ML17179B128
| ML17179B128 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/30/1993 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 9310130172 | |
| Download: ML17179B128 (12) | |
Text
' '
Docket No. 50-237 Docket No. 50-249 Commonwealth Edison Company ATTN:
Mr. M. J. Wallace Vice President, Chief Nuclear Officer Executive Towers West III 1400 Opus Place, Suite 300 Downers Grove, IL 60515
Dear Mr. Wallace:
SEP 3 O 1993
- *I, Enclosed for your review is th~ SALP 12 Report for th~ Dresden Nuclear Plant,
.covering the period August l, 1992, through August 21, 1993.
A meeting to*
discuss this report with you and your staff is scheduled for 2:00 P~m. on October J9, 1993, *at the Dresden Station. While thi.s meeting is considered a, **
. presentation and discussion forum between* Commonwealth Edison Company and the.
NRC, the meeting will be open to interested.parties as observ~rs.
1n* accordance with NRC-pol icy,. I have reviewed the recommendations resulti~g from the SALP.Board 'Assessment *and concur with their ratings.
It is my V*i ew that your conduct of nuclear activities in connection with the Dresden
- facility was adequate.
- The last SALP report discussed a decline in performance at the beginning of that period ~nd management initiatives that appeared to have a*positive*
- effect. Significant ~ersonnel and organizational changes have ~ontinued throughout this period. -Performance has improved; however, the rate of improvement.has. been slow.
The impact of ~any of t~e changes remains to be seen.
Plant Operations and Engineering received Category 3 ratings reflecting overall acceptable performance.
Iri the Operations area, weaknesse~ were observed in routine plant operations such as the loss of main condenser vacuum automatic shutdown, inadvertent opening of the safety relief valves, and reactor operation with a degraded control room habitability system.
- However, some improvement was noted in operations as evidenced by the operations department taking more control of plant activities, completion of a major procedure upgrade program, and operator perform.ance during transients and unique activities.
In'the Engineering area, the organization-often lacked a strong safety focus as shown by the resolution of the containment cooling service water issues and the slow progress made on the motor-operated valve program.
The lack of a questioning attitude and a less than rigorous approach in addressing
. engineering issues continue to be significant weaknesses in this area.
The
- addit*i*on-of-_-a-s*enfor-engtneeri-ng-manager-and-=--signifi-cant--engi-neeri-ng-resources----. ---- --
9310130172 930930*
PDR ADOCK 05000237 G
Commonwealth Edison Company 2
SEP 3 O 1993 at the site appeared positive, but the impact of these added resources has not y~t been observed.
You received Category 2 ratings in Maintenance and Plant Support reflecting good performance in these areas.
In the area of Maintenance, management has been strengthened, and several longstanding equipment problems have been resolved through effective use of internal resources with some outside assistance.
Your efforts to ~ransfer to other CECo sites the knowledge gained on resolving equipment problems, and other "lessons learned," is notable.
However, many other equipment issues still remain to be resolved.
- In the area of Plant Support, the performance-of emergency preparedness and security organizations remained at a high level; however, performance in radiological protection. was poor.
More awareness of the causes and changes in routine radiological hazards is required.
The need to conduct good ALARA planning, particularly on emergent work items, is essential to reducing the overall station dose.
In order to further reduce-station dose, continued source term reduction throughout the facility is necessary.
Your QA audit and overall self assessment program 1to -identify and correct problems was considered weak and has not provided significant input to your improvement efforts.
QA audits were generally of narrow ~cope and compliance
- oriented rather than looking more broadly at overall performance.
A common theme-among the SALP functional* areas was~ lack of effective corrective actions.
Management expectations communicated to site personnel were not always implemented as intended.
Management oversight of field activities was often weak and failed to detect where expectations were not being met or understood; the limited time spent in-plant by many managers contributed to this problem.
This was evident in some of the weaknesses relating to personnel errors discussed in the.Operations, Engineering, and Plant Support areas.
The previous SALP report discussed concerns with routine operational activities and r~diological controls. These areas continue to be a concern.
The integrated reporting program was a positive step toward improving self assessment, but that program has not been fully embraced* by the Dresden work force.
At the SALP meeting you should be prepared to discuss our findings and your plans to improve performance in the areas of Plant Operations,* Engineering,
- and Plant Support.
The meeting is intended to provide a candid dialogue in which we may discuss any comments you may have regarding our findings.
Additionally, you are requested to respond in writing, within 30 days of the meeting, specifically addressing corrective actions planned to improve your performance.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a* copy of this letter and the SALP report will be placed in the NRC's Public Document Room.
Commonwealth Edi son Company
- 3 SEP 3 0 1993 Should you have any questions concerning the SALP Report, we would be pleased to discuss them with you.
Enclosure:
SALP 12 Report No. 50-237/9300l(DRP);
50-249/9300l(DRP) cc w/enclosure:
L. 0. DelGeorge, Vice President, Nuclear Oversight and Regulatory Services M. D. Lyster, Site Vice President G. F. Spedl, Station Manager J. Shields, Regulatory As~urance Supervisor D. Farrar, Nuclear Regulatory Services Manager
- OC/LFDCB.
Resident Inspectors Dresden, LaSalle, Quad Cities Richard Hubbard J. W. Mccaffrey, Chief, Public
~ Utilities Division Robert Newmann, Office of Public.
Counsel-Licensing Project Manager, NRR State Liaison Officer Chairman, Iliinois Commerce
- Commission H. J. Miller, Riii T. 0. Martin, Riii M. L. Jordan, Riii
- C. D. Pederson, RI 11 S. Stasek, SRI, Davis-Besse Sincerely, H. J. Miller for John B. Martin Regional Administrator Riii Riii Riii Riii Riii
~~
0 Chyu Hiland~ M.McB Hasse Clayton lltJ!)f ~
~
'\\9R111 RM Riii~
NRR~l L~ RII ~~I..
~
V' '?-
.t\\llt PJ.TJ v-
~
T~artin Forney Ax1'f,¥1
- Zwolinski ler artinO-
-*~~~:;;rence-~fe:elephone__<i\\V'?_ -
~ 11-'l(~/,O/r'f --q/JP~3 ----------------
Commonwealth Edison Company 3
SEP 3 0 1993 Should you have any questions concerning the SALP Report, we would be pleased to discuss them with you.
Enclosure:
SALP 12 Report No. 50-237/9300l(DRP);
50-249/9300l(DRP) cc w/enclosure:
M. D. Lyster, Site Vice President G. *F. Spedl, Station Manager J. Shields, Regulatory Assurance Supervisor D. Farrar, Nuclear Regulatory Services Manager OC/LFDCB Resident Inspectors Dresden, LaSalle, Quad Citie_s Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Robert Newmann, Office of Public Counse 1 Licensing Project Manager, NRR State Liaison Officer Chairman, Illinois Commerce Commission H. J. Miller, Riii T. 0. Martin, Riii M. L. Jordan, Riii C. D. Pederson, Riii S. Stasek,*SRI, Davis-Besse
- y~
YE5 Riii Riii
-0 MC..
f' J.. \\,\\..
Chyu Hiland 9/2bi9.3 i?1iJ..O
\\~II~
~II RII~c..
v ~'-~cB 9~asse Cl.~y.t.o 01n
~ ("\\.(}
'1. t*
.9/w~
Riii Riii Riii NRR*
Sincerely, John B. Martin Regional Administrator Riii La Torre Riii Riii TMartin Forney Axelson Zwolinski Miller JMartin
- Concurrence by telephone
~------------ --- ----- - ---------- ----- ------
~- --
Commonwealth Edison Company cc w/enclosure: (continued)
. INPO The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque OEDO T. E. Murley, Director, NRR Director, Office of Enforcement 4
SALP Program Manager, DRIL, NRR (2 copies)
W. T. Russell, Associate Director for Inspection-and Licensee Performance, NRR J. E. Dyer, Director, Project Oirectorate 111~2, NRR L. Cox, Riii (2 copies)
TSS, Riii Riii Files RI II PRR
--------~-- ---- - -
SEP 3 O 1993
--~
SALP 12 REPORT FOR DRESDEN I.
Introduction The SALP process is used to develop the NRC's conclusions regarding a licensee's safety performance.
The SALP report documents the NRC's observations and insights on a licensee's performance and communicates the results to the licensee and the public.
It provides a vehicle for clear communication with licensee management that focuses on plant performance relative to safety risk perspectives.
The NRC utilizes SALP results when allocating NRC inspection resources at licensee.facilities.
This report is the NRC's assessment of the safety performance at the Dresden Nuclear Power Plant for the period August 1, 1992, through August 21, 1993.
An NRC SALP Board, composed -0f the individuals listed below, met on September 1, 1993, to review the observations and data on performance and to assess performance in accordance with the guidance in NRC Management Directive 8;6, "Systematic Assessment of Licensee Performance."
Board Chairperson
- T. 0. Martin, Deputy Director, Division of Reactor Projects, RIII Board Members J. A;* Zwolinski, Assistaht Director, Region III Reactors, NRR W. L. Forney, Deputy Director, Division of Reactor Safety~ RIII W. L. Axelson,. Deputy Director, Division of Radiation Safety and Safeguards, RIII
- II.
Performance Ratings Since the previous assessment period, the number of functional areas was
.reduced from seven to four.
Radiological Controls, Emergency Preparedness,
. and Security, were included in a single functional area referred to as Plant Support.
Assessment of Safety Assessment/Quality Verification activities is incorporated as part of the assessment of each of the functional areas.
Trends are no longer assigned to functional area ratings.
Current Functional Areas and Functional Area Plant Operations Maintenance Engineering Plant Support Previous Functional Areas Functional Area Plant Operations Maintenance/Surveillance Engineering/Technical Support Radiological Controls Emergency Preparedness Security Safety Assessment/Qua 1 ity.
Verification III~ *Performance Analysis A.
- Pl ant Operations and Ratings:
Rating This Period 3
2 3
2 Ratings:
Rating Last Period 3
2 3
3 improving 1
1 3 improving The overall performance in the operations area was adequate. A number of improvementi were noted in operations performance tompared to the previous period; however, some long-standing problems remained.
Management involvement has improved, and the operations department was more in charge of station activities than in the past. Self assessment capability continued to be weak.
Some of the programmatic initiatives have not been fully implemented throughout the organization, and problems continue with routine operational activities.
-__ 2 ___, ------------------ - - -
An improvement in the conduct of operations was noted resulting from increased management involvement.
The operations department was in charge with respect to the prioritization and control of work activities. Management involvement in operational activities improved through actions such as shift engineers accompanying operators on rounds.
Operations management continued to be strongly involved in operator training and qualification programs.
In spite of increased involvement, management expectations have not been fully implemented at all levels of the organization.
Initiation of the shift engineers' review board for action on performance matters was an example of more progressive management involvement. This was an improvement from the time of a control rod misposition event where operators did not disclose their errors.
The control of plant operations and the performance of operators was mixed.
Operators exhibited good control room professionalism and handled well the off-normal events such as transients, startups, automatic and normal shutdowns, and simulator examination scenarios.
In addition, fuel movements were performed well; a significant improvement over the previous period.
However, weakne~ses were evident in the conduct of routine activities such as equipment lineup~ out-of-service problems, and drywell closeout.
In addition, operators did not correct problems such as unsecured equipment carts and small contaminated water l~ak~.
Attention to detail was good for unique acti~ities and situations where there was an obvious connection to safety.
For example, the shutdown risk management program was well designed and implemented.
Conservative actions were taken when-feedwater flow capability was reduced.
However, operations did not adequately focus their attention on the more routine events such as:
the circulating water flow reversal with insufficient vacuum margin; concurrent testing of the low pressure coolant injection system and the automatic_depressurization system which resulted in an automatic opening of the safety,relief va 1 ves; and reactor operation, core alterations, and reacto_r startup with an i~operable control room habitability system.
"The performanc~ in identification and resolution of issues was mixed.
Self assessment activities were weak resulting in continued _problems with routine activities. Operators have not fully embraced the integrated reporting program as evidenced by failu.res to initiate problem identification forms (PIFs) for conditioni adverse to quality.
The inadequate cleanup of the Unit 2 and 3 drywells in the latter part of the assessment period was an example of a lack of acceptable standards.
Some initiatives to improve self assessment capability, such as the involvement of bargaining unit personnel to investigate root causes, begari at the end of the period and were just beginning to produce results.
The operations management control of outage activities was good and a significant improvement over previous outages. This resulted from an additional senior operator in the control room and the assignment of an additional shift engineer as shift outage manager.
Some improvements in programs and procedures were noted.
These included the completion of the procedure upgrade project and the enhancements to licensed and non-licensed operator training.
Emergency operating procedures remained good although one possible safety enhancement was not incorporated in a timely 3_ - ------------------- -- - -------- --- ------------
manner.
The out-of-service and equipment line-up programs were cumbersome and placed additional burdens on operations staff.
The performance rating is Category 3 in this area.
B.
- Maintenance The overall performance in the maintenance area improved during the last period and was considered good.
Management involvement and effectiveness was evident by the planning and extensive work performed during the outages.
The identification and resolution of outstanding equipment problems improved with work accomplished from the Top 50 Technical Issues list. However, many equipment problems still remained.
Maintenance personnel involvement in the integrated reporting program was weak and indicated that management expectations were not fully implemented.
Management involvement was good and significantly contributed to the improvements noted in this area.
Management commitment to improve equipment performance and reliability was demonstrated by the implementation of th*e Top 50 Technical Issues.list~ Contractor assistance was effectively used to complement station personnel knowledge and supplement resourc~s. Upper management visibility and effectiveness in the plant was good.
Improvement was noted in the safety focus of maintenance work.
Prioritization of wdrk was generally gobd with the exception of the excessive use of the**"A" prio"rity classific.ation during the outage.
Planning, *scheduling, and coordination of the Unit 2 refueling outage improved significantly compared to previous outages.
Management's decision to extend both unit outages to complete outstanding work was conservative and showed commitment to improve equipment performance.
The prioritization and planning of day-to-day activities also improved during the latter part of the period.
- However, control room and non-outage work-request backlogs increased.
The identification and resolution of technical issues improved.
During the outages, many long-standing equipment problems such as feedwater and recirculation pump* seal failures were addressed due to effective utiliiation of internal resources with the assistance of contractor support.
The resolutions appeared to be successful; however, additional time is needed to evaluate the long term effectiveness.
Robt cause determinations identified deficient vendor manuals, incorrect parts, and inadequate training as contributing factors to the long-standing, large rotating equipment problems.
Management initiatives were implemented to address these deficiencies.
Housekee~ing and material condition were acceptable and improving throughout the period.
However, management expectations were not fully implemented at times as evidenced by the presence of unsecured equipment carts and uncontained leaks. Material condition improved due to the extensive efforts during the unit outages.
The training and skill of maintenance department personnel were considered acceptable. Surveillances were generally performed well.
However, numerous events occurred due to a lack of attention to detail during maintenance 4 ------- --- ----- ----
activities. Deficiencies in basic equipment understanding and incorrect maintenance practices were identified as contributing factors to some of the long-standing equipment problems.
Initiatives such as videotaping work performed, additional training, and procedure revisions were implemented to enhance craft capabilities. It is too soon to assess the impact of these initiatives.
The performance rating is Category 2 in this area.
C.
Engineering Overall performance in the engineering area was poor.
Major changes were recently made in the organization of engineering resources at the site including a significant addition of staff. These changes appeared positive but the impact has not yet been observed.
Management involvement and oversight were insufficient to ensure the*
satisfactory resolution of several engineering issues.
Issues were sometimes resolved without a proper focus on safety, as evidenced by the approach to a design problem with the low pressure coolant injection (LPCI) and containment cooling service water (CCSW) systems for which a Severity Level III violation was issued.
The engineering organization's performance in addressing this issue was indicative of a poor understanding of plant design and testing of systems.
The decision by management in the LPCI/CCSW* case to accept a degraded condition appeared to take the path allowing easiest resolutirin rather than exploring ~lternatives, conducti~g appropriate testing, and fully
-understanding* the design parameters. Other examples of poor performance were indicative of similar problems.
These included the slow progress in testing motor-operated valves in accordance with the GL 89-10 program,
~nd weak implementation of the GL 89-13 program related to service water systems.
Weaknesses were also*noted in the identification and resolution of issues and
.support to other organizations.
Examples included the poor engineering effort associated with the emergency core cooling system room coolers and the lack of engineering involvement in the control of fuses.
Minimal understanding of design basis and regulatory requirements contributed to the weak engineering effort associated with these issues.
On the other hand, late in the.
~ssessment period, some improvement was noted in the resolution of some long~
standing equipment problems including the operation of both trains of standby gas treatment an~ the treatment of plant service water radiation monitors.
Also, contractors were used effectively late in this assessment period to resolve continuing problems with condensate and feedwater pumps and to repair packing problems on the CCSW system.
Some positive management involvement was evident in the reorganization and addition of engineering staff to the site. However, this was accomplished*
late in the assessment period and a consistent positive trend in performance has not yet been *established.
The development of a Top 50 list of material condition problems was also a positive initiative and contributed to the resolution of several issues that, in some cases, have had an impact on the plant for over*20 years.. Improvement was also noted in the reduction of the modification backlog.
Management has continued to address recognized 5
weaknesses in the understanding of plant design.
Positive initiatives underway include the continuing development of design basis documents, formulation of a comprehensive material equipment list, and rebaselining the FSAR.
Self assessment activities were not effective in identifying adverse trends.
For example, self assessments did not identify system engineering problems, nor was the poor engineering support to other plant departments identified.
Root cause evaluation was frequently poor. There was a tendency to accept evaluations that allowed continued operation of equipment without a rigorous review to determine whether the position was technically supportable.
Examples included the failure to identify causal factors associated with the CCSW pump flow, weak technical evaluations of the control room HVAC cooling water cross ties, and the reactor vessel level indication oscillations.
Ineffective system walkdowns, a lack of consistent system engineering kn owl edge of assigned systems, and the *inability of the system engineering program to provide effective engineering support to address identified plant
- problems contributed to the overall weak-perfqrmance -in this area.
In addition, the quality of a modification review ranged from good to poor -
depending on the knowledge level of the system engineer.
The performance rating is Category 3 in this area.
D.
Plant Support Plant Support was overall considered to be good.
in emergency preparedness, the excellent performance seen previously continued during this assessment period. A slight decline was seen in security management performance, but overall this area remained excellent..Chemistry and fire pr_otection were good,-with a notable improvement made in chemistry staff facilities. However, in radiation protection, the improving trend noted during the previous
. assessment did not continue.
Extensive contamination control problems
- occurred during the outage.
Inadequate exposure control planning for outage emergent work contributed to the high station dose.
The station demonstrated excellent.radiological performance on preplanned jobs as demonstrated by success in the cleanup of a reactor building.equipment drain tank, work on a source range monitor, in-service inspection, and control rod drive replacement.
Programs and procedures were generally very good.
A slight decline in management and program effectiveness resulted in several implementation
- pro bl ems with chemistry sampling and security ai::ces.s control programs.
Radiation exposure controls in 1992 were good, limiting the 1992 cumulative dose to 616 person-rem, the lowest since 1970.
- However, in the first half of 1993, cumulative dose was approximately 1515 person-rem, due mainly to the large number of work requests added to*the Unit 2 outage without well thought-out exposure control consideration and al~o due to an ~~cessive non-outage daily cumulative dose.
Poor planning of the replacement of pipe on the reactor water cleanup system and of work on two shutdown cooling system valves resulted in cumulative drises 2-3 times the original estimates.
Program and procedure deficiencies were also seen in contamination control and in the
.labelling and control of contaminated materials with high external dose rates.
-~---* --------
6
On the other hand, th~ programs and procedures related to emergency preparedness, radioactive waste transportation, and overall status of radioactive waste reduction were excellent. Steady improvements in fire protection also resulted in outstanding performance.
Self assessments in emergency preparedness were outstanding and generally good in security, fire protection, and chemistry.
To address recurring problems with personnel contaminations identified during the outage, the licensee conducted two detailed assessments; however, the duration of the assessments was such that corrective actions were not taken until after the outage.
Performance of root cause analyses and implementation of corrective actions were generally good, with notable outstanding efforts and results in security and emergency preparedness.
However, repeat problems were seen with small fires from heat treatment operations and with labelling and segregation of bags of radioactive material.
The analysis and resolution of relatively excessive non-outage daily cumulative dose were not aggressive. Analysis and resolution of a cont~nuing shoe contamination problem were also poor.
Application of resources, overall, was outstanding.
New facilities were provided for the chemistry and radiation protection staffs. The main access control point for the radiologically controlled area was also moved and improved although problems occurred during the planning of the move and the
. initial. use of the new control point.
The performance rating is Category 2 in this area.
______ _] ____________ ---- ------------ ---- ---------