IR 05000237/1997001
| ML17188A012 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/02/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17188A011 | List: |
| References | |
| 50-237-97-01, 50-237-97-1, 50-249-97-01, 50-249-97-1, NUDOCS 9801140126 | |
| Download: ML17188A012 (5) | |
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INTRODUCTION The Systematic Assessment of licensee Perfonnance (SALP) process is used to develop the Nuclear Regulatory Commission's (NRC) conclusions regarding a licensee's safety perfonnanc Four functional areas are assessed: Plant Operations, Maintenance, Engineering, and Plant Support. The SALP report documents the NRC's observations and insights on a licensee's perfonnance and communicates the results to the licensee and the public. It provides a vehicle for clear communication with licensee management that focuses on plant perfonnance relative to safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilitie This report is the NRC's assessment of the safety perfonnance at Dresden for the period December 29, 1996, through November 22, 199 An NRC SALP Board, composed of the individuals listed below, met on December 3, 1997, to assess performance in accordance with the* guidance in NRC Management Directive 8.6,
"Systematic Assessment of Licensee Perfonnance."
Board Chairperson Geoffrey E. Grant, Director, Division of Reactor Projects, Riii Board Members Robert A. Capra, Director, Project Directorate 111-2, NRR John Jacobson, Acting Deputy Director, Division of Reactor Safety, Riii 1 PERFORMANCE ANALYSIS Plant Operations Good performance in the conduct of plant operations was evident throughout the perio Perfonnances of high visibility tasks such as reactor startups and shutdowns were good. Strong emphasis was placed on planning, communications, and procedure adherence throughout the assessment period. Strong management support of conservative operations was noted and self-assessments and root cause detenninations were good. Procedure quality was generally good; however, some procedure inadequacies were observe Sustained dual-unit operations were conducted successfully during this period; however, some equipment problems caused operation at less than full power. During the latter part of the assessment period, both units operated near full power. Unit 2 was manually tripped in July in response to an error during manual feedwater control. Unit 3 operated near full power except for a short forced outage in November to repair the 3A recirculation flow sensing lin Routine operations were good. Plant material condition issues continued to challenge the operators; however, the operators correctly responded to these self-revealing events. Unit supervisors exercised effective command and control and provided appropriate oversight of plant evolutions. However, some operational errors were made. In July of 1997, during a reactor feed pump swap to address a failed feed pump minimum flow valve, inability to control the feedwater system caused the unit supervisor to direct a manual trip of the reactor. In a second example, 9801140126 980102 POR AOOCK 05000237 a
. ii operators were unable to successfully run the emergency diesel generator for a routine surveillance test. The errors committed in operations during this period were not indicative of programmatic deficiencies, but were individual personnel error Strong management support of conservative operations continued to be evident. This was supported by decisions to investigate, and subsequently shut down a unit, first following identification of increased drywell leakage and again following identification of a potential circuit breaker problem. In both cases, investigations were begun before any actual failures and before exceeding limits. The actions reflected management's emphasis on high standards, attention to detail, and a low tolerance for operator work-arounds. The Plant Operating Review Committee (PORC) continued to be strong and highly critical. For example, the PORC enforced high standards by expanding the original corrective actions for the July 1997 feedwater transien Self-assessments, problem identification, and root-cause determinations in the operations area were good. The Quality and Safety Assessment (Q&SA) Department performed critical reviews of operations' performance. The results of these were used to improve overall performance. For example, after determining which operating crew had the least errors, that crew's performance was reviewed for lessons learned. The operations department also continued to identify problems. However, some minor deficiencies were repetitive and indicative of ineffective corrective action Procedures were of sufficient quality to enable the operators to perform most tasks satisfactoril Operator adherence to procedural requirements was good with few exceptions. However, several problems were noted where a gap existed between operators' training, procedural details, and operator performance. Examples included procedures for a reactor feed pump swap, operation of an emergency diesel generator, and operation of the reactor building closed cooling water system to support spent fuel pool cooling. In some areas where the procedural level of detail was low, operators' performance was not strong enough to compensate for the procedure. In each case, management recognition of the problem was good and the licensee took action to address the identified problem The performance rating in Operations is Category Maintenance Overall performance in maintenance improved during the assessment period. A continued focus was observed in improving material t:mdition of the station, in enhancing the work control process, in reducing the maintenan~e: backlog, and in improving the training provided to craft personnel. Those initiatives improved the station's ability to plan and to execute work and resulted in sustained periods of dual unit operation. However, the quality of work and personnel errors at times were observed as weaknesses in the maintenance progra Improvement of the material condition of the plant was a chief focus during the assessment period. The Unit 3 feedwater control system was upgraded, the Unit 3 core shroud was repaired, and much of the Unit 3 reactor water cleanup system piping was repaired. However, some problems caused by plant material condition resulted in challenges to plant operations. For example, problems in the Unit 2 feedwater control system and feedwater regulating valves contributed to several feedwater transient..
The work control process also received significant attention during the assessment perio Improvements were made in the "Five-Week" maintenance work scheduling process, the "Fix It Now" process, and the minor maintenance process. An increase in the number of "on-time" job starts and completions resulted from the improvements in the scheduling and execution of wor The ability to plan and execute large scale tasks while providing high-quality work within a planned schedule was demonstrated during the Unit 3 refueling outage. The processes and programs required by the Maintenance Rule (10 CFR 50.65) were carried out effectively at the statio The quality of most maintenance activities improved during the assessment period. Most of the maintenance activities observed were conducted thoroughly and professionally, with the package present and in active use. Supervisors and system engineers monitored job progress and appropriate radiation control measures were in place. When questions arose or problems were encountered, the workers usually stopped the activity and discussed the problems with management. However, occasionally work preparation, problem solving, and execution were weak. For example, a Unit 2 feedwater transient was caused by inadequate identification of the impact of work on the feedwater control system. In a second example, station batteries were preconditioned before being tested due in part to inadequate technical reviews. A similar error was made in the last SALP assessment perio Maintenance department expectations were well understood by the managers and NRC discussions with craft personnel also showed an overall understanding of management expectations. Resources were devoted to increase maintenance training which was effective in improving workers' skills. However, some continuing problems with personnel errors were evident, which challenged operations, rendered safety systems inoperable, and resulted in inadvertent equipment actuations. Examples included an incorrect manipulation of a wrong component during logic testing of the reactor protectio*n system that resulted in a full scram signal while Unit 3 was shutdown, and a failure to reconnect the air supply line to the emergency level control transmitter for the Unit 38 Moisture Separator Drain Tank that resulted in a turbine trip during startu Quality control and self-assessment activities improved during the assessment period. The Q&SA organization satisfactorily monitored the activities in maintenance. The associated audit reports and surveillances were complete, thorough, and critical. The field monitoring reports showed that Q&SA personnel performed sufficient field monitoring activities The performance rating in Maintenance is Category Engineering Engineering performance was satisfactory and improvements were observed from the previous assessment period, particularly during the last several months. Activities associated with the NRC Confirmatory Action Letter (CAL) met the intent of the CAL and satisfied NRC requirement Self-assessment and Q&SA evaluations improved. Engineering support of plant operations improved and overall support during the recent Unit 3 refueling outage was good. However, some improvement initiatives were not fully effective in assuring consistently good engineering performanc.
Implementation of the CAL activities was good. Nuclear engineering procedures were revised to provide improved directions for potential design-basis discrepancies and calculations. The special audits performed at selected architect engineer facilities were good. Some weaknesses were observed with the initial activities associated with the formation of the Dresden Engineering Assurance Group (DEAG); subsequently those weaknesses were corrected and the DEAG was functioning effectively. An immediate screening of key parameters on 12 risk-significant systems was completed satisfactorily, but some of the more thorough followup activities associated with the Design Basis Initiative Program were delaye Design basis issues continued to be identified. While some of these issues were the result of good engineering efforts to identify problems, others, such as the Unit 3 core flow calibration problems and missing calculations, were additional examples of design control deficiencie Self-assessment and Q&SA evaluations were aggressive, performance based and identified substantive issues. A recent engineering self-assessment provided an effective evaluation of plant engineering work management and support responsiveness. The DEAG has improved the engineering products developed during the past several months. The use of auditors from other ComEd sites, other licensees and independent consultants (technical specialists) was considered good. The type, depth and conclusions of the audit findings indicated that the effectiveness of Q&SA in evaluating engineering activities had improve Engineers were knowledgeable, involved with the work conducted in their respective areas of responsibility and provided good support to operations; however, some problems were identified in the engineering area. For example, the engineering staffs inability to resolve feedwater control problems resulted in continued operation of Unit 2 in single element control, which contributed to a recent manual scram; engineering personnel missed an opportunity to identify and resolve a battery load test profile deficiency; and a Group V isolation of the isolation condenser occurred due to a design/installation deficiency. Although engineering performance was satisfactory; sustained improvement remains to be exhibited. Procedural noncompliances and attention to detail errors continued to be identified. Problems were experienced with engineering support of surveillance testing, as exhibited by the preconditioning of a battery during testing and the inappropriate use of
"NIA" for steps in an engineering surveillance procedur In response to performance deficiencies, a number of positive initiatives were implemented and resulted in some improvement during the assessment period. These initiatives included the DEAG, the Engineering Rapid Response Team and the Engineering Reporting System. However, these initiatives have not been fully effective in assuring consistently good engineering *
performanc The performance rating in Engineering is Category Plant Support Performance in the area of Plant Support remained consistent with the previous assessment period. Management involvement resulted in improved performance in the radiation protection, chemistry, security and emergency preparedness program areas. However, some weaknesses in radworker performance, chemistry technician procedural compliance and security personnel errors were identifie With some exceptions, the radiation protection program continued to improve and strong perfonnance was demonstrated in radiological work planning and oversight which helped control station dose during the 1997 refueling outage (03R14). Improvements were also noted in contamination and radioactive material controls and radiation protection (RP) procedures. The solid, liquid and gaseous radioactive waste, transportation of radioactive material, and
.environmental monitoring programs were implemented well. The RP staff continued to have strong management support for overall upgrading of the RP program. Reduction in areas controlled as contaminated continued and continued emphasis was given to reducing the station's source term by hydrolyzing hot spots in process lines. Continued examples of radworker performance deficiencies occurred during this period involving non-licensed operators, contract supervisors, and technicians failing to follow station procedures. A self-revealing event occurred in which two workers were prevented from leaving a high radiation area because a contract technician failed to ensure all workers were out of the area before locking the door. Another self-revealing event occurred resulting in a small intake of radioactive material because an adequate evaluation of the radiological work environment was not performed. Although oversight of contractor activities improved, inadequate oversight was a contributor to these-> event Overall implementation of the chemistry program was good and included an effective reactor chemistry management program to reduce chemical contaminants and initiatives for continued improvement of water quality. Chemistry staff demonstrated good analytical techniques, RP practices, and working knowledge of systems and processes. Audits and assessments were properly focused, thorough, and covered a variety of program areas. Some exceptions were noted in certain areas of the chemistry program. Chemistry technician performance was mixed and included procedural compliance problems. Another issue concerned failure to complete procedurally required surveillances on the high radiation sampling system at required interval The emergency preparedness (EP) program was maintained in an effective state of operational readiness. Sigl'.lificant changes have been implemented in the EP program since March 199 Independent and internal audits (both dated May 1997) indicated that the program was adequate to respond to an actual emergency, but that management attention was needed in the areas of maintaining emergency procedures, problem identification and tracking, corrective actions, and implementing operations support center changes. In the last six months, all of the issues from the audits and reviews were corrected, resulting in improved program effectivenes The 1997 evaluated EP exercise was a successful demonstration of the licensee's capability to implement emergency plans and procedures. Event classifications, offsite notifications, and protective action recommendations were correct and timely. In-plant activities were well thought out and well coordinated. A number of equipment mock-ups were used to enhance the exercise realism and challenge for in-plant teams. Transfers of command and control were smooth and coordinate Overall good security performance was noted in the areas of implementation of security requirements, maintenance support for security equipment, and the quality of the audits that were conducted in the security area. Those positive program indicators were in contrast to personnel errors that reduced the effectiveness of specific search and control functions of the security program. The errors involved were skill and knowledge based and were determined to be individual performance problems and not indicative of programmatic deficiencies. Lack of security oversight was determined to be a contributing factor to these error The performance rating in Plant Support is Category