IR 05000010/1985001
| ML20136F718 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/03/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20136F717 | List: |
| References | |
| 50-010-85-01, 50-10-85-1, 50-101-85-1, 50-237-85-01, 50-237-85-1, 50-249-85-01, 50-249-85-1, NUDOCS 8601070477 | |
| Download: ML20136F718 (38) | |
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SALP 5 SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE t
SG-10/85001; 50-237/85001; 50-249/85001
Inspection Report
Comonwealth Edison Company
Name of Licensee
Dresden Nuclear Power Station
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Name of Facility
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June 1, 1984 through September 30, 1985
Assessment Period
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
periodic basis and to evaluate licensee performance based upon this information.
SALP is supplemental to normal regulatory processes used to ensure compliance
to NRC rules and regulations.
SALP is intended to be sufficiently diagnostic
to provide a rational basis for allocating NRC resources and to provide
meaningful guidance to the licensee's management to promote quality and safety
of plant construction and operation.
A NRC SALP Board, composed of staff members listed below, met on November 19,
1985, to review the collection of performance observations and data to assess
the licensee's performance in accordance with the guidance in NRC Manual
Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of
the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety perforu nce
at the Dresden Nuclear Power Station for the period June 1, 1984 thrcJgh
September 30, 1985.
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SALP Board for Dresden Nuclear Power Station:
Name
Title
J. A. Hind
Director, Division of Radiological
Safety and Safeguards
C. E. Norelius
Director, Division of Reactor Projects
C. J. Paperiello
Director, Division of Reactor Safety
E. G. Greenman
Deputy Director, Division of Reactor
Projects
N. J. Chrissotimos
Chief, Reactor Projects Branch 2
L. A. Reyes
Chief, Operations Branch
G. C. Wright
Chief, Reactor Projects Section 2C
E. R. Schweibinz
Chief, Technical Support Section
D. H. Danielson
Chief, Materials and Processes Section
F. Hawkins
Chief, Quality Assurance Programs Section
R. L. Gregor
Chief, Facilities Radiation Protection
Section
M. C. Schumacher
Chief, Indepentent Measurements and
Environmental Protection Section
J. R. Creed
Chief, Safeguards Section
R. A. Gilbert
Licensing Project Manager, NRR
T. M. Tongue
Senior Resident Inspector, Braidwood
L. McGregor
Senior Resident Inspector, Dresden
R. B. Landsman
ProjectManager,ReactorProjects
Section 2C
P. R. Rescheske
Reactor Inspector
D. Miller
Senior Radiation Specialist
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II.
CRITERIA
The licensee's performance is assessed in selected functional areas
depending on whether the facility is in a construction, preoperational,
or operating phase.
Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas.
Some functional areas may not be assessed because
of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess
each functional area:
1.
Management involvement in assuring quality.
2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
Staffing (including management).
7.
Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the 5 ALP Board's assessment, each functional area evaluated is
classified into one of three performance categories.
The definition of
these performance categories is:
Category 1:
Reduced NRC attention may be appropriate.
Licensee management
attention and involvement are aggressive and oriented toward nuclear
safety.
Licensee resources are ample and effectively used so that a high
level of perform 1nce with respect to operational safety or construction
is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee
management attention and involvement are evident and management is
concerned with nuclear safety.
Licensee resources are adequate and are
reasonably effective such that satisfactory performance with respect to
operational safety or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee
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management attention and involvement is acceptable and considers nuclear
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safety, but weaknesses are evident.
Licensee resources appear to be
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strained or not effcetively used so that minimally satisfactory performance
with respect to operational safety or construction is being achieved.
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Trend: The SALP Board has also categorized the performance trend in each
functional area rated over the course of the SALP assessment period.
The
categorization describes the general or prevailing tendency (the perfor-
mance gradient) during the SALP period.
The performance trends are defined
as follows:
Improved:
Licenseeperformancehasgenerallyimprovedoverthecourse
of the SALP assessment period.
<
Same:-
Licensee performance has remained essentially constant over
the course of the SALP assessment period.
Declined:
Licensee performance has generally declined over the course
of the SALP assessment period.
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III. SUfMARY OF RESULTS
The overall regulatory performance of your facility has improved during
the current SALP period. We are encouraged by the improved performance
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in the areas of radiological controls, maintenance / modifications,
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security, and licensing activities.
However, performance in the areas
of surveillance and inservice testing declined from a Category 1 to a
Category 2 and the performance trend in the areas of plant operations and
fire protection / housekeeping also declined. Your performance in these
areas will be monitored and discussed in the next SALP Board assessment
for your facility.
Rating Last
Rating This
Functional Area
Period
Period
Trend
'A.
Plant Operations
2
Declining
B.
Radiological Controls
2
Improving
C.
Maintenance /
Modifications
2
Improving
D.
Surveillance and
Inservice Testing
2
Same
E.
Fire Protection /
Housekeeping
2
Declining
F.
1
Same
G.
Security
2
Improving
H.
Refueling
1
Same
I.
Quality Programs and
Administrative Controls 2
Same
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Licensing Activities
1
Improving
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
This functional area was routinely inspected by the resident
inspectors throughout the evaluation period. One special
inspection was conducted by the resident inspectors related to
three personnel errors that occurred in a short period of time.
Six violations were identified as follows:
SeverityLevehIV-Inadequatecorrectiveactionsresulting
a.
in a second occurrence where the corner room submarine
doors were.found open and unattended (237/84012-03).
b.
Severity Level V - Failure to investigate and evaluate
multiple alarms and indications in the control room where
secondary containment was in question (237/84016-01;
249/84015-01).
c.
Severity Level V - Failure to report scrams in accordance
with 10 CFR 50.73 (249/84021-01).
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d.
Severity Level IV - High Pressure Coolant Injection (HPCI)
room cooler service water found valved-out resulting in
HPCI being inoperable (249/85009-01).
e.
Severity Level IV - Loss of undervoltage protection on
Emergency diesel bus 34-1 for about four and one-half
minutes (249/85009-03).
f.
Severity Level IV - Suppression pool water sample line
found open allowing water to flow from the suppression
pool in containment to the secondary containment
(249/85009-02).
The violations did not appear to be programmatic or to have
generic implications to the plant.
Although the licensee's
response to all of the violations was generally prompt and
effective with consideration given to longterm corrective
actions, the responses to d, e, and f above were exceptionally
good.
The number of violations issued during this assessment
period was comparable to the number issued during the last
assessment period.
During the SALP 5 period, the licensee experienced 35
unscheduled reactor scrams (21 on Unit 2 and 14 on Unit 3).
Fourteen of the scrams occurred while the reactors were in
a shutdown condition with all rods fully inserted.
Nine
scrams resulted directly from personnel errors, of which
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one was caused by a nonlicensed operator, five by licensed
operators, and the remaining three by maintenance or other
personnel.
Three scrams during SALP 5 were due to defective
procedures, with the balance of the scrams attributed to
component failures.
During the later portion of the assessment
period, recognizing that the number of scrams being experienced
were becoming excessive, the licensee formed a scram reduction
committee chaired by the assistant superintendent for operations.
The committee's function was to perform indepth reviews of every
scram and provide feedback of the analyses to the appropriate
personnel with the intention of preventing similar scrams.
Due
to the short time the committee has been in place, a determina-
tion of its effectiveness could not be made at the time of this
report.
As discussed in Section V.F.1, LER data indicates that the number
of personnel errors during the present assessment period have
substantially increased from the last assessment period.
Of the
93 LERs submitted this period 38 involved personnel errors, of
which 20 were attributable to the operations department.
This
is a significant increase over the SALP 4 data where, although
121 LERs were submitted, only 21 involved personnel errors and
only three of these were directly attributable to the operations
department.
During the assessment period, the licensee exhibited adequate
control over plant work activities as evidenced by well planned
daily assignments of priorities, use of followup and tracking
mechanisms to ensure required work was completed in a timely
manner, and adequately stated policies that insured appropriate
levels of station management review was involved when decisions
towards safety were made.
During daily (morning and afternoon)
planning meetings, operations personnel interfaced closely with
maintenance, health physics, and other station personnel to
set up work projects for the day and night shifts respectively
with emphasis given to determination of priorities.
Staffing was adequate during the period and vacancies were
generally filled quickly with qualified and motivsted personnel.
Overall, operators were attentive to their duties and ack-
nowledged and analyzed alarm conditions promptly and thoroughly.
On many occasions, the inspectors noted a seemingly large number
of annunciators "up" (acknowledged) in the control room.
Upon
questioning of the operators, it was generally found that the
causes for the annunciators were known or that equipment trouble-
shooting was underway to determine the cause.
Distractions,
such as. radios, televisions, or non-job related reading material
are not allowed in the control room.
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During the SALP period, the licensee completed construction of
a new shift supervisor's office / locker room area. The original
plant design had resulted in a.high personnel traffic flow
through the control room for access between the shift super-
visor's office and the plant.
The newly constructed additions
have considerably reduced this problem.
The Regulatory Performance Improvement Plan (RPIP) as described
in the previous SALP 4 report has resulted in supervisors and
union personnel being more aware of the need for attention to
detail. This has been accomplished through the use of weekly
meetings dealing with timely subjects and how they relate to
Dresden and by a greater onsite presence by station and
corporate management during both normal and off-normal work
hours.
The licensee identified and presented to the NRC, in a March 25,
1985 enforcement conference, a recurring problem involving an
overall increase in personnel errors that rince 1984 has
accompanied the restart of each Dresden uni
following its
respective refuel outage.
In recognition c.' this, and to help
correct it, the licensee has assigned additional personnel on
shift for operations, health physics, and quality assurance
during the Unit 3 refueling and recirculation piping replacement
project.
These personnel will aid in the outage work and their
experience and expertise should help to reduce personnel errors,
thus providing a smoother restart following completion of the
outage.
During the assessment period,12 Reactor Operator (RO) and 12
Senior Reactor Operator (SRO) examinations were administered
to Dresden personnel.
Two of the SR0 candidates were re-
applications.
The overall pass rate was 79%, which is very
close to the national average.
Requalification examinations
were not administered by Region III at Dresden during this
period.
2.
Conclusion
The licensee is rated Category 2.
Although the category rating
is the same given in the last SALP, due to the number of
personnel errors and reactor scrams, the trend in this area is
declining.
This is a significant change from the previous SALP
rating which judged the trend to be improving.
3.
Board Recommendations
The Board recommends that increased management attention should
be given to this area to reverse the declining trend.
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B.
Radiological Controls
1.
Analysis
Seven inspections were performed during the assessment period by
regional specialists.
The inspections included outage radiation
protection, radwaste management, operational radiation protec-
tion, and confirmatory measurements.
The resident inspectors
also inspected in this area.
The following violations were
identified:
a.
Severity Level IV - Uncontrolled liquid radioactive waste
release exceeded gross beta technical specification
concentration in Unit 1 discharge canal (10/84011-03).
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b.
Severity Level IV - Failure to adhere to radiation control
procedures for:
(1) location of personal film badges on
body, (2) performing required personal frisking, (3)
reporting out-of-specification radiochemistry results to
the Radiation / Chemistry Supervisor and Shift Engineer, and
(4) service water sampling requirements to confirm high
monitor readings (10/84011-01,02,04,05); 237/84013-01,02;
249/84012-01,02).
c.
Severity Level IV - Inadequate procedure for filling the
floor drain surge tank.
Procedures did not caution that
the level indicator was inaccurate, thereby causing a liquid
spill (237/84013-03; 249/84012-03).
d.
Severity Level IV - Transfer of contaminated gas cylinders
to persons not licensed to receive or possess radioactive
material (10/85002-03; 237/85005-05; 249/85004-05).
e.
Severity Level V - Failure to specify Tc-99, I-129, H-3,
and C-14 on shipment manifests as required by 10 CFR 20.311(b) (237/85021-01; 249/85017-01).
The Severity Level IV violations were indicative of minor
programmatic breakdowns.
Licensee corrective actions were
generally timely and effective but some procedural adherence
problems still exist.
The Severity Level V violation resulted
from an inappropriate instruction from the corporate office.
Corrective action was again timely and effective.
Overall,
licensee enforcement history improved from the previous SALP
rating period.
Both the extent and severity of violations has
diminished from previous SALP evaluations.
Staffing in this functional area remains adequate.
Vacant
positions are usually filled within a reasonable time.
Significant management changes, including replacement of the
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Rad / Chem Supervisor, Lead Health Physicist, and Lead Chemist
occurred during the period.
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Other staffing changes, including several new staff reporting
to the Lead Chemist, have also occurred.
Sufficient staffing
continuity appears to have been maintained.
The changes should
result in a net strengthening of the licensee's program.
Radiation protection support has also increased with appointment
of additional Radiation / Chemistry Foremen and technicians and
the addition of a new ALARA Section.
This new section consists
of a Lead Radiological Engineer, ALARA Coordinator, and ALARA
Decon Foreman and has resulted in improved pre-job planning, job
coverage, and post-job reviews.
However, several health physics
and engineering assistant positions are vacant owing to
promotions and transfers.
The licensee's policy of rotating
Radiation / Chemistry technicians (RCTs) between health physics
and laboratory assignments results in long intervals between
successive laboratory assignments.
This could limit RCT
proficiency in the laboratory.
Management oversight appeared
adequate during this period but the quality of the laboratory
program would be vulnerable to inappropriate management changes.
The licensee's management involvement has been pervasive.
Audits
are generally thorough and comprehensive; responses and correc-
tive actions are generally good and timely.
Health physics,
chemistry, and radwaste expertise is represented on both the
station and corporate QA audit teams.
Audit findings included
radwaste transport vehicle problems, records retrievability
problems, and isolated technical specification surveillance
problems.
In the radiological protection area, improvements
have been made in job-specific surveys, personal contamination
reports, solid radwaste handling, and supervisory overview of
ongoing work in radiologically significant areas.
Personal
monitoring equipment, personal decontamination facilities, and
respirator cleaning facilities and equipment have been improved.
Also, the management decisions to conduct chemical cleaning of
Unit 2 recirculating system piping before performance of
Inservice Inspection and Induction Heating Stress Improvement
work resulted in a significant reduction in total dose to workers
(ALARA).
However, it was noted during inspections that
administrative duties assigned the Radiation / Chemistry Foremen
occasionally hindered their timely response to radiological
technical matters.
The licensee's responsiveness to NRC initiatives in the radiation
protection area has been good during this assessment period as
evidenced by improvements in self-identification and correction
of radiation protection problems, management support for
implementation of radiation protection procedures, contamination
controls, and health physics coverage of radiologically signifi-
cantjobs.
Evidence of these improvements is noted by more
thorough licensee review of Radiological Occurrence Report and
personnel contamination events, stronger disciplinary actions
for offenders of radiation protection procedures, a reduction
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in dose at the station, and a dramatic reduction in the extent
of contaminated areas.
Also improved was ALARA pre-job planning,
job coverage, and post-job reviews.
The licensee's approach to
resolution of these issues has been technically sound and
thorough.
The training and qualification program contributes to an adequate
understanding of work and fair adherence to procedures with a
modest number of personnel errors.
The policy of rotating RCTs
between health physics and laboratory assignments results in a
long interval between successive laboratory assignments and
requires a high degree of oversight and supervision.
However,
retraining has been enhanced by increasing scheduled formal
training sessions and broadening the scope of retraining to
include refresher training.
Insufficient time has elapsed to
assess effectiveness of the enhanced retraining.
The licensee's approach to resolution of technical issues
generally results in sound and timely resolutions with
appropriate emphasis on radiological safety.
Effectiveness
of the ALARA program has continued to improve during this
assessment period.
Increased ALARA awareness by the station
staff, addition of appropriate manpower to support the ALARA
organization, and greater management support have resulted in
more extensive pre-job planning, engineering controls, and
post-job reviews.
Total worker doses during this assessment period, about 890
person-rem per reactor in 1984 and estimated to be approximately
the same for 1985, represent significant decreases (30 to 35
percent) over the licensee's recent five year dose averages and
are about 20 percent below the national average for U.S. boiling
water reactors.
A further reduction for 1985 was not projected
because of Unit 3 recirculating system piping replacement
scheduled to begin during the fourth calendar quarter.
The licensee's radiological effluents continue to be about
average for U.S. boiling water reactors.
One unplanned liquid
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release above technical specification limits and one unplanned
release below technical specification limits occurred during the
assessment period.
There were no transportation incidents.
Laboratory performance continued to be satisfactory during this
period.
Instrument QC programs were satisfactory and analytical
instruments were operable and calibrated.
An ion chromatograph
obtained during the period-is expected to be put into use by
early 1986.
Laboratory procedures appeared satisfactory. The
licensee has implemented a program to check RCT analyses of blind
samples for conductivity, silica, chlorides, and pH prior to
their starting a three-week laboratory assignment.
The station
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also analyzed fluid samples provided by the corporate laboratory.
These programs should be strengthened and expanded to include
radiological samples to better check laboratory and individual
analyst performance.
Laboratory performance in confirmatory measurements continued
.to be very good with 28 agreements in 29 comparisons made during
the period.
Problems noted in the past with the Automated
Analytical Instrumentation Systems (AAIS) appeared to have been
resolved.
An experienced radiochemist with experience at the
plant provides good oversight for gamma spectroscopy.
2.
Conclusion
The licensee is rated Category 2 in this area.
This is an
improvement over the Category 3 achieved in SALP 4.
3.
Board Recommendations
None.
C.
Maintenance / Modifications
1.
Analysis
This functional area was inspected routinely throughout the
assessment period by both resident and regional inspectors.
In addition, six special inspections were conducted by regional
personnel.
The following violations were identified:
a.
Severity Level V - Hold points and work request forms
were not completed in accordance with approved procedures
(237/85008-01; 249/85007-01).
b.
Severity Level V - Failure of the control rod scram
surveillance procedure to provide for the review and
approval of test results (237/85032-03; 249/85028-03).
c.
Severity Level IV - Failure to perform adequate QC
inspection for piping suspension system n.odifications
to assure conformance to design documentation
(237/84027-01; 249/85013-01).
d.
Severity Level IV - Failure of the Architect Engineer
(AE) to conduct an adequate transient operability analysis
for the LPCI system snubber failure (237/84027-04).
e.
Severity Level IV - Failure to have prescribed standards
and procedures for Class IE cable splicing (237/85014-04a).
f.
Severity Level IV - Failure to assure that design basis
requirements are translated into specifications, drawings,
procedures, and instructions (237/85014-05b).
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One of_the special inspections conducted in this area was
performed.to provide for an indepth' review and evaluation of
the maintenance program and its implementation.
This was the
first in a planned series'of inspections of this type and
was prompted by the Category 3 -rating received in this func-
'tional area during the last assessment pericd (SALP 4).
As
part of the review an extensive sampling of work packages was
inspected, of which approximately 25% were found to have work
request forms not completed in accordance with approved
procedures.
This resulted in the issuance of violation a. as
described above.
Other concerns noted included:
A relatively large work request package backlog and the
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inadequate storage of incomplete packages.
The inability of Quality Control to support maintenance
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acti'/itics during periods when the workload is high.
Some craft personnel were not aware that maintenance
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procedures were required to be at the job site.
It should be noted that although violation a. above did not
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involve a significant' safety issue, the fact that such a'large
. proportion (25%) of the work packages were incomplete. reflects
poorly on the licensee's ability to control and evaluate work
activities. The licensee agreed that plant performance in
regard to the items identified required improvement.
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Another inspection in this functional area was conducted to
determine the adequacy of the licensee's program to meet the
requirements of Generic Letter 83-28, Required Actions Based
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on Generic Implications of Salem ATWS Events".
The inspection
addressed' equipment classification, vendor. interface, post-
maintenance testing,'and reactor trip system reliability.
Violation b. was issued as a result of this inspection; however,
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in' general the licensee's program adequately met the requirements
of Generic Letter 83-28 as ascertained from the areas inspected.
Inspections were conducted to examine the inservice inspection
program including review of activities related to:
(1) the
licensee's actions to satisfy requirements of NRC Generic Letter 84-11; (2) the licensee's actions related to-the Unit 2
Main Steamline-(MS) and Low Pressure Coolant Injection (LPCI)
piping snubber failures, including an independent review to
determine the cause of failure, and followup of Confirmatory
Action Letter 85-04; (3) the replacement of the Unit 2 Reactor
Water Cleanup System piping, including a review of procedures,
welder qualifications, radiographs, and other related documenta-
tion, and observations of piping spool fabrication and inprocess
welding; and (4) the licensee's actions to evaluate the effects
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of upgrading safety-related piping system supports that meet
IE Bulletin 79-14 location verification requirements.
As a
result of these inspections, violations c. and d. were
identified.
The violations were not repetitive of any identified
during the previous assessment period, and do not appear to have
generic or programmatic implications.
A significant causal
factor in the inspection discrepancies was the failure of
personnel to adhere to field change procedures.
Two inspections were conducted during the assessment period to
evaluate the Unit 2 125V DC system modification performed to
replace the degraded Unit 2 battery with the Unit 1 High
Pressure Coolant Injection Battery.
Two violations (e) and (f)
were identified to have occurred during the modification.
In summary, the licensee has shown overall improvement in this
functional area since the last assessment (SALP 4) as evidenced
by a significant reduction in the number of LERs issued as a
result of personnel errors by maintenance / modification work
groups (14 in SALP 4 as compared to 4 this period) and in a
reduction of NRC violations issued (11 violations in SALP 4 as
compared to 6 violations this SALP period).
However, further
improvements are required in the area of program implementation.
The licensee has dedicated additional resources to this area in
the form of management attention, training, and better communica-
tions with workers and first-line supervisors to create a
greater awareness of maintenance activities.
The licensee has continued to develop new procedures as necessary
and to use an extensive system of maintenance manuals (as
outlined in previous SALP reports) to aid maintenance activities
onsite.
Response to NRC initiatives is generally timely with
few longstanding issues attributable to the licensee.
Resolution
of technical issues from a safety perspective has been generally
conservative, sound, and thorough.
Maintenance records were generally complete, well maintained,
and available.
Maintenance personnel were adequately trained
and direct observations of work activities indicate the work
force has an adequate understanding of work practices and
procedures.
The inadequacy in the Architect Engineer's operability analysis
performed for the LPCI system snubber failure and the failure of
quality control to adequately inspect modifications to assure
conformance to the design documentation indcate that, although
there is an overall improvement in license- (
%rmance in this
functional area, a decline in performance.s %
rent in this
one narrow area.
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2.
Conclusion
The licensee is rated Category 2 in this area.
This is an
improvement over the Category 3 received in SALP 4.
3.
Board Recommendations
None.
D.
Surveillance and Inservice Testing
1.
Analysis
During the assessment period, the resident and regional inspectors
routinely inspected this area, concentrating on implementation
of procedures.
The inspectors also verified that procedures
were adequate, that test instrumentation was calibrated, that
limiting conditions for operation were met, that removal and
restoration of the affected components was accomplished, that
test results conformed with Technical Specifications and
procedure requirements and were reviewed by personnel other than
the individual directing the test, and that any deficiencies
identified during the testing were properly reviewed and resolved
by appropriate management personnel.
During these inspections
the following six violations were identified:
a.
Severity Level V - Inadequate procedures resulting in no
'
precaution to operators on SBGTS flow and passive supports
for batteries being left off after maintenance (237/84018-
02A,'2B; 249/84017-02A, 28).
b.
Severity Level V - A number of examples of failure to adhere
to surveillance procedures (237/85016-01).
c.
Severity Level V - A number of examples of failure to
implement Quality Assurance procedures (237/85016-02).
d.
Severity Level IV - Failure to trend and evaluate valve
inservice testing data for Unit 3 during 1984 (249/
85005-07).
e.
Severity Level V - Failure to use calibrated measuring and
test equipment during surveillance testing (237/85006-06;
249/85005-06).
f.
Severity Level V - Failure to verify remote position
indicators for accessible valves and to measure pump
i
suction pressure with an idle pump as required by
Section XI of the ASME Code (237/85006-01; 249/85005-01).
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2This'is aLsignificant increase from.the previous assessment
-period when there were no violations and may be indicative of a
relaxed attitude and inattention to detail.' Furthermore, there
were several examples for two of the violations indicating that
there were more than six events.
Additionally, the events are
not limited to any specific functional area.but rather involve
diverse areas such as operational-surveillance, core performance
testing and inservice testing.
This may be indicative of a
-
.
programmatic weakness in surveillance testing.
'
.During inspection of core performance testing and startup
related activities it became evident that improvements are.
needed in the quality of surveillance records and implementation
of surveillance procedures (violations b. and c.).
While
evidence of management involvement exists, violations b. and c.
and.the necessary supplemental responses indicate increased
attention is required to not'only assure proper implementation
of procedures but to ensure timely and thorough evaluation and
response to identified concerns.
~The inspections relating to the inservice inspection (ISI) of
piping systems and the. functional testing of snubbers included a
review of the ISI program, procedures and drawings, equipment
and material certifications, personnel qualifications, records
and associated documentation for completed work, and selected
records'of nondestructive examinations performed during the
October 1984 to April 1985 refueling outage for Unit 2.
The
completeness, availability, and quality of the documentation
indicated the appropriate levels of management overview were-
being applied.
Except for violations (d), (e) and (f), the licensee had fully
implemented the inservice testing program f~ ?" ps and valves
and was conducting Letting in accordance with appropriate
schedules and approved test procedures.
Pump testing was
generally well defined and determination of operability was
made in a timely manner.
In addition to violation d., the
licensee was unable to verify or retrieve the valve test results
during the inspection.-
The licensee continues to show managerial involvement and the
approach to technical and NRC issues is appropriate and timely.
The licensee's responsiveness to inspection related concerns was
deemed very good.
The ifcensee submitted the required reports
and associated analyses within the time constraints imposed.'
The. licensee's training, staffing, and qualifications were
adequate.
Management control systems were effective in that
activities received prior planning and priorities had been
assigned.
Activities were controlled through the use of well
s
stated and defined procedures.
As stated previously, although
.
.:__a_________
_ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _. _ _. _ _. _ _ _ _ _ _ _. _ _ __ _ _ _ _. _ _ _ _ _ _. _ - _ _ _ - -.. _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _. _.. _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _. _ _. _ _ _. - _. _ _ _. _ _ _.. _ _ _ _ _ _ _ _ _ -..... - - _ _ _ _ _ _. _ _ _ _ _ _. _ _. _ _ _ - - _ _ _. _. _ _ _
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.
.
the licensee was unable to retrieve valve test results during an
inspection, overal records were found to be generally well
maintained and available.
The records also indicated that
equipment and material certifications were current and complete
and that personnel were trained and certified.
2.
Conclusion
The licensee is rated Category 2 in this area.
This is a
reduction from the rating received in the last SALP period.
This is primarily due to the increase in violations and the
apparent programmatic weaknesses indicated.
3.
Board Recommendations
None.
E.
Fire Protection / Housekeeping
1.
Analysis
Throughout the assessment period, the resident inspectors
observed the implementation of the licensee's fire protection
program.
One inspection involving a region based inspector was
also conducted to review the circumstances leading to Licensee
Event Report (LER) No. 85-029-0 and the corrective actions
related to the event.
Two violations were issued as follows:
a.
Severity Level IV - Failure to establish a continuous
fire watch in a timely manner (237/85028-01; 249/85023-01).
b.
Severity Level IV - Failure to test the automatic actuation
of the Master Cardox system valve (237/84011-02);
249/84010-02).
The first violation was identified as a result of a special
surveillance test in which three of five fire dampers failed in
the open position.
A major factor contributing to this event
was a lack of understanding of the Technical Specification
requirements for inoperable fire dampers on the part of the
Station Fire Marshall.
This resulted in a delay in notifying
the Operations Department of the failed dampers.
This is viewed
as a training deficiency. The Operations Department promptly
established the required fire watches upon notification of the
Thus, the technical issues were properly
addressed once identified.
The LER itself was submitted in a
timely manner and contained the required information.
The
licensee was very cooperative in resolving the issues identified
in the LER.
No other violations or open items were identified.
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Housekeeping and plant appearance have improved throughout the
SALP period.
The licensee has established a special crew for
this purpose, supervised by an ex-shift foreman who holds an
SR0 license.
Along with general cleaning, the crew has the
responsibility of reducing the contaminated areas in the plant,
painting and generally improving appearances.
This has resulted
in. improved appearance in numerous areas in the plant and in a
number of areas that were made accessible without protective
clothing.
In spite of the foregoing, housekeeping at Dresden
remains a problem with craft personnel not picking up after
completion of a job and areas becoming recontaminated during
maintenance work.
In addition, it is common to see numerous
cigarette butts and loose trash in non-safety /non-health physics
controlled areas reflecting poor attitudes on the part of the
work force.
Station management has acknowledged this situation.
'Although housekeeping is an important factor in fire prevention,
the board also recognizes the necessity of maintaining the plant
as clean as reasonably possible to prevent dirt, dust, etc. from
intruding into safety-related systems and components since their
presence can ultimately challenge the reliability of system
operability.
The licensee should take steps to correct the
attitudes that have resulted in the poor housekeeping habits,
especially at the worker and f;irst line supervisor levels.
.c \\
With regard to final implemer.tation of the fire protection
requirements of 10 CFR 50 Appendix R, as they apply to Dresden,
,
there are a numtier of outstanding issues.
Thesd issues are the
. subject of ongoing discussion between the licensee and the NRC.
2.'
Co'nclusion
'
The licensee is rated Category 2 in this area.
The trend was
improving early in.the SALP perio'd and has shifted to declining
-later in the period.-
3.
Board Recommendations
s
The board noted that shortly after the close of the} SALP 5
'
period, a fire protection inspection was conducted which indi-
cated potentially significant weaknesses in the implementation
of existing. fire protection requirements.
These weaknesses,
some of which were. identified by the licensee, are currently
D
under review by the licensee in an effort to improve the program.
- This effort will be closely monitored by. Region III.
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- F..-
Emergency Preparedness-
1.
< Analysis
'
Three inspections were conducted during the. period to evaluate
the.following aspects of the. licensee's emergency preparedness
program:
(1) emergency detection and classification,
(2) protective. action decision' making,-(3) emergency notifications,
(4) emergency communications' systems, (5) shift augmentation
provisions, (6) emergency preparedness training, (7) independent
audits of emergency preparedness, and (8) implementation of
_
changes to the emergency-preparedness program.
Two of these
. inspections were observations-of annual emergency exercises.
No
violations or deviations from commitments were identified during
the period.
~Manag' ment involvement in the emergency preparedness program has
e
been adequate with evidence of assignment of prioritics and
explicit procedures for control of activities.
Independent
,
s
audits of:the emergency preparedness program were thorough,
being adequate.in scope, depth, and frequency. Audit records
were complete, well-maintained, and readily available.
During
the period'the. licensee has improved its capability to monitor
corrective actions by utilizing effective tracking systems.
Administrative procedures were adhered to regarding the prepara-
' tion, review, and distribution of the emergency plan and its
~
implementing-procedures.
Plan'and procedure revisions were
consistent and did not decrease their effectiveness.
Training
recordkeeping improved during the period; however, updating of
records, with training performed,_in a timely manner remains as
a problem area.
Management involvement and control in assuring quality of the
emergency preparedness program is further evidenced by the
licensee's corrective action system, which promptly recognized
and addressed several nonreportable concerns..For example, a
Quality Assurance. Surveillance of.a Health Physics Drill iden-
tified the need for a timing device and a lack of heating where
low temperatures could cause adverse affects.
These items were
-brought to management attention and both were resolved in~a
timely manner.
The licensee's responsiveness to NRC initiatives has been
l
timely, with technically sound and thorough responses in almost
all. cases. Whenever the-licensee was required to formally-
,
respond-to-exercise weaknesses, they responded weil before the
due dates.
All proposed corrective actions were acceptable,
.
including the~ proposed completion schedules.
Effective
corrective _ actions on the majority of the previously identified
.open items were completed during the period.
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.
Records of eight activations of the emergency plan were evaluated
during the SALP period.
All emergency conditions were properly
classified.
Initial notifications to the NRC and State of
Illinois were completed in a timely manner following each
emergency declaration.
The licensee has maintained a prioritized roster of sufficient
numbers of qualified personnel to fill well-defined key positions
in the emergency organization.
Augmentation capabilities have
been adequately demonstrated by periodic drills.
The licensee
has involved both primary and alternate persons assigned to key
positions in emergency drills and exercises.
The licensee's training and qualification program contributes
to an adequate understanding of emergency responsibilities with
only a modest number of personnel errors, as evidenced by
exercise and walkthrough performances.
However, some areas
were identified which indicated a decrease in training emphasis.
In the Operational Support Center, the lack of adequate briefings
of teams has been identified in the last two exercise inspections.
Additionally, some radiological control personnel exhibited
insufficient knowledge of various tasks and associated procedures
during both exercises.
2.
Conclusion-
The licensee is rated Category 1 in this area, with the trend
being essentially the same throughout the period.
3.
Board Recommendations
None.
G.
Security
1.
Analysis
Two routine security inspections were conducted by region based
physical security inspectors during the assessment period.
In
addition, the resident inspectors routinely conducted observations
of security activities.
Two violations were identified relative
to the security program as follows:
a.
Severity Level IV - The licensee failed to adequately
implement a section of the background screening program
for contractor employees (10/85003-04; 237/85007-04;
249/85006-04).
b.
Severity Level V - The licensee failed to implement an
adequate compensatory measure (10/85003-02; 237/85007-02;
249/85006-02).
m
.
.
In addition to the two violations, a concern was identified
regarding an ineffective maintenance program for some security
related equipment.
Further, an anonymously written allegation was received by
Region III that dealt with an individual working onsite while
under the influence of alcohol and that he had been terminated
from other nuclear sites for alcohol and drug abuse.
The
inspectors determined that the licensee took adequate and
immediate followup action after receiving the information.
The allegation was not substantiated and no enforcement action
was required.
Regarding the compensatory measure violation, the implementation
of the compensatory measures for the failure of a perimeter
intrusion alarm zone was not effective, in that the CCTV being
used to monitor the affected zones was out of focus.
Therefore,
the guard posted to observe and monitor could not adequately
assess activities in the alarm zone.
The significance of this
violation was increased due to the fact that:
(1) a work
-request had apparently been written but not acted on for a long
time;'(2) guards apparently had become complacent and used a
less effective system; and (3) the importance of complete
implementation of compensatory measures should have-been recognized
as critical, based on the Severity Level III violation cited in
the last SALP period.
The violations identified were early in the assessment period,
were minor, and were corrected in a timely manner.
The item of concern identified the lack of timely action by
the electrical maintenance department to repair security-related
equipmyt.
Individually, none of the outstanding maintenance
items represented a significant failure of the security program;
however, the volume of items appeared to indicate a lack of
management action in assuring those items were corrected in a
timely manner.
Additionally, the licensee's preventative
maintenance program for the CCTV and protected area intrusion
alarm system was discontinued approximately two years ago due
to manpower shortages.
Based en this finding, the licensee was requested to respond to
the concern describing their short and long range program for
reducing the backlog of outstanding electrical maintenance
requests.
Additionally, the licensee was requested to
immediately re-establish a preventive maintenance program for
security-related electrical items and to keep the Region
informed of progress in the area. The licensee responded to
this concern in a timely manner and the corrective actions taken
appaar to be adequate.
.
.
There were no technical. issues involving physical security, from
a safety aspect, which required resolution during this assessment
period.
The licensee has provided a technically sound and thorough
response to NRC initiatives such as the development of a security
drill program to address all of the contingency events identified
in the Safeguards Contingency plan.
. Events reported under 10 CFR 73.71 were accurately identified
and reported in a timely manner.
The number of reportable
events-decreased significantly in this assessment period which
was attributed to improvements made to the security computer.
Positions within the security organization are identified and
responsibilities are defined.
The staffing levels for the
uniformed security force appeared adequate.
There is good
communication between the licensee and the contract guard force.
The training effectiveness and qualification of the guard force
is adequate.
This was demonstrated during the alert that occurred
during the assessment period, when the guards performed their
duties adequately and in a professional manner.
Corporate security involvement has increased during this
assessment period and has provided excellent support to site
security operations.
The licensee promoted from within to fill
vacancies at the corporate (Senior Nuclear Security Adminis-
trator) and site (Station Security Administrator) levels.
Both
individuals are knowledgeable of past and current security
practices at Dresden.
Due to his vast experience, the promotion
of the Station Security Administrator to a corporate security
level position should further enhance corporate involvement with
the site.
Good communication exists among corporate, site security,
and Region III NRC.
Except for the maintenance concern, senior management support
of security operations was made evident by the upgrading of
the security computer, the purchasing of new explosive detectors,
closed circuit television cameras, and the construction of new
nuclear security training facilities which include both
administrative offices and classrooms.
In summary, the contract security performance and corporate
security involvement in site activities has been strong and
consistent except in the electrical maintenance backlog of
. security equipment.
__
.
.
Conclusion
The licensee is rated Category 2 in this area, which is the
same SALP rating given in the previous assessment period.
A positive trend has been identified during this assessment
period in that the licensee continues to increase its efforts in
upgrading security.
3.
Board Recommendations
None.
H.
Refueling
1.
Analysis
Refueling activities we're inspected by the resident inspectors
during the refueling outage on Unit 2, and the return to power
on Unit 3.
The licensee continues to maintain their high
level of performance.
Personnel involved are well trained
and staffing is ample.
The licensee completed the remaining
shipments of Unit 1 spent fuel from West Valley, New York to
Dresden without incident.
One inspection of core physics and refueling was performed by
a Region III specialist.
No violations were identified.
The
inspection activities included a review of training records,
fuel handling equipment check out procedures, fuel handling and
surveillance test procedures, results of fuel reuse inspections
and fuel sipping operations, and several shifts of core alterations
for Unit 2.
The licensee continues to use a permanently assigned refueling
group that demonstrated the qualities of a well managed and
proficient fuel handling team.
There was evidence of prior
management attention and planning as the fuel movements were
handled safely and efficiently.
There was good coordination and
communication among the various licensee work groups that support
fuel handling.
Problems encountered were handled effectively
with minimal loss of time.
Personnel were knowledgeable of
their duties and staffing was adequate to support all fuel
handling evolutions.
2.
Conclusion
The licensee continues to be rated Category 1 in this area.
3.
Board Recommendations
None.
.
.
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I.
~ Quality Programs and Admir.istrative Controls
H.
1.
Analysis
Routine observations by resident inspectors were made in this
area.. This functional area was also examined.by four region
based inspectors during two inspections within the assessment
- period. These inspections were performed to determine the
adequacy of procurement, calibration, tests and experiments,
Lquality program control, records, and offsite review committee
and support staff activities.
The following violations were
identified:
a.
Severity Level IV'- Failure to evalu-te a possible
discrepancy for disposition in a timely manner
(237/84026-01; 249/84023-01).
- b.
Severity Level IV - Three examples of failure to follow
'
procedures (237/84015-07; 249/84014-07).
c.
Severity Level V - Failure to perforr a seismic evaluation
on a substitute motor for the HPCI aue.iliary oil pump
(237/84015-08; 249/85014-08).
'd.
Severity. Level V - Failure to provide training on QA
program changes within the time frame specified by the
QA program (237/85029-02; 249/85024-02).
The-procurement inspection was a special inspection of the Ceco
procurement program and its implementation at all operating
sites.
During this inspection violations b. and c. specific
to Dresden were disclosed.
--With. regard to violation-b., the examples involved purchase
orders failing to impose'a. review for suitability of application
on-the vendor as required by the Ceco procurement program.
- While the individual examples had minor safety significance, the
multiple examples of the failure to impose programmatic
requirements indicated the need for added management attention
in this' area. 'With regard to violation c.,
the motor is
currently in a hold status pending a licensee decision on its
disposition. The licensee has implemented procedure changes
for both items,.which should preclude recurrence.
_InadditiontotheDresdenspecific.itemsaddressedabove,six
other items.were disclosed relating to the Ceco corporate
_
procurement program which apply to Dresden as well as the other
operating sites..These items were of~ concern, in that they
represented programmatic' weaknesses that provided a potential
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for the procurement, installation, and use of unqualified items.
-
The licensee's proposed action re' eating to these unresolved
items' appears to mitigate some of the weaknesses; however,
further NRC review is required before these items can be
- ~
dispositioned.
With regard to violation d.on training, the licensee had a
commitment to train all appropriate personnel on changes to the
nuclear Quality Assurance Manual within 60 days of the date of
i
revisions so that the changes would be effectively implemented.
<
'
On one recent revision, there were over 20 job classifications
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-of site personnel who were not given the required training
'
within the specified' time period.
This failure was of concern
.
because.of the number of personnel who did not receive the
training in a timely manner.
Some of the changes were
administrative in nature without direct safety applications, so
the overall_ impact'of this' violation was_of limited safety
'
significance.
- The. licensee's performance in the functional areas of
'
Calibration, Records, Offsite Review and Support Staff was -
a
found to be satisfactory.
No_ items of concern were identified
requiring further action by the licensee or the NRC in these
{
three areas.
In-' summary, the procurement area was controlled by a sometimes
.
.poorly stated program containing some weaknesses. Weaknesses
in program implementation indicated.the lack of management
-
. attention in this area and the need for more effective staff-
~
training.
The failure to provide training in QA program
~
changes also supported the need for more management attention.
The licensee has initiated corrective action to address these
,
issues.
The other area of inspection disclosed one minor item of concern
-in the functional area of Tests and Experiments.
The licensee.
will be conducting a special sampling review of completed
>
'
modification and maintenance work packages to verify that the
required technical evaluation had been completed on replacement
parts used in safety-related components.
'
2.
Conclusion
,
'
The licensee is-rated a Category 2 in this area.
,
3.
Board Recommendations
'
None.
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J.
Licensing Activities
~1.
Analysis
a.
Methodology
The basis for this appraisal was the licensee's performance
in support of licensing actions that were either completed
or had a significant level of activity during the current
rating period..These actions, consisted of amendment
requests, exemption requests, responses to generic letters,
TMI items, and other actions, including the following
specific items:
(1)_ Multiplant Action Items (MPAs) completed or having a
significant level of review action completed include:
NUREG-0737 Item (six items closed for D2 and D3,
one item (I.A.2.1) near closure for both units)
NUREG-0737 Technical Specifications - GL 83-36.
Completed except for Post Accident Sampling and
Control Room Habitability for the station
NUREG-0737 Supplement 1 Items:
SPDS in progress review, station
DCRDR in progress review, Final
Summary Report submitted
Procedures Generation Package (PGP)
for E0Ps.
RAI sent
Response to GL 81-04, NUREG-0313, completed
Control of Heavy Loads, Phase II, completed
Mark I Long Term Program, completed
GL 84-13 TS (Snubbers), completed
Environmental Qualification Schedular Extension,
completed
Radiological Effluents T.S. (RETS), completed
IST (2nd ten years) Relief Requests approved
GL 83-28, Salem ATWS Items 1.1, 3.1.1, 3.1.2,
3.1.3, 3.2.1, 3.2.2, 3.2.3, and 4.5.1 completed
IE Bulletin No. 84-01, Cracks in Mark I Contain-
ment Vent Headers completed
.
.
.
Response to GL 84-09, RAI sent
- -
B-24, Containment Isolation Depenjability by
Demonstration of Purge and Vent Vilve Operability,
near closure
Response to GL 84-11, completed
Appendix R Schedular Exemptions - RAI sent,
near closure
(2) Plant Specific Action Items completed or having a
significant level of review include:
Reformatting of entire Technical Specification
.
for D2 and 03, completed
Emergency Preparedness Exercise Exemption, issued
Transfer of Dresden 1 Spent Fuel from West Valley
to Dresden Station, completed
-Decontamination of Dresden 1, completed except
for disposal
s
T.S. change relating to extension of MAPLHGR Curves,
D3,_ completed
T.S. for Cycle 10 Restart, D2, completed
Installation of Liquid H2 Storaga Tank at Dresden,
near completion
T.S. relating to Administrative Controls, D2 and
D3, completed
T.S. relating to SEP Topics VI-7.C.1 and XV-iS,
,
D2 and D3, completed
T.S. relating to Revision of T.S. Table 3.7.1, D2
and D3, completed
T.S. relating to Economic Generation Control, D2
and D3, completed
SEP Item - Thermal Overload Protection of M0Vs,
02, completed
T.S. - Deletion of Recirculation Equalizer Valves,
03, completed
Appendix J Exemptions, 03, completed
,
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b.
-Management Involvement and Control in Assuring' Quality.
Commonwealth Edison management has an awareness of the
various licensing issues by virtue of-its extensive
experience in the. industry, technical expertise, and active
participation in Owners Group and professional organization
activities.
Commonwealth management takes actions in a
,
timely manner to ensure safety issues are properly addressed.
These actions include. frequent. visits to NRC Headquarters
by the Director of Nuclear Licensing to discuss progress in
-
general on resolution of outstanding _ issues.
Specific
examples of this attribute in the report period are: (1)
the involvement of management all through the period
relative'to the req'uirements of Generic Letter 84-11 which
relates to the inspections of BWR stainless steel piping.
Because of management _ involvement with this issue,
Commonwealth's response to GL 84-11 was such that the staff
considered them acceptable relative to current IGSCC
concerns; (2) the response to NRC's need for effective
action and/or information regarding the loss of offsite
power event at Dresden 2 on August 16, 1985; and (3) the
care that Commonwealth took in evaluating the September 19,
1985 event where leaking scram solenoid valves caused
reactor: coolant to leak into the Reactor Building via the
vent and drain valves.
c.
Approach to Resolution of Technical Issues from a Safety
Standpoint
Commonwealth's responses to most technical issues are su:h
that few reviewer Request' for Additional Information (RAIs)
.
are needed. When RAIs are issued, Commonwealth's responses
are timely and technically accurate. The need for conference
calls to resolve issues are rare and, when~ conference calls
are made, Commonwealth has the proper technical expertise
available to respond to remaining staff concerns.
They
have a well qualified engineering staff and even a recent
licensing contact change did not interrupt the flow of
information to continue adequate review of outstanding
issues..This is an indication of the depth of quality of
Commonwealth's staff.
They also make appropriate use of
contractors when needed.
The resolution of the large number of multiplant issues
demonstrates that Commonw2alth's staff understands complex
technical issues in terms of' plant safety, plant operation,
and responsiveness to regulatory concerns.
.
.
During the report psiod several issues were identified for
which prompt and effective action was appropriate.
In each
case, the licensee promptly evaluated the problem and took
action to provide interim repairs or other appropriate
actions to satisfactorily resolve the issue from a
safety standpoint.
In each case Commonwealth Edison
furnished the staff promptly with the information required
to evaluate the possible safety concerns.
In addition, as
required for staff licensing actions, the necessary docu-
mentation was made available so that licensing deadlines
could be met without straining staff resources.
d.
Responsiveness to NRC Initiatives
Communication between NRC and Commonwealth generally occurs
between the respective licensing staffs.
However, on the
occasions where the need for information directly from
Dresden occurs, appropriate and technically competent
personnel have responded to staff concerns.
All technical
specification requests are initiated by the station and
the cooperation in satisfying staff documentation needs
during TS processing has been excellent.
This cooperation,
in fact, was extremely important during the reformatting of
the entire D2 and D3 Technical Specifications during the
evaluation period.
While Commonwealth responds to most staff concerns promptly
and is very cooperative when urgent safety issues appear,
they are much slower to respond to concerns that do not
effect them in an immediate way.
This causes reviews of
such concerns to remain outstanding longer than the staff
believes necessary.
Three specific items of this type
are:
(1) the closure of SEP items which will lead to the
Provisional Operating License-Full Term Operating Licensee
conversion for Dresden 2; (2) the licensing issues relating
to the use of the Mobile Volume Reduction System; and (3)
the approval of the use of the Liquid Hydrogen Storage Tank.
Resolution of these issues should be expedited during the
next rating period.
e.
Housekeeping
The NRR Project Manager has visited the site on numerous
occasions.
However, during the evaluation period the
visits involved issues which did not require an extensive
site tour. Visits to the Control Room were made in March
and June 1985. The Control Room appeared to be well
maintained and operated in a professional manner.
There
was no evidence of food and drink containers and all
reading material appeared related to operational needs.
In
earlier discussions with the Dresden Senior Resident
.
,
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- _.
-. _ -
...
__
.
.
Inspector, a concern was expressed by him of housekeeping
problems at Dresden. However, more recent contacts
indicated that these concerns were being reduced.
f.
Fire Protection
Nearly all ~ plant modifications resulting from the NRC
staff fire protection review have been completed, and
exemptions were issued where appropriate.-
In late 1983, NRC issued a clarification of the
requirements of Appendix R.
In response to the NRC
clarification, the licensee then initiated an independent
review of their fire protection program, and additional
exemptions were requested beyond those resulting from the
original NRC fire protection review.
These are currently
under NRC staff review.
2.
Conclusion
The licensee is rated Category 1 in this area.
This is an
improvement from last years Category 2 and is due to improve-
ments in timeliness and resolution of licensing activities.
3.
Board Recommendations
None.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
Unit 1 was officially declared " Retired in Place" on August 31, 1984.
Presently, the licensee is deliberating the disposition of the unit.
Chemical cleaning commenced on September 12, 1984.
"
Units 2 and 3 engaged in routine power operation throughout most
of SALP 5.
A major scheduled Unit 2 outage for plant refueling,
modification, and maintenance began on October 5, 1984 and was
completed on April 13, 1985.
A major unscheduled outage for
turbine repair was in progress at the beginning of the assessment
period for Unit 3 and was completed on July 21, 1984.
The remaining outages throughout the period are summarized below:
_U__ nit 2
June 21 to July 1, 1984
Repair 2A feed regulator valve
June 9 to June 13, 1985
Repair 2B MG set
June 18 to June 20, 1985
Repair EHC
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_- _
_-.
.
_
August 2 to August 6, 1985
Repair turbine oil reservoir
tank
August 16 to August 22, 1985
Repair auxiliary transformer
August 22 to August 25, 1985
Repair 2B feed pump
September 29 to October 10,
1985
Inspect snubbers
Unit 3
August 21 to August 22, 1984
Repair 3A feedwater valve
September 11, 1984
Repair EHC oil leak
September 25 to October 1, 1984
Repair main condenser leak
October 1 to October 4, 1984
Repair feedwater regulator
valve
October 4 to October 5, 1984
Repair EHC oil leak
October 20 to October 23, 1984
Feedwater regulator valve
problems
October 26 to November 2, 1984
Routine maintenance
January 12 to January 14, 1985
Oil trip solenoid valve on
turbine
April 26 to May 3, 1985
Repair feedwater heaters and
take measurements of recircula-
tion piping
Unit 2 scrammed twenty-one times (ten occurred while shutdown) and
Unit 3 fourteen times (four occurred while shutdown).
Fourteen of
the Unit 2 scrams and none of the Unit 3 scrams were attributed to
equipment malfunctions and required minor maintenance prior to
returning the units to service.
Two scrams occurred at power for
Unit 2 which were attributable to personnel error.
Three scrams
occurred at power for Unit 3 which were attributable to personnel
error. While both units were shut down, four scrams were attributed
to personnel error.
Three scrams during SALP 5 were due to defective
procedures.
The licensee formed a scram reduction committee late in this SALP
period because the number of scrams have approximately doubled each
of the last two SALP periods. The purpose of this committee is to
review each scram and provide feedback to all appropriate site
personnel to prevent similar scrams from occurring in the future.
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B.
Inspection Activities
A special NRC HQ's trial outage team inspection was begun on
September 5-6, 1985, to assess the stations' performance during
the Unit 3 recirculation pipe replacement. This is the second
of two NRC inspections to be performed on plants that will have
extended outages.
The inspection is being conducted in accordance
with a proposed NRC procedure to analyze details of new designs /
modifications for older sites.
Violation data for Dresden is presented in Table 1, which includes
Inspection Reports 84009 through 85014 for Unit 1, 84010 through
85032 for Unit 2, and 84009 through 85028 for Unit 3.
TABLE 1
INSPECTION ACTIVITY AND ENFORCEMENT
No. of Violations in Each Severity Level
Functional
Unit 1
Unit 2
Unit 3
Site
Areas
III
IV V
III
IV V
III
IV V
III
IV V
A.
Plant
Operations
1 1
3 2
4 2
B.
Radiological
Controls
3 1
3 1
4 1
C.
Maintenance /
Modifications
4 2
1 2
4 2
D.
Surveillance
and Inservice
Testing
1 3
1 5
E.
Fire Protection
2
F.
Emergency
Preparedness
G.
Security
1 1
1 1
1 1
1 1
H.
Refueling
I.
Quality Programs
and Administrative
Controls
2 2
2 2
2 2
J.
Licensing
Activities
TOTALS
4 1
13 12
13 11
18 13
.
.
C.
Investigations and Allegations Review
During a safeguards inspection, reviews were made as followups to
three anonymous allegations received on December 4, 1985 by the
Senior Resident Inspector.
The allegations concerned:
(1) DNI-
Radman suspected of alcohol use, (2) Commonwealth Edison Company
was told of the problem and did nothing,'and (3) Commonwealth
Edison Company needs a quality screening program.
The inspectors
determined that the licensee took adequate and immediate action
after receiving the information.
No violations of regulatory
requirements were identified and the allegation was not
substantiated.
On January 7,1985, a NRC contractor employee contacted the NRC
with concerns about an incident that occurred four years ago when
control rod drive pressure was too high, went offscale, and a rod
moved more than 1 notch.
A review of the incident determined that
the licensee reported.this in an LER which was followed by the
residents and closed in a routine inspection.
No violations of
regulatory requirements were identified.
D.
Escalated Enforcement Actions
There were no escalated enforcement actions during the assessment
period.
However, an Order imposing civil penalties in the cumulative
amount of $130,000 was issued in 1985 for violations occurring during
SALP 4.
E.
Management Conferences Held During Appraisal Period
1.
Confirmatory Action Letters (CAL)
A CAL was issued April 15, 1985 to confirm licensee action
regarding monitoring and surveillance actions required as a-
result of the damage sustained by several main steam piping
mechanical snubbers at Unit 2.
2.
Management Conferences
a.
September 7, 1984 (Glen Ellyn, Illinois)
Meeting to discuss licensee performance in regards to
'
their Regulatory Performance Improvement Plan (RPIP).
.
b.
September 17, 1984 (Glen Ellyn, Illinois)
Management meeting to review Systematic Assessment of
Licensee Performance (SALP 4).
s
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c.
March 7, 1985 (Glen Ellyn, Illinois)
Meeting to discuss licensee performance in regard to
their RPIP.
d.
June 24. 1985 (LaSalle County Station)
Meeting to discuss licensee performance in regard to
their RPIP.
e.
July 16, 1985 (Glen Ellyn, Illinois)
Meeting to discuss additional aspects of the licensee's
RPIP.
3.
Enforcement Conferences
March 25, 1985 (Glen Ellyn, Illinois)
Meeting to discuss the increase in personnel errors and
HPCI inoperability.
F.
Review of Licensee Event Reports and 10 CFR 21 Reports
1.
Licensee Event Reports (LERs)
LER's issued during the 16 month SALP 5 period are presented
below:
Unit 2
Unit 3
LERs No.
LERs No.
84-05 through 84-25
84-05 through 84-23
85-01 through 85-34
85-01 through 85-16
Proximate Cause Code *
Number During Salp 5
Personnel Error (A)
Design Manufacturing,
Construction / Installation (B)
Defective Procedures (D)
Others (X)
Total
- TJ
- Proximate cause is the cause assigned by the licensee according
to NUREG-1022, " Licensee Event Report System."
<
,
.
During the SALP 5 period, 93 Licensee Event Reports (LERs) which
were required by 10 CFR 50.73 were submitted.
Of these, two
-addressed occurrences on Unit 1, 56 were associated with Unit 2,
and 35 LERs were submitted relating to Unit 3.
In most cases,
the LERs were submitted in a timely manner and in accordance
with NUREG-1022, " Licensee Event Report System." However, in
four cases, LERs were submitted which exceeded the 30 day time
limit.
This was due, in part, to some initial confusion on the
part of the licensee as to what specifically constituted a
reportable occurrence following the change of the NRC reporting
requirements in January 1984.
The licensee conducted a review
of station deviation reports (DVRs) in the Fall of 1984 to
ascertain if all reportable items were issued as LERs and found
that some had been overlooked.
These were then subsequently
made into LERs and submitted.
During subsequent reviews, no
further problems in this area have been identified to date.
Because of the change in reporting requirements that occurred
in January 1984, a detailed comparison of LERs submitted during
SALP 4 and SALP 5 could not be made.
However, tha number of
LERs as a result of personnel errors have increased signifi-
cantly.
A portion of an enforcement conference discussed this
increase.
The number of component failures that were reportable
decreased during the last SALP period.
This is indicative of the
licensee's increased management attention in this area.
Of the 93 LER's submitted by the licensee during the SALP 5
period, 35 were due to unscheduled scrams or RPS actuation
which are discussed in this report under the Operations
Functional Area.
A review of the LERs identified that the
licensee has reported a number of ESF events even though the
actuation was anticipated and would therefore not be reportable.
During the SALP 5 period, where events are caused by personnel
error, and the licensee's investigation reveals that it was
carelessness or disregard by an individual, the licensee has
exercised stronger actions against the individuals who caused
the event.
This has been part of the effort to improve attitudes
and achieve a better sense of accountability to perconnel working
in the plant.
Notwithstanding the positive aspects of the licensee's reporting
system, an assessment by the Office for Analysis and Evaluation
of Operational Data (AEOD) of the quality of LERs submitted found
that the LERs were of barely acceptable quality based on the
requirements contained in 10 CFR 50.73.
The most significant
areas that need improvement are:
root cause discussions,
personnel error discussions, corrective actions to prevent
recurrence, safety assessment information, manufacturer and
<
model number information, date and time information, text
presentation consistency, text readability, and abstracts and
x
.
.
titles need to be written such that they better describe the
essence of the event.
A copy of the AE0D report has been
provided to the licensee so that the specific deficiencies noted
can be corrected in future LERs.
2.
10 CFR 21 Reports
No 10 CFR 21 reports were submitted during the assessment
period.
G.
Licensing Actions
1.-
NRR Site and Corporate Office Visits
March 17-20, 1985 - Site Visit, add RETS to Technical
Specifications and prepare an official version of the
reformatted Technical Specifications for Dresden 2 and 3.
June 9-11, 1985 - Corporate office visit on June 19, 1985, to
accompany J. Zwolinski and C. Jamerson on "get acquainted"
tour. Talked with corporate and technical personnel to ensure
that current regulatory requirements were well understood.
Site Visit on morning of June 11, 1985.
J. Zwolinski and
C. Jamerson met with station management, visited TSC, Control
Room, HRSS, and areas where MVRS is proposed to be placed and
where H Storage Tank is placed, but not approved for use.
J. Zwolinski and C. Jamerson also visited Commonwealth's
Training Center at Braidwood.
2.
Commission Briefing
None.
3.
Schedular Extension Granted
January 3, 1985, Equipment Qualification, Dresden Unit 3.
4.
Relief Granted
March 5, 1985 IST Program - Second 10 Year Interval.
5.
Exemptions Granted
August 14, 1984, - Emergency Preparedness Exercise Exemption,
02 and D3.
September 26, 1985 - Schedular Exemption from Requirements
of Appendix J, D3.
6.
License Amendments Issued
i
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. Unit 2-
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' Amendment-No. 82, issued August-6, 1984, Reformatted Technical
- Specifications.
Amendment No. 83, issued November 16, 1984, Radiological
.
Effluent Technical Specifications.
~
Amendment No 84, issued January 17, 1985, Technical Specifica-
tion changes relating to the Cycle 10 Reload.
Amendment No. 85, issued February 27, 1985, Technical
Specification changes relating to Snubbers and Reflecting
- the_ guidance of Generic Letter 84-13.
Amendment No. 86,_ issued March 20, 1985,- -Technical Specification
changes Relating to Administrative Control and Reportability.
Amendment No.- 87, issued May 30, 1985, Technical Specification
Amendments Resolving-SEP Topics-VI-7.C.1 and XV-16.
- Amendment No. 88, issued May 30, 1985, Technical Specification
changes to Revise Table 3.7.1.
Amendment No. 89,. issued May 30, 1985, Technical Specifications:
Relating to Economic Generation Control.
Amendment No. 90, issued June 24, 1985, Technical Specifications
Relating to TMI Action Items Covered by Generic Letter 83-36.
Unit'3
Amendment No. 75, issued August 6, 1984, Reformatted Technical
Specifications.
Amendment No. 76, issued September 14, 1984, Technical
Specification changes Relating to the Extension of Certain
MAPLHGR Curves.
Amendment No. 77, issued November 16, 1984, Radiological
Effluent Technical Specifications.
Amendment No. 78, issued February 27, 1985, Technical
Specification changes Relating to Snubbers and Reflecting
the Guidance of Generic Letter 84-13.
Amendment No. 19, issued March 20, 1985, Technical
Specification changes Relating to Administrative Control
and Reportability.
~
cr
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Amendment-No. 80, issued May 30, 1985, Technical Specification
Amendments Resolving SE0 Topics VI-7.C.1 and SV-16.
Amendment No. 81, issued May 30, 1985, Technical Specification
changes to Revise Table 3.7.1.
Amendment No. 82,' issued May 30, 1985,-Technical Specifications
Relating to Econmic Generation Control.
Amendment No. 83, issued' June 24, 1985, Technical Specifications
Relating.to TMI Action Items Covered by Generic Letter 83-36.
Amendment No. 84, issued September 17, 1985, Technical
Specification and License changes Relating to Deletion of
Recirculation Equalizer Valves.
7.
Emergency / Exigent Technical Specification
Emergency Technical Specification for Dresden 3 on LPCI-Loop A -
Extension of LC0 was completed, (but not issued when Licensee was
able to complete the required repairs within the seven day period
specified in the existing Technical Specifications), for issuance.
by 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />,- August 4, 1985.
8.
Orders Issued
A document entitled " Issuance of Order Confirming Licensee
Commitment on Emergency Response Capability" was issued on
June 12, 1984.
9.
NRR/ Licensee Management Conference
Conference in Bethesda on July 23, 1985 regarding the details
of Commonwealth's program for reactor coolant system piping
replacement during the next refueling outage scheduled to
start October 26, 1985.
,
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38