IR 05000237/1988023
| ML17201M298 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/20/1989 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17201M297 | List: |
| References | |
| 50-237-88-23, 50-249-88-24, NUDOCS 8901270368 | |
| Download: ML17201M298 (25) | |
Text
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v U. *s. NUCLEAR. REGULA TORY COMM I SS ION REGION I I I Report Nos. 50-237/88023(DRP); 50-249/88024(DRP)
Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690
_
Facility Name:
Dresden Nu1:;lear Power Station, Units 2 and 3 Inspecti_on At:
Dresden Site, Morris, IL Inspection Conducted:
December 5, 1988, thru JanLrary.6, 1989 Inspector:
S. G. Du Pont Approved By:
M. A. Ring, Chief~~~
Reactor Projects Sect.{_o-;;J..8...,.,.. --- /1.o/'1 Date Inspection Summary Inspection during the period of December 5, 1988 thru January 6, 1989 (Report Nos. 50-237/88023(DRP); 50-249/88024(DRP))
Areas Inspected: Special unannounced resident inspection of the licensee's corrective actions associated with the NRC Diagnostic Evaluation Team's (DET)
findings of August 198 The. inspection was the second biannual review by the NRC on the licensee's progress and was primarily directed towards the finding~ contained in Section 3 of the DET report associated with operati6ns, maintenance, testing, operat~r training, quality programs and management overvie Results:
No violations or deviations were identifie *The inspection found that all of the DET concerns related to operations have been successfully resolved and that further review during the next biannual inspection is no longer neede The inspection also found that, although progress has been made to resolve the findings associated with maintenance, not all of the licensee's improvements in ~aintenance had been complete Final resolution of the DET findings associated with maintenance will require inspection and verification during the next biannual revie. 0
Many of the improvements associ~ted with _maintenance have produced positive trends but have not been fully implemente *Examples of thes~ are the licensed 1 s trending program and
maintenance procedure upgrade effort Management and quality assurance efforts.in re~olving DET findings and concerns have been very good as demonstrated by*, *
adherence to the 1987 established resolution schedule and the development and implementation of the integrated Dresden.
Station Improvement Plan (DSIP).
The improvements in the !ST program have resulted in improved unit availability, component availability and a decrease in forced putages related to eqtiipment failure Management involvement has resulted in an im~roved awareness of station goals by non-supervisory personne *
- DETAILS Persons Contacted
.
.
Commonwealth Edison Company (CECo)
- E. Eenigenburg, Station Manager
- L. Gerner, Production Superintendent
- C. Schroeder, Services Superintendent
- C. Allen, Performance Improvement Supervisor T. Ciesla, Assistant Superintendent - Planning D. Van Pelt, Assistant Superintendent - Maintenance
.
J. Brunner, Assistant Superintendent - Technical Services J. Kotowski, Assistant Superintendent - Operations R. Christensen, Unit 1 Operating Engineer G. Smith, Unit 2 Operatin~ Engineer
- K. Peterman, Regulatory Assurance Supervisor W. Pietryga, Unit 3 Operating Engineer J. Achterberg, Technical Staff Supervisor R. Geier, Q.C. Supervisor
.D. Sharper, Waste Systems Engineer D. Adam, Assistant to the Assistant Superint~ndent - Technical Services J. Mayer, Station Security Administrator D. Morey, Chemistry Services Supervisor D. Saccomando, Health Physics Services Supervisor
- Netzel~ Q.A. Superintendent
- T. Lewis, Regulatory.Assurance Staff
- . * Bergan~ Onsite Nuclear Safety The inspector also talked.with and interviewed several other lic~nsee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, and contract security personne *Denotes those attending one or more exit inte~views condu~ted informally at various times throughout the inspection period and on January 6, 198.
Followup of Previously Identified Items (92701)
(Closed) Unresolved Items (237/88017-17 and 249/88018-17):
(DET Item 2.2.2.2) Unit 2 Licensee Event Report (LER) 87018-00 documented that the High Pressure Coolant Injection (HPCI) room cooler fan belts failed and the DET found that there were no preventive maintenance procedures for HPCI fan belts similar to procedure DMP 5700-3 on LPC Paragraph 5.c. of this report discusses the addition of the HPCI room cooler fan belts to the preventive maintenance schedule to receive the same preventive inspection and surveillance activities as the LPCI room cooler fan belts. These items are considered to be close (Closed) Unresolved Items (237/88017-19 and 249/88018-19):
(DET Item 2.2.2.3) verify that mai,ntenance procedures contain safety-related de power motors for motor operated valves (MOV).
Paragraph 5.d. of this
report discusses the licensee's corrective ~ctions of developing a new maintenance procedure to include required maintenance activities associated with de MDV motor These items are considered close (Closed) Open Items (237/88017-25' and 249/88018-25):
(DET Item 2.2.2.5)
ver.i fy that maintenance staffing* is adequate for procedure writers and work analyst During the review of the licensee's progress associated with the maintenance procedure upgrade efforts, the inspector's conclusio~, based upon the adherence to the accepted procedure rewrite schedule, is that the licensee's staffing efforts of late 1987 are
- effective and satisfactor These items are considered to be close (Closed) Unresolved Items (237/88017-27 and 249/88018-27):
(DET Item 2.2.. 3.3) verify that the licensee's Inservice 1esting (IST) program is
.adequat An !ST team inspection, documented in inspection reports*
.237/88026 and 249/88026, found that the Dresden !ST program (submitted
. on April 5, 1988) is adequat These it_ems are considered close No violations or deviations were identifie.
Review of Licensee Corrective Actions Associated With the August 1987 Diagnostic Evaluation Team (DET) Report The.follo~in~ sections ~ertain to the licensee's detailed response to the individual sections of th~ DET report dated Novembei 6, 198 The DET findings were contained in Sections 2.2, "Specific Find)ngs and Conclusions" and 3.0, "Detailed Evaluation Results" of the DET repor Resolution of the findings noted in Section 2.2 of the DET report are addressed in Paragraph 2 of this repor The items noted in Paragraphs 4 through 10 are primarily the responses to the individual details noted within Section 3.0 of the DET repor For tracking and traceability to tne DET report, the numbering listed below, 3.1.1, 3.2.1, etc, corresponds to the listing as contained within
. the DET ~epor Paragraph 4, 3.1 Operations Paragraph 5' 3.2 Maintenance Paragraph 6' 3.3 Testing Paragraph 7, 3.4 Operator Training Paragraph 8, 3.5 Quality Programs Paragraph 9, 3.7 Management Overview Note:
Concerns associated with Radiation and Chemistry (DET Section 3.6)
were resolved previously by Region initiated inspection.
DET Findings.Related to Operations Section 3.1 (92720)
The DET report contains nine (3.1.1, 3.1.2 through 3.1.9) findings with s~veral contributing examples pertain1ng to operatio DET Finding* 3.1.1, "Operator 1 s Adherence to and Control of Procedure Cl). Examples:
0 The DET observed several instances where the control roo~
operating staff ~sed uncbntrolled P&IDs and ~lectrical schematics in the control room and the Shift Engineer's offic The DET-observed one instanc~ of an operator not _
following ~stablished procedures during activities to clear the accumulator high level alarm on a control rod drive (CRD) hydraulic control unit (HCU).
(2)
Licensee's Corrective Actions:
-_The licensee removed all uncontrolled electrical schematics and P&IDs from the control room and the Shift Engineer's office. A review of administrative.procedures revealed that all procedures, except OAP 3~5, 110ut of Service, 11 contained requirements to utilize only controlled copies of documentation for processes relating to operation at D~esde OAP 3-5 was revised to require the use-of only controlled drawing Additionally, the Operations Department personnel received training on use of controlled prints onl In addition, the licensee ~eviewed the instance wher~ an opefator failed to follow procedures during HCU operatio This review-revealed that procedure DOP 300-6, 11 CRD Accumulator Charging, 11 was inadequate in that procedure DOP 300-11, 11 CRD
_Accumulator Water Removal,
11 was not referenced and the ability to go from one procedure to the other did not exist. Both DOP 300-6 and 300-11 were revised and a not~ concerning operation of valve 305-111 was added to DOP 300- (3)
Region or Resident Inspector Verification:
The resident inspectors verified that uncontrolled prints were _
removed from the control room and Shift Engineers office in
_
December 1987. Additionally, the inspectors conducted a weekly random inspection during backshifts since January 1988 to -
verify compliance with the policy and procedures on using only_
controlled print The inspectors also reviewed the revisions to DOP 300-6 and 300-11 and found them adequat This DET finding is considered to be resolve DET Finding 3.1.2, "Control Room Environment."
(1)
Examples:
The DET observed that the control room lighting was low and the noise level was hig The control room board mimics were designed with little attention to human factors engineerin ~. *
Remodeling efforts to address the poor lighting, high noise and poor human factoring was in progress during the DET, but progress in correcting the physical appearance of the co~trol room had been slo (2)
Licensee £orrective Actions:
The activities ~ssociated with the re~odeling efforts are continuing and are scheduled to be completed for Unit 2 during the current outage and during the fall 1989 outage for Unit (3) * ~egion and Resident Inspector Verifications:
The resident inspectors monitor the progress of the contro room remodeli~g daily, including the Unit 1 pahel removal for the remodeling of the new Shift Engineer office to be attached to the Units 2 and 3 control roo This finding is ongoing and is not expected to be complete until early 1990.
. DET Finding 3. L 3, "Management Centro l of Overtim.
(1)
Examples:
0
The DET fdund instances where the operators exceeded the OAP ].1 working hours limit *
The DET found that the typical shift. rotation at Dresden was backwards in terms of circadian (biological) rhyth The Operations Department seemed to be inadequately staffed at the Nuclear Station Operator.(NSO) level (2)
Licensee's Corrective Actions:
( 3)
The licensee issued a new administrative procedure OAP 7-21 to control operator working hour OAP 7-21 requires evaluation and prior approval f~r all working hours beyond the scheduled shift. Additionally, extra operators were assigried to the day shift to eliminate the need to have operators perform double shift work during increased testing and operating activities ass6ciated with the day shift. Additionally; a fourth NSO will be added to each shift in 1989, satisfying the need for extra day shift NSOs while providing better coverage of activitie *The licensee conducted an evaluation of circadian shift rotation and had conducted rotations in this manner for a one year period in the pas At the end of that year, the rotation was over-whelmingly rejected by shift personne Region and Resident Inspector Verification:
The resident inspector verified through direct observation and documentation review that the working hour limits contained in OAP 7-21 had not been exceeded to date and that OAP 7-21 adequately controlled operator overtime as recommended by NRC
. *
policy. Additionally, the Region is pursuing similar adminis-trative 1 imits for Radiation Protection, Chemistry and Maintenance p~rsonnel. The example noted in the DET report resulted in a Notic.e of Violatio This DET finding is considered to be resolved~ DET Finding 3.1.4, "Compliance With Technical Specifications."
(1)
Ex amp 1 es:
'
The Technical Specification Limiting Condition for Operation (LCO) for the reactor protection intermediate range monitor (IRM) and average power range monitor (APRM) downscale trip functi~n was exceede The surveillance testing and operability requir~ments for the High Pressure Coolant Injection system (HPCI) did not verify and test HPCl at rated fl ow and reactor pressure as prescribed by the Technical Specification LCO; (2)
Licensee Actions:
The licensee initiated a control system using covers for the IRM and APRM bypassing joysticks to prevent bypassing more IRM/APRM chann~ls than allowed by the Technical Specification LC In additicin, a Technical Specification change request to test HPCI at the rated flow of 5000 gpm and rated reactor pressure of 300 psig was submitted to NR (3)
Region and Resident Inspector Verification: -
The resident inspectors issued *two Notices of Violation, one for the instance noted by the DET and a second in December 1987 for a repeat instanc The licensee's correcti~e actions to prevent bypassing IRM/APRM channels in excess of the Technical Specifications were determined to be adequate in January 198 *
The Technical Specification change request is being tracked as
- items 237/88017-18 and 249/88018~1 This concern remains open pending action on the change reques DET Finding 3.1.5, "Operations and Maintenance Interface.
(1) Examples:
The DET observed that coordination did not exist between the Operations and Maintenance Departments to ensure that the Standbi Gas Treatment System ( SBGT) was tested to verify operability of the SBGT charcoa 1 filters if any areas from which the system takes suction are ~ainte ' *
0
0 The DET observed, through interviews with NSOs, that maintenance personnel were not instructed to place a high priority on returning equipment required by LCOs back to operable status by initiating around the clock coverage to complete repair~.
- The DET observed,. through interviews with NSOs, that a long standing problem With-spiking IRM channels had not received appropriate attentio The DET observed, through interviews with NSOs, that a long standing problem existed with a nuisance alarm annunciation associated with the scrampilot valve air header high pressure alarm during a half scra The DET observed, through intervi~ws with NSOs, that excessive oil leaks exist; (2)
Licensee's Corrective Actions:
The licensee took several generic corrective actions addressing communications between department One was to issue Dresden Policy Statement #16 requiring all departments to inform the shift and appropriate NSOs of activities within the plan Another was to conduct maintenance schedule meetings with attendance by operations personnel. Additionally, long term schedules were developed to ensure correction of the IRM spiking, scram valve leakage and other long standing problem To ensure that all equipment is repaired within the requirements of LCOs, the work request process was revised to require around the clock coverage of out of service equipmen (3)
Region and Resident Inspector Verification:
The resident inspectors verified through docu~ent review of the May and June, 1987 and May and June, 1988 LCO logs. that the*
duration per LCO has been reduced from an average of 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> to about 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> The inspectors also verified that the number of LCOs entered between July and August 1988, was
.
reduced by an additional 10% compared to the June and July 1988 perio This DET concern is considered to be resolve DET Finding 3.L6, "Operations and Training Interface."
(1) Examples:
The DET observed, through interviews with NSOs, that no effective mechanism existed for comments on received training.
- The DET observed, through interviews with NSOs, that training was not individualized and only marginally effective and that more performance based training on the Dresden simulator was needed.*
(2)
Licensee's Corrective Actions:
The licensee committed in the Fall of 1987," to the NRC that two.of the continuing training cycles would be mandatory for all licensed individuals, both shift and administrativ Additionally, the licensee committed to ensure that all individuals would attend all training cycles through an administrative control process ensuring makeup of missed attendanc The simulator. training was also increased.from 3 days per year to 10 day The Training Inquiry process has been enhanced to ensure that the inquiry is responded to in a timely manner by assigning a due date to all inquirie (3)
Regi-0n and Resident Inspector Verification:
The Region has scheduled a training verification fo~ late 1988 or early 1989, in addition to an operator requalification examination. *This item is bei.ng tracked as items 237/88017-30 and 249/88018-3 This DET concern is considered to be ope DET Finding 3.1.7, 11 0perati~g Shift Control and Oversight....
(1) Examples:
The DET observed, through interviews with Shift Engineers (SE), that SEs were not being informed of scheduled maintenance activities planned to occur during the shif (2)
Licensee Corrective Actions:,
The SE *attends several meetings, including the daily morning meeting, weekly department meeting and the maintenance schedule meetin In addition~ *Changes noted in response to DET Finding 3.1.5 above have increased the communicatioh to the shift and SEs pertain~ng to maintenance and testing activities scheduled.
during the shif This DET concern is considered to be resolve DET Finding 3.1.9, 11 Interviews.
(1) Examples:*
The following were observed by the DET through interviews*
with the operators:
0
0 The effect of overtime on the safe operation of the plant was cited by the 6perators as a major proble (Seve~al *
sought out DET members to express their concerns.)
Operators commented on ~xcessive demands that often included being held over for the next shift; being called in early; working; as a matter of course,. two double shifts in 2 days; and, in one case, wbrking six double shifts (each shift is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) in 7 day Many operators believed that they could not be promote Although the operators were pl eased with their job security and were loyal to CECo,. they discussed in detail the lack of promotion opportunity. At the management level., the lack of a 4-year degree was believed to be a contributing factor. Genera.lly, only shift control room engineers (who are engineers with degrees) are promote The operators noted that the slow personnel turnover and.the strict seniority rules hindered the promotion proces Operators were discouraged by the lack of fonnal response
- from management to changes they initiated. Because no response was routinely provided to the opera~ions personnel after they h~d submitted inquiries and change requests regarding training and plant procedures, operators believed that the inquiries were 11 lost 11 or had been disregarde The DET considered the inadequate-response in these areas to be a major cause of low moral Some operators believed that the control room.improvements were being done primarily because of an INPO commitment and not to-improve the work environment for operator In particular, operators noted that the plans for control room improvement had been 11 on the drawing board" for 4 to 5 years, but were being continually delayed until the most recent INPO evaluation. This was an example of personnel skepticism about the plant improvement initiatives and management's commitment to the Of these four examples, only the first was deemed to be
.
regulatory in nature and was addressed by issuance of a Notice of Violation, as noted in Paragraph 3.c. of thi~ repor The re~aining three were addressed by the licensee belo (2)
Licensee Corrective Actions:
Within 1987, one operator was promoted to Engineering Assistant, two operators to training instructors, and five operators to Shift Foreman, all of which are management positions. This trend in promotion has continued into 198 The other findings pertaining to inquiries are addressed with Finding 3.1.6 and the control room with Finding 3. *
(3). Region and Resident Inspector Verification:
As addressed above and*pertaining to Findings 3.1.2 and 3.1.6, the Region and resident inspectors have initiated and scheduled followup and verification of the regulatory related.issue The concern is' resolve No violations or deviations were identified in this are.
DET Findings Related to Mai~teri~rice, Sectiort 3.2 (92720)
The QET had several findings in the areas of preventive and corrective maintenance activities and maint~nance trendin DET Finding 3.2.1.1, 11 Lubrication Program for Motor Operated Valves.
(1)
Examples:
.. o
0
0 The DET noted that there had been no periodic program for inspection cir relubricatiori of MOV ~ctuator The DET noted that 17 Limitorque MOVs inside the Unit 2 drywell were lubricated with an apparently unqualifie grease, Mobilux EP- *
The DET expressed a concern that Mobilux EP-0 grease may migrate and accumulate in the Belleville spring packs in MOV actuator The DET found procedure DMP 040-17, Revision 0, 11Limitcirque Environmental Qualification Surveillance,
contained inadequate guidance regarding MOV lubrication in that the procedure requires lubrication of MOV main gear boxes whenever the MOVs require repairs instead of on a planned lubrication interva The DET found that procedures DMP 040-17 and DMP 040-18, Revision 0, 11Limitorque Environmental Qualification -
Maintenance, 11 contained inadequate guidance regarding lubrication of MOV limit switch assemblie (2)
Licensee's Corrective Actions:
The licensee extended their MOV surveillance and inspettion program from the Environmental Qualified (EQ) safety related MOVs to all safety related MOV Additionally, a modified program was extended to all Balance of Plant (BOP) MOVs.
(3)
The Licensee has also submitted Mobilux EP~o grease to an
- operability evaluation by the B~chtel _Power Corporation (Bechtel).
Bethtel completed the evaluation and issued a report of the conclusions on April 27, 1988.. This*r~port
.
was forwarded by the licensee to the Office of Nuclear Reactor Regulation (NRR) for review and resolUtio The Bechtel report also addressed the concern of possible grease migration and concluded that Mobilux EP grease was equal to Exxon Nebula EP greas Additional evaluations were requested of Wyle Labs to test Mobilux EP under extreme conditions to supplement the
. Becht~l report and for Limitorque to evaluate hydraulic lock-up associated with possible grease migratio The licensee also revised procedures DMP 040-17 and DMP 040-18 to contain instructions for lubricating and inspecting MOV limit switch assemblie Additionally~ procedure DMP 040-36, 11Limitorque EQ Lubrication Surveillance Mechanical Maintenance," -
was created to contain the MOV m~in g~a~ case lubrication instructio Regi-0n or Resident Inspector Verification~
The inspector verified that the MOV surveillance and inspection program had been expanded to include all safety related MOV Additionally, the BOP MOVs had been added to the licensee's MOV overhaul schedule. Curre_ntly, about half of the safety related MOVs have been overhauled with scheduled completion by May 198 Some of the BOP MOVs have also been overhauled, but the remaining MOVs are not scheduled to be overhauled until after June 198 The inspector also verified the revised procedure The final verification of the licensee's corrective actions will be accompliihed by the Region III m~intenance team inspection in January 198 *
NRR is evaluating the application of Mobilux EP grease per NRR tracking items M671582 and M67159 This DET finding is considered to be open.* DET Finding 3. 2.1. 2, 11 MOV Torque Switch and Limit Switch Setpoi nt (1)
Examples:
The DET found the settings of torque switches for safety-related MOV operators did not appear to be based on expected design differential pressures. Additionally, the licensee 1 s response to Bu 11 et in 85-03, "Motor-Operated
. Valve Common-Mode Failure During Plant Transients Due to Improper Switch Settings, 11 did not document a listing of the design differential pressure *
0 The DET noted that setting MOV limit switches was often inconsistent with the procedural guidance per DMP 040-9,
"Limitorque V~lve Operator Maintenance."
The DET's review of DMP 040-9 revealed that the procedure
'did-not control torque switch settings for non--safety-related MOV (2)
Licensee's Corrective Actions:
The licensee is addressing these concerns with the concerns addressed by NRC inspection reports 237/87033 and 249/87032 which revi~wed the DET findings in detai (3)
Region or Resi~ent Inspector Verification:
A region based inspector conducted an indepth review -bf the DET concerns and Bulletin 85-0 The inspection resulted in 10 detailed open and unr~solved items (237/87033-01 through 10 and 249/87032-01through10). The review of th~ licensee's corrective actions will be addressed by a region based team inspectio This DET finding remains op~ c DET Finding 3.2.1.3, "Maintenance Corrective Actions".
(1) Examples:
0
0 The DET noted that Licensee Event Report.(LER) 87018-00 documented the inoperability of the Unit 2 HPCI system room cooler on June 6, 1987, because of the failure of the fan motor belts. The failure was attributed to wear and age of the belts. Additionally, no preventive maintenance procedure existed to perform periodic inspection and replacement of the fan belt The DET noted that simi_lar preventive maintenance deficiencies discovered by the licensee performed in-depth functional inspection of the Unit 3 emergency diesel generator existed with the High Pressure Coolant Injection (HPCI) syste The DET noted that the licensee preventive maintenance procedures for MOV motors did n6t contain pictorial instruction for removal and installation for the motor and motor pinion gea The DET also expressed concerns with problems associated with the fEedwater regulating valves (FRVs).
This issue is not addressed in this report because of extensive documentation and resolution in inspection reports
- 237/87029, 249/87028, 237/87026, and 249/8702 This issue is considered to be close (2)
Licensee's Corrective Actions:
The licensee added the HPCI room cooler fans to the preventive maintenance task schedule for inspection of wear and replacement on a refueling outage basis. Additionally, the licensee performed an in-depth function~l inspection of the Unit 2 HPCI in July 198 The licensee also revised DMP 040-09 to cohtain installation and removal instructions for MOV pinipn gears.
. This DET finding remains ope DET finding 3.2.L4, "Maintenance Procedures" (1)
Examples:
0
0 Th~ DET found that procedure DM~ 040-17 did ncit adequately contain instructions for maintenance on direct current (de) motor *
Procedure DMP 040-11 did not contain a caution ~tatement t~
ensure that a valve is back seated at its normal operatin temperatur No pr~ventive maintenance procedure had been established to periodically inspect the brake rotating friction disc for excessive wear on the recirculation system pump suction valves' motor brake The DET found that many safety-related and balance-of-plant system components did not have maintenance procedure (2)
Licensee's Corrective Actions:
The licensee developed a new electrical maintenance procedure DEP 040-9, which contained inspection and maintenance instruc-tions on de moto~ Procedure DEP 040-11 was developed to replace DMP 040-11.. DEP 040-11 contained a caution statement ensuring that valves are backseated at normal system operating temperature Procedure DEP 040-09 was also developed to inspect motor brak~ pads for wear and proper adjustm~n During the DET evaluation, the licensee was in the progress of developing procedures to address maintenance of all components and had developed 25 new procedure Currently, over 100 new procedures have been developed arid 400 of the 450 existing maintenance procedure~ have been revise This finding is considered to be ope. *
e.
OET Finding 3.2.2, "Maintenance Trending."
(1) Examples:
0
0 The OET fo~nd the governing procedure for trending~ OAP 4-10, did not trend by component typ The OET found that work requests did not always document the cause of failure or corrective actions taken because
- of the lack of information, machinery hi story was not complet OAP 4-10 does not provide requirements for a periodic review to ensure that actions recorded on the trending worksheet log are being c6mpleted or for corrective actions oversight by maintenance managemen The DET found that the lubricatf6n and oil analysis trending program had been ineffective in improving station maintenance activitie (2). Licensee's Cortective Actions:
(3)
'
The licensee initiated an improvement program for the Total Job Management (TJM) system data base~ In late 1987, a s~lf assessment was performed to evaluate statibn system performance and to determine the 15 systems with the least acceptable performance.* The licensee also conducted training on the importance ~f documenting failure and corrective action inform.ation on work requests. *In addition, Maintenance Memorandums 38 and 44 were written as interim corrective actions to resolve weaknesses in the trending progra Memorandum 38 implemented a failure analysis draft procedure to provide a consistent method of performing systematic analysis of main-tenance problems to determine root cause of failure and est'ablish appropriate corrective actio The memorandum also provided an attached article from Nuclear News, August 1987, discussing root cause determination as guidance and referenc Memorandum 44 addressed the post maintenance review of work requests, identifying the process in which work request history is to be entered in the TJM history fil Region or Resident Inspector Verification:
An inspector from NRR Special Inspection Branch conducted a review of the licensee's maintenance improvement effort This review is documented in inspection reports 237/88022 and 249/8802 The review found that improvements had been made to the TJM equipment history system, but final improvements were pending the 100% system walkdown effort being performed by the licensee. This effort is being done to provide accurate identification of actual as-built conditions of all component
- model type and identification for the TJ Although improve-ments have been found to be adequate, the licensee's efforts
- to accurately update the TJM is pending and will be reviewed by the NRC after completio This DET finding.is considered to be open.*
No violations or deviatidns were identified in this are. * DET Findings Related to Testing, Section 3.3 (92720)
. In general, the DET f6und s~veral deficiencies in th~ area of Inservice Testing (IST). *
In response the licensee made extensive corrections and developed a new IST program, which was submitted to the Office of Nuclear Reactor Regulations (NRR) for review and approval on April 15, 198 * DET Finding 3.3.1, "ASME Section XI Valve Testing."
(1) Examples:
(2)
. 0
0
0
The licensee did not have administrative procedures to control IST activities and to enstire *that all required tests were performed, evaluated, and trende The*DET found that several ASME Section XI valves listed in the IST program were not teste The DET found that the HPCI injection isolation valves were ~troked tested in the clos~d direction rather than ope The DET found inconsistencies between the requirements of the Technical Specifications, IST program and surveillance testin *
The DET found that the IST program was not revised to reflect the current as-built system configuratio The DET found that the IST program contained incorrect information regarding critical valve parameter The DET found that several relief requests from ASME Section XI contain inaccurate informatio Licensee's Actions:
The licensee developed and implemented in March 1988, procedure OAP 11-21, "Inservi.ce Inspection Testing Program for Pumps and Valves.
The procedure provides for the administration of the
!ST program by specifying the various testing methods and
. 16
actions for pumps and valves. Additionally, OAP 11-21 defines the responsibilities of operating and testing personne The license~ reviewed the deficiency noted by the DET on valves not tested. Several of these valves (1402-4A(B), 1402-38A(B),
1501-13A(B) and 2302-14) were found to have been tested and were consolidated in surveillance procedure DOS 1600-1,
Quarte~ly Valve Timing~" to provide ease of auditing. All of the other valves except 2-301-94, were added to the reactor refueling procedure to ensure timing during refueling*outage Valve 2-301-94 is a manual valve and is not part of the !ST program or required by ASM *
The testing fequirement for the Core Sp~ay injection valve
_(incorrectly identified as HPCI in the DET report)
2{3)-1402~24A(B) was revised in the April 15, 1988, i~sue of the !ST ~rogra~ to requir~ stroke testing in the correct direction (Open rather than Closed).
The IST program and surveillance procedures were also revised to ensure that inconsistencies di~ not exist between the IST program~
surveillance procedur~s and Technical Specification The. licensee upgraded the !ST program to include the components
. installed by modification To ensure that all future modifi-cations are included in the !ST program, the administrative procedure (OAP) 5-1 controlling modifications was revised to ensure that the IST coordinator reviews modifications for IST program impacts, such as installation or removal of component The April 15, 1988, issue of the !ST program also contained the corrections to the program pertaining to the DET ide~tified va 1 ve parameters. * Procedures DOS 1600-1, "Quarterly Va 1 ve Timing," and DOS 1600-18, "Cold Shutdown Valve Testing," were also revised to contain the correct valve parameter The licensee evaluate~ the pump and valve relief r~quests (VRs) noted in the DET report and revised VR-4, VR-5, VR-8, VR-13, VR-15 and VR-1 Additionally, relief requests VR-9 and VR-14 were delete *
(3)
Regional or Resident Inspection Verification:
In December 1988, Regional and Resident inspectors reviewed the licensee's IST progra This review included an e*valuation of procedures OAP 11-12, OAP 11-22, OAP 14-5, DOS.1500-2, DOS 1500-10, DOS l600-18 and DOS 1400- The review found the licensee's procedures to be adequate in controlling IST activities. Additionally, a review of the licensee's IST program revealed that the DET concerns with IST activities were adequately resolved.
17 DET Finding 3.3.2, "ASME Section XI Pump Testing.".
(1)
Examples:
0 The lic~nsee did not have any admintstrative procedures in place t6 control Section XI pump testing and to ensure that all required testing was performe Seve~al tests were accepted by the licensee even though test acceptance criteria were violate (2) * Licensee's Actions:
Procedure DAP 11-21, "Inservice Inspectirin Testing Program for Pumps and Valves," was written and implemented to specify the various testing methods, actions and responsibilities of personnel involved with IST. *
Th~ licensee* also ensured that sp~cific t~~t procedures, such as, DOS 1500-10, "LPCI Pump Operability Test," contained proper actions to be taken if test data fall outside the acceptance rang The procedures (including OAP 11-21) prescribe that, if data is in the alert range, the test. frequency must be
- double If the data is in the required ~ction range, the Shift Engineer (operations) must declare the affected pump inoperable, enter the pump in the degraded equipment*log and take all actions required by Technical. Specification (3) Regional or Resident Inspector Verification:
A regional ~eview of the licensee's implementation of the IST program, documented in inspection reports 237/88026 and 249/88026, revealed that the IST progra~ adequately resolved the DET concerns associated with IST activiti~ DET Finding 3.3.3, "Plant Performance Monitoring/IST Section Staff (PPM/IST).
.
(1)
Examples:
0 The DET conside~ed the Dresden PPM/IST staff to be low in background experience with 19 staff years between 6 staff member The DET found the lack of a cohesive IST program had contributed to the previously noted DET findings (3. and 3. 3. 2).
(2)
Licensee's Actions:
The licensee separated the PPM and IST staffs and increased the IST group by adding an IST engineer, a vibration technician,
- a GE-consultant and a staff member with Quality Assurance experience. Additionally, a comprehensi~e IST program.was developed and submitted to NRR for review and approval on *
April 15, 198 (3)
Regicin~l or Resident Inspector Verificatiori:
A regional review of the IST program implementation, documented in inspection reports 237/88026 and 249/88026, found the IST staff to be experienced and effective. Additionally, the IST program was found to be cohesive and. effectiv No violations or deviations were identified in this are ~
Operator Training; Sectibn 3.4 (92720). DET Finding.3.4.1 "Training Staff" Examples :
.
The DET found a general lack of plant experience of the training staff and inadequate staffing to support non-licensed operati~g personnel trainin Both licensed and non-licensed operators were in the same retraining classes; (2)
Licensee Actions:
The licensee took several actions to increase the training staff and to provide an increase in the staff's plant experienc Several experienced licensed personnel have been added. to the
- training staff. Additionally, both the CECo training and GE (simulator) instructor staffs have walked down plant systems and observed control room evolutions to acquire plant operations and system experien~ *
The licensee has also separated the licensed and non-licensed training to ensure that required training is conducte (3)
Regional or Resident Inspector Verifications:
The inspector verified that the licensee had initiated the abtive ch~nges. This DET finding is considered to be close DET Finding 3.4.2, 11 Requalification Program for Licensed Operators" (1) Examples:
The DET found learning objectives did not indicate the standard of expected performanc The DET found that requalification instructions were exam oriehtated instead of a comprehensive requalification based
.progra The DET found that retraining quizzes relied heavily on design bases ahd placed little emphasis on job-required.
k_nowl edg (2)
Licensee's Actions:
The licensee has performed several actic:ins to improve the overall conduct of t~aining.. Procedures have been initiated to require clear training objectives explaining the performance standard associated with the related training subjects, student feedback on the instruction material and to incltide job related subjects into the lesson plan (3)
Regional *or Resident Verification.:
Because of the genera 1 overa 11 weakness in the training program identified by the DET, an 1nitial inspection by the Region was conducted in late 1987, with a scheduled team inspection in 198 *This DET fihding is *considered to be ope *No violations or deviations were identified in this are.
Quality Programs, Section 3.5 (92720) DET Finding 3.5.1, "Quality Assurance of Operation (1)
Examples:
0 The QA department seemed to suffer from high turnover and understaffin Of twelve (12) personnel, only six (6) were available for regularly scheduled QA activitie (2)
Licensee Action:
CECo QA is structured such that QA inspectors are reassigned to other facilities on a routine basis to provide a 11 fresh 11 loo Additionally, the QA department has shifted more effort from the routine survei 11 ance to more progressive diagnostic type inspections, such as SSFis and self assessment This DET finding is conside.red to not be a regulatory concern and the licensee's actions appear to adequate, therefore, this finding is considered to be resolve DET finding 3.5.2, "Licensee Improvement Initiatives."
(1)
Examples:
0 o*
The DET.found that QA personnel were not actively involved with the site ongoing improvement initiative.
.
The DET found that, although the individual improvement initiatives seemed to have been well conceived, there was no collective thrust or directio All improvement initiatives were under the cognizance of the Station Manager; however, the corrective actions and followup were not centrally tracke (2)
Licensee Actions:
The licensee developed a comprehensive and integrated improvement pla The Dresden Station Improvement Plan (DSIP).
DSIP incor~orated all previous impro~ement initiatives, DET finding~, corpo~ate goals and INPO initiatives into one pla Trending tracking has also improved with the addition of Dresden specific performanc indicators to the Monthly Plant Status report; The report trends 116 performance indicators in 13 fuhctional areas~ Each indicator is also identified based upon what type of perform-ance, such as station, NRC, INPO or Corporate with goals, yearly and monthly trend The site QA department has increased their involvement in evaluating station performance by conducting a second SSFI on the Unit 2 HPCI and participating in several self assessment This DET finding is tonsidered to be ope DET Finding 3.5.5, "Audit and Surveillance Progra (1) Examples:
The DET found that the licensee QA department audits conducted during 1986 and 1987 in the maintenance and IST areas were program oriented rather than emphasizing correct work activitie *
(2) licensee Action:
The site QA.conducted an audit of the IST progra This audit, with others, contained increased emphases on observation of in-process work activities. Additionally, this audit demonstrates QA's involvement in the DSIP by reviewing the second 10-ye:ar IST program against ASME Section XI and Technical Specifications to ensure that inconsistencies did not exist. These actions appear to be adequate and therefore, this finding is considered to be close * DET Finding 3.5.7, "Corrective Actions and Root Cause Analysis.
(1) Examples:**
(2).The DET found that the Regu*l c;itory Assurance Department had several tracking systems for *external comniitments to INPO
- and the NRC, but did not track all internal actions, for example; the status and action required by discrepancy records (DRs) and deviation reports (DVRs).
The DET determined thai root caus~ *analysis and followup
- were not accomplished as one coordinated, cohesive activity and did not constitute a separate, plant-wide progra Lic~nsee Actions~
'
'
'
The licens~e ~valuated the use of the Nuclea~ Tracking System (NTS) for daily tracking bf DVRs and DRs; However, the responsibility of 'tracking DVRs and DRs was shifted from the Office Supervisor to the Quality Control Supervisor as a result of a QA audit. Additionally, the DVR/DR process was improved to provide a 45 day turn-around on issuance of the repcirt These actions increased the ability of the licensee to find and verify DVR/DRs in the process~ In addition, internal commitments
.
between departments and committees have been added, including DVRs* and DRs, to a computer b_ased information system as the Daily Regulatory Activities Lis The list provides the ability to review commitments in a short listing of items..
The station's personnel error reduction program ~as incorporated into an administrative procedure, OAP 2-8, and the Scram/ESF
- reduction program was included in procedure OAP 7-1 Addi~
tionally, ov~r.17 Dresden personnel received root ~ause investigation training from EG&G Services~ This effort included perscinnel from various station departments; maintenance, operations, technical staff and engineerin *
(3)
Resident Verification:
The inspector verified, through observations and record reviews, that the internal tracking system has been effective. Addi-tionally, root cause evaluations improvement efforts have contributed significantly to the increased performance of the Dresden station during 198 Several performance indicators demonstrate the improved performance as follows:
Performance Indicator 1987 1988 Total Scrams at Power
1 Percentage of Personnel Errors vs LERs
/
24%
10%
Forced Outage Rate (U2)
8.0%
.8%
Forced Outage Rate (U3)
22.0%
0%
Also, several other performance records, such as a dual unit operating run of 156 days (second best BWR record) and no reactor scrams for 403 day~ on either unit (world BWR-record),
indicaie the effectiveness of the licensee.'s improvement and root cause evaluation program *
This DET finding is considered to be close No violations or deviations were identified in this are.
Manageme~t Overview, Section 3.1 (92720)
- DET Finding 3.7.1, "Strategic Plan (5-Year) and Station Goals.
(1) Examples:
0
.
.
The DET found discrepancies be~ween the Station Goals and th~ Strategic Plan. This included the goals not addressing all of the improvement initiatives.
. The Station Manager did not have a staff dedicated to the various improvement initiative (2)
Licensee Actions:
The licensee incorporated the Str~tegic Plan, NRC and INPO initiatives, and the station improvement initiatives into one integrated plan, DSI Additionally, a new superintendent position, Superintendent of Plant Improvements (SPI), was_
created and filed in Jate 1987, to direct and track the actions required by the DSI The SPI was assisted by the Regulatory As~urance Department and reported to the Station Manage In late 1988, the position was down graded to Performance Improvement Supervisor (PIS) with reportin9 to the Services Superintendent (direct) and Plant Manager (indirect).
(3) * Regional or resident Verification:
The resident staff followed tt)e progress of the DSIP as par of the routine assignments and Re~ional management met monthly,*
throughout 1988, with Dresden to discuss progress of the actions contained in the DSIP. *These meetings also reviewed and addressed the trends and performance indicators contained in the D~esden Station Monthly Status Repor This DET finding i~ considered to be close * DET Finding 3.7.2, "Improvement Initiatives."
(1) Examples:
- The DET found that ~~ny of the improvement initiative~ in place in 1987 were based upon an INPO evaluation in 1985 and did ~ot reflect recent indications of program weaknes The purpose and objectives of the initiatives w~re not defined or *communicated to non-supervisory personne The initiatives did not address all areas requiring improvement (2)
Licensee Actions:
During the development of the DSIP, ihe licensee included the results of several self-assessments and INPO and consultant assisted assessments in most of the functional areas as part of the initiatives contained within the DSI The DSIP was developed to be a 11 li_ving 11 document with the ability to assess each of the initiatives, goals and actions contained within the DSIP against effective~ess and current program weaknesse After the NRC issued SALP 7, the DSIP wa revised to reflect the needed improvements in maintehanc~.
The licensee also initiated several methods of communicating the goals of the DSIP to all station personne An appraisal and standard process was initiated to provide a periodic assessment of personnel performance and a forum for communication between supervision and station personne Also~ the 11Daily Update, 11 a daily memorandum to all station personnel containing the expected daily tasks, was expanded to contain Station, regulator and industry information. This information includes Station goals and progress, industrial events and NRC Information Notices. Another station-wide information, a monthly news-letter, *was initiated in late 198 The newsletter provides information on the progress of all departments and a general monthly progress of the Station goals by the Station Manage (3)
Regional or Resident Inspector Verification:
The NRC has noticed an increased awareness by.station personnel, in the goals of the Statio The inspector has noticed an increased participation of non-supervisory personnel in the monthly status meetings and in initiating recommendations that have resulted in improved conditions at the facility. Addi-tionally, team work between departments has been evident as demonstrated by interdepartment efforts associated with complex Station improvements, such as, the service water mainte~ance outage and the Unit 2 contrdl room human factor modification This DET finding is considered to be close.
Exit Interview (30703)
The 1nspectors met with licensee representatives (denoted in Para_graph 1)
informally throughout the inspectior. period and on January 6, 1989, and summarized the scope and findings of the inspection activitie *
The inspectors also discussed the likely informatio.nal content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection; The l i cen_see did not identify any such documents/processes as proprietar The. licensee acknowledged the findings of the inspectio