Text

Advises of NRC Planned Insp Effort Resulting from Dresden Plant Performance Review Completed on 990201.Historical Listing of Plant Issues & Details of NRC Insp Plan for Next 8 Months Encl
	ML17191B296
Person / Time
Site:	Dresden
Issue date:	03/26/1999
From:	Grant G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O; COMMONWEALTH EDISON CO.
References
	NUDOCS 9903300389
	Download: ML17191B296 (48)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION Mr. Oliver D. Kingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West Ill 1400 Opus Place, Suite 500 Downers Grove, IL 60515 REGION 111 801 WARRENVILLE ROAD LISLE, ILLINOIS 60532-4351 March 26, 1999

SUBJECT:

PLANT PERFORMANCE REVIEW - DRESDEN

Dear Mr. Kingsley:

On February 1, 1999, the NRC staff completed a Plant Performance Review (PPR) of Dresden Nuclear Power Station. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. Plant Performance Reviews provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. Plant Performance Reviews examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last 6 months to ensure that the assessments reflect current performance. The PPR for Dresden involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period of April 1, 1998, through January 31, 1999. The NRC's most recent summary of licensee performance was provided in a letter of January 2, 1998, and was discussed in a public meeting with you on January 16, 1998.

As discussed in the NRC's Administrative Letter 98-07 of October 2, 1998, the PPR provides an assessment of licensee performance during an interim period that the NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program. The NRC suspended its

SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC will decide whether to resume the SALP program or terminate it in favor of another process.

During this period, Unit 2 started in a refueling outage which completed on April 15, 1998, but on April 20, the unit scrammed from about 60 percent power. The immediate cause was a generator trip due to a load reject caused by an incorrectly performed modification on the unit auxiliary transformer. On April 22, the unit was restarted. On June 20, the Unit 2 main turbine tripped and Unit 2 aufomatically scrammed from full power. Unit 2 was restored to full power on June 23, 1998, and remained at power until August 6, 1998, when the generator was taken off line to address a generator ground problem. The problem was corrected, the generator placed back on line, and near-full power restored by August 10, 1998. Full power was achieved on August 13, 1998. Since then there have been scattered power reductions to support maintenance work, and a decrease to below 25 percent power for single loop operation to replace brushes on a recirculation pump motor-generator set in late November.

9903300389 990326 PDR ADOCK 05000237 G

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0. Kingsley At the start of this period, Unit 3 was near full power. On April 9, 1998, a full Group I (main steam) isolation and scram occurred. The cause was a spurious isolation signal. On April 13, Unit 3 was restarted. On May 2, the operators manually scrammed the unit from low power for a planned outage to replace the main transformer. On May 15, 1998, startup commenced, but on May 16, operators manually scrammed the unit due to a loss of condenser vacuum. A leaking relief valve caused the loss of the vacuum. The unit reached full power on May 24, but on May 25, operators manually tripped the turbine and generator, but not the reactor, due to a.

loss of all cooling for the main power transformer. A failure of the cooling system's power selection device caused the loss of cooling. On May 26, 1998, operators synchronized the g~nerator to the grid. Unit 3 remained at full power except for small decreases to support maintenance and surveillance testing. On October 30, 1998, the operators.decreased power to about 550 MWe because of a failed-open discharge valve on the 3C circulating water pump.

The licensee used a hydraulic operator to close the valve and returned Unit 3 to near full power, where it remained until it was shut down for a planned refueling outage at the end of January 1999.

Overall, performance at Dresden was acceptable. Operator performance was good in responding to the several scrams in April through June and during planned power changes.

Two significant problem areas which emerged were failures by operators to identify applicable Technical Specification requirements and fundamental errors committed by non-licensed operators. The licensee has taken actions to reverse these trends and recent im.provements were noted. Besides the equipment problems related to scrams, recent equipment problems continued to impact operators, including recirculation speed control problems with loose connections and rod block monitor system errors. Entering 1999, however, both units had been operating for extensive periods.

Performance in operations was consistent. Operators generally performed well while.

maintaining both reactors near steady-state full power during the last part of the assessment period. In particular, the operations staff continued to maintain high standards. Early in the review period, the operators were challenged by several unplanned scrams and performed well..

In the middle of the reporting period, the operations staff had a series of missed entries into limiting conditions for operations which culminated in a violation of Technical Specifications *in August. Subsequent actions taken by the licensee were effective in stopping the negative trend in meeting Technical Specifications. Throughout the period, the operations staff has been challenged to respond to equipment problems associated with the material condition of the plant arid with plant design. The operators had to perform down power evolutions, drywell entries, and single loop evolutions to address some equipment problems. Overall, the performance by operations during these complex and infrequent evolutions was good. Some errors in plant and equipment monitoring were noted by the inspectors; in one instance the inspectors identified that a control rod drive accumulator was inoperable. Errors committed by non-operations personnel have also presented challenges to the operators to ensure the plant.

was maintained within the requirements of the Technical Specifications. Resident inspectors will perform the core inspection program in operations, and focus regional initiative inspection on operator performance with respect to Technical Specifications entry conditions, time limits for limiting conditions for operation, and responses to challenges from plant equipment and personnel errors.

0. Kingsley Performance in maintenance was improved including noted improvement in support of operations in response to emergent concerns. Additionally, there have been improvements in the planning and execution of safety-related equipment and plant outages and on-line maintenance activities. This has led to a significant reduction in the nonoutage work request backlog. Nonetheless, personnel errors, longstanding, repetitive material condition issues, and inadequate work instructions continued to affect plant operations adversely. The Region will perform the core inspection program in maintenance and focus regional initiative inspection on material condition, on-line maintenance and activities that present challenges to limiting conditions for operations.

Performance in engineering was improved. In particular, the implementation of engineering department self-assessments and corrective actions to address technical problems improved.

The quality of engineering products also improved during the *period. However, instances of weakness in the engineering support to *operations were identified. The root cause investigations were effective with one notable exception involving post accident monitoring. In addition, some weaknesses were identified in the implementation of the temporary alteration program. Engineering contributed to the improvement in material condition with a decrease in the number and frequency of high pressure coolant injection problems, but several long standing material condition issues remain. The Region will perform the core inspection program in engineering and regional initiative inspection which will focus on the temporary alteration program and the. licensee's progress in addressing the remaining longstanding material condition issues associated with safety-related equipment, such as the high pressure coolant injection system. In addition, regional initiative inspection will focus on engineering support to operations to ensure weaknesses previously identified through events have been adequately addressed.

Performance in plant support was consistent. Programs in the plarit support area including as-low-as-reasonably-achievable planning, radiological controls, chemistry, radiological environmental monitoring, security and fire protection were generally effective with occasional lapses in program implementation and oversight. Emergency preparedness programs were effectively implemented. Personnel performance in the plant support area improved somewhat, although isolated worker performance problems continued. Material condition was generally good, but not entirely consistent throughout the station. Self-assessments were thorough and self-critical and corrective action progress was tracked effectively. The Region will conduct core inspections in the plant support area with *emphasis on ensuring that program implementation and personnel performance lapses be addressed to improve overall program consistency. Regional initiative inspection will focus on material condition issues with plant support equipment. contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Commonwealth Edison Company. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance. In addition,

0. Kir:igsley the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration. This material will be placed in the Public Document Room as part of the normal issuance of NRC inspection reports and other correspondence.

This letter advises you of our planned inspection effort resulting from the Dresden PPR review.

It 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. Enclosure 2 details our inspection plan for the next 6 months. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.

The inspection schedule is subject to revision because of anticipated changes to the NRC's inspection program. We will promptly notify you of any changes to the inspection plan. If you have any questions, please contact Mark Ring at (630) 829-9703.

Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25

Enclosures:

1. Plant Issues Matrix

2. Inspection Plan Sincerely, ls/Geoffrey E. Grant Geoffrey E. Grant, Director Division of Reactor Projects DOCUMENT NAME: G:\\DRES\\INSPPLNB.DRE To receive a co of this document, indicate in the box "C" =Co without attachmenUenclosure "E" =Co with attachmenUenclosure "N" = No co OFFICE Riii 6 Riii NAME DATE 031"0/99 OFFICIAL RECORD COPY

O: Kingsley cc w/encls:

D. Helwig, Senior Vice President H. Stanley, PWR Vice President C. Crane, BWR Vice President R. Krich, Vice President, Regulatory Services DCD - Licensing M. Heffley, Site Vice President P. Swafford, Station Manager F. Spangenberg, Regulatory Assurance Manager M. Aguilar, Assistant Attorney General State Liaison Officer Chairman, Illinois Commerce Commission C. Adelman, Will County Executive/

Board Chairman B. Ward, Will County Sheriff D. Gould, Will County Emergency Management Coordinator/Director The Honorable Arthur Schultz J. Mezera, City Manager J. Church, Kendall County Board Chairman R. Randall, Kendall County Sheriff D. Kaufman, Grundy County Board. Chairman J. L. Olson, Grundy County Sheriff J. Lutz, Grundy County Emergency Management Coordinator/Director The Honqrable Robert T. Feeney The Honorable Keith Flatness The Honorable Thomas J. McKinney The Honorable John Jensen The Honorable Elmer Rolando The Honorable Richard Girot The Honorable William Weidling The Honorable Wayne Chesson M. T. Gibson, Channahon Village Administrator The Honorable Bertha J. Hofer G. C. Holmes, Shorewood Village Administrator The Honorable James Clementi INPO

0. Kingsley Distribution:

SAR (E-Mail)

RPC (E-Mail)

G. Tracy, OEDO w/encls Chief, NRR/DISP/PIPB w/encls T. Boyce, NRR w/encls Project Director, NRR w/encls Project Mgr., NRR w/encls J. Caldwell, Riii w/encls B. Clayton, Riii w/encls R. Lickus, Riii w/encls SRI Dresden w/encls DRP w/encls DRS (2) w/encls RI 11 PRR w/encls PUBLIC IE-01 w/encls.*

Docket File w/encls GREENS Page:

1of12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Dale Source Area ID Type Codes Item Description 01/09/1999 1998030 Pri: OPS NRC MISC Pri: lC The inspectors walked down accessible portions of the high pressure coolant injection systems." the core Sec:

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spray systems. and the low pressure coolant injection systems. The inspectors identified no substantive concerns from these wolkdowns. Equipment operability. observed material condition. and housekeeping Ter:

were generally acceptable. (Section 02. 1) 01/09/1999 1998030 Pri: OPS Licensee NEG Pri: lA Four instances were identified where Technical Specification and Dresden Administration Technical Sec:

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Requirement (DATR) Limiting Coriditions for Operation (LCO) time limits were not met either because station personnel did not understand the impact of their activities on these requirements. or did not realize Ter:

conditions hod changed which warranted on entry into*the LCO action statements.. (Section 04.2) 01/09/1999 1998030 Pri: OPS NRC NEG Pri: lC The licensee's response to previous problems with the post-accident hydrogen and oxygen monitoring It Sec:

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system foiled to identify another H2/02 monitor annunciator procedure that also contained errors. This issue was subsequently corrected. (Section 03. 1)

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01/09/1999 1998030 Pri: OPS NRC STR Pri: lA The non licensed operators (NLOs) effectively identified equipment abnormalities during the conduct of their Sec:

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rounds. The early identification of the equipment deficiencies allowed the station to remove the equipment from service in an orde.rly fashion before the problems presented a more severe challenge to plant Ter:

operations. (Section 04. 1) 01/09/1999 1998030-01 Pri: OPS NRC NCV Pri: JC Ori December 1. 1998. the licensee identified that the 18-month fire damper surveillance had not been Sec:

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completed prior to the critical due date of April 30. 1998. The surveillance work request hod been improperly closed without the acceptance criteria being met. A total of 13 dampers hod not been inspected when Ter:

'the surveillance hod been signed off as being complete. instead. station personnel hod written action requests to build scaffold. remove insulation. and inspect the dampers.

01/09/1999 1998030-02 Pri: OPS NRC NCV Pri: lA On December 1. 1998. the licensee identified that the. monthly primary containment locked valve checklist Sec:

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was not completed in accordance with the requirements of TS 3.7.A. The TS allowed valve position checks in high radiation areas (inaccessible areas) to be verified by administrative controls. The licensee utilized tw~

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primary containment locked valve checklists. one for accessible areas and one for inaccessible areas. Th licensee hod improved radiological conditions in areas of the torus and previously "inaccessible" areas were -

now accessible for valve checks.

01/09/1999 1998030-03 Pri: OPS NRC NCV Pri: lA Non-Routine Sample Time Requirement Exceeded due to Chemistry Technician Personnel Error. Licensee Sec:

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Event Report 50-249/96003-00 documented that on April 15. 1996. a service water effluent sample was invalid

. because it was taken from on isolated section of the service water system. The error occurred when a Ter:

chemistry technician took samples from a section of the service water system that hod been token out-of-service. The licensee adjusted the out-of-service boundary and took a sample. That sample. and the lost valid sample. were below the lower limits of detection for the instruments. The licensee found the root cause to be a personnel error by the chemistry technician.

11/24/1998 1998026 Pri: OPS NRC NEG Pri: lA The setpoints for the heat trace on the post-occident sampling system were less than setpoints listed on a Sec:

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local placard. The actual value for one heat trace line was drifting below the alarm setpoint listed in on annunciator procedure. but no alarm actuated. The licensee failed to assure that this condition was Ter:

detected during routine rounds. (Section 02.2)

Item Type (Compliance,Followup,Other), To 03/25/1999

Page: 2of 12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 11/24/1998 1998026 Pri: OPS Self NEG Pri: lA

Procedural inadequacy and inattention to detail on the part of the operators directly caused 6 reactor Sec:

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protection system half-scram condition during turbine control valve.testing. These errors were self-revealing and were similar in nature to other items documented in this report that were indicative of a lack of a Ter:

questioning attit.ude. (Section 04.2) 11/24/1998 1998026 Pri: OPS Self NEG Pri: lC Inadequate out-of-service (OOS) directions resulted in the initiation of work on the fire protection system that Sec:

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was outside of the established tagout boundary. It was fortuitous that the system breached was at low pressure and that no significant adverse consequences resulted from the errors. (Section 04.4)

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l 1 /24/1998 1998026 Pri: OPS NRC POS Pri: lA Overall control room performance was good. Performance outside of the control room was acceptable Sec:

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with respect to performing procedurally-required rounds. but was not as effective at identifying issues outside of the rounds procedures. (Section 04. l)

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11/24/1998 1998026 Pri: OPS Self POS Pri: 18 Inadequate work procedures. combined with weak maintenance practices. caused the 3C circulating Sec:

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water pump discharge valve to fail open with the pump secured. which resulted in a significant challenge to the control room operators. Operators responded appropriately and correctly implemented the abnormal Ter:

operating procedures to prevent the transient from getting worse. (Section 04.3) 11/24/1998 1998026 Pri: OPS Licensee WK Pri: 2A The licensee declared the Unit 3 high pressure coolant injection (HPCI) system inoperable due to the failure Sec:

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of the gland seol leakoff (GSLO) condenser level control system to perform its safety-related function. As discussed in Section E4.1. the inspectors recognized the licensee's efforts to address problems with the GSLO Ter:

condenser. however. this repeat failure of this HPCI subsystem showed that the licensee's prior corrective actions to address this issue were not effective enough to correct the deficiency. (Section 02.1) 11/24/1998 1998026-01 Pri: OPS Self NCV Pri: lC During performance of the test. operators received an unexpected reactor protection system (RPS)

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half-scram signal. The licensee documented the occurrence via problem identification form (PIF) 01998-05643. The licensee's prompt investigation efforts revealed that the operating crew hod selected the Ter:

incorrect RPS test box. Contributing factors included procedural adequacy and operator attention-to-de!.

concerns that were self-revealing as a result of the unexpected half-scram.

10115/1998 1998025 Pri: OPS NRC NEG Pri: 2A Radiological housekeeping and material condition in the radioactive waste building was Inconsistent with Sec: PLTSUP Sec:

higher standards maintained in other plant areas. which the licensee planned to address. In addition. while

.the effluent monitor control terminal in the main control room functioned properly, a panel placard used as Ter:

an aid to assist operators select monitor data from the terminal. listed information that was inconsistent with the liquid effluent monitors 10/06/1998 1998024 Pri: OPS NRC MISC Pri: lA The licensee hod taken actions to prevent basic operational errors and to stop a negative error trend. The Sec:

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inspectors initially saw mixed performance in the area. but noted that no active violations of Technical

. Specifications happened in this period. Toward the end of the inspection period. operator performance Ter:

improved

!tom T11no tr.nmnli~nr.o Fnllnw11n.nthP.r\\, Tn 01/2~/1 ~HHl

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Date Source Area ID 10/06/1998 1998024 Pri: OPS NRC Sec:

10/06/1998 1998024-01 Prl: OPS NRC Sec: PLTSUP 09/23/1998 1998023 Prl: OPS NRC Sec:

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lfpm Tvn<> lf:nmnli~nr.1> Fnllnw11n.Oth1>rl. Tn ()~/2S/Hl!'.l!'.l United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Template Type Codes NEG Pri: lA Sec:

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POS Pri: SA Sec:ss Ter: SC POS Pri: SB Sec:

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PLANT ISSUE MATRIX By Primary Functional Area Item Description The operational status bf equipment continued to challenge the smooth operations of the plant. Problems with the reactor recirculation system resulted in power reductions and significant work on the reactor recirculation control system. Failures in the rod block monitor systems prevented withdrawal of control rods.

The inspectors identified on inoperable control rod. The licensee identified that the reactor building -.

suppression chamber vacuum breakers hod not been proven operable. Overall. the operational status of facilities and equipment challenged the station In Audit Report ComEd-98-01, the licensee identified deficiencies in fire brigade qualifications and initiated Corrective Action Record 12-98-007. This record identified two examples where many fire brigade members hod not completed the required training.

e The operating experience program was ettectively implemented. Operating experience information was evaluated appropriately. and adequate corrective actions were identified and implemented in a timely manner The nuclear oversight self-assessment program was ettectively implemented and provided valuable performance insights The corrective action process was ettective and the threshold for identifying and correcting problems was low. The licensee hod identified significant issues and implemented timely corrective actions which achieved lasting results. (Section 07.1)

The root cause analysis program was ettectively implemented. Issues were thoroughly investigated. the root causes identified were reasonable. and corrective actions were comprehensive and timely. (Section 07.2.

Contrary to the above. on August 20. 1998. the licensee moved on irradiated fuel lbundle in the secondary containment while on RCU was inoperable.

Material condition issues continued to adversely ottect plant operations. Plant personnel responded appropriately to the equipment failures. (Section M2. l)

The inspectors identified that contract maintenance activities resulted in making the Technical Support Center air filtration unit inoperable. The contract maintenance stoH hod propped open on emergency door in the Technical Support Center without operations permission. The operations staff entered the oppropriqte DATR LCO ofter the inspectors informed the staff.. The licensee counseled the contract maintenance stoH

. and highlighted the issue throughout the station. (Section M4. l)

Page: 4 of 12 Region Ill DRESDEN Dale 01/09/1999 11/24/1998 11/24/1998 11 /24/1998 10/06/1998 10/06/1998 09/23/1998 09/23/1998 09/23/1998 Source 1998030 1998026 1998026 1998026-02 1998024 1998024 1998023-05 1998023-06 1998023-02 Functional Area Pri: MAINT Sec:

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Pri: MAINT Sec: OTHER United States Nuclear Regulatory Commission PLANT ISSUE MATRIX Date: 03/25/1999 Time: 07:09:07 ID NRC NRC NRC Self NRC NRC Licensee Licensee NRC Type POS POS POS NCV NEG POS NCV NCV By Primary Functional Area Template Codes Item Description Pri: 3A The maintenance activities observed by the inspectors were performed correctly. (Section M4.2) sec:

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Work octivi,ties on major unscheduled items were performed well. Routine scheduled work was usually performed well. However. inadequate maintenance restoration on the circulating water system required the operators to perform a rapid load drop. (Section Ml.1)

Work observed during maintenance on the low pressure coolant injection system was performed in accordance with procedures. Good communications and interactions between maintenance.

engineering. and operations allowed the activities to be completed within the planned time frame without any major delays or issues. (Section M4.3) instrument maintenance technicians performed Dresden instrument surveillance "Reactor Building Ventilation Radiation Monitor Channel Calibration." and. due to personnel error. caused on automatic initiation of the safety-related SGTS. During the performance of the surveillance. the procedural steps correctly required that the te.chnicion adjust the TRIP CHECK ADJUST potentiometer. The instrument maintenance deportment technician turned the power supply knob for the radiation monitor to the OFF position instead.

. The major work activities were performed correctly and required equipment was returned tQ service within the required times. The licensee reviewed the work for areas of improvement. The inspectors noted some minor issues that indicated a need for better attention to detail. The licensee identified a negative trend in the performance of the electrical maintenance deportment (Section M 1.1 ).

The licensee met the initial goals and objectives of the Strategic Reform Initiatives associated with improving the plant material condition. Sustained improvements in plant material condition hove yet to be demonstrated (Section M6. l).

During routine surveillance testing. the licensee identified that the Unit 2 HPCI low flow switch trip setpoint was below the technical specification limit of 600 gallons per minute. The root cause of this event was determined to be setpoint drift.

On June 10. 1997. a service discharge test on the Unit 3 125 VDC battery was performed. Following that test.

the licensee identified that the battery was pre-conditioned since on equalization charge Emd maintenance activities to remove and clean intercell connectors were completed just prior to the test. The root cause of the problem was on inadequate technical review of the modified performance test prerequisites because the technical reviewers did not identify or adequately question the as-found requirements for service discharge test perforn:once.

VIO IV Pri: lC The licensee foiled to implement the IST program as required by TS 4.0.E Sec:

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Item Tvpe (Compliance.Followup,Other), To 03/25/1999

Page: 5of12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Dale Source Area ID Type Codes Item Description 01 /27 /1999 1999004 Pri: ENG NRC POS Pri: 5C Engineering involvement in the corrective action process was good for the specific Items reviewed.

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Corrective actions were acceptable (All Sections).

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01/09/1999 1998030 Pri: ENG NRC POS Pri: 48 Engineering personnel were satisfactorily involved in the resolution and disposition of previously identified Sec:

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issues. The licensee's corrective action process adequately implemented corrective actions to resolve the issues. (Sections E8. l - E8.6)

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11/24/1998 1998026 Pri: ENG NRC NEG Pri: 48 The heat trace system temperature controllers for the post accident monitoring system were not set correc Sec:

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and were not in the routine calibration program. The design temperature specifications provided by the licensee regarding system operability were inconsistent. (Section E4.2)

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11/24/1998 1998026 Pri: ENG NRC POS Pri: 48 The licensee was pro-active in following up on the original plan to reduce scrams. derates. and challenges.

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and identified that progress had stalled. Corrective actions established ownership of the plan's recommendations to maintain progress in implementation. (Section E2. l)

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11 /24/1998 1998026 Pri: ENG NRC POS Pri: 48 The inspectors concluded that the licensee's troubleshooting and investigation plan for the high pressure Sec:

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. coolant injection system (HPCI) failures was thorough. However. the inspectors continue to be concerned about the number of HPCI failures over the past two years. The licensee established a team to perform a Ter:

point-by-point review of the HPCI system. (Section E4. l) 10/06/1998 1998024 Pri: ENG NRC NEG Pri: 48 The engineers were also active in troubleshooting the systems. Usually the engineers stayed In good contact Sec:

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with operations. However. in one instance. the engineering staff did not assure that the operations staff had a good understanding of the expected performance of a 250-VDC charger. As a result. the operations staff Ter:

removed the charger from service when the charger was behaving as the engineer expected.

e 10/06/1998 1998024 Pri: ENG NRC POS Pri: 48 The involvement by engineers during maintenance and troubleshooting was appropriate. The engineers Sec:

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were knowledgeable of their systems. and actively participated in resolving identified problems (Section E4. l).

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09/23/1998 1998023 Pri: ENG NRC MISC Pri: 48 Operability determinations were of good quality and provided adequate justification for the conclusions with Sec:

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two exceptions. In one case. an operability determination to address condensate storage tank vortexing concerns failed to account for all condensate storage tank wa_tec loss sources. In a second case. the Ter:

licensee failed to complete a timely 10 CFR 50.59 safety evaluation to address a potential unreviewed safety question identified in an operability determination.

09/23/1998 1998023 Pri: ENG NRC POS Pri: lC The modifications. temporary alterations. and engineering requests reviewed were adequately designed.

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evaluated. installed. and tested. Two minor deficiencies were identified.

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Item Type (Compliance.Followup.Other), To 03/25/1999

Page: 6of 12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 09/23/1998 1998023 Pri: ENG NRC POS Pri: <18 Overall, the material condition and housekeeping of the station were satisfactory, and the ability of Sec:

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engineering personnel to identify material condition problems was acceptable. However, the team identified a number of material condition items such as loose or missing fasteners and screws, and various oil Ter:

and water leaks. The as-built configuration of the plant was in conformance with the description in the Updated Final Safety Analysis Report.

09/23/1998 1998023 Pri: ENG*

NRC POS Pri: <18 The vast majority of the temporary alterations reviewed were properly approved, installed, and Sec:

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documented. However, a number of deficiencies regarding the adherence to temporary alteration procedure requirements, such as the performance of quarterly wolkdowns and extended installation Ter:

reviews, were identified. In addition, two examples were identified in which temporary alterations were installed in the plant without proper approval.

09/23/1998 1998023 Pri: ENG NRC POS Pri: <18 Overall. the surveillance tests observed and documentation results reviewed were within the required Sec:

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acceptance criteria. Two examples were identified in which surveillance procedures were not adequate to

demonstrate that equipment met technical specification requirements Ter:

09/23/1998 1998023 Pri: ENG NRC POS Pri: <1C 1 O CFR 50.59 safety evaluations were of good quality and the licensee hod on acceptable program for Sec:

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ensuring that trained.and qualified personnel prepared and reviewed safety evaluations. Three examples were identified in which safety evaluations were not reported as required.

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09/23/1998 1998023 Pri: ENG NRC POS Pri: SA Engineering deportment self-assessment activities were effective. In particular, the threshold for the Sec:

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identification of problems was low: identified problems were elevated to the proper levels of management for resolution: operability issues were addressed: and corrective actions were adequate, timely, and properly Ter:

prioritized. The engineering deportment self-assessment audit schedule was comprehensive and included all major engineering functional areas.

09/23/1998 1998023-01 Pri: ENG NRC VIOIV Pri: lC The licensee foiled to review TALTs for extended installation as required by DAP 05-08. "Temorary Alterations".

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In addition, one unauthorized TALT was identified in the plant.

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e 09/23/1998 1998023-03 Pri: ENG Licensee NCV Pri: <1C During a self-assessment of the inservice testing (IST) program, the licensee identified four IST Code Sec:

Sec:

non-compliances: two related to check valves, one related to pressure isolation valve leakage testing, and one related to flow instrument ranges. In addition. during a followup assessment. three odditionol IST Code Ter:

non-compliance issues were identified: two related to check valve inspections. and one related to seat leakage testing. The licensee determined that the root cause of the IST non-compliance issues was that due to personnel error. the IST program did not fully incorporate the Code requirements.

09/23/1998 1998023-0<1 Pri: ENG Licensee NCV Pri: <1A On November 12, 1996: the licensee identified that the CCSW inlet temperature must be maintained below Sec:

Sec:

8<1 F to prevent exceeding thE! design peak suppression pool temperature of 170 F and stay within the bounds of. the existing containment analysis. The licensee determined that the root cause of this event was Ter:

inadequate design documentation which led to confusion regarding the original design basis. In addition, inadequate management oversight and design control led to low expectations which resulted in poor identification and resolution of the design basis issue, and inadequate implementation of compensatory actions to.address the operability issues.

Item Type (Compliance.Followup;Other), To 03/2S/1999

Page: 7 of 12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 08/28/1998 1998022 Pri: ENG NRC POS Pri: 5C Corrective actions for the previously identified issues were acceptable. Engineering involvement in the Sec:

Sec:

corredive action process was good (Sections E8. l - E8. 18).

Ter:

08/28/1998 1998022-01 Pri: ENG NRC VIOIV Pri: 4C A violation of 10 CFR Part 50. Appendix B. Criterion V. "Instructions, Procedures. and Drawings." was issued Sec:

Sec:

concerning an inadequate procedure for the control of equipment draining and process sampling related to the fire protection system (Section E8.19).

Ter:

02/26/1999 1999005 Pri: PLTSUP NRC NEG Pri: lC Weaknesses in the quality control and testing of a device fabricated by the licensee coupled with radiatio Sec:

Sec:

protection staH communication problems and problems with the development and documentation of an ALARA plan, caused a worker to ingest a small quantity of radioactive material during local power range Ter:

monitor replacement work. While no significant radiological consequences resulted, the worker was placed at increased radiological risk (Section Rl.3).

02/26/1999 1999005 Pri: PLTSUP NRC POS Pri: lC The ALARA program was eHectively implemented. ALARA plans were generally well developed and Sec:

Sec:

thorough, consistent with the potential radiological risks. and ALARA initiatives contributed to substantial dose savings. Protective clothing requirements were routinely relaxed to address heat stress concerns.

Ter:

improve worker eHiciency and thereby reduce doses. and associated ALARA evaluations were technically sound to support the initiatives implemented (Section Rl.2).

02/26/1999 1999005 Pri: PLTSUP NRO POS Pri: lC The licensee's program for the control and testing of portable high eHiciency particulate air (HEPA) filtered Sec:

Sec:

systems and vacuums was generally eHective. The licensee demonstrated good initiative and developed a program for chemical testing portable HEPA units (Section R2. l).

Ter:

02/26/1999

]999005 Pri: PLTSUP NRC POS Pri: lC Radworker performance had improved compared to previous outages as evidenced by problem Sec:

Sec:

identification form data, the relatively low number of personnel contamination events and other performance information. Worker contaminations were routinely planned as an ALARA measure. which e Ter:

proved eHective in keeping doses ALARA (Section R4. l).

02/26/1999 1999005 Pri: PLTSUP NRC POS Pri: lC Radiological postings were effectively maintained and accurately reflected the area radiological Sec:

Sec:

conditions. and high and locked high radiation areas were controlled consistent with station procedures and regulatory requirements. Appropriate contamination control practices were observed to be used by workers Ter:

and radiological controls for observed work activities were as prescribed by the ALARA plan. Housekeeping and material condition were generally good and exceptions noted by the inspectors were promptly corrected by the licensee (Section R4.2).

02/26/1999 1999005 Pri: PLTSUP

. NRC POS.

Pri: 3B Outage staHing and training for the radiation protection program was generally eHes:;tive. The training of Sec:

Sec:

contract radiation protection staH was completed in accordance with station procedures. and adequately prepared workers for assigned outage tasks (Section R5. l).

Ter; Item Tvoe (Comoliance.Followup,Other). To 03/25/1999

Page: 8 of 12 United States Nuclear Regulatory Commission Dote: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE MATRIX DRESDEN By Primary Functional Area Functional Template Dote Source Area ID Type Codes Item Description 02/26/1999 1999005 Pri: PLTSUP NRC STR Pri: lC Station dose performance for the Unit 3 refueling outage was excellent. Effective ALARA program Sec:

Sec:

implementation and generally good work planning. improved radiation worker performance and oversight of radiological work. and continued source term reduction initiatives produced the lowest collective Ter:

refueling outage dose in station history (Section R l. l ).

02/26/1999 1999005 Pri: PLTSUP NRC STR Pri: lC The licensee implemented a relatively aggressive and effective source term reduction program. and Sec:

Sec:

continued to monitor and track its effectiveness and explore methods to achieve further station dose savings (Section R l.4).

Ter:

02/26/1999 1999005-01 Pri: PLTSUP NRC NCV Pri: lC Isolated problems were identified with the radiological control of HEPA filtered systems and vacuums. One Sec:

Sec:

Non-Cited Violation was identified regarding thE;i failure to follow a station procedure for return of filtered vacuum cleaners used in radiologically posted areas (Section R2. l).

Ter:

01/15/1999 1999001 Pri: PLTSUP NRC MISC Pri: 18 The EP training program appeared effective. Interviewed key emergency response personnel demonstrated Sec:

Sec:

competent knowledge of responsibilities and emergency procedures. A number of plant deportments appeared to hove few. if any, staff fully qualified for respiratory protection ready to respond in the event of Ter:

on emergency. (Section P5) 01/15/1999 1999001 Pri: PLTSUP NRC MISC Pri: lC Emergency response facilities. equipment. and supplies were well-maintained. Demonstration of selected Sec:

Sec:

emergency response equipment verified that the equipment was operable. The implementation of the augmentation drill process did not effectively demonstrate the capability to augment the onshitt staff in a Ter:

short period of time. (Section P2. l) 01/15/1999 1999001 Pri: PLTSUP NRC MISC Pri: lC Management support for the program appeared strong as indicated by the successful implementation of a Sec:

Sec:

number of program upgrades. The EP trainer position hod been filled otter a six month vacancy, putting the organization bock in line with all other ComEd EP programs. (Section P6)

Ter:

e 01/15/1999 1999001 Pri: PLTSUP NRC POS Pri: lC The emergency implementing procedures reviewed were clear and easy to use. The Nuclear Tracking Sec:

Sec:

System was on effective method to track and close EP issues. (Section P3)

Ter:

01/15/1999 1999001 Pri: PLTSUP NRC POS Pri: lC The licensee's 1998 Site Quality and Safety Assessment EP program audit and 1998 EP Self-Assessment Report Sec:

Sec:

were effective in identifying a number of issues and satisfying the requirements of 10 CFR 50.54(t). (Section P7)

Ter:

01/15/1999 1999001 Pri: PLTSUP NRC STR Pri: lC Overall. the EP program was in on effective state of operational readiness. Management support to the Sec:

Sec:

program was strong. and interviewed key emergency response personnel demonstrated a good working knowledge of responsibilities and emergency procedures. (X 1)

Ter:

Item Tvoe (Comoliance.Followup,Other), To 03/25/1999

Page: 9of 12 United States Nuclear Regulatory Commission Date: 03/25/1999 Time: 07:09:07 Region Ill PLANT ISSUE.MATRIX DRESDEN By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 01/09/1999 1998030 Pri: PLTSUP NRC MISC Pri: lC *Overall. the licensee's radiation protection staff enforced the plant's radiological control standcirds.

Sec:

However, the inspectors observed several minor radiation protection issues. The inspectors were concerned that these examples. along with others. were not identified and addressed by the licensee prior to the Ter:

inspectors* identification. (Section Rl. l) 12/03/1998 1998029 Pri: PLTSUP NRC MISC Pri: lC The performance of the observed fire drill was good. A weakness was identified where the offsite fire Sec:

Sec:

department had not participated in fire drills with onsite fire brigade members since 1994.

Ter:

12/03/1998 1998029 Pri: PLTSUP NRC POS Pri: lC The inspector concluded that the fire protection procedures reviewed provided adequate fire protection Sec:

Sec:

controls and were adequately implemented by station personnel.

Ter:

12/03/1998

. 1998029 Pri: PLTSUP NRC STR Pri: lC Fire protection quality assurance audit reports and checklists were thorough and contained substantive Sec:

Sec:

findings.

Ter:

12/03/1998 1998029-01 Pri: PLTSUP NRC URI Pri: 2A Housekeeping was good and combustible material was well controlled. Required fire protection features Sec:

Sec:

appeared to be we)I maintained. One unresolved item was identified regarding fire stops and fire retardant coatings on redundant cable trays which were no longer maintained by the licensee in risk sensitive areas Ter:

11/24/1998 1998026 Pri: PLTSUP NRC NEG Pri: l B The inspectors identified an emergent negative trend in Unit 3 drywell air chemistry. Though minor, the issue Sec:

Sec:

revealed a lack of coordination and communication between departments with respect to early identification of potential drywell leaks. (Section R4. l)

Ter:

11 /24/1998 1998026 Pri: PLTSUP NRC NEG Pri: lC The security force showed mixed performance. The security staff twice intercepted prohibited items prior toe Sec:

Sec:

the items being introduced to the plant. However. personnel errors within security resulted in the unplanned outage of an electronic zone. (Section S4. l)

Ter:

11/24/1998 1998026 Pri: PLTSUP NRC POS Pri: l_C The licensee decontaminated a large portion of the Unit 3 torus basement. Unit 2 torus basement Sec:

Sec:

decontamination was planned. (Section R2. l)

Ter:

11/06/1998 1998028 Pri: PLTSUP NRC POS Pri: lC The REMP was well implemented and station oversighf of.contractor ac_tivities was effective. Data showed Sec:

Sec:

that plant operations did not have a discernible radiological impact on the environment. Sample collection.

sample change-out and pump calibration field practices simulated by the contractor technician were Ter:

technically sound. and the individual exhibited a thorough knowledge of the sample stations and sampling processes Item Type (Compliance,Followup,Other), To 03/25/1999

10/16/1998 10/15/1998 1998027-01 1998025 Pri: PLTSUP Sec:

Pri: PLTSUP Se.c:

Item Type (Compliance,Followup,Other), To 03/25/1999 NRC NRC VIO IV Pri: l C Sec:

Ter:

POS Pri: lC Sec:

Ter:

The inadequate search of a hand-carried package that entered the protected area. The failure was caused when a security search officer failed to recognize that an x-ray image displayed a partial picture of a package being searched. Inspection results showed that site licensee and contractor security personnel were not aware of a vulnerability in their package search program that could have allowed unauthorized material to enter the protected area. Corrective action was implemented in a timely and effective manner.

(Section S 1.2)

Radiological effluents were generally well controlled. although* several abnormal releases occurred that involved small quantities of radioactivity released through both liquid and gaseous effluent pathways.

Effluents were properly quantified. and doses were determined consistent with the Offsite Dose Calculatio.n Manual and remained well below regulatory limits

Page:

11of12 Region Ill DRESDEN Date 10/15/1998 10/15/1998 10/15/1998 Source 1998025 1998025 1998025 Functional Area Pri: PLTSUP Sec:

Pri: PLTSUP Sec:

ID NRC NRC NRC United States Nuclear Regulatory Commission PLANT ISSUE MATRIX Dale:* 03/25/ 1999 Time: 07:09:07 Type POS POS WK Template Codes Pri: lC Sec:

Ter:

Pri: lC Sec:

Ter:

Pri: lC Sec:

Ter:

By Primary Functional Area Item Description Overall. the liquid and gaseous effluent monitoring program was effectively implemented. Effluents were properly monitored. process effluent monitors were calibrated and functionally tested at required intervals.

and the calibration and test program was implemented in accordance with approved station procedures Positive steps were initiated to reclaim the main concentrator waste tank vault, and address long term problems with the radiological conditions in the room and with tank level instrumentation Performance and reliability problems with the Unit 2 service water monitor and the Unit 2/3 main chimney monitor have continued for several years. which the licensee recognized and recently focused additional efforts to address 10/15/1998 1998025-02 Pri: PLTSUP Licensee NCV Pri: lC Sec:

A non-cited violation was identified for the failure to sample a slightly contaminated liquid. prior to discharge into a clean floor drain in the turbine building. Discrepancies in certain liquid effluent flow paths described in the Updated Final Safety Analysis Report (UFSAR) were also identified. along with a 'potential weakness in the effluent sampling program for the Waste Water Treatment Facility (Section R l. l ).

10/06/1998 1998024 10/06/1998 1998024 09/23/1998 1998023 Sec:

Pri: PLTSUP Sec:

Prl: PLTSUP Sec:

Pri: OTHER Sec:

llnm T"no lr.nmnli,.nro Fnllriw11n.OlhAr). To 03/25/1999 NRC NRC NRC NEG NEG MISC Ter:

Pri: lC Sec:

Ter:

. Pri: 28 Sec:

Ter:

The station locked a formal policy regarding control of personnel secondary dosimetry outside the protected areas. The inspectors ide.ntified a weakness in the treatment and control of electronic dosimetry (Section R4. l).

The rodwoste facilities were maintained to lower housekeeping and material condition standards than the rest of the plant (Section R2. l).

Pri: 4C The licensee hod mode adequate progress in the implementation of the strategic reform initiatives reviewe Sec:

Ter:

Page:

12 of 12 Type Codes:

BU Bulletin CDR Construction DEV Deviation EEi Escalated Enforcement Item IFI

Inspector follow-up item LER Licensee Event Report LIC Licensing Issue MISC Miscellaneous MV Minor Violation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non-Conformance P21 Port 21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation WK Weakness United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Legend Template Codes:

l A Normal Operations l B Operations During Transients lC Programs and Processes 2A Equipment Condition 2B Programs and Processes 3A Work Performance 3B KSA 3C Work Environment 4A Design 4B Engineering Support 4C Programs and Processes 5A Identification 5B Analysis 5C Resolution.

ID Codes:

1;~ -.

-~:-1~--R-e-ve-a-le_d ___ I

[censee Licensee

_ _J Functional Areas:

OPS MAINT ENG PLTSUP OTHER Operations Maintenance Engineering Plant Support Other Dale: 03/25/1999 Time: 07:09:07 EEis ore apparent violations of NRC Requirements that ore being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy). NUREG-1600. However. the NRC hos not reached its final enforcement decision on the issues identified by the EEis

and the PIM entries may be modified when the final decisions are made.

URls ore unresolved items about which more information is required to determine whether the issue in question is an acceptable item. a deviation. a nonconformance. or a violation. A URI may also be a potential violation that is not likely to be considered for escalated enforcement action. However. the NRC has not reached its final conclusions on the issues. and the PIM entries may be modified when the final conclusions are made.

Item Tvoe (Coinpliance,Followup,Other), To 03/25/1999

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "All/Multiple" ; Beginning Date = "11/23/1997" ; Ending Date = "10/1/1998".

IC!JI DATE II TYPE II SOURCE 11 m BY II SALP llsMM coDEsll DESCRIPTION II 7/14/1998 Positive IA 1998019 2

4/9/1998 LEA IA 1998015 3

2/13/1998 Strength IA 98006 OAP 4

2/13/1998 LEA IA 98006 OAP NRG All/Multiple 1C Self-

-All/Multiple 18 Revealed Licensee All/Multiple. SA NRG All/Multiple SC Page 1 of 2 Areas of the response to the NRC's request for information under 1 O CFR 50.54(f) regarding safety performance at Commonwealth Edison reviewed by the inspectors showed good performance.

On April 9, 1998, Dresden Unit 3 experienced a full closure of all main steam isolation valves (MSIVs) from full power which resulted in a reactor scram. Initially, the cause of the MSIV closure was unknown. Dresden Station's Root Cause Analysis Team, established to evaluate this evee concluded that the most probable cause for the MSIV closure and resultant scram was a combination of two factors. The first factor was the discovery of a failed main steam line high flow switch during surveillance testing. Technical Specifications then required the MSIV trip channel

. associated with this failed flow switch be placed in a trip condition.

Therefore, the A portion of the MSIV trip system was placed in the tripped condition, thus satisfying one half of the MSIV closure logic. The second factor involved a loss of continuity for a contact associated with a time delay relay in the B MSIV trip system. This satisfied the second half of the MSIV closure logic and resulted in all MS IVs closing. The inspectors concluded the root cause effort was thorough and agreed with the licensee's conclusion.

The independent safety evaluation group was actively and effectively searching for procedures that allowed the torus to be bypassed, and getting them revised.

Once initiated, corrective actions to stop the practice of inerting and e deinerting the drywell and torus together were effective. The licensee's self-assessment of the timeliness of the corrective actions did not

. address the performance of the operations or the regulatory assurance departments.

3/24/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. Fo.r issues that do not have an actual date or a date of identification, use the LEA or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IA for NRC Inspection Report or LEA for Licensee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

~

DESCRIPTION Details of the issue from the LEA text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES.

SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements

EEis are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A-Normal EEi*

Escalated Enforcement Issue - WaitinQ Final NRC Action escalated enforcement action in accordance B - During Transients LEA License Event Report to the NRC with the "General Statement of Policy and C - Programs and Processes Procedure for NRC Enforcement Action" LicensinQ LicensinQ Issue from NRR (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (EmerQency Preparedness Findinq, etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcem.ent decision on the issues B - Programs and Processes NeQative Individual Poor Licensee Performance identified by the EEis and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance StrenQth Overall Stronq Licensee Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities.

URI**

Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL-11 Notice of Violation - Severity Level II (2) request a predecisional enforcement A* Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B - Engineering Support VIO/SL-IV Notice of Violation

Severity Level IV

- URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Pe.rformance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is a.n A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B -Analysis the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear ReQulatorv Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page 2 of 2

PLANT ISSUES.MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Operations" ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998'

\\C!JI DATE II TYPE II souRCE ll 1D BY II SALP llsMM coDEsll DESCRIPTION II 8/25/1998 VIO/SL-IV 2

8/25/1998 Strength 3

8/25/1998 Positive 4

7/30/1998 5

. 7 /14/1998 NCV 6

7/14/1998 Positive 7

7/14/1998 Positive 8

6/20/1998 Positive 9

6/20/1998 LER IR 1998021 IR 1998021 IR 1998021 IR 1998021 IR 1998019 IR 1998019 IR 1998019 IR 1998019.

IR 1998019 Licensee Operations NRC Operations NRC Operations Self-Operations Revealed Licensee Operations NRC Operations NRC Operations Self-Operations Revealed Self-Operations Revealed 1A 1A 1A 2A 1A 1B 1C 1B 2A Page 1 of 7 During this inspection period, the operators violated Technical Specifications during movement of spent fuel. The failure to recognize entry conditions and action statements of the Technical Specifications continued a negative trend (Section 04.2).

Routine performance was generally acceptable (Section 04.1 ).

The licensee planned power change evolutions well and executed troubleshooting activities in accordance with the plans. Operators performed the evolutions in a deliberate and controlled manner (Section 01.2).

The licensee declared the Unit 2 HPCI system inoperable during this inspection period due to the failure of the trip solenoid valve. The symptoms of this failure were similar to an earlier failure (Section 02.1 ).

Routine performance was generally acceptable. However, three times during this period operators failed to recognize issues addressed in Technical Specifications until prompted by other operators.

The operators in the control room performed correctly during the startup from the scram. Communications were clear and complete, and good command and control was evident. The inspectors identified no significant issues.

Overall, the Quality and Safety Assessment oversight of operations waA good. Audits of recent operational activities were informative, relevant~

and demonstrated good attention to detail by the auditors.

The operators responded to the turbine trip and scram correctly and in accordance with procedures.

The material condition (failed shut vent valve) of the 2A electro hydraulic control (EHC) pump caused the pump not to vent. Operators continued to run the pump despite multiple indications of equipment trouble. After about 3 minutes; the pump forced a slug of air through the EHC system, where the slug caused pressure oscillations and an automatic turbine trip and reactor scram. Subsequent event follow-up by the event response team and the plant operations review committee was considered thorough and demanding.

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" : SALP Area = "Operations" ; Beginning Date = '11 /23/1997" ; Ending Date = '10/1 /1998' 1w1 DATE II TYPE II SOURCE II IDBY II

SALP llsMM CODEsll DESCRIPTION 11 10 5/27/1998 Positive IR 1998014 NRC

Operations 1B Operators performed well during the conduct of reactor startups, reactor shutdowns, and in response to automatic reactor scrams. The operators conducted communications and heightened level of awareness briefs and executed tasks in a conservative and deliberate manner. (Sections 01.3, 01.4, 01.5, 01.6, 01.7, 01.10) 11 5/27/1998 Positive IR1998014 NRC Operations 1B The operators conducted an excellent heightened level of awareness -

brief in preparation for entering a higher-than-normal shutdown risk condition to troubleshoot a ground on the 250 VDC system. The planning and preparation for the task demonstrated a conservative policy with respect to shutdown risk activities. (Section 04.1) 12 5/27/1998 Strength IR 1998014 NRC Operations 1C The plant operations review committee (PORC) meetings were aggressive and probing, as was the management review meeting (MRM). The board members in both cases did not accept easy answers from the presenters. The PORC meetings and MRM added value to plant operations and supported a conservative operating philosophy. (Section 07.1) 13 5/27/1998 Negative

IR 1998014 NRC Operations 2A The excessive number of challenges to the operators presented opportunities for errors. For example, the choice to tolerate a leaking cross-around relief valve eventually led to a loss of condenser vacuum and a manual scram of Unit 3 on May 16, 1998. (Sections 01.8 and 01.9) 14 5/27/1998 LEA IR 1998014 NRC Operations SC The lice~see declared the Unit 2 high pressure coolant injection (HPC-system inoperable twice during this inspection period due to material condition issues. The material condition and repetitive failures of the HPCI system represented a challenge to operators. The repetitive failures of the gland seal leakoff condenser indicated that the licensee's prior corrective actions to address the deficiency were not completely effective. (Section 02.2) 15 5/25/1998............

IR 98014 Self-Operations 18 On May 25, 1998, the operators manually tripped the turbine and Revealed generator, but not the reactor, due to a loss of all cooling for the main power transformer. A failure of the cooling system's power selection device caused the loss of cooling. On May 26, 1998, operators synchronized the generator to the grid.

Page 2 of 7

PLANT ISSUES MATRIX Dresd-en 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column =* 'SALP" ; SALP Area = "Operations' ; Beginning Date = "11/23/1997" ; Ending Date = "10/1/1998" IC!JI DATE II TYPE II souRcE 11 m BY II SALP llsMM cooEsll DESCRIPTION II 16 5/20/1998 Negative IR 1998017 NRC 17 5/20/1998 Positive IR 1998017 NRC 18 5/20/1998 Negative IR 1998017 NRC 19 5/20/1998 Negative IR 1998017 NRC 20 4/17 /1998 Negative IR1998015 NRC Operations 18 Operations 18 Operations 58 Operations 58 Operations 18 Page 3 of 7 The inspectors noted that a control room distraction involving frequent steam jet air ejector (SJAE) drain level alarms and oscillating off gas flow existed during the reactor startup on May 15-16, 1998, due to an inadequate warmup and drain down of steam piping during alignment of the SJAE.

This special inspection included aspects of licensee operations and A.

engineering associated with the manual reactor scram from about 30.,.

percent power due to increasing main condenser pressure on May 16, 1998. Operations personnel appropriately and conservatively initiated a manual reactor _scram on increasing main condenser pressure prior to reaching an automatic trip set point The inspectors identified an example of poor communications between operations and engineering personnel about the cause for oscillating off gas flow indications and SJAE liquid level annunciators. Operations personnel believed the oscillations were due to instrumentation errors, where as, engineering personnel believed the oscillations were due to the introduction of undar:npened flow oscillations during SJAE system alignment The event review team performed a thorough analysis of the reactor.

scram and CAR valve 3 leakage. However, the event review team performed a limited assessment of the oscillations associated with the SJAE operation.

e The inspectors concluded that the operating crew was not effective in preventing RPV water level from entering the HPCI steam line after the event. The combination of the nuclear station operator (NSO) circumventing the automatic operation of the feedwater level control system (FWLCS) for eight seconds, decay heat, reducing pressure when initiating the isolation condenser, control rod drive water addition, and the inability to reinitiate the reactor waterclean up system in a timely manner all contributed to the high RPV water level.

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = 'Operations' : Beginning Date = "11/23/1997' ; Ending Date= '10/1/1998'

\\GJI DATE II TYPE II SOURCE II IDBY II SALP

11sMM CODEsll DESCRIPTION 11 21 4/17/1998 Positive IR 1998015 NRC Operations 18 The inspectors concluded that the operator's action to close the high pressure coolant injection (HPCI) steam line isolation valve after the receipt of the HPCI drain pot high level alarm with reactor pressure vessel (RPV) level +60 inches medium range was appropriate. The licensee concluded the amount of water that entered the HPCI steam line after the Unit 3 scram would not have had a negative impact on the system had it been called upon under the specific conditions observed during this -

event. The inspectors considered this was reasonable.

22 4/17/1998 Negative IR 1998015 NRC Operations 1C The inspectors concluded that the expectation of the NSO, that the FWLCS would control au!omatically after the individual feedwater regulating valve controllers were placed in manual and then back in auto, indicated a training weakness.

23 4/3/1998 Negative IR 98009 NRC Operations 1A Operators demonstrated a lack of attention to detail and weak operating practices during a reactivity management event. While the control rod mispositioning event held minimal safety significance, this event was similar in nature to the fuel bundle errors also documented in the report.

The licensee's prompt investigation into the event was thorough and appropriate.

24 3/3/1998 Positive IR 98005 OL NRC Operations 1A The.inspectors concluded that licensed operators discharged their duties

. in an efficient and professional manner. The control room operators were very attentive to the control panel indications and promptly communicated any abnormalities. The control room decorum was businesslike. e 25 3/3/19Q8 VIO/SL-IV IR 98005 OL NRC Operations 1A The inspectors identified a violation of 10 CFR 55.27 in which documentation of medical qualification data and test results for an operator performing the function of a licensed operator was not maintained or made available for NRC review upon request.

26 3/3/1998 VIO/SL-IV IR 98005 OL NRG Operations 1A The inspectors identified a violation in which procedures addressing the operations of a safeguards diesel generator were lacking appropriate guidance and the level of detail among related procedures was not consistent.

27 3/3/1998 Strength IR 98005 OL NRC Operations 1A In general, the licensed operator continuing training program was implemented in accordance with program guidance and met the regulatory requirements.

Page 4 of 7

PLANT ISSUES MATRIX

-Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Operations' ; Beginning Date = "11/23/1997" ; Ending Date = "10/1/1998" j~I DATE II TYPE II souRcE II 10 BY II SALP llsMM coDEsll DESCRIPTION II 28 2/20/1998 Negative IR 98003 DRP NRC Operations 1A 29 2/20/1998 Strength

. IR 98003 DRP NRC Operations 1 B 30 2/20/1998 Negative IR 98003 DRP NRC Operations.

1 B 31 1/13/1998 VIO/SL-IV IR 98003 DRP Self-Operations 1A Revealed 32 1/13/1998 Positive IR 98003 DRP NRC Operations 1 B 33 1/12/1998 Negative IR 97028 NRC Operations 1A 34 1/12/1998 Negative IR 97028 NRC Operations 1 A Page 5 of 7 The availability and performance of the licensee's high pressure coolant injection system continued an adverse trend during this inspection period.

The inspectors did not identify any performance deficiencies during the Unit 2 startup from a forced outage. Operators completed the startup of Unit 2 correctly and safely. The inspectors concluded that the Management Review Meeting was a positive meeting and added valu.

plant operations.

The inspectors were concerned that the operators were not completely in control of the shutdown cooling evolution as evidenced by the turn of reactor pressure and temperature parameters. The inspectors also identified that the corrective action process failed to resolve the adverse condition adequately.

The performance of an on-line surveillance test resulted in a turbine trip and the reactor scram of Unit 2 that occurred on January 13, 1998. The event resulted from an inadequate procedure and inadequate review of the plant impact of the surveillance test.

The operators' response to an automatic scram that occurred on January 13, 1998 was correct and in accordance with procedures.

The material condition of the HPCI system impacted system availability and required operator work-arounds to assure HPCI system operabilit\\A Repetitive equipment problems with the gland seal condenser level swl'flll" caused Unit 3 HPCI to be declared inoperable, and the alignment of the condensate storage tank once caused both HPCI systems to be declared inoperable.

The operations staff was slow to declare the HPCI system inoperable following the gland seal leak off condenser low level switch failure on December 29, 1997. More than 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> passed from the first symptom until operations recognized that the system was inoperable. Even after recognition, the limiting conditions for operation were not retroactively entered.

Other/NA

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' ; SALP Area = 'Operations" ; Beginning Date = "11/23/1997' ; Ending Date = '10/1/1998' lwl DATE II TYPE II souRcE 11 m sY II sALP llsMM coDEsll DEscR1PT10N II 35 1 /12/1998 Negative IR 97028 NRC Operations 36 1/12/1998 Strength IR 97028 NRC Operations 37 1/12/1998 VIO/SL-IV IR 97028 NRC Operations 38 1/12/1998 Negative IR 97028 Licensee Operations 39 12/23/1997 Positive IR 97028 Self-Operations Revealed 1A 18 1C 2A 18 Page 6 of 7 Operators generally were knowledgeable of the HPCI system parameters, settings, and requirements. The inspectors identified one instance involving turbine lube oil temperature where the requirements were not known.

Teamwork/Skill Level Operations personnel exhibited safe operating practices during the startup of Unit 2 that commenced on December 26. Crew briefs and -

heightened level of awareness briefs were informative, contingency actions were discussed, and peer checks were performed.

Teamwork/Skill Level The licensee failed to follow the procedural requirements to provide feedback to the problem identification form (PIF) originator. Subsequent to the inspectors' review of the process, the licensee independently identified this procedural adherence concern and entered it into the corrective action program. The licensee met the procedural requirements before the end of the inspection period.

Personnel. Performance Deficiency The inspectors concluded that the licensee's root cause team performed a thorough investigation of the reactor trip, the root cause, and equipment response following the reactor scram. The licensee's team concluded that the root cause of the event was the failure to perform the actions identified in GE SIL 500 regarding local power range monitor spiking.

The inspectors' review reached the same conclusion.

Equipment e Malfunction (Unit 2) Full reactor scram from 100% power due to a spurious APRM signal during an unrelated surveillance of reactor vessel high pressure scram signals.

The operators' response to the automatic reactor trip was good. The inspectors concluded that the actual safety consequences of this event were low. Operator and plant equipment response were generally as expected for an automatic reactor trip from full power. The exception involved the response of the feedwater level control (FWLC) system which over filled the vector vessel; however, in this case there were no adverse consequences from the level overshoot since the HPCI system was already isolated for troubleshooting efforts.

Equipment Malfunction

3/24/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LEA or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CbDE table.

SOURCE The document that contains the issue information: IA for NRC Inspection Report or LEA for Licensee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LEA text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements

. EEis are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Norm.al EEi*

Escalated Enforcement Issue - Waitinq Final NRC Action escalated enforcement action in accordance B - During Transients LEA License Event Report to the NRC with the "General Statement of Policy and C - Programs and Processes Procedure for NRG Enforcement Action" LicensinQ Licensinq Issue from NRR (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emerqency Preparedness Findinq, etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues 8 - Programs and Processes NeQative Individual Poor Licensee Performance identified by the EEis and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strenath Overall Stronq Licensee Performance are made. Before the NRC makes its 8 - Knowledge,, Skills, and Abilities Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment URI**

provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I

( 1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL-11 Notice of Violation - Severity Level II (2) request a predecisional enforcement A - Design VIO/SL-111 Notice of Violation - Severity Level 111 conference.

8 - Engineering Support VIO/SL-IV Notice of Violation - Severity Level IV

- URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - Analysis the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issu§lS, and the PIM NRC The Nuclear Requlatory Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page 7 of 7

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Maintenance' ; Beginning Date = '11/23/1997' ; Ending Date= '10/1/1998' IGJI DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll DESCRIPTION II 8/25/1998 Negative IA 1998021 NRG Maintenance 2A Material condition issues continued to adversely affect plant operations.

Some of these issues represented rework for the maintenance organization (Section M2.1 ).

2 8/25/1998 Misc IA 1998021 NRG Maintenance 28 The inspectors noted discrepancies between administrative and procedural requirements for independent verification. The licensee's Nuclear Oversight group also identified this issue and was pursuing it e through the corrective action process (Section M3.1 ).

3 8/5/1998 Negative IA 1998021 Self-Maintenance 3A Poor work practices on the refuel floor presented an unnecessary Revealed challenge to control room operators (Section M4.2).

4 7/31/1998 VIO/SL-IV IA 1998021 Self-Maintenance 3A Failure to execute procedures correctly resulted in the generation of an Revealed unexpected half-scram and disabled part of a reactor core protective feature. Independent verification, as implemented in this case, failed to prevent the error (Section M4.1 ).

5 7/14/1998 Negative IA 1998019 Self-Maintenance 2A The material condition of the plant equipment affected station operation Revealed and availability. For example, a failure in the electro hydraulic control pump's vent valve led to a reactor scram, an emergency diesel generator failed a surveillance test due to a loose wire in the governor system, and the security diesel generator started due to failed electrical distribution systems, then twice tripped off due to material condition.

6 7/14/1998 Positive IA 1998019 NRG Maintenance 3A No concerns were identified with maintenance activities directly observed. The mechanics and technicians followed procedures and v.fj instructions, and correctly documented the results. Issues discussed a station management meetings showed that the licensee was placing importance on emergent equipment problems commensurate with operations' requests, and that the licensee was actively using its planning procedures to assign work priorities. Review of issues identified in problem identification forms (PIFs) did not typically reveal significant rework or maintenance errors.

7 7/14/1998 Negative IA 1998019 NRG Maintenance 3A Maintenance on the core spray system was performed on-line for the first time instead of during a refueling outage. Problems venting the core spray system following the maintenance led to additional unplanned core spray system outage time.

Pag!3 1 of 7

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Maintenance' ; Beginning Date= '11/23/1997' ; Ending Date= '10/1/1998" IC!JI DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll.

DESCRIPTION 11 8

7/14/1998 Negative.

IR 1998019 Licensee Maintenance SC A potential common mode failure impacted the operability of the safety-related Containment Cooling Service Water (CCSW) pumps. The failure occurred during the conduct of routine maintenance activities. Once the problem was identified, the station responded aggressively to verify operability of the remaining CCSW pumps.

9 5/27/1998 Negative IR 1998014 NRC Maintenance 2A Equipment failures presented multiple challenges to the operators durin.

the inspection period. Some failures required quick initial operator response, and others created operator workarounds.* The events were primarily self-revealing in nature and were not identified through the licensee's formal surveillance testing or preventive maintenance programs. Lastly, some failures, such as the HPCI system and reactor feed pump ventilation problems, were repeat items, and the repeated problems showed that past licensee efforts were not successful. (Section M2.2) 10 5/27/1998 Positive IR 1998014 NRC Maintenance 28 The reactor pressure vessel (RPV) pressure test was a credible test that identified various items in the RPV system that needed repair before a unit restart. The test was a well controlled and performed test. (Section M1.1) 11 5/27/1998 Negative IR1998014 NRC Maintenance 28 Continuing a trend documented in prior NRC inspection reports, inadequate written procedures and work instructions created adverse equipment conditions and challenged the operators. In the Unit 2 main transformer case, inadequate modification instructions directly contribu.

to a condition that resulted in an automatic reactor scram from approximately 60 percent power. (Section M3.1) 12 5/27/1998.

Positive IR 1998014 NRC Maintenance 28 The licensee's drywell housekeeping efforts resulted in a level of drywell cleanliness that was adequate to support Unit 2 restart following the refueling outage. (Section M2.1) 13 5/27/1998 Strength IR 1998014 NRC Maintenance 28 The licensee successfully planned and executed a maintenance outage to replace the Unit 3 main transformer. (Section M1.2)

Page 2 of 7

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column,; 'SALP" ; SALP Area = 'Maintenance" ; Beginning Date = '11/23/1997' ; Ending Date= '10/1/1998'

\\C!JI DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll DESCRIPTION II 14 5/6/1998 Negative TS amendment ltr NRG Maintenance 28 The Technical Specification requirement that all MSSVs be set pressure dated 8/7 /98 tested or replaced each 40 months was added by the Dresden Technical Specification Upgrade Program (TSUP), license amendments Nos. 150 and 145, dated June 28, 1996. Your staff had an opportunity to complete this MSSV surveillance in the spring of 1997 during the Unit 3 refueling outage. The 40 month MSSV surveillance interval plus the 25 percent extension of TS 4.0.8 would expire on August 13, 1998 if not extended-one-time to a 60 month interval to allow plant operation to the next refueling outage. The staff considers that your staff's implementation of the TSUP amendment and planning for the last Unit 3 refueling outage was deficient for not including this surveillance. These deficiencies indicate that improvements are needed at Dresden to ensure that surveillance schedules are updated to implement changes to Technical Specification surveillance requirements.

15 4/27/1998 Positive IR 1998012 NRG Maintenance 28 In general, the licensee's inservice inspection program implementation met ASME,Section XI requirements. (Section M3.1) 16 4/27/1998 Positive IR 1998012 NRG Maintenance 28 Nondestructive examination was performed in accordance with applicable procedures by qualified NDE personnel. (Section MS.1) 17 4/27/1998 Positive IR 1998012 NRG Maintenance 28 The system leakage test met ASME Code requirements and was effectively implemented using lessons learned. (Section M1.3) 18 4/27/1998 Strength IR 1998012 NRG Maintenance 28 Overall the inservice inspection program was implemented in <:in effect.

manner. (Section M1.2) 19 4/27/1998 Positive IR 1998012 NRG Maintenance 3A The strainer modification had good supervisory oversight and was properly performed and controlled. (Section M 1.1) 20 4/17/1998 Positive IR 1998015 NRG Maintenance 28 The inspectors concluded that the licensee performed a thorough root cause analysis of the Unit 3 main steam isolation valve closure. The inspectors agreed with the licensee conclusion regarding the most probable cause for the main steam isolation valve closure and observed that the root cause team attempted to eliminate all other potential causes.

Page 3 of 7

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' ; SALP Area = "Maintenance" ; Beginning Date = "11/23/1997' ; Ending Date = '10/1/1998'

\\[!]I DATE II TYPE II SOURCE II IDBY. II SALP llsMM CODEsll DESCRIPTION II 21 4/17/1998 IA 1998015 NRC Maintenance 28 The inspectors concluded that the licensee entered the correct limiting condition for operation at the appropriate time for the failure of the 2E main steam line flow switch. The time spent in the limiting condition for operation could have been reduced by having a work package to repair a main steam line flow switch pre-prepared. The inspectors concluded that having the A MSIV trip system in a tripped condition was a contributing cause of the scram.

. e 22 4/3/1998 Positive IA 98009 NRC Maintenance 3A Maintenance department personnel performance during brush replacement on the Unit 3 re8:ctor recirculation motor generator sets was good. (Section M 1.2) 23 3/21/1998 Weakness IA 98003 NRC Maintenance. 28 Inadequate written work instructions and procedures impacted plant operations and maintenance. For example, an automatic reactor trip occurred during a surveillance test, and equipment was damaged due to installation of incorrect parts during maintenance of an emergency diesel generator... The violations all involved inadequate procedures or failure to follow procedures and represented a continuing trend of procedural and work instruction problems. Cover Letter 24 3/12/1998 Positive IA 98010 DRS NRC Maintenance 28 Weaknesses in the Delphi risk determination process, regarding weighting of operating and accident mitigation factors, and in the lack of availability of systems' performance criteria status were corrected.

25 3/12/1998 Strength.

IA 98010 DRS.

NRC Maintenance 28 The licensee properly addressed an unresolved item involving e

classification of structures, systems, and components when the only reliability criterion was no Maintenance Preventable Functional Failures.

Performance criteria for assessing the effectiveness of preventive maintenance.on (a)(2) systems/functions had been extensively revised and were more conservative, thorough, and informative. The unresolved item was closed.

26 3/12/1998 Strength IA 98010 DRS NRC Maintenance 28

The licensee properly addressed a violation involving failure to inelude the reactor vessel level indication function of the control rod drive hydraulic sy?tem within the scope of the program. A detailed review of the current scoping list.did not identify any omissions. The violation was closed.

27 3/12/1998 Positive IA 98010 DRS NRC Maintenance 58 A maintenance rule implementation self-assessment, conducted in January 1998, provided valuable input for improvements in the program.

Page 4 of 7

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Maintenance' : Beginning Date = '11/23/1997' ; Ending Date = "10/1/1998" lwl DATE II TYPE II souRcE II 1D sy II sALP llsMM coDEsll DEscR1PT10N II 28 3/12/1998 Positive IA 98010 DRS 29 2/20/1998 Weakness IA 98003 OAP 30 2/20/1998 Positive IA 98003 OAP 31 2/20/1998 VIO/SL-IV IA 98003 OAP 32 2/20/1998 VIO/SL-IV IR 98003 OAP NRC Maintenance SC

_NRC Maintenance. 2A NRC Maintenance 2A NRC Maintenance 28 NRG.

Maintenance 38 Page 5 of' 7 Corrective actions taken to resolve the February 1997 findings of Quality Assurance audit QAA 12-97-17 were acceptable. The associated inspection follow-up item was closed.

Some events caused by ttie material condition issues, such as the occurrence of premature hydrogen recombination in the off-gas system, were repeat items, similar to those documented in prior NRC inspecti *.

reports. The unavailability of the high pressure coolant injection syste has been a continuing problem at Dresden. During this inspection period, both the Unit2 and Unit 3 HPCI systems were again rendered inoperable*

due to equipment failures. cover letter The licensee improved the material condition of the control rod drive system by performing maintenance that resulted in better performance during the subsequent reactor startup. Other systems, such as the feedwater system and the high pressure coolant injection system, were observed to have minor leaks that required corrective maintenance during the inspection period.

The licensee completed major diesel maintenance within the time. allowed by Technical Specifications. However, errors in package preparation and failures of the errors to be detected during the review cycle led to rework, damage to equipment, and increased unavailability of safety-related equipment.

The inspectors identified incorrectly constructed scaffolding th~! was i-contact with safety-related equipment. Shortly after the end of the inspection period, the licensee identified that the safety-related standby gas treatment system was damaged and made inoperable by incorrectly constructed scaffolding.

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' ; SALP Area = 'Maintenance" ; Beginning Date = "11 /23/1997" ; Ending Date = "10/1/1998"

\\C!JI DATE II TYPE II souRcE II 1D BY II SALP llsMM coDEsll DESCRIPTION II 33 2/6/1998 Weakness 34 1/13/1998 35 1/12/1998 Weakness 36 1/12/1998 Weakness 37 12/13/1997 VIO/SL-IV IR 97028 DRP 50.72 call IR 97028 IR 97028 IR 97028 IR 97028 NRC Maintenance 2A Self-Maintenance 28 Revealed NRC Maintenance 2A NRC Maintenance 28 Self-Maintenance

. 38 Revealed Page 6 of 7 Plant material condition and some maintenance continued to challenge the operators. On December 6, 1997, efforts to restore the Unit 3 A train of the offgas system resulted in an offgas system fire. On December 13, work performed by the staff caused an unplanned entry into a two-hour limiting condition for operation. On December 23, Unit 2 automatically scrammed due to a spurious average power range monitor (APRM) signal during an unrelated surveillance of reactor pressure vessel higtA pressure scram signals. On three occasions during this inspection perr.

one or both HPCI systems were inoperable due to material condition and design issues. Some of the material condition issues were repeat items that.the station had not been able to resolve successfully. Cover Letter Unit 2 scrammed from full power. The cause was attributed mechanics isolating a reactor vessel level instrument causing a transient in a common sensing line which produced a turbine trip.

Personnel Performance Deficiency Collectively, equipment failures and material condition issues involving a control rod drive, a torus cooling test valve, an HPCI isolation, erratic operation of a recirc motor generating set, the offgas system, reactor water cleanup and feedwater level control, represented challenges and distractions for operators and other plant staff. The issues especially represented a burden to operators who had.either to respond to the original event, or to take additional compensatory actions.

Equipmen&

Malfunction Not all rework was captured into the rework trending program.

Inadequate.Procedure/Instruction On December 13, work performed without referencing a required procedure, combined with material condition,* resulted in a trip of the Unit 3 125 V battery charger and placed both units unexpectedly into a two-hour limiting condition for operations. The subsequent follow up work was not performed in accordance with station administrative procedures.

Specifically, the "condition" met sign off was used when a condition had not been met.

Personnel Performance Deficiency

3/24/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRG internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection report date.

TYPE The categorization* of the issue - see the TYPE ITEM CODE table.

SOURCE The documentthat contains the issue information: IR for NRG Inspection Report or LER for Licensee Event Report.

IDBY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries*.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRG Requirements

. EEis are apparent violations of NRG 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal EEi*

Escalated Enforcement Issue - Waitinq Final NRG Action escalated enforcement action in accordance*

B - During Transients LEA License Event Report to the NRG with the "General Statement of Policy and C - Programs and Processes Procedure for NRG Enforcement Action" LicensinQ Licensinq Issue from NRR (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emerqency Preparedness Findinq, etc.)

However, the NRG has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes NeQative Individual Poor Licensee Performance identified by the EEis and the PIM entries 3

Human Perfor.mance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strenqth Overall Strong Licensee Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities.

URI**

Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL~ll Notice of Violation - Severitv Level II (2) request a predecisional enforcement

A-Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B - Engineering Support VIO/SL-IV Notice of Violation - Severity Level IV

- UR ls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - Analysis the NRG has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Requlatcirv Commission entries may be modified when the final Self-Revealed Identification by an event (e.q., equipment breakdown) conclusions are made.

Other Identification unknown Page 7 of 7

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Engineering' ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998'

\\WI DATE II TYPE II SOURCE 11 m BY II SALP llsMM coDEsll DESCRIPTION I\\

8/25/1998 Licensing IA 1998021 NRC 2

8/25/1998 Negative IA 1998021 NRC 3

7/14/1998 VIO/Sl-IV IR 1998019 NRC 4

7 /14/1998 Negative IA 1998019 NRC 5

5/27/1998 Negative IA 1998014 NRC Engineering Engineering SC Engineering 48 Engineering 58 Engineering 48 Page 1 of 6 the overall use of "information only" drawings as described in UFSAR Section 1.7, is considered unresolved pending the inspector's review of the issue with the office of Nuclear Reactor Regulation (URI 50-237/249-98021-03(DRP)

Some of the older outstanding problems at the station are similar to current problems experienced by the station that are documented in.,a recent NRC inspection reports. Examples included HPCI system mate9" condition deficiencies, off-gas system fires, and reactor vessel post-scram overfill problems due to inadequacies associated with the feed water level control system. While the licensee has made progress in resolving old concerns, and the current issues are not as severe as the older items, the repetitiveness of several of the items indicated that licensee corrective actions had not always been effective at eliminating the concerns.

The post accident monitoring (PAM) instrumentation was lost when a nonsafety-related circuit tripped, revealing that instruments required by Technical Specifications were inappropriately powered by nonsafety-related circuits. The selected instruments did not meet the requirements specified in the Updated Final Safety Analysis Report (UFSAR).

Engineering personnel reviewing the loss of PAM took 3 days to conclude that the instruments were inoperable due to use of nonsafety-related power.

The root cause report on the loss of Post Accident Monitoring instrumentation performed by the licensee contained factual errors and information that could not be proven. The root cause report failed to discuss significant issues.

The incorrect modification package for the main steam line radiation monitor was similar in nature to previously documented NRC concerns with the adequacy of written instructions. The matter was also similar in nature to the concern discussed in Section M3.1, where an incorrect modification package directly contributed to a reador scram. In this case, the incorrect alarm set points in the modification package potentially placed the licensee in noncompliance with facility operating license conditions. This was an unresolved item. (Section E1.1)

PLANT ISSUES MATRIX

oresden 3124/1999/

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' ; SALP Area = "Engineering" ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998' I GJ I DATE 11 TYPE 11 SOURCE 11 ID BY 11 SALP 11 SMM CODES 11 DESCRIPTION 11 6

5/20/1998 Negative IR 1998017 7

5/16/1998 ENS call 8

4/27/1998 Positive IR 1998012 9

4/20/1998 LER IR 98014 10 4/17/1998 NCV IR 1998019 11

. 4/17/1998 Negative IR 1998015 Licensee

Engineering 58 Self-Engineering 2A Revealed NRG Engineering SC Self-Engineering 4A Revealed Licensee Engineering 4A Licensee Engineering 48 Page 2 of 6 The licensee identified an.example of poor communications between operations and engineering personnel which involved a lack of guidance on expected changes in plarit parameters following the identification that cross around relief (CAR) was leaking.

A manual scram was initiated from 33% power due to decreasing condenser vacuum. The cause was a leaking cross around relief valve-.

on a moisture separator.

W' Corrective actions taken to prevent recurrence of problems that resulted in violations, inspector follow up items, and licensee event reports were implemented and effective. (Section EB)

On April 20, Unit 2 scrammed from about 60 percent power, thus entering a forced outage (D2F32). The immediate cause was a generator trip due to a load reject caused by an incorrectly performed modification on the unit auxiliary transformer. On April 22, 1998, startup commenced and on April 23 operators synchronized the unit to the grid.

During the Unit 2 refueling outage (D2R 15) the licensee identified a modification to remove the Main Steam Line Radiation Monitor trip setpoint from the reactor protection system. The modification package incorrectly specified an alarm setpoint of 3.0 times normal background rates with hydrogen addition in service vice the license condition required 1.5 times normal background. Unit 2 startup from the refueling outage.A commenced on April 15, 1998, and the licensee discovered the setpoi1*

error ori April 17, 1998. Following the Unit 2 reactor scram on April 20, 1998, the licensee corrected the alarm setpoint. This non-repetitive, non-willful, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.8.1 of the NRG enforcement policy (NCV 50-237;98019-04).

The inspectors concluded that the response of reactor parameters to the transient was as expected.* However, a discrepancy between actual plant response and the Updated Final Safety Analysis Report, Section 15.2.4.1 description of reactor pressure and level, was identified by the root cause team. Licensee personnel stated that the need for an Updated Final Safety Analysis Report change would be addressed in the final root cause report.

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column,,; "SALP' ; SALP Area = "Engineering' ; Beginning Date = "11/23/1997" ; Ending Date = "10/1/1998"

\\w1 DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll DESCRIPTION II 12 3/4/1998 Licensing Letter dtd 4/1 /98 NRC Engineering 4C At Dresden, the submittals from ComEd have generally been satisfactory, although a few have been very good and a few were not well done. A few submittals, such as amendments 156/151 which removed the 24/28 Vdc batteries and distribution system from Technical Specifications, would have benefitted from a concise summary since they gave rather complicated descriptions of simple issues. Two issues needing close.

attention from ComEd include documenting any changes in commitm dates and documenting closure of R.G. 1.97issues.

13 2/20/1998 Negative IR 98003 DRP NRC Engineering 4A The feedwater level control (FWLC) system response presented a challenge to operators following a reactor scram. The compensatory

actions that operators were required to take following a scram constituted an operator work-around. Pending permanent resolution of the FWLC system performance issues, the station was re.lying on operator intervention following a scram to prevent water intrusion into HPCI system steam lines.

14 2/20/1998 Positive IR 98003 DRP.

NRC Engineering 48 The potential to overfill the reactor vessel following a reactor trip on either of the units required additional operator actions. The identification of the issue showed a good questioning attitude by engineering personnel.

15 2/13/1998 EEi IR 98006 DRP NRC Engineering 1C Issues involving the use of drywell and torus containment isolation valves were not promptly and thoroughly dispositioned at Dresden, resulting in an unanalyzed bypass of a containment feature during inerting and deinerting evolutions. An apparent violation was identified involving the failure to ensure that the design basis was correctly translated into procedures such that procedures allowed simultaneous opening of.

drywell and torus ventilation valves. A second apparent violation was identified for failure to promptly identify and correct the conditions which allowed this practice following notification of the issue by the LaSalle Station and by NRG inspectors.

16 1/27/1998 VIO/SL-IV IR 97021 DRS NRC En.gineering 4A From November 1994 through November 21, 1997, the Fire Protection Report, referenced as part of the UFSAR, had not been updated and the required revision updates submitted to the NRC. VIO 50-237/249-97021-03(DRS)

Page 3 of 6

PLANT ISSUES MATRIX

-Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Engineering' ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998' IGJI DATE II TYPE II SOURCE II 1D BY II SALP llsMM coDEsll DESCRIPTION II 17 1/27/1998 URI IR 97021 DRS NRC 18 1/27/1998 VIO/SL-IV IR 97021 DRS NRC 19 1/27/1998 VIO/SL-IV IR 97021 DRS NRC 20 1/27/1998 Strength IR 97021 DRS NRC 21 1/27/1998 Strength IR 97021 DRS NRC 22 1 /14/1998 Positive IR 1998019 NRC 23 1/12/1998 Negative IR 97028 NRC Engineering 4A Engineering 4A Engineering 48 Engine*ering 4C Engineering 4C Engineering *

48 Engineering 48 Page 4 of 6 The team had concerns that the UFSAR did not accurately characterize the plant's design-basis or the plant's capability to respond to a potential Dresden Lock and Dam failure. As a result, the team concluded that further review by the licensee and NRC was required. An NRC URI was initiated to document these concerns. URI 50-237/249-97021-01 (DRS))

As of November 21, 1997, the fire pre-plans had not been updated sine&

September 1992. VIO 50-237/249-97021-04(DRS)

In November 1994, the licensee identified that a prior inadvertent change to the Dresden Station's control room ventilation system design deleted the automatic smoke purge mode transfer capability. From November 1994 to March 1996, the licensee failed to perform a written safety evaluation to provide the bases for the determination that the change did not involve an unreviewed safety question. VIO 50-237/249-97021-02{DRS))

Overall the inspection concluded that the engineering staff was effective in the identification and resolution of technical issues. Self-assessments exhibited a pro-active trend in the attempt to disclose performance problems within the engineering organization. The quality of engineering activities was in most cases technically sound.

The team concluded that all commitments and corrective actions identified by Confirmatory Action Letter (CAL) No. Rlll-96-016,.dated November 21, 1996, including those activities associated with the Dresden Engineering Assurance Group (DEAG) have satisfied NRC requirements. The CAL was closed.

The licensee organized a team to determine methods of scram and derate reduction and improve material condition. This effort had the potential to improve plant material condition and reduce significant challenges to the operators.

The licensee's response to identified errors in the setpoints for HPCI system oil temperatures was poor. The licensee's original explanation of setpoint tolerances was. incorrect, and the situation was not addressed until Operators wrote a second problem identification form.

Other/NA

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Engineering" ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998' IWI DATE II TYPE II

.souRcE II 1D BY II SALP llsMM coDEsll DESCRIPTION II 24 1/7/1998 LER 25 12123/1997 Negative LER 249/98001 Licensee Engineering 4A IR 97028 Self-Engineering 4A.

Revealed Page 5 of 6 Post-LOCA temperature in the secondary containment higher than values used for the environmental qualification of electrical equipment due to original design error.

The FWLC system response presented a potential challenge to the operators following the reactor scram. The compensatory actions that the operators were required to take following a scram on Unit 2 were ope.

workarounds. *Pending permanent resolution of the Unit 2 FWLC syst issues, the station was relying on operator intervention following a scram to prevent water intrusion into HPCI steam lines.

Equipment Malfunction

3/24/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRG internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LEA or inspection report date.

TYPE The categorization of the issue ~ see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRG Inspection Report or LEA for Lice.nsee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

~

DESCRIPTION Details of the issue from the LEA text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRG Requirements

EEis are apparent violations of NRG 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal EEi*

Escalated Enforcement Issue - Waitinq Final NRG Action escalated enforcement action in accordance B - During Transients LEA License Event Report to the NRG with the "General Statement of Policy and C - Programs and Processes Procedure for NRG Enforcement Action" Licensing Licensinq Issue from NRA (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emerqency Preparedness Findinq, etc.)

However, the NRG has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Neqative Individual Poor Licensee Performance identified by the EEis and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strength Overall Stronq Licensee Performance are made. Before the NRG makes its B - Knowledge, Skills, and Abilities

URI**

Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL-11 Notice of Violation - Severity Level II (2) request a predecisional enforcement A - Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B - Engine~ring Support VIO/SL-IV Notice of Violation - Severity Level IV

- URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - Analysis the NRG has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page 6 of 6

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" : SALP Area = "Plant Support" : Beginning Date = "11/23/1997" ; Ending Date = "10/1/1998"

\\C!JI DATE II

TYPE II souRcE 11 m BY II SALP llsMM coDEsll DESCRIPTION II 8/13/1998 Weakness IR 1998021 Licensee 2

7 /17 /1998 Strength IR 1998020.

NRC 3

7 /17 /1998 Positive IR 1998020 NRC 4.

7/17/1998 Strength IR 1998020 NRC 5

7/17/1998 Strength IR 1998020 NRC Plant Support Plant Support Plant Support Plant Support Plant Support 28 Page 1 of 7 On August 13, 1998, the licensee released a truckload of dirt offsite. The licensee subsequently sampled the dirt and two of the four samples

exceeded the licensee's radiological criteria for free-release of material from the station. While the radiological consequences of the event were minor, breakdowns in licensee processes and practices resulted in the

. release of contaminated soil from the site.

The audit and surveillance program for the packaging and transportati.

of radioactive material, for the 1 O CFR 71 quality assurance (QA) program and for the processing of radwaste was effectively implemented. Audits and surveillances were generally properly focused, were of sufficient scope and depth to assess program performance, and any identified deficiencies were adequately corrected. The QA organization, however, acknowledged that an alternative focus for future audits of the 10 CFR 71 QA program would enhance the assessment program (Section R7.1 ).

The training provided to staff involved in the shipping and transportation of radioactive material was adequate and satisfied Department of Transportation (DOT) regulations. Qualified shipping personnel completed a comprehensive course in radioactive material transportation regulations and procedures and were cognizant of pertinent DOT regulations (Section R5.1 ).

Licensee oversight of vendor onsite radwaste processing activities wae appropriate. Wet solid wastes were processed in accordance with the vendor's process control program (PCP) and procedures, and dewatered waste streams were sampled and verified to ensure that regulatory limits for free standing liquid were not exceeded. (Section R1.1 ).

The radioactive material packaging and transportation program was well implemented. Radwaste shipments were appropriately classified; vehicle and package surveys were performed as required; and manifests were completed in accordance with regulatory requirements. The scaling ffictor program for classifying waste streams was technically sound and properly implemented. However, minor problems were identified with the adequacy of certain procedures (Section R1.2).

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Plant Support' ; Beginning Date = "11 /23/1997" ; Ending Date = "10/1 /1998" IC!JI DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll DESCRIPTION II 6

7/17/1998 Negative IA 1998020 NRC Plant The licensee's process control program did not include sufficient detail Support concerning 10 CFR 61.56 waste characteristic requirements, and both the PCP and Updated Final Safety Analysis Report (UFSAR) were not fully consistent with current onsite waste processing activities (Section R1.1 ).

7 7/14/1998 Negative IA 199809 Self-Plant 2A The security diesel failed twice when called upon and once during a te.

Revealed Support*

run due to material condition.

8 7/14/1998 Positive IA 1998019 NRC Plant 3C Overall, the licensee's radiation protection staff enforced the plant's Support radiological control standards. The licensee continued to use personnel functioning as "greeters" to assure that workers entering the radiologically controlled area were aware of dose rates and administrative protection requirements.

9 6/4/1998 Negative IA 1998018 Licensee Plant The licensee identified two examples.in which terminated plant personnel Support were allowed unescorted access to the protected area and ten additional examples which terminated personnel had the opportunity to gain unauthorized access. The events, which were of low safety significance, were related to a programmatic deficiency in a procedure and inconsistent action by a contractor supervisor. Adequate corrective action was implemented.

10 6/4/1998 Negativ~

IA 1998018 NRC Plant 2A Within the last year, delays in repair of some security equipment assigned Support to the licensee's Electrical and Mechanical Maintenance organization.

have increased. The licensee is taking action to identify the causes a to establish measures to reduce the delays.to repair security equipment.

. 11 6/4/1998 VIO/SL-IV IA 1998018 Licensee Plant 3A One licensee-identified violation was noted in *which two license-Support designated personnel failed to complete required FFD "call-out work record" forms for individuals contacted for unscheduled work. Previously required fitness-for-duty implemented corrective action has resulted in improved performance in completing those forms but has not been totally effective in preventing recurrence.

12 5/27/1998 Positive IA 1998014 NRC Plant The licensee's radiation protection staff enforced the plant's radiological Support control standards. The licensee continued to use personnel functioning as "greeters" to assure that workers entering the radiologically controlled area were aware of dose rates and administrative protection requirements. (Section R1.1)

Page 2 of 7

PLANT ISSUES MATRIX Dresden-3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Plant Support' ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998'

\\~I DATE II TYPE II SOURCE 11 m BY II SALP llsMM coDEsll DESCRIPTION II 13 5/8/1998 Positive IA 1998016 NRC 14 5/8/1998 Strength IA 1998016 NRC 15 5/8/1998 Negative IA 1998016 Licensee 16 5/8/1998 Positive IA 1998016 NRC 17 5/8/1998 Strength

IA 1998016 NRC Plant Support Plant Support Plant Support Plant Support Plant Support 28 3A 3C 3C Page 3 of 7 The calibration arid test programs for the whole body contamination monitors and the whole body counters (WBCs) were technically sound and implemented in accordance with station procedures. Contamination monitor alarms were set at appropriate levels and instrument sensitivity and alarm operability were successfully demonstrated. However, a minor discrepancy was identified with the acceptance criteria specified in the WBC calibration procedure and its application to the last full A

calibration.

WI' Radiological postings were well maintained and accurately reflected the area radiological conditions. Container labeling was acceptable, although some minor deficiencies were noted, which the licensee planned to evaluate and address. Radworker practices throughout the balance of the plant were appropriate, and radiological housekeeping and material condition of reactor and turbine buildings was good, with the' exception of water intrusion problems in the Unit 2 condensate pump booster area.

One violation was identified concerning an inadequate evaluation of the airborne concentrations during the tensioning of the Unit 2 drywell cover on April 11, 1998, contributing to an intake of radioactivity greater than that planned. Additionally, the RP staff identified several problems related to the work activity that included job turnover and supervisory oversight weaknesses, APT job coverage deficiencies and problems with the scope of the pre-job briefings and associated documentation.

The ALARA group was actively involved in the work planning process, e and an effective interface existed between RP and the work control group. Outage dose goals were being met due to minimal emergent work and rework and successful performance of work scheduled to date.

Radiological preparations for work activities were good with one exception

. related to the preparation for high risk work in the drywell to repair a leaking control rod drive (CAD). Those preparations failed to include surveys of shoot-out steel prior to the initiation of work in the area, causing the CRD repairs to be delayed. ALARA plans were well developed and clearly conveyed the radiological work requirements, and pre-job briefings attended by the inspectors were thorough. Radiological control of work activities and radiation worker practices were good.

Engineering controls, ALARA initiatives and job planning were instrumental in controlling dose.

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = "Plant Support' ; Beginning Date = '11/23/1997' ; Ending Date = '10/1/1998'

.\\CiJI DATE II TYPE II souRCE II 1D BY II SALP llsMM coDEsll DESCRIPTION II 18 3/24/1998 Strength IR 1998011 NRC 19 3/24/1998 Positive IR 1998011 NRC 20 3/24/1998 Positive IR 1998011 NRC 21 3/24/1998 Misc IR 1998011 NRC 22 3/24/1998 Negative IR 1998011 NAC Plant Support Plant Support Plant Support Plant Support Plant Support 3A 3A 3c Page 4 of 7 The training of prospective contract (RP) staff was completed in accordance with station procedures, and adequately prepared workers for assigned outage tasks (Section R5).

Administration of the RP program during the first half of the planned 40-day outage was generally good, and was not adversely affected by the RP organization changes made just prior to the outage, and the unexpected loss of several contract radiation protection support staff e in the outage (Section R6).

Radiological control of work activities was good with some exceptions related to occasional drywell work coordination and oversight problems.

ALARA initiatives, engineering controls and job planning were effectively implemented, and efforts to control dose, prevent intake of radioactive material and limit personnel contamination events were successful (Section R1.2).

Although there was no significant dose producing emergent work and

rework during the outage, work scope additions after the outage dose goals were established contributed to some early accelerated outage work and associated dose. With the exception of weaknesses associated primarily with the scaffolding construction program, the planning, scheduling and implementation of the outage work process was sufficient (Section R1.1).

Radiological housekeeping and control and labeling of radioactive e materi.al was good in most areas. However, general housekeeping in certain areas of the drywell was poor, and a water drip from a known leaky valve in the drywell was apparently not addressed until the problem was brought to the licensee's attention by the inspectors. While radiation area posting discrepancies were noted in the reactor building, areas were posted and controlled in accordance with NRC requirements (Section R4.2).

PLANT ISSUES MATRIX 3/24/1999 Dresden Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Plant Support" ; Beginning Date= "11i23/1997" ; Ending Date= "10/1/1998"

\\C!JI DATE II TYPE II SOURCE II IDBY II SALP llsMM coDEsll DESCRIPTION II 23 3/24/1998 Positive IR 1998011 NRC Plant.

3C Radiation worker (radworker) practices improved as the outage Support progressed and in general, were better than previous refueling outages.

Initiatives such as the greeter program, increased emphasis on worker responsibility, first line supervisory oversight and stronger radiation protection (RP) control point oversight, were instrumental in reduCing poor racjworker practices. While the station's aggressive approach in challenging craft workers about crew size and knowledge of the e

radiological work environment had some positive effect on contractor work control and dose, continued emphasis in this area is warranted (Section R4.1 ).

24 3/11/1998 Negative IR 98008 DRS NRC Plant 1C The inspector identified that the licensee failed to conduct a for-cause Support drug test after receiving credible information that an individual was abusing drugs. The credible information was the results of a recent drug test. Licensee's actions regarding sanctions taken against the individual appeared appropriate to address the safety aspects of the event to deter drug use and maintain plant safety. The event was an isolated error and not indicative of a programmatic problem.

25 3/11/1998 VIO/SL-IV IR 98008 DRS NRC Plant 1C The inspector observed a violation when a vehicle was inadequately Support searched. Weak attention to detail by the search officer caused the violation. Prior licensee corrective action for similar findings in two previous inspections that focused on weak individual performance did not prevent recurrence.

26 3/11/1998 Negative IR 98008 DRS NRC Plant 1C The licensee failed to suspend un~scorted access for a plant employe-Support a timely manner. The event appeared to be an isolated individual error related to weak attention-to-detail by a clerk in the licensee's badging department and not a programmatic problem. Licensee corrective action was implemented in a timely and effective manner.

27 2/20/1998 Strength IR 98003 OAP NRC Plant 1C Overall performance of radiation protection personnel was good. The Support radiation protection personnel maintained up-to-date survey maps, responded correctly to potentially contaminated personnel, and challenged plant workers' understanding of radiation hazards and controls.

Page 5 of 7

PLANT ISSUES MATRIX Dresden 3/24/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Plant Support" ; Beginning Date = '11/23/1997' ; Ending Date = *10/1/1998' I~ I DATE 11 TYPE 11 SOURCE 11 ID BY 11 SALP 11 SMM CODES 11 DESCRIPTION 11 28 2/S/1998 Strength IR 98004 NRC 29 2/S/1998 Strength IR 98004 NRC 30 2/S/1998 Positive IR 98004 NRC Plant Support*.

Plant Support Plant Support 1C SC SC Page 6 of 7 The unconditional release program was based on a sound technical basis and was consistent with industry survey methods and standards. The training program appeared comprehensive and the training records

indicated that all radiation protection technicians had completed the most recent training. Instruments used for unconditional release were qualified, and observations of technicians performing unconditional surveys during previous inspections indicated they were accomplishe required.

Corrective actions taken to prevent recurrence of problems in the material unconditional release program that resulted in violations, LER's, and.

Problem Identification Forms were implemented and effective.

Corrective actions taken to prevent recurrence of problems in the material unconditional release program that resulted in violations, LER's, and Problem Identification Forms were implemented and effective.

3/24/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRG internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection r.eport date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRG Inspection Report or LER for Licensee Event Report.

ID BY Identification of who discovered the issue - see _table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

tt DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRG Requirements

. EEis are apparent violations of NRG 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal EEi*

Escalated Enforcement Issue - Waitinq Final NRG Action escalated enforcement action in accordance 8 - During Transients LEA License Event Report to the NRG with the "General Statement of Policy and C *- Programs and Processes Licensinci Licensing Issue from NRR Procedure for NRG Enforcement Action" (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emerqency Preparedness Findino, etc.)

However, the NRG has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues 8 - Programs and Processes NeQative Individual Poor Licensee Performance identified by the EEis and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strencith Overall Strong Licensee Performance are made. Before the NRG makes its 8 - Knowledge, Skills, and Abilities URI**

Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I

( 1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL-11 Notice of Violation - Severity Level II (2) request a predecisional enforcement A - Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

8 - Engineering Support.

VIO/SL-IV Notice of Violation - Severity Level IV

- *uRls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an A - Identification acceptable item, a deviation, a IDBY nonconformance, or a violation. However, 8 - Analysis the NRG has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Requlatorv Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page? of 7

DRESDEN INSPECTION I ACTIVITY PLAN IP - Inspection Procedure Tl - Temporary Instruction Core - Minimum NRC Inspection Program (mandatory all plants)

Regional Initiative - Discretionary Inspections NUMBER OF INSPECTION NRC I

TITLE I PROGRAM AREA INSPECTORS/

ACTIVITY INDIVIDUALS IP81700 Security (SEC1) 1 NRCB 96-03 ECCS Strainer Audit 4

IP82301 Emergency Preparedness 4

IP82302 Exercise IP81700 Security (SEC2) 1 IP83750 Radiation Protection 1-2 IP86750 Transportation IP37550 Engineering & Technical Support IP40500 Problem ldent., Res., & Prevent.

7 IP37001 50.59 Safety Evaluation Program Notes:

CD Followup on previously identified weaknesses in Engineering.

PLANNED DATES

March 8 - 12, 1999 March 29 - April 2, 1999 May 25 - 28, 1999 July 12 - 16, 1999 July 26 - 30, 1999 August 30 - September 17, 1999 TYPE OF INSPECTION/

ACTIVITY-COMMENTS Core Audit Core Core Core Core Regional lnitiativeCD

ML17191B296

Contents

Text

SUBJECT:

Dear Mr. Kingsley:

Enclosures:

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