IR 05000237/1990001
| ML17202U821 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/29/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202U820 | List: |
| References | |
| 50-237-90-01-01, 50-237-90-1-1, 50-249-90-01, 50-249-90-1, NUDOCS 9009110125 | |
| Download: ML17202U821 (18) | |
Text
"
FINAL SALP REPORT U.S. 'NUCLEAR REGULATORY. COMMISSION
REGION III
SYSTEMATIC ASSESSMENT.OF LICENSEE PERFORMANCE 50-237/90001; 50-249/90001 Inspectibn Report Nos.
Commonwealth Edison Company Nam~ of Licensee Dresden Station Name of Facility February 1, *1989 through April 30, 1990 Assessment Period
.. ~.
900911012s 90g~~37
~DR ADOCK PNU Enclosure l SALP 9
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Enclosure 1 *
Dresden Summary of Meeting with Commonwealth Edison Company on Ju.ly 23; 1990 The findings and conclusions of the SALP Board are documented in Report No. 50-237/90001; No. 50-249/90001 and w~re discussed with the licensee on July 23, 1990, at*the Dresden:Statio While the meeting was primaiily a discussion between the licensee and NRC, *it was open to members of* the public as observer The following licensee and NRC personn-el were in attendance, as well as the noted observer Commonwealth Edison Company 8. Thomas, President
"
C. Reed, Senior Vice President Nuclear Operations E. Eenigenburg, Station Manager D. Farrar, General Nuclear :services M. Turbak, Perf. Improvement Manager L. Gerner, T~chnical Superintendeht D. Galle, VP 8WR Operati_ons..
.
8. Saunders, Corp. Nuclear Security Administrator D. Morey, Chemistry Services Supervisor*
D. Demos, District Superintendent*
J. Kotowski, Production Superintendent E. Mantel, Services Director L. DelGeorge, Assistance Vice President Quality Programs Assessment D. Slager, Information Services Supervisor J. Mayer, Station Security Administrator J. Zucchi, Assistant Station Security Admini.strator Walker~ Instrument Maintenance Su~ervisor D. Saccomando, Health Physics Supervisor K. Yates, Administration Onsite Nuclear Safety B. Viehl, Engirieering Design Supervisor Kociuba~ Nuclear* Quality Programs Superintendent R. Williams, Senior Quality Assurance Inspector*
R. Tuetken, Engineering and Technical Support -
BWR Project Manager M. Korchinsky, Operating Engineer L. Holden, Onsite Program Administrator NSEP E. Zebus, Project Manager, ENC R. Holman, Emergency Preparedness D. Lowenstein, Regulatory Assurance R. Falbo, Regulatory Assurance Assistant S. Stiles, Training Superviso~
R. Stobert, Aux Operating Engineer B. Zank, Operating Engineer J. Schrage, Health Physics Supervisor
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D. Booth*, Master Electrician L. Sebby, Maintenance Staff Superiritendent K. Brennan, Regulatory Assurance Supervisor, ENC K. Peterman, Regul afory Assurance *supervisor E. *Netzel, Qua 1 i ty Assuranc'e Superi nten'dent.
Nuclear Regulatory Commission A. Bert Davis, Regional Administrator C. Paperiello, Deputy Regional Administrator W. Forney, Deputy Dir~cto~, Division of Reactor Projects B. Siegel, P~oject Manage~ - Dresden S. DuPont, Senior Resident Inspector D. Hills, Resident Inspector M. Peck,. Resident Inspector, Dresden C. Jones, Health Physicist
K. Carr, Chairman
A. Vietti-Cook, Technical Assistance to Ch~irman
.J. Wechselberger, Acting Project Director, NRR R. DuBord, Technical* Intern T. Laughton; Technical Intern Illinois Department of Nuclear Safety J. Roman, Resident Enginee~
APS Security C. Baker, Regional Operatiohs M~nager V. Gengler, Security Force Manager Others *
.J. Zagar, Chief Steward* IBEW LU 1460 Comments Received from Licensee Commonwealth Edison Company's response to the Dresden Initial SALP 9 Report dated August 13, 1990, includ~d sever~l comm~nts that has resulted in a revision to the Initial SALP Report." These changes are* listed 'in Enclosure 2, Revision sheet, and revised pages are included ~s Enclosure At the Jul~ 23, 1990 SALP meeting, there was di~cussio~ of the impact that the station blackout issue had upon the overall rating of the Safety Assessment/Quality Verification (SA/QV) functional are In order to address *the licens~e
.s comments, the SALP btiard was recorivened OQ August 21, 1990 (the board members are listed below). The board reevaluated the entire functional area of *sA/QV and concluded that ~he weaknesses in the conteri~ of li~ensing submittals overall, lack of timeliness in the resolution of NRC initiatives~ and nonperformance based audits early in the assessm~nt period was not performance at a
,.:
SALP 1 leve The single issue of submittals regarding station blackout was not considered pivotal to a SALP 1 verses a SALP 2 improving rating however, the the SALP text did over emphasize its impact~ The SA/QV iection has therefore been revised to give a better representation of {t~
significance in the a~sessme~t and recogniti6n of strong and improving performanc~:
Board Chairman E. ~reen~an, Director, Division of Reactor Projects (DRP)
Board Members J. M. Hinds, Chief, Section lB, DRP T. 0. Martin, De~uty Director, Division* of Reactor Safety (DRS)
R. Barrett, Project Director, Project Directorate 111~2; NRR B. Siegel, Project Manager, NRR S. DuPont, Senior Resi~ent Inspector, DRP Other Attendees C. J. Paperiello, Deputy Regional Administrator C. D. Pederson, Chief,.Technical Support Staff D. E. Jones,.Reactor Engineer, DRP
- Region~l Admini~trator's Concl~sio~s Based on Consideration '.of Licensee Comments I concur with the SALP Board findings and have concluded that the overall rating in the affected area has.not change ' '
- i
Enclosure REVISION SHEET PAGE LINE NOW READS SHOULD READ
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. 2 Several
... response deleted-
8-12
. On a...
issues.
deleted
- 22 Inserted 3 paragraphs Basis: Clarification of th~ quality of*the.lice~sees submittals*to NRR:
pages 25-30 were renumbered as a result -of the above revisions, with the addition of a page 3 *
Enclosure 2 The' licensee identified pastdesign problemsas described in section IV,F of this re~ort and as indicated by the HPCI drain pot piping thetmal and seismic design discrepanci~s identified by a licensee safety system functional inspectio The lic.ensee was aggressive.in_ finding, eva.luating and conservatively rectifying ifftcult equipment problems such ~s the LPCI outboard injection v v st m o_ -p-1 ul}ger -separation, the HPCI system. feedwater bac eaka e, nd the recirculation pump inner seal cooler leak e e ents.'
The li_censee applied a low threshold for nd resolution of deviation repo~ts wh~ch aided in the-identi *c ~-
n of and directed management attention toward specific a
'problem.
. _ -
.
. The license
'root cause analjsis ~as *aggressi~e a~d thorough in arr1v1ng the correct conclusions as exemplified by the licensee*:s res on~e January_ 16, 1990 loss of offsite
- Powe~ ~v~nt. -!
e ses, the licen~ee's root cause analysis was in1t1ally in r ect, such as the main generator reverse
.
power relay failu. s,~_ motor generator. (MG) set thermal overload trips,_- and l
steam line radiation monitor lockup These events occurre *
than once before the correct root cause_ was identifie rt<e"; *cases were difficult to analyze and tt was only through the
- igence of the licen~ee.that correct root causes were eventua y termined, Speci_al investigations coordinated by _the license gulatory as'surance organization for issues such as the grea i covered on the torus to reactor building vatuum breaker chec ve seats were thorough and comprehensiv *
Management's abi 1 i ty to recogniz was exemp-lified by the licensee's f:ebr r
25, 1990 Unit 3 50
. percent power plateau speci a_l _revi e a_.!}er. the post-re foe l_i ng *
outage startup and the. licensee's ef ~to increase the size of the plant technical staf QA aud1 s re scheduled; based
. on audit and assessment experience in t p
vious year, to eff~ttively target problem areas. * Sever osa1s to meet requirements presented in initial licensin ittals were not conservative with regards to safet These inc uded station blackout ( SBO), wetwe 11 venting, and* post-ac *dent hydrogen contro The initial response to the SBO rule did not significantly improve the reliability of onsite or'offsite po er system Subsequent submittals and discussions resulted i the addit1on of a diesel generator to improve the reliability o onsite powe This resolution which is und~r staff teview, app~ars to meet the SBO Rul The licensee's responsiveness to NRC initiatives was go Response to generic letters, bulletins and informati~n n were tim-el Or:i occasion, time* extensions for responding o regulatory actions were requested and mad These requests resulted in a more comprehensive respons A quality assura surveillance c~nducted as a result of NRC concerns ab~ut an
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. '...,
Enclosure 2 upward trend'in ()Utstanding control room work requests resulted in specific -actions to addre~s and resolve the~~roblem. Another exa~ple consisted of actions taken, includin~ increased QA vigilance and QC involvement, due to NRC concerns regar'ding ontractor control in the previous asses~ment. This resulted in t
on-schedule completion of the Unit 3 refueling outage-with fe problem This was also aided by an increased emphasis on plan ing and taging of activities during the out_ag On a few s~ nsiveness to followup actions was not goo d l censing response to the Salem ATWS Item 4.5.3, the maso alls, and the post-accident hydrogen gen~ration issues. T
~see' s responsiveness was good with respect to
. allegations ga ding unsealed fire openings inside conduit*
. re wa 11 s and pyrocrete covering polyurethane in fire wans..
he licensee,.in general, expedited thorough responses tp va iou~ inquiries originating with*the NRC regional and NRR staff Lice anagement at several levels aggressively*
pursued continued m nications with the NRC resident inspectors and.NRR t ff with the intent of sharing and resolving cohcern The lic~n Nuclear Tracking System ensured that NRC findings and s were approp~iately processe Staffing as ~ell as the
~K,iveness.of the training and qualification prog*ram was ~eilent. The licensee's site QA and QC organizations were *staf * d~nsure experience in a wide range of discipline The nization was committed to the evaluation of operational act
es by having QA engineers with SRO licenses. ln addition, th QA supervisor was experienced in radiation protectio Th~ QA o an o
was especially effective through the perform~nce o-dep h audits and surveillances of ~mergency prepare radiation protection, and security activitie On a rout1 ea as needed basis, QA also conducted ~eactive ~urveillances scope and quality Df the audits/surveillances were good in
~e~*
ing technical performance, compliance ~ith NRC. requir *
and training of security personne Licensee responses t
ecuri ty finding were timely and.technically* soun The au i involved in security were qua 1 ifi ed and competent to pe or~~hei r audit.
responsibilitie The licensee security orga Gtton also
established an internal audit funciion io sup~ ement QA revie~
activitie Both audit.organizations were p6si
~ve contributing factors to the security organization's performan
.
However, the QA audits in the mainteriance are~*were fo~nd n t to be performance bas~d during the first half 6f the peri The audits improved, in ge~eral, during the last half of he period by in.corporating a per'formance based methodolog The onsite r~view committee was appropriately staffed with qualifi individuals resulting in g~nerally ~omprehensive and tho ugh review The Nuclear Safety Group exceeded Technical Spec"fication requirements. by including an onsite as well as the required off site conting~nt... The _Nuclear Safety Group conducted 2 :. *
Enclosure 3
- The licensee identified past ~es~gn problems as described in section IV.F of this ~eport and as indicated by the HPCI drain pot piping thermal and seismic d~sign discrepancies identified by a licensee safety system functional inspectio The licensee was aggressi~e in finding, ev~luatirig and conservatively
- rectjfying difficult equipment problems such as the LPCI outboard injection valve* stem to. plunger separation, the HPCI system feedwater backleakage, and the recirculation pump inner seal cooler leakage event The licensee applied a low threshold for issuance and resolution of deviation reports which aided in the identification of and directed management attention toward specific plant problem.
.
The license~'s.r6ot cause analysis was aggressive and thorough in arriving at the correct conclusions as exemplified by the licensee's, response to the January 16, 1990 ross of offsite power even In a few cases, the licensee's root cause analysis was initially incorrect; such ~s ihe main generator reverse power relay fa i l.ures, RPS motor generator (MG) set thermal overload trips~ and main steam line radiation monitor lockup These events occurred mbre than once before.the correct root cause was identifie These cases were difficult to analyze and it was only through the diligence of the licensee that correct root causes ~e~e.eventuall~ determine Special investigations coordinated by the 1 icensee' s regulatory assurance organization*
for issues such as the grease. discovered on the torus to reactor*
building *vacuum breaker check valve seats were thorough and comprehensiv Management's* ability to recognize and address adverse trends was exemplified by the licensee's' February 25, 1'990 Uni"t 3 50 percent power plateau speci~l review after the post-refueling outage startup and the licensee's effor~s to increase the size of the plant technica1 staf QA audits were scheduled, based on audit and assessment experience in the previous year, to effectively ~arget p.roblem are.a A quality assurance surveillance conducted as a result of NRC coricerns about an upward trend in outstanding control room work requests resulted in specific actions to address and resolve the.proble Another example consisted of actions taken, including.increased QA vigilance and QC involvement; due to NRC concerns regarding contractor.control i~ the previous assessment: This resulted in the on-schedule completion of the Unit 3 refueling outage with few problem This was also aided by an increased emphasis on planning and staging of acti.vities.during the outag~. The licensee'~ responsiveness was good with respect to allegations regarding unsealed fire openings inside conduit penetrations in fire walls and pyrocrete covering polyurethane in fire wall The licensee, in general, expedited thorough responses to
~arious inquiries originating with the NRC regional and NRR staff Licensee management at several levels aggressively
Enclosure 3 pursued continued good communications with the NRC resident inspectors and NRR staff with th~ intent of sharing and resolving concern The licensee.' s Nuclear Tracking System ensured that. NRC findings and commitments* were appropriately processe *
The licensee's corpbrate management was generally involved in licensing activities~ especially the more complicated issties necessitating upper level decision..:making.. On 'safety and/or compliance issues that directly affected continued plant operations, corpor~te management was almost always involved and provided effective leadershi Overall, the quality of and technical content of engineering evaluations submitted by the licensee and its contractors was acceptabl However, initial sub~ittals often lacked some information, or ~ere not comprehensive enough, necessitating requests for additional information to obtain the additional information needed to complete the review~..
The licensee's responsi~eness to NRC initiatives has, in general, been timely for Bulletins, Generic Letters, special inspections and nonobligatory surveys~ Although the licensee has, on* occasion, requested time extensions for responding to
- regulatory actions, the licensee has generally produced a better product than.would have been provided by the ori gi na l sched~le. However, there h~ve been instances where the licensee has not been very responsive in follow-up actions and in some ir:istances the time to obtain resolution. has gone beyond reasonable ex~ectati6n Two issues, in particular, illustrate th1s -p~in~; Salem ATWS, Item 4.5.3, Reactor Trip '
Reliability~ for which the licensee took over 18 months to prov~de a more definitive endorsement of the BWR Owners Group Generic responsei and the response to the Generic Letter on masonry walls.for which the licensee took approximately 11 months to obtain. final resolution after the staff rejected the licensee's original_ approac The licensee has submitted many licensing amendments and responses to many staff initiated issues during this SALP perio However, one issue,.station bl~ckout, because of the Dresden plant.design, had a much greater safety *significance than any bther issue addressed during this period~. Although the licensee was aware, through prior discussions with the staff, that the onsite *and offsite power distribution systems were two areas where plant shutdown capability could be significantly enhanced, 'the licensee's initial response to the Station Blackout Rule (10 CFR 50.63} did little to improve the reliability of
these system In addition to not meeting the requiremen~s.of the rule, in accordance with the acceptance criteria contained in Regulatory Guide. 1.155, the initial submittal proposed a modification that was questionable.in value (sharing of the
Enc lo sure 3 swing diesel betwe~n both units during station blackout conditions);. Subsequent submittals,.meetings, and discus~ion resulted in the licensee pro~osing the addit~on of a diesel generator to.improve the reliability of onsite powe This resolution which is under staff review, appears to meet the SBO Rul Although resolution. of this issue will significantly enhance the availabi]ity of onsite power the initial response provided indicates th~t the licensee, in this instance, may ~ot be adequately attuned to i dent ifyi,ng those issues wh1 ch could provide a significant improvement to plant safet Staffing as well as the effectiveness of the training and qualification program was excellen The licensee*~ site QA and QC organizat~ons were staffed to ensure experience in a wide range of disciplines. *The QA organization was committed to the
~valuati~n of operational activiti~s by having QA engineers with*
SRO li.cense In addition; the QA supervisor was experienced in radiation protection... The QA~rganization was especially effective through the performance of in-depth audits and surveillan~es of emergency preparedness, radiation protection, and security activiti~ On a ro~tine and as needed.basis, QA*
also conducted reactive surveillance The scope and quality of the audits/surveillances were good in assessing technical performance,,compliance with NRC requirements, and training of security personne Li cerisee resporises to QA secu.ri ty findings were timely and technically soun The auditors involved in
- security were qualified and competent to perform their audit responsibilitie The licensee security organization also established ~n internal audit f~~ction to su~plemint QA review activities. 'Both audit organizations w~re positive contributin~
factors to the security organization's performanc However, the QA audits in the maintenance ~rea were found not t6 be
- performance based during the first half of the perio The audits impr,oved, in general, during the last half of the period by incorporating a performance based methodolog The.onsite review committee was appropriately_:staffed with qualified individuals resulting in generally compr~hensive and tho~ou~h review The Nuclear Safety Group exceeded Technical Specification requirements by including an onsite as well as.the required
.offsite ~ontingent. The Nuclear Safety Group.conducted quarterl meetings with plant ma.n~gement to discuss recurring events,
. corrective action evaluation and the results of various other Nuclear Safety* Group review This group **was effective in identifying adverse trends such as the timeliness of devia.tion report proces'si n Corporate asses.sments were conducted by knowledgeable individual ~anagement att~ntion ~as directed toward improvement in.the QC group as exemplified by a staffing increase and ~dditional job spe~ific trainin The inc~eased competence of* this group was shown by the.ability of the QA organization to release certain oversight functions back to the QC group such as radwaste shipment reviews and receipt inspection Enclosure 3 Additionalli,' the Qt organizatioAal improvements resulted in effective O'v'.:ers i ght of outage activities and an over a 11 reduction of error.
Performance.Rating The 1 i censee s *performance is rated Category 2 improving in this are The licensee's performance was rated Category 2 improving in the previous-assessment perio.
Recommen~atibns Non '*.
- *
- . *,..
Enclosure 3 Supporttng Data and Summaries Licensee Activities Un.it 2 Dresden Uni.t 2 began the SALP assessment period in a scheduled maintenance 6utage, which began on October 30, 198 Unit 2 was
.. returned to service from this outage on February 21 ;* 1989, after which, the unit operated routinely at varied power levels.
throughout the majority of the SALP assessment p.eriod including reduced power loads and ~ev~ral short outages for maintenance, surveillance and equipment re~ai~s. Unit 2 ended the SALP operating routinely ~t full powe *
Dresden.Unit* 2 experienced 12 ESF actuations (including two safety injection signals).~nd fou~ automatic reactor strams..
Three scrams occurred as the result of equipment failures, and one was the r~sult of a personnel erro Significant outage~ an~ events which occu~red during the ~ALP assessment period are summarized belo Significant Dutages and Events a. During October 30, 1988 through February 21, 1989, Unit 2 was shutdown for its eleventh refueling outage..
On March 4, 198~,-Unit Z scrammed due to the l.oss of reactor feedwater pump oil pressure control circuitry during _the 125 VDC battery ground checking... Adjustments and repatrs were made, and the unit was returned to service' on March~. 198 c. * *During March 16-17, 1989, Unit 2 was shutdown to perform o~erspeed trip setpoint test On July.12, 1989, Unit.2 s~rammed due to a main steam line (MSL) radiation monitor spurious signa The "A"*MSL rad1ation monitor was replaced, and the unit was returned to ser~i~e on July 14, 198 * On Decemb:er 10, '1989, Unit 2 shutdown for a planned maintenance outage an'd restarted on December 20, 198 The major activities included facility t_esting of batterie On bec~mber 22, 1989, Unit 2 was se~arated from the grid *
due to seal oil backing up into the generator casing~ It was dete~~ined that a clogged seal oil float trap caused oil to overflow the hydrogen seal oil drain enlargement, resulting in oil backing up into the gerierator casin The unit was back on line December 25, 1989.
g.
Enclosure 3 On January 5, 1990, Unit 2 experienced an -automatic rea~tor scram as 'the result of procedural defici~nci~s during ~ surveillance test such that inadequate controls
- were provided to prevent a potential pressure transien The unit was back on line January 10,.J,.99 On January 16; 1990, Unit 2 experienced an.automatic reactor scram and a loss of offsite power as the result of a condensate pump failure and subsequent low Vessel leve The unit was returned to service on January 23, 199 * Unit 3 Dresden Untt 3 began the SALP assessment ~eriod operating at appfoximately* 97% power.. On December 3, 1989, refueling
. activities began, following a continuous operating run of 185 day Unit 3 was returned to service on February 10, 1990, and operated routinely through the remainder of the assessment perio Dresden Unit 3 experienced*three ESF actuations (including one safety injection signal) and four automatic reacto~ scram All of the scrams ciccurred as either.the result of equipment 1ailures or spurious signals during testin Significant outages and everits that occurred during the SALP assessment period are summarized below.
Sig~ificant Outages and Ev~nts On March 25, 1989, Unit 3 scrammed and experienced a loss
- of offs He power as the result of a 345-k.V breaker failure.. The unit was returned to service on March 27, -
'198 b.. On March 30, 1989; Unit.3 experienced an automatic scram due to a MSL radiation monitor.spurious signal during RPS EPA testin The unit was returned to service on April 1, 198 On Apr11 15, 1989, Unit 3-scrammed during turbine *testing as a.result of a defective master~slave.relay contact on the No. 2 turbine stop valv The rela~ was replaced and the unit was returned to service on April 17, 1989.. During May 5-31, 1989i Unit 3 was.shutdown for a scheduled maintenance outage to replace the *degradi~g unit main transforme During December 3, 1989, through February ll, *1990, Unit 3 wa~ shutdown fo~ a scheduled refueling outag The unit completed a 185 continuous operating run prior to the outag *
'Enclosure 3 f'.
On February il, 19.90, Unit 3 was shutdown as a precaution due to seal leak~ge.on the B reactor recirculation pum The ieal ~as verified to be operational and the unit was*
returned to s~rvice on February 23, 199 '
'
' On Mar~h 10, 1990~ Unit 3 scrammed as a result of a MSIV pilot air line failur The direct line was replaced ~nd other air lines were inspecte Th~ unit was returned to service on March 11, 199.
Inspection Acti~i~ies
. Thirty""five inspection reports are discussed in this,SALP Report (February 1, 1989 through April
~O, 1990) and are.listed in Par~graph 1 of this section, Insp~ction Datar. Table 1 lists the violations by.functional areas and severity levels:
Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar '
. Inspection Data Facility: Dresden Nuclea~ ppwer Station Unit 2 Docket No.:
050-00237 Inspection Reports No.:
89005 through 89008~.89010 through 89026, and 90002 through 90012 Unit 3 Docket No.:
050-00249 Inspection Reports No.:
89005 through 89026, and 90002 through 90011 TABLE 1.
Number of *Violations in Each Severity Level Unit 2 Unit 3 Common Functional Areas III IV v
III IV v
III IV v
. Plant Operations l
.- Radiological Controls 1 ~aintenance/Su~veillance -
2 1 Emergency Preparedness Security *
- -
1 E~gineefing/Technical Support
1 Safety Assessme.nt/
Quality Verification
-
Unit*2 Unit 3 Common TOTALS III IV v. III IV v
III IV
- V
'2 '.
2
....
Enclosure 3 Special Inspection Summar Significant inspectitins conducted during ihe Dre~den SALP 9 assessment period are listed below: On March 25-26, 1989, a team inspection was conducted as a result of the* Unit 3 scram and.loss of offsite power on March 25, 1989 (Inspection Report Nos. 237/89005; 249/89005).
'* During April 17-21, 1989, a team inspection of the EQ program was conducted (Inspection Report Nos.* 237/89010; 249/89009). During A~ril 24-25, ~989,*a special inspection of the emergency preparedness program was conducted (Inspection Report* Nos. 237/89014; 249/89013).
d; During Ju_ly 31 - August 4, _1989, a team Regulatory Effectivehess Review was conducted (Inspection R~port Nos.,237/89024; 249/89023)~
- During October.31 - November 3, 1989, a* team inspection of the emergency preparedness ~xercise was conducted (Inspection Report Nos. 237/89021; 249/89020). During November 1-4; 1989, an augmented inspection team inspection.of the Units 2 and 3 HPCI waterhammer events was conducted (Inspection Report Nos. 237/89023; 249/89022). During January 9-24, 1990, an inspection of the emergency preparedness program was conducted (Inspection Report Nos. 237/90002; 249/90002).
- During January*17-20, 1990, an augmented team inspection of the Unit 2 January 16, 1990 lOss of offsite power event was conducted (Inspection Report No. 237/90004)
i~ * During April 10-13, 1990, a team inspection of the emergency preparedness exercise was conducted (Inspection Report Nos. 237/90007; 249/90008). Escalated Enforcement Actions Non Confirmatory Action Letters (CAL) *
A CAL was issued on January 17, 1990; (CAL RIII-90-001) addressing the root cause determination and corrective actions associated with the Unit 2 reactor scram and loss of 6ffsite power.
- Review of Licensee Event Reeorts ( LERs)
Collectively, 50 LERs were issued during this SALP period, in accordance with NUREG-1022 guideline Unit 2 LER Nos.:
89001 through 89032, and 90001 through 90003.
..
Unit 3 LER Nos.:
89001 through 89011, and 90001 through 9000 Table 2 below;* shows cause area counts,by unit: *
Table 2 Number of LERs by Cause Cause Areas Personnel Errors Design Deficiencies External
Procedure.Inadequacies Equipment/Component Other/Unknown TOTALS Un it.1
13 o*
Enclosure 3 assessment Unit 3
2
4
1
Table 3 below *shows a cause code comp~~ison of SALP 8 and SALP 9:
. Table 3 SALP 8 SALP 9 (12 Mo.)
(15 Mo.)
Cause Areas N Percent N.Percent Personnel Errors
1.0 Design Deficiencies
- . External 0.0 Procedure Inadequacies
'..
2.0 Equipment/Component
4.0 Other/Unknown 2.0 TOTALS
100%
.100%
Frequency LERs/Mo.3 NOTE:
The above LER information was derived fro~ the review of LERs performed by the NRC staff, and may not coincide with the licensee's cause code assignments per NUREG-1022 guideline *.;.
~
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- . e Commonwealth Edison 1400 Opus Place
.
.
. Downers Grove, Illinois 60515 Mt. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory'Commission *
Region *III
.
799 Roosevelt Road Glen Ellyn, IL 60137 *,
August 13, 19 S~bject: Dresden Station.Units 2 and 3 Response to the SALP 9 Board Report NRC Docket Nos. 50-237 and 50-249
. ENCLOSURE 4 Reference:
A.B. Davis <NRC) letter to*C. Reed <CECo),
dated June 29, 1990, transmitting the SALP 9 Board Report No. 50-237/90001 and 50-249/90001 Mr. Davis:
The referenced letter transmitted the SALP_ 9 Board Report foi Dresden Station which summarized*the station's performance rati~g for the period of February l, 1989 through April 30, 199 Commo~wealth Edison appreciated the opportunity to discuss this report wfth members of the NRC staff:during the meeting held at Dresden Station on July 23, 1990.. The purpose of this letter is to provide Commonwealth Edison's comment *We are pleased to receive Category l ratings i~ the areas of Plant Operations, Emergency Preparedness, and Securit In the areas of Maintenance/Surv~illance, Radiological Controls, Engineering/Technical
. Support, and.Safety Assessment/Quality Verification~ we note your recognition of continued general improvemen We believe that this SALP report reflects the overall continuation of the improving trend at Dresden Station over the last four years.* We wi 11 continue to focus our efforts on programs and
. initiatives that will sustain this positive tren ' Based on our review of the SALP report, we would.like to discuss three topics *in this letter. Those topics being:
the addi.tion of personnel
- to Dresden Station's Technical Staff, the implementation of the Maintenance Improvement Program for balante-of-pla~t equipment, and the apparent ratirig
. impact one issue had in the area of Safety Assessment/Q~ality Verificatio *As indicated in the Engineering/Technical Support area of the SALP report, Commonwealth Edison has been increasing the number of personnel in Dresden Station'.s Technical Staff to address manpower concern This effort will increase the number of personnel in t~e Technical Staff by approximately thirty-five percent (35%)'.
To ensure the maximum benefit is gained from these staffing additions, an exten~ive training program is being develope *
...
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ENCLOSURE 4 Mr. A. B. Davis 2.:..
August 13, 1990 The Maintenance/Surveillance area of the SALP report indicated that
- the Maintenance Improvement Program for balance-of-plant equipment was not yet
- complete, and consequently, an improved reliability for balance-of-plant equipment has.not been. realize The Maintenance Improvement Program is being applied simultaneously to both safety~related arid balance-of-plant system Approximately fifty percent (50%) of.the s.ystems scheduled for preventative maintenance improvements are balance-of-~lant. It is expected that this effort will result in improved reliability of the balance-of-plant equipmen In the area of Safety Assessment/Quality VerificationJ the dialogue shared at the SALP meeting (on July 23, 1990) was very productive and reflects an open di.scussion on issues important fo our continuing improvemen Your staff ackn*owl edges the strong and con ti nui ng improvement in our performance
.based Quality Ass~rance audits, as well as station management activities which monitor performance and ensure quality.,
We also agree in large measure with your staff's assess~ent of the need for:,.and the progress we are making in, the i~provement.in quality and timelineis of our license submittals on technical issu~s. In this regard, while.we und~rstand the concern expressed with respect to our original station blackout submittal, the impact of an individual submittal upon the overall S~fety Assessment/Quality Verification rating was greater than we expecte This is especially true where th~
submittal was significantly expanded_ within the SALP period to provide for more than minimal compliance with the rul While we believe our SALP rating of 2 and improving shows strong safety performance, we believe that a SALP 1 rating is justifie Recognizing that such ratings have a subjectiv~ element, we will accept your decision.* However, we would ask that our overall strong safety assessment/quality verification performance be acknowledged clearly and given its proper weigh Commonwealth Edfson apprec~ates the efforti of the ~RC in pre~aring the SALP repor Please direct any comments regarding this response to the Nuclear Licensing Departmen cc: Si~gel - Project Manager, NRR Respectfully, d dJ. J ~A *
- L.0. DelGeof~
--Assistant Vice-President S. DuPont - Senior Resident.Inspector-, Dresden Station NRC Document Control' *Desk lmw/MHR/LOD ID163