ML050620408
| ML050620408 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/02/2005 |
| From: | Satorius M Division Reactor Projects III |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-05-001 | |
| Download: ML050620408 (7) | |
Text
March 2, 2005 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
ANNUAL ASSESSMENT LETTER - DRESDEN NUCLEAR POWER STATION (REPORT 05000237/200501; 05000249/200501)
Dear Mr. Crane:
On February 9, 2005, the NRC staff completed its end-of-cycle plant performance assessment of the Dresden Nuclear Power Station. The end-of-cycle review for Dresden Nuclear Power Station involved the participation of all reactor technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2004. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.
This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as Exempt from Public Disclosure in accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.
Overall, Dresden operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green).
While plant performance for the most recent quarter is within the licensee response column of the Action Matrix, there were safety significant performance indicators that were other than Green during the first three quarters of the assessment cycle. Dresden Unit 2 performance entered the Regulatory Response Column of the Action Matrix in the second quarter of 2004, based on one White PI (unplanned scrams per 7000 critical hours) in the Initiating Events Cornerstone. You conducted a root cause investigation to determine the causes and implemented corrective actions for each scram. In a supplemental inspection, conducted in October 2004, we concluded that you had appropriately addressed the causes of each reactor scram. This PI returned to Green in the third quarter of 2004. For Dresden Unit 3, plant performance was in the Regulatory Response Column of the NRCs Action Matrix for the first 2 quarters of 2004, based on a White high pressure coolant injection (HPCI) safety system unavailability PI in the Mitigating Systems Cornerstone. Your previously completed root cause investigation identified causes and proposed corrective actions for this issue. We completed
C. Crane our supplemental inspection on this PI in 2003, which determined that you appropriately addressed this issue. This PI went Green in the third quarter of 2004. Therefore, we plan to conduct only baseline inspections at your facility through September 30, 2006. In addition, if the station proceeds with plans to replace the steam dryer on Unit 2 in the next refueling outage, we also plan to perform inspection procedure 71004, Extended Power Uprate, to inspect activities related to the steam dryer replacement.
In our Mid-Cycle Performance Review Letter, dated August 30, 2004, we advised you of a substantive cross-cutting issue in the area of human performance. While we noted that the number and significance of human performance cross-cutting issues have decreased slightly, human performance issues sharing the common causal factor of personnel errors and involving various departments at the site have continued through the third and fourth quarters of 2004.
Examples included: engineering personnel failed to perform an adequate operability evaluation for the installation of incorrect flanges on the main steam relief valve discharge lines on both units; electrical maintenance personnel failed to implement protected pathway barrier requirements which resulted in the tripping of a safety related bus; operations personnel failed to understand surveillance testing prerequisite requirements, and, as a result, unexpected rod motion occurred during the testing; electrical maintenance personnel removed a drywell cooler breaker that was tagged for testing with the tags still on the breaker; and operations personnel mispositioned a valve in the flow path for draining the Unit 2 torus to the hotwell. We understand that you have developed a Human Performance Improvement Plan, but that progress is not complete on some of the actions. Therefore, in accordance with the criteria described in NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, Section 0305-06.06.i. Substantive Cross-Cutting Issues, we are continuing the substantive cross-cutting human performance issue. Further reduction in the number, significance, and common causality is needed to resolve this issue. We will continue to monitor your performance in the human performance cross-cutting area through the baseline inspection program and evaluate the results in our semi-annual trend review at the mid-cycle assessment point. We request that you provide a written response to this substantive cross-cutting issue, including your plans to resolve the issue, within 60 days of this letter, and that you discuss your views at the annual public meeting.
The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. The plan also contains inspections using Independent Spent Fuel Storage Installation procedures. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle review meeting.
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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
C. Crane If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Mark A. Satorius, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
Dresden Inspection/Activity Plan cc w/encl:
Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission
C. Crane If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Mark A. Satorius, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
Dresden Inspection/Activity Plan cc w/encl:
Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission DOCUMENT NAME: G:\\Branch TSS\\EOC Ltrs\\eoc 030205\\Dresden.wpd To receive a copy of this document, indicate in the box "C" = Copy w ithout att achment/enclosure "E" = Copy w ith attachment/enclosure "N "
= No copy OFFICE RIII RIII NAME MRing:co MSatorius DATE 03/02/05 03/02/05 OFFICIAL RECORD COPY
C. Crane ADAMS Distribution:
AJM MXB RidsNrrDipmIipb GEG KGO DRC1 CAA1 DRPIII DRSIII PLB1 JRK1 ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
Institute of Nuclear Power Operations (INPO)
Dresden Inspection / Activity Plan 03/01/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 02/28/2005 08:16:28 Report 22 1
7111404
- REVIEW EMERGENCY PLAN CHANGES Baseline Inspections 01/19/2005 03/11/2005 Emergency Action Level and Emergency Plan Changes IP 7111404 2, 3 3
FPI
- TRIENNIAL FIRE PROTECTION Baseline Inspections 03/14/2005 04/01/2005 Fire Protection IP 7111105T 2, 3 2
71114
- EP EXERCISE & EP PI INSPECTION Baseline Inspections 03/07/2005 03/11/2005 Exercise Evaluation IP 7111401 2, 3 Baseline Inspections 03/07/2005 03/11/2005 Performance Indicator Verification IP 71151 2, 3 1
MAINT
- BIENNIAL MAINTENANCE RULE INSPECTION Baseline Inspections 04/11/2005 04/15/2005 Maintenance Effectiveness IP 7111112B 2, 3 1
- RADIOLOGICAL EFFLUENT CONTROL Baseline Inspections 04/25/2005 04/29/2005 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112201 2, 3 Baseline Inspections 04/25/2005 04/29/2005 Performance Indicator Verification IP 71151 2, 3 2
- OPERATION OF AN ISFSI Other Routine 05/01/2005 06/30/2005 Operation Of An ISFSI IP 60855 2, 3 5
SSDPC
- SAFETY SYSTEM DESIGN & PERFORMANCE Baseline Inspections 07/25/2005 08/12/2005 Safety System Design and Performance Capability IP 7111121 2, 3 1
- RADIOLOGICAL ACCESS CONTROL Baseline Inspections 08/01/2005 08/05/2005 Access Control to Radiologically Significant Areas IP 7112101 2, 3 Baseline Inspections 08/01/2005 08/05/2005 Performance Indicator Verification IP 71151 2, 3 1
- UNIT 2 ISI INSPECTION Baseline Inspections 10/31/2005 11/11/2005 Inservice Inspection Activities - BWR IP 7111108G 2
1 71121.02
- OUTAGE ALARA Baseline Inspections 11/14/2005 11/18/2005 ALARA Planning and Controls IP 7112102 2, 3 Baseline Inspections 11/14/2005 11/18/2005 Performance Indicator Verification IP 71151 2, 3 2
- PROBLEM IDENTIFICATION AND RESOLUTION Baseline Inspections 01/01/2006 01/31/2006 Identification and Resolution of Problems IP 71152B 2, 3 1
71114
- BASELINE EP INSPECTION Baseline Inspections 01/09/2006 01/13/2006 Alert and Notification System Testing IP 7111402 2, 3 Baseline Inspections 01/09/2006 01/13/2006 Emergency Response Organization Augmentation Testing IP 7111403 2, 3 Baseline Inspections 01/09/2006 01/13/2006 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 7111405 2, 3 Baseline Inspections 01/09/2006 01/13/2006 Performance Indicator Verification IP 71151 2, 3 3
FY 2005
- DRESDEN INIT PREP 01/2006 Not Applicable 01/09/2006 01/13/2006 OL - INITIAL EXAM - DRESDEN - AUG/SEP 2005 W90124 2
3 FY 2005
- DRESDEN INIT EXAM 02/2006 Not Applicable 02/06/2006 02/10/2006 OL - INITIAL EXAM - DRESDEN - AUG/SEP 2005 W90124 2
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Dresden Inspection / Activity Plan 03/01/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 02/28/2005 08:16:28 Report 22 1
7112103
- RADIOLOGICAL INSTRUMENTATION Baseline Inspections 02/27/2006 03/03/2006 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 2, 3 Baseline Inspections 02/27/2006 03/03/2006 Performance Indicator Verification IP 71151 2, 3 1
HS
- HEAT SINK INSPECTION Baseline Inspections 03/20/2006 03/24/2006 Heat Sink Performance IP 7111107B 2
1 ISFSI
- OPERATION OF AN ISFSI Other Routine 05/01/2006 06/30/2006 Operation of an Independent Spent Fuel Storage Installation at Operating Plants IP 60855.1 2, 3 1
7112203
- REMP AND RAD MATERIAL CONTROL Baseline Inspections 05/22/2006 05/26/2006 Radiological Environmental Monitoring Program IP 7112203 2, 3 Baseline Inspections 05/22/2006 05/26/2006 Performance Indicator Verification IP 71151 2, 3 1
7112101
- RADIOLOGICAL ACCESS CONTROL Baseline Inspections 08/28/2006 09/01/2006 Access Control to Radiologically Significant Areas IP 7112101 2, 3 Baseline Inspections 08/28/2006 09/01/2006 Performance Indicator Verification IP 71151 2, 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.