IR 05000237/2010006
| ML101020460 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/09/2010 |
| From: | Ring M NRC/RGN-III/DRP/B1 |
| To: | Pardee C Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-10-006 | |
| Download: ML101020460 (22) | |
Text
April 9, 2010
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 & 3 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000237/2010006; 05000249/2010006
Dear Mr. Pardee:
On March 19, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Dresden Nuclear Power Station, Units 2 and 3.
The enclosed report documents the inspection findings, which were discussed on March 19, 2010, with Mr. Tim Hanley and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. Based on the results of this inspection, the team concluded that in general, problems were properly identified, evaluated, and corrected. However, the team observed that some issues should have been recognized and addressed more aggressively. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Docket Nos. 50-237; 50-249;72-037 License Nos. DPR-19; DPR-25
Enclosure:
Inspection Report 05000237/2010006; 05000249/2010006
w/Attachment: Supplemental Information
REGION III==
Docket Nos:
50-237; 50-249 License Nos:
05000237/2010006; 05000249/2010006 Licensee:
Exelon Generation Company Facility:
Dresden Nuclear Power Station, Units 2 and 3 Location:
Morris, IL Dates:
March 1, 2010 - March 19, 2010 Inspectors:
Stuart Sheldon, Senior Reactor Engineer (Team Lead)
Andrew Dunlop, Senior Reactor Engineer
Charles Phillips, Senior Resident Inspector
Robert Winter, Reactor Inspector
Robert Schultz, IEMA Resident Inspector
Approved by:
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000237/2010006, 05000249/2010006; 3/1/2010 - 3/19/2010; Dresden Nuclear Power
Station, Units 2 & 3; Routine Biennial Problem Identification and Resolution Inspection.
The inspection was conducted by regional and resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Dresden Nuclear Power Station was generally good. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria, were properly evaluated commensurate with their safety significance, and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. Two observations were identified where the licensee needed to more aggressively recognize and address issues. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of review of the employee concerns program, safety culture survey results, and interviews conducted during the inspection, workers at the site are willing to enter safety concerns into the CAP.
No findings of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
The activities documented in Sections
.1 through.4 constituted one biennial sample of
problem identification and resolution (PI&R) as defined in Inspection Procedure (IP) 71152.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by station staff. The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC problem identification and resolution inspection conducted in March 2008. The selection of issues ensured an adequate review of issues across NRC cornerstones.
The inspectors reviewed issues identified through NRC generic communications, self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. In addition, the inspectors reviewed Action Requests (ARs) and a selection of completed CAP documents from the licensees investigative methods, such as, root cause analyses, common cause analyses, and equipment apparent cause evaluations. Specifically, the inspectors determined if the station staff was identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also reviewed the effectiveness of corrective action for selected issue reports, completed investigations, and NRC findings, including non-cited violations (NCVs).
The inspectors selected the Unit 2 station blackout (SBO) diesel generator and the Unit 3 isolation condenser as samples for a five year review. The inspectors review was to determine whether the station staff was properly monitoring and evaluating the performance of the systems through effective implementation of station monitoring programs.
The inspectors attended the daily Management Review Committee (MRC) and Station Ownership Committee (SOC) meetings to observe how the station processed items entered into the CAP during the inspection. Specific documents reviewed are listed in the Attachment to this report.
b.
Assessment
- (1) Identification of Issues The inspectors concluded, in general, that the station identified issues and entered them into the CAP at the appropriate level. The inspectors review of operating experience reports identified that the licensee was appropriately including the issues in the CAP.
The licensee also used the CAP to document instances where previous corrective action was ineffective or inappropriately closed. Licensee audits and assessments were of good depth and identified issues similar to those that were self-revealed or raised during previous NRC inspections. Also, during this inspection, there were no instances identified where conditions adverse to quality were being handled outside the corrective action program.
- (2) Prioritization and Evaluation of Issues The team determined that the licensee was generally effective at prioritizing and evaluating issues. The inspectors identified a few instances where the significance level was either inconsistent or did not meet procedural guidance. Given the large number of issues in the CAP, this was not seen as significant. Evaluations reviewed were generally technically adequate and of appropriate depth. There were no instances in which the licensee did not adequately consider operability and reportability requirements. The inspectors noted that the station had recently taken steps to monitor and increase the number and quality of CAP evaluations.
The inspectors observations of the SOC concluded that the committee consistently reviewed the initial screening of the issue by the department CAP coordinator. The SOC directed member follow-up of issues that required additional information so the committee could perform its function. The inspectors concluded that none of the issues that were assigned the additional follow-up resulted in an inappropriate prioritization of the issue based on significance. However, the inspectors observed that better documentation of the issues and actions taken would help the documents meet the procedural requirement of stand-alone documentation.
Examples of SOC action taken were to assign work requests, evaluations, and/or corrective action to specific departmental groups. The inspectors also observed the MRC function in an oversight role of the SOC. For example, the MRC changed the SOC recommended action of some issues based on committee dialogue and additional station awareness of the issue. The MRC member dialogue in the review of several CAP investigative documents was informative, and provided feedback to the staff on the appropriate implementation of the CAP. MRC members periodically observed SOC meetings and provided generally constructive feedback. The inspectors considered this to be a beneficial activity. Also, the MRC performed grading of investigative CAP products to provide feedback on product quality to the sponsoring manager.
The inspectors concluded that in general, issues were properly prioritized and evaluated well. However, the inspectors developed two observations regarding inadequate evaluation.
1. Evaluation of Operations Human Performance Issues
The team identified a weakness in the evaluation of operations human performance issues. The team reviewed Root Cause Report (RCR) 893376, Assignment 2, concerning the causes of cyclic operations performance from 2005 to 2009. The RCR identified several examples of Nuclear Oversight (NOS) assessments between 2005 and 2009 which identified poor operations performance. They are listed below:
- AR 290395290395(January 12, 2005) Documented the equivalent of a yellow NOS rating (yellow ratings did not exist then). No corrective actions were specified.
- AR 543697543697(October 13, 2006) NOS rated operations performance 3Q06 Yellow
- significant self-revealed events due to Ops human performance were noted in 3 of the last 4 quarters. No corrective actions were specified.
- AR 578558578558(January 12, 2007) NOS identified Ops performance as Yellow in 4Q06. Analysis associated with this Common Cause Analysis (CCA) was limited.
- AR 767685767685(April 25, 2008) NOS identified Ops performance as Yellow for 1Q08.
RCR 893376 stated Ops was rated yellow by NOS and did nothing in response.
- AR 813920813920(September 3, 2008) NOS identified Ops as Yellow for 2T08.
Second reporting period in a row with a Yellow rating. No corrective actions were specified.
- AR 844505844505(November 13, 2008) NOS provided clear evidence, citing additional examples where operations department personnel were not meeting basic fundamental expectations. RCR 893376 stated Ops appeared to have under-reacted to the identified issues.
- AR 881736881736(February 17, 2009) NOS Trimester Report identifies Operations Cyclic Performance. This AR resulted in RCR 893376.
The RCR did not ask the question, why were so many valid NOS observations and assessments made without any sustained change to operations department performance? The fact that the station lacked an adequate response to valid NOS observations and assessments over four years should have been identified as a cause and led to additional corrective action in RCR 893376.
2. Addressing Atypical Indications During Surveillances
AR 602959602959was initiated on March 13, 2007, due to 2-0302-50B, 2B control rod drive (CRD) pump suction pressure indicator reading higher than expected during a surveillance. Instead of evaluating, (e.g., measuring pressure to see if the condition was real), Work Order (WO) 1010528 was generated to replace the indicator. This WO was closed on July 18, 2007, when the indicator was replaced. Subsequently, AR 758798758798was initiated on April 3, 2008, which led to WO 1125513 to address a degraded check valve, which was the underlying cause of the higher than normal pressure. This WO was still open as of March 19, 2010, three years after the initial problem identification.
AR 825148825148was initiated in October, 2008 due to a pressure indicator reading higher than expected during a diesel generator cooling water (DGCW) pump quarterly surveillance. This pressure indicator reading was used as an acceptance criterion for check valve 3-3999-640 in surveillance procedure DOS-6600-08. A WO written to calibrate the gauge was subsequently cancelled in error. AR 879473879473was initiated in February 2009 to identify the issue again. In response to questions from an inspector, AR 914138914138was initiated in April 2009 to address the actual condition, which resulted in a change to DGCW pump quarterly surveillance procedure DOS-6600-08. This pressure indicator in question was originally assumed to be inaccurate when, in fact, the condition was real and the surveillance was therefore inadequate. By not investigating the unusual reading, the licensee violated 10 CFR 50 Appendix B, Criterion XI, Test Control. This violation was determined to be minor as the check valve was subsequently verified to be operable.
- (3) Effectiveness of Corrective Action The licensee had been issued four findings since the last PI&R inspection with cross cutting aspects in corrective action. However, corrective actions for the samples reviewed were, in general, appropriate, and appeared to have been effective. The inspectors determined that the licensee generated assignment reports when corrective actions were identified as either inadequate or inappropriate. The inspectors identified one example of untimely corrective action. The inspectors also reviewed selected NRC findings for the past two years and observed two examples of ineffective corrective action.
1. Untimely Corrective Action for Wall Thinning
Engineering evaluation (EC) 371759 evaluated a degraded condition on condensate storage tank piping line 2/3-3350A-6. The evaluation determined that the condition would be acceptable through May 2009. The inspectors identified that the work order to correct the condition was scheduled for March 2011. In response, the licensee initiated AR 1042146 to reevaluate the wall thickness of line 2/3-3350A-6. By not correcting the condition or reevaluating the condition within the specified time, the licensee violated 10 CFR 50 Appendix B, Criterion XVI, Corrective Action. This violation was determined to be minor due to the actual values of wall thickness with the EC and the reasonable assurance of current operability.
2. Ineffective Response to NRC Violations
The team identified that the response to NRC Violation 2008004-02 in AR 806945806945 Water on Floor While Filling 2B Core Spray Evaluation, was ineffective. In 2008, the licensee spilled water onto the floor of the Unit 2 reactor building several times by overflowing floor drains. The licensee only addressed the human performance aspect of the issue in one event where operators overfilled a system causing water to enter the floor drain system. The human performance aspect of the issue was a barrier. The actual problem was an equipment issue with the floor drain system. If the floor drain system had not been plugged the water would not have spilled onto the floor. The failure to address equipment issues with the floor drain system resulted in repeat occurrences on U3 one year later during the U3 refueling outage.
The team identified that two of the corrective actions from Violation 2009004-05 were inappropriately delayed or closed. AR 950488950488was assigned to address this violation.
In AR 950488950488assignment 14, changes to corporate procedure WC-AA-106, Work Screening and Processing, were closed out to another action tracking item 745177. That assignment went to Peach Bottom (owner of the corporate procedure), but there was neither guidance on what the procedural changes needed to be nor was there a contact listed from Dresden to find out what the procedure changes were expected to be. In addition, the due date was moved out to December 31, 2010.
This was not timely. In AR 950488950488assignment 15, the action specified in the apparent cause evaluation (ACE) was closed inappropriately. The expected action was to make additional changes to WC-AA-106, Work Screening and Processing, to verify leak reduction program work orders were given a high priority and excluded from the condition based monitoring program. The basis for the exclusion was that there are no acceptable leak conditions within the boundary of the leak reduction program, while leaks assigned to the condition based monitoring program are considered acceptable and are not repaired unless the condition gets worse. AR 950488950488assignment 15 was worded slightly different from what was described as needed in the ACE and therefore was closed inappropriately.
Both of these issues were considered to be minor.
.2 Assessment of the Use of Operating Experience (OE)
a. Inspection Scope
The inspectors reviewed the licensees implementation of the facilitys OE program.
Specifically, the inspectors reviewed implementing OE program procedures, completed evaluations of OE issues and events, and use of OE as part of root cause analyses, apparent cause evaluations, common cause analyses, and maintenance rule functional failure evaluations. The inspectors also attended SOC and MRC meetings to observe the use of OE information. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were effective and timely implemented.
b.
Assessment In general, the inspectors concluded that the station appropriately considered industry and NRC OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations. Within the last two years, there were two findings that had been identified where OE was not adequately taken into account. These included the inadvertent control rod movement event while shutdown and a General Electric SIL recommending replacement of relays. The only additional item identified during this inspection concerned the review of Information Notice (IN) 2008-11, Service Water System Degradation at Brunswick 1, which identified an issue with degraded rubber lining material that caused fouling of heat exchangers. The licensees review focused on the type of valve (butterfly) identified in the OE and not the material that caused the fouling, such that it was concluded that this was not applicable to Dresden since there were no butterfly valves upstream of heat exchangers. However, in the component cooling service water system there were wafer style check valves with soft seats. These valves had previously been identified with degraded soft seats and required replacement. Although the valve types in the IN were not identical to those at Dresden, the purpose of the IN was to inform licensees about the degradation to a material that could potentially foul heat exchangers, which appeared to be applicable to the soft seat material in the check valves and should have been evaluated under the OE.
In response to inspector questions, the licensee initiated AR1044831.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed selected focused area self-assessments (FASA), check-in self-assessments, and NOS audits of the corrective action program, materials management and procurement engineering, and the functional areas of operations and maintenance. The inspectors evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the inspectors also interviewed licensee staff regarding the implementation of the audit and self-assessment programs.
b.
Assessment No findings of significance were identified.
The inspectors concluded that the self-assessments and NOS audits were generally critical and probing. Multi-discipline teams were utilized, when appropriate, to gain a broad perspective. There were a number of deficiencies and recommendations identified across the spectrum of performance, including issues of improper CAP implementation. As appropriate, the self-assessment and NOS audit deficiencies were documented in the CAP.
However, there appeared to be a lack of operations department performed self-assessments. The team only identified one such assessment, 2008 Dresden Clearance and Tagging Check-in Assessment. Almost all assessments were as a result of NOS, NRC, or self-revealed event-related issues.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The inspectors interviewed members of the Dresden station staff to determine if there were any impediments to the establishment of a safety conscious work environment.
In addition, the inspectors discussed the implementation of the Employee Concerns Program (ECP) with the ECP Coordinator, and reviewed their 2009 activities to identify any emergent issues or potential trends. Licensee activities to publicize the CAP and ECP programs were also reviewed.
b.
Assessment No findings of significance were identified.
The inspectors determined that the conditions at the Dresden station were conducive to identifying issues. The staff was aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. Staff interviews identified that issues could be freely communicated to supervision, and that several of the individuals interviewed had previously initiated issue reports. In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to identify issues. The inspectors interviewed the ECP Coordinator and concluded that the coordinator was focused on ensuring all site individuals were aware of the program, comprehensive in the review of individual concerns, and used the corrective action and employee concerns programs to appropriately resolve issues.
4OA6 Management Meetings
.1
Exit Meeting Summary
On March 19, 2010, the inspectors presented the inspection results to Mr. Tim Hanley, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary and no proprietary material was reviewed during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
T. Hanley
Site Vice President
S. Marik
Plant Manager
M. Marchionda-Palmer
Regulatory Assurance Manager
S. Vercelli
Work Control Director
P. OBrien
Site CAP Manager
S. Clark
ECP Coordinator
J. Griffin
NRC Coordinator
B. Rybak
Principle Regulatory Engineer
R. Ruffin
Regulatory Assurance
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
None