell cheek plate repair Staffing* in the outage/planning area has been increased during this asse~sment period. During the previous assessment period the planning organization consisted of three individuals; an Assistant Superintendent-Planning and two work analysts. During this assessment period four additional work analysts were added to the planning organizatio The staffing level was increased to support the larger work scope being given the planning group, which included upgrading the surveillance program and tracking of unscheduled outage items to be worked during short unexpected outage Pending outage related work requests at the end of the assessment period were 105.

Conclusion The licensee's *performance was not rated because of an incomplete assessment of all of the elements within this are During the previous assessment period, the licensee's performance was rated Category.

Board Recommendation None 19 Quality Programs and Administrative Controls Affecting Quality Analysis The evaluation of this area addresses two related but separate function First, it involves the assessment of the licensee's management activities aimed at achieving quality in overall plant activitie This assessment, in great measure, is a reflection of the quality of licensee activities in individual functional areas addressed in other sections of this repor Second, it involves the assessment of the licensee's internal, independent quality oversight activities such as those performed

. by the quality control/assurance organizations..

Evaluation of this second attribute was based on three.

inspections by regional inspector The areas examined during those three inspections primarily included followup evaluations of 43 previous findings identified from 1984 through 198 The findings were in the broad areas of modifications, procurement, and maintenance,.and included -training, work controls, corrective action, and. quality verification. During the followup evaluations, 42 of the 43 inspection findings were closed and no safety issues or violations were identifie Enforcement history in this area improve The t)ilo violations (one Severity Level III and one Severity Level V) that were issued during this assessment were identified as potential violations subject to enforcement action in the SALP 6 report as a result of the SSOMI finding No violations were identified in this area during this assessment period. Dµring the previous assessment period (SALP 6), two Severity Level V violations were issue With respect to management's general effectiveness in achieving quality in facility operation, an improvement trend was established during the last 4 months of this assessment period. This trend was exhibited by a significant reduction in reactor scrams (no scrams occurred during the last 3 months of the period compared with the 1987 quarterly rate of 3.7 scrams), only 4 personnel errors occurred in the last

.quarter of 1987, compared with the 1987 quarterly average of 6.6, an overall reduction of personnel errors from 56 in 1986 to 24 in 1987, reduction of personnel contaminations to 65 during the last 3 months compared with the 1987 quarterly average of 267, and the 101 days of continuous dual-unit operation compared with 76 days in 1978 - the best that had been ~reviously achieved at Dresde All of these trends have continued into the first quarter of the SALP 8 perio The overall reduction of personnel errors is an example of the licensee's response to NRC i~itiatives, i~ that the SALP 6 ~eport"identified personnel

errors as a significant weakness warranting management involvement. This improvement is also 1n large measure due to the 11 censee' s effort to deve 1 op persona 1 accountabi 11ty for personnel error Effective management involvement was also evident in the improvement of the appearance of the plant, both inside and outside the reactor and turbine buildings. A significant effort*

was noted in the upgrading of hQusekeeping and area maintenanc The licensee implemented several program enhancements during the assessment period to improve the overall performance in this functional area. Management appeared to be more involved in ensuring quality than during the previous assessment perio Management support for quality assurance (QA) and quality control (QC) activities improved and there was increased cooperation with crafts personnel. There was a marked improvement in the use of QC and QA hold points in maintenance and modification procedures, work travelers, QC checklists and maintenance work requests; QC inspection of cleanliness and open systems was apparen Inclusion of hold points increased from a total of 25 in 1986 to 84 by July 1987. Other indications of increased management involvement included the writing of discrepancy reports during installations, increased QA surveillance of work in progress, and field verification of facility change requests. Discrepancy reports.written by QC staff increased from 5 of 96 in 1985 to 17 of 87 by July 198 A significant and effective aid to improve managemen oversight of station activities was the Dresden Station Weekly Repor This report included information about trends in reactor scrams, deviation reports, personnel contamination, and personnel errors. This report helped to enhance management effectiveness in taking corrective action that reduced errors caused by maintenance personnel. It was noted that maintenance personnel were personally held accountable for errors and there was a significant downward trend in errors caused by maintenance crafts person A weakness was identified in the area of trend analysis of maintenance activities, relating to the inability of current computer software to identify failure of specific equipment types common to several plant systems, although a.manual method could be use The approach used by the licensee to resolve technical issues from a safety standpoint was generally conservative and technically sound. *This was evident in most of the resolutions of the 42 items reviewed during the three inspections, which included several procurement-related problems dating back to 198 Procedures 1n that area were revised to improve methods for purchasing and dedicating materials and parts designated as

commercial grad Problems fn the area of modifications, such as misclassification of equipment, control of drawings, and misapplication of administrative controls, were aggressively corrected by the license The licensee, in most cases, aggressively responded to problems and weaknesses identified by the inspectors, especially during the followup inspections of modifications in mid 1987, and procurement in late 198 No specific strength or weakness in regard to QA training was noted; however, selection and training of first-line supervisory personnel needed improvement, especially in regard to quality consciousness and awareness of administrative controls that affect safety and quality. Early in the assessment period, the licensee established a task force to review supervisory training programs for possible improvemen Results are inconclusive to dat Staffing in the quality assurance organization was found to be adequat The Quality Assurance Department increased its commitment to oversee the day-to-day plant operations during the last*3 months of the assessment period. This includes daily observation and ev~luation of control room acti~ities (including backshift modifications) and examinatton of operating logs, records, and other pertinent document One QA auditor currently maintaining a senior reactor operator (SRO) license and two other auditors currentl~.in licensed operator tratning.strengthen the technical credibility of this effort. To increase its effectiveness, the Quality Assurance Department has increased the amount of effective auditing by reviewing the effectiveness of the various improvement programs, instead of following the traditional practice of reviewing the compliance of activities with the program The licensee's response to NRC initiatives improved significantly during this assessment period as exhibited by the implementation of many varied improvement program However, the DET found that, although many of the.improvement programs were resulting in noted improving trends, some of the programs were not achieving the expected results and separate programs were not integrated into an overall plant improvement pla In response to the DET concern, the licensee created a new management position, Programs Improvement Superintendent, to develop and monitor the overall integrated station improv~ment plan.. The ~lan incorporates specific performance indicators and action requirements into the various program During the last 3 months of the assessment period, overall plant performance indicated that the initial implementation of the integrated plan was effectiv.

Conclusion The licensee's performance was rated Category 2 in this are During the previous assessment period, the licensee's performance was rated Category.

Board Recommendations None J. * Engineering/Technical Support Analysis*

Thi~ is a new functional area which was not rated in previous SALP Evaluation of this functional area was based on the results of three inspections conducted by regional inspectors and technical reviewers from headquarters, and the review of several modificat~ons by both resident and regional inspector Additionally, a diagnostic evaluation team (DET) reviewed the inservice testing (IST) program for motor-operated valve Analysis of this functional area included special inspections, one involving the licensee's response to IE Bulletin 85-03 (motor operated valves), and the other involving anticipated transient without scram (ATWS) mitigation systems. Also included in these inspections was a review of the licensee's actions resulting from design and/or construction discrepancies in regard to drywell structural steel connections, embedment plate anchor straps, and the piping portion of the Mark I modification progra The first two discrepancies stemmed from deficiencies during original construction. The third *

discrepancy originated from an extensive modification effor During this assessment period, several modifications were reviewed and assessed by the NRC staff. The first pertained to the recurring phenomenon of control rod drives (CROs) failing to fully insert following a reactor scra During the Unit 2 outage, the licensee installed 12 new BWR/6 drive mechanisms, which have performed acceptabl A second modification pertained to the installation of a digital feedwater control system to replace the original analog control syste During the review of the Unit 3 feedwater transients on July 11 and August 7, 1987, it was determined that the digitaJ control system had been an effective modification that provided more accurate control to the operato *

Additionally, a third modification resulted from analysis of the Unit 3 feedwater transients which showed that the transients were primarily the result of hydraulic forces across the feedwater regulating valve (FRV) plu The licen~ee modified the FRVs by installing hydraulic damping pneumatic controlrers

to alleviate the internal hydraulic force The licensee also developed and conducted an effective post modification testing effor Additionally, the resident inspectors observed several other modifications, including the vibration mounting of the main steamline ~ress~re switches, the isolation condense~ isolation.

circuitry, and the new rod worth minimizer (RWM).

Each of these modifications resolved historical problems and have increased reliabilit *

The licensee's response to technical issues improved during this assessment period, as demonstrated by the resolution of historical problems pertaining to the high pressure coolant injection system and main steamline design deficiencies, and the installation of the digital feedwater control system Although the previously noted modifications indicated effective management involvement to resolve.historical problems and an improvement in the effectiveness of the modification program, a complete assessment of the overall program has not been performed. Significant weaknesses in the modification program had been identified by the Safety Systems Outage Modification inspectfon (SSOMI) conducted during the SALP 6 perio The licensee has made various corrections as a result of these identified weaknesse However, not all of these corrections were verified during this assessmen Enforcement history in this area indicated two violations.*

As a result of the three previously described discrepant areas, embedment plate anchor straps, drywell steel connections, and the Mark I modification program, two Severity Level IV violations were issued for inadequate design control and for f~ilure to

• *accomplish work in accordance with the specified drawing The multiple examples of minor discrepancies indicate that a minor programmatic breakdown may have occurre The subsequent corrective action programs were promptly implemented and were comprehensiv Management's involvement in these structural areas was considered to be good once the problems were identified. After the discovery of the initial discrepancies in the above areas, management was closely involved in the subsequent investigation and corrective action program All three programs were carefully conceptualized to determine the overall extent and significance of any further discrepancies. Well-defined

_procedures with coordinated priorities were established to control all of the subsequent activities. Corporate management was highly involved in the site activities, and decisions were made at a level that allowed effective management review The programs were established in an expeditious manner with thorough and technically sound reviews being performed. Corrective actions to preclude future recurrences recognized the root cause_

of the problems and reinforced the previously implemented as-built inspection progra Several concerns were raised during the special inspections of the licensee's actions in regard to IE Bulletin BS-03 and the ATWS mitigation systems involving an apparently inadequate program for handling valve switch ~ettings and insufficient procedures concerning the reliability of motor-operated valves (MOVs).

These findings were also addressed by the DE The licensee is currently addressing these discrepancies and is revising the inservice testing and inservice inspection program In regard to the embedment plate, drywell structural steel connections, and the Mark I modification program, the licensee demonstrated a clear understanding of the underlying issue Regarding the drywell structural steel connections, the overall extent of the problem was not recognized initially. However, once the problem was recognized, it was thoroughly resolved by additional actions of the license The resolution of each issue was technically sound and exhibited adequate conservatism Although two of the programs are not complete, measures were expeditiously taken and adequate progress has been made considering the extensive nature of the program The licensee's ~esponse to NRC initiatives was generally adequate, although the licensee's initial response to IE Bulleti~ SS-03 was iftadequate.because the licensee failed to provide all requested informatio The licensee resolved this deficiency after this assessment perio The above construction-related discrepancies were all reported in a timely manner and the information provided was basically *

complete and accurat Because of the extensive nature of the corrective action programs, updated reports and additional information have been submitte The reports have properly analyzed the associated events. Additionally, two events involving the failure of MOVs during surveillance testing were accurately identified and corrected in a timely manne Further analysis was conducted to prevent recurrence of these and associated problem The engineering support staff at the station appeared to be competent and adequately knowledgeable of plant activities..

The licensee, however, continues to rely almost exclusively on outside consultants to provide the technical expertise needed for every aspect of design and analysi If stronger technical oversite of the consultants activities is not provided by the licensee, other programs similar to the Mark I piping configuration verification program could be the outcom A system-engineering concept was implemented toward the end of,'

the assessment perio.

Conclusions The licensee's performance is rated Category 2 in this area. lecause this is a new area, no rating is available for the previous assessment perio S

..

Board Recommendations None Licensing Activities Analysis This evaluation represents the integrated inputs of the licensing project manager (LPM) *nd the technical review groups that expended a significant amount of effort on Dresden licensing actions during the rating perio The basis of 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 rating period. _These actions, consisting of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, included the following specific items:

0

0

0

0

0-0 Dresden 2 Integrated Plant Safety Analysis Report (IPSAR),

Revision 1

inservice testing (IST), second '10-year period 10 CFR 50, Appendix R exemptions alternate safe shutdown exemptions administrative Technical Specification (TS) changes pipe configuration verification program flued head anchor and support review 4-kV crosstie TS changes diesel generator reliability TS changes embedment plate review Dresden 2 reload TS changes Nine open-multiplant actions are associated with both Dresden unit Of these nine items, two (A-19 and A-20) are being

_ reviewed by the Boiling Water Reactor Owners Grou The remaining seven are being reviewed by_ the NRR staf The Appendix R review of additional modifications and exemptions was brought about by the licensee's review based on additional NRC guidanc One additional submittal was required of the 1~cense~ for NRR to complete the staff revie~.

Management's involvement to ensure quality was mixed during the assessment period but showed improvement during the last 3 month The major licensing activities for the SALP period were the additional modifications and exemptions in regard to Appendix R, the Unit 2 reload TS changes, and the IPSAR supplement. During these activities, there was evidence of prior planning and assignment of priorities. The additional Appendix R modifications and exemptions were example Responses to the 1983 IPSAR languished during the previous SALP period, but they were made a high priority in this perio Corporate management was usually involved in site activities which was more evident later in the SALP perio The quality control of TS requests associated with the Unit 2 reload amendment was marginal during the first quarter of the assessment perio The licensee implemented a TS improvement program during the last quarter of the assessment period to increase the quality of the TS request The licensee's approach to resolving technical issues from a safety standpoint was generally conservative and technically soun The licensee's understanding of the issues was generally apparent and the responses were viable, generally $OUnd, and thorough: Conservatism was routinely exhibited when the potential for safety significance existed. Resolutions were generally timely. This was evident in the responses in regard to Appendix R exemptions and the IPSA Generally, the licensee's response to NRC initiatives was good, as exhibited by its timely responses to major NRC concerns and initiatives associated with the IPSAR, Appendix R, and other.

issues. Acceptable resolutions were generally propose In general, staffing was adequate with the exception of the

_ double assignment (Quad Cities and Dr~sden) of the Nuclear Licensing Administrator for Dresden during most -of the SALP period. Although no major issues were significantly delayed, overload was evidenced in other ways, such as slower response to lesser items and the lower quality of the Unit 2 reload TS request. This was corrected late in the SALP perio Additionally, the licensing staff was increased toward the end of the assessment period to improve support and the overall performance in this functional area~ Conclusion The licensee's performance was rated Category 2 in this are During the previous assessment period, the licensee's performance was rated Category The drop is due to slow response to issues (e.g. alternate safe shutdown), technical specification problems, and, in general, the apparent excessive workload of the Nuclear Licensing Administrator. A correction has been made, by the licensee~ l~te in the SALP period, however, not in time to affect SALP.

Board Recommendation None Training and Qualification Effectiveness Analysis Evaluation of this functional area was based on a training effect~veness inspection; inservice testing and snubber testin inspections, emergency preparedness inspections, observations by the resident inspectors, DET observations, and the results of licensed operator replacement and requalification examinations administered by the NRC during the assessment period. This functional area covers all aspects of the licensee's training program, including initial and requalification training of licensed-operators, training of nonlicensed maintenance, radiological, and chemistry personnel; emergency preparedness; station fire protection; and nuclear general education t~ainin Although the enforcement history does not indicate any violations of NRC requirements relativ~ to training, several significant deficiencies were identified relative to the licensee's ttaining program during the the assessment peri_o Poor performance on the part of senior reactor operators and reactor operators during the January 1987 NRC-administered requalification examinations indicated significant weakness in the licensed-operator requalification training program (this area was discussed in SALP 6). Several of the identified weaknesses, including failure to use procedures during the simulator examination have been corrected, or improvement has been noted.. However, the NRC Diagnostic Evaluation Team (DET), August 1987, concluded that overall training was weak and that the requalification program represented the weakest portion of the progra The DET also noted that as a result of the upgrade program, conducted in response to the poor performance on the requalification examinations, the problems regarding the requalification of licensed operators were being addressed. Additionally, the team observed that improvements were being adequately implemented in the control roo Other observations during this assessment indicated that training was adequate or improving in emergency preparedness, security, and radiological protection. Additionally, the resident inspectors observed that the lessons-learned training pertaining to personnel errors signifi~antly improved the performance of all departments in reducing the number of personnel errors at Dresde *

Management's involvement in ensuring quality was mixed during the first half and sltghtly improving during the last quarter of the assessment period. Past training improvement initiatives have been largely a reaction to audit findings by the NRC and other As a result of the Confirmatory Action Letter (CAL)

in response to the January 1987 requalification examinations,*

short and long-term improvements in the licensed operator requalification program were initiated. In September 1987, the NRC reviewed the licensee's actions in response to the CAL and found them to be adequat As noted above, the DET also observed the implementation of these improvements in the control roo However, in October 1987, an additional NRC review resulted in an unresolved concern pertaining to lack of mandatory attendance during specific training cycles, which is inconsistent with the present requirements of 10 CFR 55.59.a. Additionally, the licensee's program made a distinction between the training requirements for on-shift and administrative licensed operators which is inconsistent with 10 CFR 5 Another identified weakness pertained to the general station weakness of maintaining approved procedures current with the requirements. Although the requirements of 10 CFR SS were changed in early 1987, not all of the licensee's administrative procedures were corrected to reflect these requirement After the assessment period, these deficiencies were addresse The licensee removed the distinction of separating onshift license holders from administrative holders by requiring mandatory attendance of all license holders during all eight cycles. Currently, the licensee is developing a contingency program to ensure full attend~nce in cases of ~raining that was missed because of plant operating conditions or student illness/emergencies. Another weakness pertained to the operating experience of the training staff. During the asse~sment period, in response to this deficiency, the licensee made the following changes:

two experienced nuclear station operators and a shift engineer were added to the training staff and one member of the training staff was placed on shift for 1 year to gain Dresden-specific operating experience. After the assessment period, another member of the training staff, who does not have previous Dresden operating experience, w111 also be placed on shift for l year to acquire operating experienc Additionally, in an attempt to 1mprove the overall quality of training, management has implemented or 1s in the process of implementing the following:

an increase in the total training staff, an increase in the number of experienced licensed operators on the training staff, separate training for licensed and nonlicensed personnel, development of a crew concept.

(a shift crew of operators and supervisors) for simulator training, and increased simulator training from 4 to 10 day The training improvements contributed to improved Operator response to events as demonstrated by the following example Because of the lessons-learned training on the July 11, 1987 fe~dwater transient at Unit 3, the operating crew avoided a vessel low level condition and a subsequent automatic scram on August 7, 1987, during the second feedwater transien In addition, the shift engineer's decision to have the unit manually scrammed because of leaks in the feedwater and high pressure

• coolant injection system was attributed to the lessons-learned training process. Another indication of improved lessons-learned training was demonstrated by the unit operator taking action to manually scram Unit 3 before (or not relying on) the automatic scram function when a condenser hotwell leak resulted in a loss.

of vacuu The passing of the initial license examinations in Octobe~ 1987; by eight of nine senior reactor operators also demonstrated the effectiveness of the improvement Although the overall performance of the statiOn has demonstrated improvements, weaknesses still exist in classroom trainin These include the need for improving (a) the learning objecti¥es by in.dicating the standard of performance expected of the students; (b) the effectiveness of routine quizzes; and (c) the quality of the instructor.

Conclusion The licensee's performance was rated Category 2 1n this area. *

During the previous assessment period, the licensee's performance was rated Category.

Board Recommendation None

', SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 2 At the beginning of this assessment period, Dresden Unit 2

.was still experiencing its 10th refueling outage which began on November 29, 198 Major outage activities included local lea.le. rate tests, torus cleaning, normal pump(s) and valve(s)

maintenance, and fuel loadin The reactor was made critical and ~as synchronized to the grid, thus ending the refueling outage on May 7, 198 Toward the end of the assessment period, the licensee achieved a new site record of 101 days of continuous dual-unit operation. Major activities or significant outages *

that occurred during the assessment period are summarized below:

Major Activities/Significant Outages November 29, 1986 - May 7, 1987 - Unit 2 was in its 10th scheduled refueling outag July 17-20, 1987 - A scram on low reactor water level caused by feedwater regulator valve failure resulted 1n the shutdown of Unit The unit remained shut down so that the root cause of the 28 valve failure could be investigated and the necessary repairs could be mad August 5-6, 1987 - Unit 2 was shut down for a maintenance outag * August 21-27, 1987 - Unit 2 experienced feedwater regulator failure when a valve stem separated from the disc assembl The unit was shut down so that the 2A feedwater regulator valve stem and disc assembly could be replaced~* September 18-22, 1987 - A forced outage occurred at Unit 2 because of the failure of secondary containment leak rate

.tests. Both units were* shut down so that the leaking seals on the truck. bay door and secondary containment interloc door could be repaire Several possible leak.age paths were investigated before the required differential pressure was achieve October 4-5, 1987 - Unit 2 ~as shut down so that the torque switch on the 28 low pressure coolant injection suction valve motor could be replace October 20-21, 1987 -

Unit 2 scrammed from 100% power and remained shut down so that main steam leak tests could be performed, problems with the main steam isolation valve

. closures could.be investigated, and the installation of vibration dampers could be complete Unit 2 experienced 5 engineered safety features (ESF) actuations and 6 reactor scrams (4 scrams were at greater than or equal to 15% power, and 2 scrams were without rod motion). Only 1 reactor scram, and no ESF actuation resulted because of personnel error.

Unit 3 Dresden Unit 3 was on line and operating at normal power until the latter part of the assessment period when the licensee reduced power to perform intensive engineering investigations and repair its feedwater syste Toward the end of the assessment period, the licensee achieved a new site record of 101 days of continuous dual-unit operation.* Additionally, Unit 3 operated 125 days continuously toward the end of the

• assessment period. Major activities or significant outages that occurred during the assessment period are summarized below:

Major Activities/Significant Outages January 4-5, 1987 - Unit 3 was shut down so that an electrohydraulic control system oil leak could be repaire February 26, 1987 -

Unit 3 was shut down for a 4~da maintenance outage. Activities included repair and replacement of the recirculating pump, shutdown cooling water pump, and heat exchanger * March 1-13, 1987 - Unit 3 went off line so that the high pressure coolant injection auxiliary oil pump and an oil

.1 eak in the el ectrohydraul i c control *system could be repaire In addition, the licensee replaced certain torus area snubber April 9-21, 1987 -

Unit 3 was manually scrammed as a**

result of low main condenser vacuum and high condensate demineralizer inlet temperatur The unit remained shut do~n so that the actual tause~ of the condenser inleakage could be determine In addition, repairs were made to the turbine building oil drain lin May 12-14, 1987 - Unit 3 experienced a forced outage resulting from an automatic trip of the reactor feedwater pumps on low suction pres~ure due to an auto trip of the 3C condensate booster pump on instantaneous overcurren The unit remained shut down so that the problem could be investigate July 11-17, 1987 - Unit 3 experienced a forced outage*

resultitig from the failure of a 2A feedwater regulator valv The unit remained* shut down so the licensee could determine proper vibration set *points and evaluate the

.replacel!,lent of fe_edwate_r re_g_ulator valve I~vestigations

of the rack supports for main steam line pressure switches, inservice leak checks, feedw~ter regulator station snubber and pump vibration surveillances, and other corrective actions to upgrade the feedwater level control system were conducte August 7-September 4, 1987 - Unit 3 was shut down for intensive engineering investigations and repairs after the August 7, 1987, feedwater system transient even Major activities included nondestructive examinations of feedwater lines, replacement of feedwater regulator valve pneumatic diaphragm actuators, walkdowns of feedwater/

condensate system piping, repairs of damaged feedwater pipe supports, and vibration testin September S-11, 1987 - Unit 3's isolation condenser was declared inoperable after it isolated on a high condensate flow during a special test. The unit was shut down for repairs and the replacement of a leaking gland seal on the drain pum September 12-13, 1987 - Unit 3 was shut down so that the the pressure control valve could be repaired and scheduled ove~speed tests ~n the turbine/generator could be performe * September 18-23, 1987 - Unit 3 was shut down because of the failure of the secondary containment leak rate test The unit remained shut down so that additional secondary

• containment leak rate tests and repairs could be performe September 28-29, 1987 - Unit 3 experienced a scram resulting from spurious vibration on the main steam line pressur_e switche The unit remained shut down so that the causes of the spurious signals could be reviewed and the steam line flow switch, whtch caused the group I isolation, could be calibrate * October 4-S, 1987 - Unit 3 was shut down so that the torque switch on the 28 LPCI suction valve motor could be replaced and teste October 6-Sr 1987 - Unit 3 was shut down for post-modification testing of the feedwater system. Activities included the replacement of a preloaded hydraulic damper spring on the new pneumatic valve position operato Unit 3 experienced 6 ESF actuations and 9 reactor scrams (6 scrams wereat greater than or equal to 15% power, 1 scram was at less than 15% power, and 2 scrams were without rod motion).

Three reactors scrams were the result of personnel errors and two of these als~ were ESF actuation Inspection Activities Forty inspection reports were issued during this January through January 31. 1988 assessment period; however. two of these inspection reports were addressed in a previous SALP report (i.e.* Inspection Reports Nos. 237/860027. 249/86032 and 237/860029. and 249/860033).

Significant inspection activities are listed in Paragraph 2 of this section. "Special Inspection Summary.

11 Inspection Data Facility Name:

Dresden Unit:

Docket No.:

50-237 Inspection Report Nos.:

86027 through 86029. 87001 through 87013. 87015 through 87023. and 87026 through 8703 Facility Name:

Dresden Unit:

Docket No.:

50-249 Inspection Report Nos.:

86032 through 86034. 87001 through 87004. 87006 through 87010. 87012. 87013. 87015 through 87022. and 87024 through 8703 Table I Number of Violations in Each Severity Level*

UNIT 2 UNIT 3 COMMON Functional Areas III IV y

III IV v

III IV y

A. Plant Operations

1

B. Radiological Controls **

c. Maintenance D. Surveillance ***

E. Fire Protection F. Emergency Preparedness

G. Security

2 H. Outages I. Quality Prog. & Adm *

1*

Controls Affecting Quality J. Engineering/Technical Supt

K. Licensing Activities L. Training & Qualification Effectiveness TOTALS

1

s

• Indicates violations associated with the SSOMI findings as previously identified and discussed in SALP DE ** Two potential v'iolations were identified during the SALP period. enforcement action including severity level still pendin One potential violation was identified during the SALP period. enforcement action including severity level still pendin.

Special Inspection Summary A special augmented inspection team (AIT) inspection was conducted from August 7 through August 25, 1987, to review the circumstances surrounding the August 7, 1987, feedwater system transient and the reactor water cleanup system damage that occurred during the reactor shutdown (237/87029; 249/87028, PN-IIl-87~105). The annual emergency preparedness exercise was conducted during September 1-4, 1987 (237/87027; 249/87026). A special diagnostic evaluation team (DET) inspection was conducted from August 17 through August 28, 1987, to provide NRC senior management with additional information so that it could make an informed decision on the overall performance of the Dresden Nuclear Power Station (documented in a letter to CECo from V. Stello, Jr., Executive Director for Operations, NRC, dated November 25, 1987). A special task force review* of equipment performance was conducted from April 20 through May 7, 1987, to determine if systematic equipment problems existed that had been overlooked by the NRC or CECo (documented in a letter to CECo from C. E. Norelius, Director, Division of Reactor Prtijects, Region Ill, NRC, dated September*4, 1987). Investigation and Allegations Review Seven allegations were reported during this assessment period. Three of the seven allegations and four previously reported allegations were closed during this assessment period. Additionally, one of the seven was closed after the*the assessment perio Four allegations remained open at the end.of this assessment perio Escalated Enforcement Actions A Notice of a Severity Level III Violation and Proposed Imposition of a Civil Penalty in the amount of $25,000 was issued to the licensee on June 12, 1987. This action wa~ based on a violation relating to the protection area physical barrier and its uncontrolled access (Enforcement Case No. 87053).

• A Notice of a Severity Level III Violation and Proposed Imposition of Civil Penalty in the amount of $25,000 was issued to the licensee on April 24, 198 This action was based on a violation of NRC regulatory requirements that occurred when licensed operators failed to monitor the reactor water temperature for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, resulting in the reactor water temperature exceeding 212°F without the primary containment integrity being maintained as required (Inspection Report No. 237/87011, 249/87010, Enforcement Case No. EA-87049).

36 A Notice of a Severity Level 111 Violation and Proposed Imposition of Civil Penalty in the amount of $25,000 was issued to the licensee on May 22, 198 Thi~ action was based on a major weakness in the modification area identified during the safety systems outage modification inspection (SSOMI) during the SALP 6 period, including design control change, installation of equipment, procedures and instructions, QA/QC overview of modification activities, corrective action implementation, and control of testin The licensee paid the civil penalty on June 23, 1987 (Inspection Reports Nos. 249/86009, 249/86012, 237/86015, 249/86017, Enforcement Case No. EA-87026).

The violation was discussed in the SALP 6 report. The Severity Level III violation was issued during this SALP perio Two additional enforcement cases remained under NRC review at the end.

of the assessment period. These cases involve failure of employees to adhere to procedural requirements and the release of unmonitored radioactive liquid (237/87003, 249/87003), and an apparent violation of 10 CFR 50.36, which occurred when Unit 2 operated for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with the drywell suppression chamber differential pressure less than 1.00 psid and for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the commencement of de-inerting activities (237/87005).

No violations relating to these events were issued during this assessment perio * * Licensee Conferertces Held During Assessment Period January 9, 1987, Regional Office: A management meeting was held with licensee representatives to discuss the licensee's training program of operating licensing~ February 6, 1987., Regional Office:

An enforcement conference was held with licensee representatives to discuss the findings of inspectiQns relating to radiation and maintenance outage activities, which included the failure of two employees to adhere to procedural requirements, an unmonitored radioactive liquid release, and violations of limiting condition for operations (LCO) (237/87003; 249/87003). February 26, 1987, Regional Office:

An enforcement conference was held with licensee representatives to discuss concerns identified during the SSOMis conducted at Dresden Units 2 and 3 (237/86009, 249/86012). March 25, 1987, Site: A management meeting and Commissioner tout of the Dresden site was conducted with licensee representative..

April 2, 1987, Regional Office:

An enforcement conference was held with licensee representatives to discuss the enforcement options pertaining to an apparent violation of the licensee's sec_urity plan relating to the protection area physical barrie.

A~ri1* 3, 1987,. Regional Office: A management meeting was held with licensee representatives to discuss the piping problems and corrective actions taken at the Dresden facilit.

April 10, 1987, Regional Office:

An enforcement conference was held with licensee representatives to review and discuss the enforcement options pertaining to an apparent violation of the licensee's security plan relating to the protection area physical barrie.

May 29, 1987, R~gional Office: A management meeting was held with licensee representatives to discuss Dresden's performanc.

June 4, 1987, Regional Office:

An enforcement conference was held with licensee representatives to discuss Dresden's operating performance (see Section V.D.2 for details).

1 July 30, 1987, Headquarters: A management meeting was held with licensee representatives to discuss the screening criteria that were being utilized for Dresden'$ Mark I piping configuration verification progra.

August 18, 1987, Regional Office: A management meeting was held with licensee representatives to discuss the guidance the licensee had prepared to issue to its nuclear sta-tions regarding the proper interpretation of Technical Specification 3. (Standard Technical Specificatio~ 3.0.3).

1 August 19, 1987~ Regional Office: A management meeting wa~

held with licensee representatives to discuss the August 7, 1987, feedwater transient at Dresden Unit 3 and,the licensee's corrective actions in preparation for startu.

September 14, 1987, Regional Offic~~ A management meeting w~~

.conducted with licensee representatives to review flued head anchors at Dresden.*

14~ * September 23, 1987, Chicago, Illinois: A management meeting was held with licensee representatives and Region III staff for the diagnostic team inspection at Dresde The meeting was*

conduc~ed by representatives of the Office of Analysis and Evaluation of Operational Dat.

October 19, 1987, Regional Office: A management meeting was held with lice~see representatives to discuss the results of safety system functional inspections performed by the licensee and the licensee's proposal to verify modifications implemented before the program upgrade at Dresde * 1 October 23, 1987, Site: A Commissioner toured the Dresden facility and conducted a management *meeting with licensee representative. October 28, 1987, Headquarters: A management meeting was held with licensee representatives to discuss the licensee's program for improving regulatory performance at Dresde.

November 3, 1987, Regional Office: A management meeting was held with licensee representatives to discuss the environmental qualification of certain cables at the sit.

December 11, 1987, Regional Office: A management meeting was held with licensee representatives to discuss the feedwater testing program and other actions resulting from the August 7, 1987, feedwater transient at Unit zo*.

January 19, 1988, Regional Office:

An enforcement conference was held with licensee representatives to discuss the deinerting events of November 28-29, 1986, at Dresde. January 26, 1988, Regional Office: A management meeting was held with licensee representatives to discuss the role of the licensee's QA Departmen The purpose of the meeting was to

.delineate the NRC's expectations regarding quality and to review various licensee's initiatives in this are.

January 27, 1988, Dresden Station: A management meeting was held with licensee representatives to review the progress of the licensee's program to improve the performance and material condition of the Dresden station, as discussed in the December 17, 1987 Commi-ssion meeting on nuclear power plant performanc Confirmatory Action Letters (CALs)

Two CALs were issued during this assessment period and are summarized below: On March 17, 1987, a CAL was issued as a result of the 50%

failure rate on NRC requalification *examinations administered during the week of January 26, 198 The CAL detailed areas of concern including increasing the control room staffing requirements, suggested removal of the operators who failed the NRC requalification examinations, provided a brief outline of the licensee's short-term upgrade program, and requested that the licensee present a long-term improvement plan to the staff (CAL-RIII-87001, Amendment 1). On August 11, 1987, a CAL was issued relating to the feedwate system problems at Dresden Unit 3, on July 11, 1987, that led to a manual scram on August 7, 198 The CAL detailed a list of actions to be conducted by the licensee, which included determining the cause of the pipe breaks, monitoring systems during return-to-power operations, implementing corrective actions to repair all equipment damage, and conducting.thorough reviews and analyses of recurring feedwater system abnormalities (CAL-Rill-87-014).

39 A Review of Licensee Event Reports and 10 CFR 21 Reports Submitted by the Licensee CFR 21 Reports None Licensee Event Reports (LERs) Unit 2 Dresden Docket No.:

50-237 *

LER Nos.:

86029, 86030, 87001 through 8703 Thirty-seven LERs were issued during this assessment period for Unit Two of these documented events that had occurred during the last month of the SALP 6 perio Unit 3 Dresden Docket No.:

50-249 LER ~os.: 86022, 86025, 86026, and 87001 through 8701 Twenty-one LERs were issued during this SALP period for Unit 3. Three of these documented events that had occurred during the last month of the SALP 6 perio BASIC CAUSES Unit 2 Unit 3 Personnel Errors 27% ( 9)

24% ( 5)

Procedural Inadequacies 10% ( 4)

10% ( 2)

Equipment/Component 34% (13)

42% ( 9)

Design Discrepanci~s 16% ( 6)

14% ( 3)

• External 0% ( 0)

0% ( O)

Other 13% { 5}

10% { 2}

Totals 100% (37)

100% (21)

Collectively~ the licensee issued SS LERs during this assessment period; the following shows the basic causes and a comparison of these LERs with those issued during the SALP 6"period:

• BASIC CAUSES.

Personnel Errors Procedural Inadequacies Equipment/Component *

Design Discrepancies External Other

.. "Totals

SALP 6 56% (41)

13% ( 9)

7% ( 5)

3% ( 2)

0% ( 0)

21% 05)

100% (72)

SALP 7 24% (14)

10% (.6)

38% (22)

16% ( 9)

0% ( O)

12% { 7 % (58)

The frequency'of LER issuance during this 13-month assessment period was 4.4 LERs per month; this was a slight decrease of 0.4 LERs since the last SALP perio NOTE:

The information on LERs in Section V was derived from a review of LERs performed by NRC staff and may or may not completely coincide with the licensee's single proximate cause assignment In addition, the table 1s based on assigning one cause code frir each LER and may not correspond to the identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each even NRR Activities NRR/LICENSEE MEETINGS DATE Utility briefing on licensing issues May 14, 1987 Flued head anchor September 14, 1987 De-inerting Technical January 11, 1988 Specification Flued head anchor audit January 26-29, 1988 NRR/LICENSEE/REGION MEETINGS SALP 6 Board March 17, 1987 Management meeting to discuss May 29, 1987 Dresden performance Enforcement Conference on June 4, 1987 Environmental Qualification De-inert1ng Technical Specification August 18, 1987 Dresden 3 feedwater oscillation August 20, 1987 presentation by CECo

. Diagnostic evaluation team briefing September 23, 1987 SSFI discussion October 19, 1987 Dresden 3 feedwater oscillation December 11, 1987 testing results De-inerting Enforcement Conference January 19, 1988 NRR SITE VISITS/MEETINGS Fire protection April 6-7, 1987 General visit May 4-5, 1987 Crutchfield site visit June 17, 1987 Diagnostic evaluation team August 17, 1987 entrance Dresden 3 feedwater oscillation August 18, 1987

.site visit Fire protection October 26-27, 1987 Maintenance performance January 29, 1988 indicators 41 COMMISSION MEETINGS None COMMISSIONERS SITE VISITS Commissioner Asseltine March 25, 1987 Commissioner Rogers October 23, 1987 NRR EVENT BRIEFINGS Dresden 3 feedwater oscillation August 11, 1987 ACRS MEETINGS None EXTENSIONS GRANTED None RELIEFS GRANTED None 1 EXEMPTIONS GRANTED Drywell gap exemption September 28, 1987 from Appendix R 1 LICENSE AMENDMENTS ISSUED Amendment 95 Dresden 2 March 31, 1987 Cycle 11 reload Amendment 96/91 4-kV crosstie October 9, 1987 Amendment 97/92 Administrative January 22, 1988 1 EMERGENCY TECHNICAL SPECIFICATIONS ISSUED None 1 ORDERS ISSUED None 42