ML17191B468

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Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities.Plant Issue Matrix Encl
ML17191B468
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 09/30/1999
From: Ring M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
NUDOCS 9910120039
Download: ML17191B468 (36)


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Mr. Oliver D. KingJley President, Nuclear! Gener~tion Group Commonwealth Edison Company ATTN: Regulatol)I Services Executive Towers West Ill 1400 Opus Place, /Suite 500 Downers Grove, Ill 60515 I

September 30, 1999

SUBJECT:

MID-CYCLE PLANT PERFORMANCE REVIEW (PPR) - DRESDEN I

I Dear Mr. Kingsley'.

i On September 1, ;1999, the NRC staff completed the mid-cycle.Plant Performance Review (PPR) of Dresden) Nuclear Power Station. The staff conducted these reviews for all operating nuclear power plants to integrate performance information and to plan for inspection activities.

The focus of this performance review was to identify changes i.n performance over the past 6 months at your facility and to allocate inspection resources over the next? months.

I Our 6-month review of Dresden identified that your performance in certain areas warranted increased NRC attention:

I In the area of engineering, an engineering and technical support inspection originally scheduled for the fall of 1999 has been rescheduled to early in 2000. This inspectiqn was in response to past equipment problems. Based on our review, the assigned resources on this inspection were refocused to include reviews of controls on computer software and engineering support to maintenance. The inspection team will include five inspectora and use Inspection Procedures 37001, 37550, and 40500.

The resident inspectors will focus regional initiative inspection efforts on reviewing maintenance and material condition issues. Also, *a core inservice inspection planned during th~ fall outage will look at causes for the pipe leak that occurred on the

I contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that wereiconsidered during this PPR process to ~rrive at our integrated review of licensee perfomiance trends. The PIM includes items summarized from iAspection reports or other docketed correspondence between the NRC and Commonwealth Edison Company from September 1, 1 S98, to September 1, 1999. As noted above, g.reater emphasis was placed on those issues identified in the past 6 months during this performance review. The NRC does not I

attempt to document all aspects of licensee programs and performance that may be functioning appropriately.* Rather, the NRC only documents issues that it believes warrant management attention or rep~esent noteworthy aspects of performance.

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'l 9910120039 990930 PDR ADOCK 05000237 Q

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0. Kingsley

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I This letter advises you of our plans for future inspection activities at your facility so that you will have an opportunity to prepare.for these inspections and to provide us with feedback on any planned inspections which may conflict with. your plant activities. Enclosure 2 details.our inspection plan through March 2000 to coincide with the scheduled implementation of the revised reactor oversight process in April 2000. The rationale or basis for each inspection I

outside the core inspection program is discussed above so that you *are aware of the reason for emphasis in these program areas. Re~ident inspections are not listed due to their ongoing and continuous nature. !

I If circumstances ari 1~e which cause us to change this.inspection plan, we will contact you to discuss the change: as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may /have.

Docket Nos. 50.:.237; 50-249 License No~. DP*-19; DPR-25

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Enclosures:

1. i Plant Issues Matrix

.2'. f Inspection Plan i

See Attached Distribution

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I Sincerely,

'/s/ R. Learch for.

Mark A. Ring, Chief Reactor Projects Branch 1 DOCUMENT NAME: G:\\DRES\\INSPTN PLAN9WPD

  • To receive a of lhia lioa.ment, indicate in Iha box "C"
  • C without attacnmenl/ancloaure "E"
  • C with attacnmenl/aridoaura 'W'
  • No OFFICE Rill C Rill

~ Rill E Rill NAME Lerch:co Grobe

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DATE 09/ 1/99 09~99 09f2.1 /99 OFFICIAL RECORD COPY

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0. Kingsley cc w/encls:
  • D. Helwig, Senior Vice President, Nuclear Services C. Crane, Senior Vice President, Nuclear Operations H. Stanley, Vice President, Nuclear Operations R. Krich, Vice President, Regulatory Services DCD *- Licensing M. Heffley, Site Vice President P. Swafford, Station Manager D. Ambler, 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 Honorable 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 Chief, NRR/DIPM/llPB T. Boyce, *NRR w/encls Project Director, NRR w/encls Project Mgr., NRR w/encls J. Caldwell, Rill w/encls B. Clayton, Rill w/encls R. Lickus, Rill w/encls SRI Dresden w/encls DRP w/encls DRS w/ends

  • Rill PRR w/encls PUBLIC IE-01 w/encls
  • Docket File w/encls GREENS.\\ \\

Page: 1of31 09/23/199914:20:53 IR Report 3 Region Ill DRESDEN Date 08/1211999 Source 1999012 Dockets Discussed:

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t.l~LLU:>UKt. 1 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID

. Type NRC NEG NRC NEG NRC POS NRC POS NRC POS

By Primary Functional Area Template Item Title Codes

. Item Description Prl: 1 A Divergence between the local sight glass and the remote control room* Indications for torus ievel caused ope Sec:

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Divergence between the local sight glass and the remote control room indications for torus level caused operators to enter and execute the Dresden Emergency Operating Procedures.

Failure of Unit l's Isolation condenser reactor return valve (3-1301-4) to open during valve cycling caused the

  • Failure of Unit J's isolation condenser reactor return valve (3-1301-4) to open during valve cycling caused the isolation condenser to become inoperable. The inspectors concluded that the operators performed well during the performance of the single loop operation.

The overall condition of the high pre~sure coolant Injection system and the Isolation conden*ser system on b

appeared acceptable. The status of the systems was correct for the mode of ~peration.

Radwaste operators demonstrated a heightened level of awareness by identifying Increased unknown inputs Radwaste'operators demonstrated a heightened level of awareness by-identifying increased unknown inputs*into the floor drain collector tank. A leak in the containment cooling service water piping was subsequently.located. The licensee responded well by planning and executing a replacement of the leaking pipe within the time allowed by Technical Specifications.

. The performance In operations was acceptable. Goo~ monitoring, briefs, and communications were evident The performance in operations was acceptable. Good monitoring, briefs, and communications were evident throughout the period. The licensee identified some minor issues regarding activation_ of the shift technical advisor and use of short duration time clocks during surveillance testing.

Failure to perform TS required tests The LER reported that on March 23, 1997, during a review of previous shifts' log book entries, an operator recognized that surveillance tests required by Action Statement 2.a. of Dresden TS 3.9.A., had not been performed within the required intervals. Action Statement 2.a. stated that with one of the required diesel generators not operable, a demonstration to show that the offsite power sources were operable was to be complete within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the diesel was declared Inoperable and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Contrary to this, the licensee failed to perform the required tests.

Item Type (Compliance.Followup.Other), From 08/31/1.998 To 08/3111999

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG NRC STR NRC NOED NRC NCV NRC MISC NRC NEG By Primary Functlonal Area Template Item Tltle.

Codes Item Description Prl: 1A Leakage Into the Unit 2 torus suggested that a potentlal secondary containment bypass exlste.d. After questl

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Leakage Into the Unit 2 torus suggested that a potential secondary containment bypass existed. After questioning by the Inspectors, the licensee performed an operability evaluation and concluded that the secondary containment was operable. The Inspectors agreed with the licensee's conclusion.

Operator performarice during plant evolutlons anci power operations was good. The operators performed the Operator performance during plant evolutions and power operations was good. The operators performed the correct

  • Technical Specification actions. The Inspectors agreed with the licensee's conclusion The NRC applled enforcement discretion The Technical Specifications required a shutdown of Unit 3 due to failure of the combination safety/relief valve.. The lii:ensee took actions to comply with the Technical Specifications, but also presented information that showed that the combination safety/relief valve was not credited In the plant's accident analyses. The Nuclear Regulatory Commission applied enforcement discretion which permitted Unit3 to continue operating~~ power.

Licensee Identified some Instances where operators, both llcensed and non-llcensed, failed.to follow all the a.*

The performance In operations was generally acceptable. The licensee identified some instances where operators, both licensed and non-licensed, failed to follow all the administrative procedures or failed to communicate properly.

On March 21, 1999, the licensee decreased reactor load to approximately 40 percent power to perform a dryw On March 21, 1999;the licensee decreased reactor load to a~roximate~ 40 percent power to perform a drywell entry to invest~ate the source of Increased drywell leakage.

perators

  • iscovered that the reactor pressure boundary was eakln~ from a failed weld on a 1-inch diameter instrumentation line for the reactor recirculation *
  • .system. O~erators s ut down the Unit 3 reactor (and started forced outage D3F28) In accordance with Dresden Technical pecifications. The repairs were completed and the plant returned to power on March 24. Unit 3 remained at full power throughout the remainder-of the Inspection period.

Throughout the Inspection period, the llcensee took steps to address the low pressure coolant Injection (LPC

. Throughout the in~ction period, the licensee took steps to address the low pressure coolant injection (LPCI) heat exchan~er pressu ation. However, the Inspectors were* concerned that despite indications that the pressurization of the L Cl system was Increasing, there was a lack of formalized guidance to the operators for a LPCI system pressurization threshold and actions to be taken. (Section 02.4) llem Type (Compliance,Followup.Other). From 08/3111998 To 08/3111999 e

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG NRC NEG NRC POS NRC POS NRC POS NRC MISC By Primary Functlonal Area Template Item TIUe Codes Item Description Prl: 2A A material condlUon problem, In combination with a procedural Inadequacy, created an unnecessary burden Sec:

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A material condition problem, In combination with a procedural Inadequacy, created an unnecessary burden to the operators. As a result, hydrogen addition system effectiveness was reduced until the procedure could be revised to support placing the system In service. This Issue was similar in nature to _a concern documented in the prior.

Inspection report. Operators did not enter the procedural inadequacy concern Into the system's corrective action process. (Section 02.2)

Material condition deficiencies presented unnecessary challenges to the operators foll owing completion oft Material condition deficiencies presented unnecessary challenges to the operators following completion of the Unit 3 refueling outage. The licensee had either worked on the Items during the refueling outage or reviewed them for deletion from the outage. (Section 02.3)

The Inspectors ~oncluded that operators established and followed a conservative contingency.jllanfollowlng The Inspectors concluded that operators established and followed a co.nservative contingency plan "following the initial Identification of increased drywell activity. The inspectors also noted that operations engaged other support organizations to track' and trend apparent drywell leakage. (Section 02. 1)

The operators performed routine operations In a safe manner. (Section 04.1 The operators performed routine operations in a safe manner. (Section 04. 1)

  • the overall performance of operators during the Unit 3 shutdown due to pressure boundary leakage and dur The inspectors eo~cluded that the overall performance of operators during the Unit 3 shuidown due to pressure boundary leakage and during the subsequent startup was good. (Section 04.2)

Spurious operation of the shutdown cooling high temperature lsolatlon twice caused losses of shutdown coo Spurious operation of the shutdown cooling high temperature isolation twice caused losses of shutdown cooling.

The operators responded appropriately and restored cooling. (Section 02. 1)

Item Type (Compliance,Followup,Other), From 08/31/1998 To 08/3111999

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX

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Type

  • NRC NEG NRC NEG NRC NEG NRC NEG NRC
  • PCS NRC PCS By Primary Functional Area Template Item Title Codas Item Description Prl: 1A the length of time that the Isolation condenser, a relatively high worth system In the plant's Probablllstlc Rls Sac:

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Dua to a combination of procedural problems and a repetitive material condition challenge, operators were unable to immediately perform the actions of the annunciator response procedure. As a result, the length of time that the Isolation condenser, a relatively high worth system In the plant's Probabilistic Risk Assessment, was in an alarm status was unnecessarily lengthened. (Section 02.2)

Operator performance In opening an Instrument valve during restoration from the Unit 3 hydrostatic test led Operator performance in opening an instrument valve during restoration from the Unit 3 hydrostatic test led to an unplanned full scram while the reactor_was shutdown. (Section 04.3)

Five Instances occurred during the Inspection period where actions by station personnel resulted In lnadvert Five instances occurred during the Inspection period *where actions by station personnel resulted in inadve'rtent LCO entries. While no LCO time clocks or action statements were violated, the items presented an unnecessary challenrce for control room og:rators. The events were similar in nature to four items documented in the prior NRC inspect on report. (Section

. 7)

The station failed to ensure that the latest revision of a procedure was available to control room operators pr The station failed to ensure that the latest revision of a procedure was available to control room operaiors prior to

  • performance of a test. ogerators did not document the occurrence via the Problem Identification Form (PIF) process until questioned y the inspectors. (Section 03.1)

The plant management personnel provided proper oversight of the outage activities on *unit 3 while malnta.in The plant management personnel provided proper oversight of the outage activities on Unit 3 while maintaining Unit 2 operating at full power. (Section 01.2)

Overall operator performance was good.

Overall operator'performance was good.. In general, the operations staff followed procedures correctly, used good command and control, and took correct actions. This resulted in generally smooth operations, and contributed to good housekeeping in the plant. (Section 04.3)

Item Type (Compliance.Followup.Other). From 08/3111998 To 08/3111999 e

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC POS NRC POS Licensee POS NRC POS NRC NCV NRC MISC By Primary Functlonal Area Template Item Tltle Codes Item Description Prl: 18 Operators completed the Unit 3 shutdown safely and correctly. (Section 04.1)

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Operators completed the Unit 3 shutdown safely and correctly. (Section 04.1)

Operators performed well during the conduct of the reactor startup.

Operators performed well during the conduct of the reactor startup. The operators conducted good heightened level of awareness briefs, and communicated well and executed tasks in a conservative and deliberate manner. (Section 04.2)

There were no Identified fuel handling errors such as mlspositions and misorlentations during either the par There were no identified fuel handling errors such as mispositions and misorientations during eiiher the partial offload or fuel shuffle evolutions. Inspectors also reviewed a video tape of the final reactor core loading audit and ictenlified no errors. (Section 04. 5)

The Inspectors concluded that housekeeping In both the drywell and torus was good as evidenced by closeo The inspectors concluded that housekeeping in both the drywell and torus was good as evidenced by closeout Inspections which only found minor discrepancies. (Section 04.6)

Inadequate procedure major contributor for exceeding TS limit Procedural inadequacies contributed to the licensee inadvertently exeeeding a Technical Specification limitation for drywell-to-torus leakage and the subsequent entry into the drywell-to-torus differential pressure limiting condition for operation (LCO). The inspectors also noted that the operator failed to recognize that the valve manipulation being performed on this system would cause equalization between the drywell and the torus. (Section 04.4) accessible portions of the high pressure coolant Injection systems, the core spray systems, and the low pres The inspectors 'walked down accessible portions of the high pressure coolant injection systems. the core spray systems, and the low pressure coolant injection systems. The inspectors identified no substantive concerns from these walkdowns. Equipment operability, observed material condition, and housekeeping were generally acceptable. (Section 02.1)

Item Type (Compliance,Followup,Other). From 08/3111998 To 0813111999

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type Licensee NEG NRC NEG NRC STR NRC NCV NRC NCV NRC NCV By Primary Functional Area Template Item TIUe Codes

. Item DescrlpUon Prl:.1A Four Instances were ldenUfled where Technical Specification and Dresden Administration Technical Require Sec:

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Four Instances were Identified where Technical Specification and Dresden Administration Technical Requirement (DATR) Limiting Conditions for Operation (LCO) time limits were not met either because station personnel did not understand the impact of their activities ori these requirements, or did not realize conditions had changed which warranted an entry Into the LCO action statements. (Section 04.2)

  • *The licensee's response to previous problems with the post-accident hydrogen and oxygen monitoring syste The licensee's response to previous problems with the post-accident hydrogen and oxi11en monitoring system failed to ldent~ another H2/02 monitor annunciator procedure that also contained errors. T 1s issue was subseguently correcte. (Section 03.1)

The non licensed operatoni (NLOs) effecUvely Identified equipment abnormalities

  • The non licensed operators (NLOs) effectively Identified equipment abnormalities during the conduct of their round.s.

The early identification of the equipment deficiencies allowed the station to remove the equipment from service in an orderly fashion before the problems presented a more severe challenge to plant operations. (Section 04.1)

Failure to Verify fire Damper Operability On December 1, 1998, the licensee Identified that the 18-month fire damper.surveillance had not been ccimpleted prior to the critical due date of -;f ril 30, 1998. The surveillance work request had been improperly closed without the acceptance criteria being met.

total of 13 dampers had not been inspected when the surveillance had been signed off as being complete. Instead, station personnel had written action requests to build scaffold, remove Insulation, and inspect the dampers.

Failure to Verify Operability of all Primary Containment Isolation Valves On December 1, 1998, the licensee Identified that the monthly primary containment locked valve checklist was not completed in accordance with the re?iulrements of TS 3. 7.A. The TS allowed valve eosition checks In high radiation areas (inaccessible areas) to be veri 1ed by administrative controls. The licensee utilized two primary containment locked valve checklists, one for accessible areas and one for inaccessible areas. The licensee had improved radiological conditions In areas of the torus and previously "inaccessible" areas were now accessible for valve checks.

Failure to collect service water grab sample every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Non-Routine Sam~e Time Requirement Exceeded due to Chemistry Technician Personnel Error. Licensee Event Report 50-249196 3-00 documented that on April 15, 1996, a service water effluent sample was invalid because it was taken from an Isolated section of the service. water system. The error occurred when a chemistry technician took samf.'es from a section of the service water system that had been taken out-of-service. The licensee adjusted the out-o -service boundary and took a sample. That sample, and the last 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.

Item Type (Complianee,Followup,Other). From 08/3111998 To 08131/1999 e

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United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG Self NEG Self NEG NRC POS Self POS Licensee WK By Primary FuncUonal Area Template Item TIUe Codes Item Description Prl: 1A The setpolnts for the heat trace on the post-accident sampling system were less than setpolnts listed on a lo Sec:

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The setpolnts for the heat trace on the post-accident sampling system were less than setpoints listed on a local placard. The actual value for one heat trace line was drifting below the alann setpoint listed in an annunciator procedure, but no alann actuated. The licensee failed to assure that.this condition was detected during routine rounds. (Section 02.2)

Procedural Inadequacy and Inattention to detail on the part of the operators directly caused a reactor protect Procedural Inadequacy and Inattention lo detail on the part of the operators directly caused a reactor 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 questioning attitude. (Section

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Inadequate out-of-service dlrecUons resulted In the Initiation of work on the fire protectlo*n system t~at was o Inadequate out-of-service (OOS) directions resulted in the initiation of work on the fire protection system that 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)

Overall control room performance was good.

Overall control room perfonnance was good. Perfonnance outside of the control room was acceptable with respect to performing procedurally-required rounds, but was not as effective at identifying Issues outside of the rounds procedures. (Section 04.1)

Inadequate work procedures, combined with weak maintenance pracUces, caused the 3C circulating water pu Inadequate work procedures, combined with weak maintenance practices. caused the 3C circulating water pump discharge valve to fall open with the pump secured, which resulted in a significant challenge to the. control room

  • operators. Operators responded appropriately and correctly implemented the abnormal operating procedures to prevent the transient from getting worse. (Section 04.3)

The licensee declared the Unit 3 high pressure coolant Injection (HPCI) system Inoperable due to the failure o

. The licensee declared the Unit 3 high pressure coolant injection (HPCI) system inoperable due to the failure of the gland seal 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 lo address problems with the GSLO condenser,.

however, this repeal failure of this HPCI subsystem showed that the licensee's prior corrective actions to address tlils Issue were not effective enough to correct the deficiency. (Section O;l.1)

'"*"-*****~ "'"n*I ~*nm nRl11/1Q'IR To 08131/1999

.e

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  • 05000249 DRESDEN 3 Hii15/1998 1998025 Dockets Discussed:

05000237DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1991!

  • 1998024 Dockets Discussed:
  • 05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024-01" Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0912311998 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: OPS Sec:

Prl: OPS Sec: PLTSUP Prt:ops Sec:

_)

Prl: OPS Sec:

  • Prl:OPS Sec: PLTSUP Prl: OPS Sec:

United States Nudear Regulatory Commission PLANT ISSUE MATRIX ID Type Self NCV NRC NEG NRC MISC NRC NEG NRC NCV NRC POS By Primary Functional Area Template Item Title Codes Item Description Prl: 1C Inadequate Surveillance lnstiucUons Sec:

Ter:

Prl: 2A Sec:

Ter:

Prl: 1A sec:

Ter:

Prl: 1A Sec:

Ter:

Prl: 1C

-Sec: -

Ter:

Prl: 1C Sec:

Ter:

During performance of the test, operators" received an unexpected reactor protection system (RPS) half-scram

-signal. The licensee documented the occurrence via problem identification form (PIF) D1998-05643. The licensee's prompt investigation efforts revealed that the operating crew had selected the.Incorrect RPS test box. Contributing factors included procedural adequacy and operator attention-to-detail concerns that were self-revealing as a result of the unexpected half-scram. -

Radiological housekeeping and materlal condition In the radioactive waste building was Inconsistent with hi Radiological housekeeping and material condition in the radioactive waste building was inconsistent with h~her standards maintained in other plant areas, which the licensee planned to address. In addition. while the e uent monitor control terminal in the main control room functioned property. a panel placard *used as an aid to assist operators select monitor data from the terminal, listed information that was inconsistent with the liquid effluent monitors The licensee had taken actions to.prevent basic operational errors and to stop a negative error trend.

The licensee had taken actions to prevent basic operational errors and to stop a negative error trend. The 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 improved The operational status of equipment continued to challenge the smooth operations of the planl The operational status of 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 inspe'ctors identified an inoperable control rod. The licensee identified that-the reactor building - suppression chamber. vacuum breakers had not been proven operable. Overall, the operat~onal status of facilities *and equipment challenged the station Failure-to complete requrled fire brigade training 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 had not completed the required training.

The operating experience program was effectively Implemented.

The operating experience program was effectively implemented. Operating experience information was evaluated appropriately, and adequate corrective actions were identified and implemented in a timely manner Item Type (Compliance,Followup,Other), From 08/3111998 To 08~1/1999 e

e

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05000237 DRESDEN 2

. 05000249 DRESDEN 3 0912311998 1998023 Dockets Discussed:

05000237 DRESDEN 2 -

05000249 DRESDEN 3 0811211999 1999012 Dockets Discussed:

  • 05000237 DRESDEN 2 05000249 DRESDEN 3 08/1211999 1999012 Dockets Discussed:

05Q00237 DRESDEN 2 05000249 DRESDEN 3

. 0811211999 1999012 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl:OPS Sec:

Prl: OPS Sec:

Prl:OPS Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Jype NRC POS NRC POS NRC*

POS

  • NRC NEG NRC NEG
  • NRC POS By Primary Functional Area Template Item Tltle Codes Item Description Prl: 1 C The nuclear oversight self-assessment program was effectively Implemented and provided valuable performa Sec:

Ter:

Prl:SA sec:se Ter: SC Prl:se Sec:

Ter:

Prl: 1A Sec:

Ter:

Prl: 1A Sec:

Ter:

Prl: 1A Sec:

Tei:

The nuclear oversight self-assessment program was effectively implemented and provided valuable performance insights The corrective action process was effective.

The corrective action process was effective and the threshold for identifying and correcting problems was low. The licensee had identified significant Issues and implemented timely corrective actions which achieved lasting results.

(Section 07.1)

The root cause analysis program was effectively Implemented.

The root cause analysis program was effectively implemented. Issues were thoroughly investigated, the root causes Identified were reasonable, and corrective actions were comprehensive.and timely. (Section 07.2)

The performance In operations was acceptable. Good monitoring, briefs, and communications were evident The performance in operations was acceptable. Good monitoring, briefs, and communications were evident throughout the period. The licensee identified some minor issues regarding activation of the shift t~chnical advisor and use of short duration time clocks during surveillance. testing.

A non-cited violation was Identified which_ was due fo maintenance personn~I not properly verifying that the A non-cited violation was identified which was due to maintenance personnel not properly verifying that the motor pinion gear key for the isolation condenser return valve motor actuator was staked in place. The isolation condenser reactor return valve failed and caused the isolation condenser to be inoperable. This resulted in the licensee having to enter single recirc loop operation and perform a drywell entry to repair the valve.

Maintenance department personnel performed well during the performance of both.routine and emergent tas Maintenance department personnel performed well during the performance of both routine arid emergent tasks. The Outage Control Center personnel performed in a well organized and deliberate fashion. This resulted in the licensee successfully responding to.challenges such as the unplanned Technical Specification required limiting conditions for operation for the isolation condenser and containment cooling service water.

Item Type (Compliance.Followup,Other). From 08/31/1998 To 08/3111999

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05000237 DRESDEN 2.

06/24/1999 1999011

- Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 06124/1~99 1999011 i:>ockets Discussed:

05000237 DRESDEN 2,

05000249 DRESDEN 3 06124/19~.9 1999011 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 06124/1999 1999011 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT

  • Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type

.NRC NCV NRC NCV NRC NEG NRC NEG NRC NEG NRC NEG By Primary Functional Area Template Item Tltle Codes Item Description Prl: 3A.

Maintenance workers falled to verify that the motor pinion gear of the Isolation condenser& reactor return val Sec:*

Ter:

Prl: 1C Sec:

Ter:

Prl:2A

  • Sec:

Ter:

. Prl: 2A Sec:

Ter:

Prl:3A Sec:*

Ter:

Prl:3A Sec:

Ter:

A non-cited violation was identified which was due to maintenance personnel not properly verifying that the motor pinion gear key for the isolation condenser return valve motor actuator was staked in place. The isolation condenser reactor return valve faile_d and caused the isolation condenser to be inoperable. This resulted in the licensee having to enter single recirc loop operation and perform a drywell*entry to repair the valve.

Licensee exceeded requirements, by 39 days, of TS Table 4.2.F-1

  • quarterly surveillance frequency for the so TS Table 4.2.F-1, required a quarterly surveillance frequency for the source range monitors. Contrary to the _above, on April 16, 1997, the licensee exceeded the requirement by 39 days.

Loose bolts penetrating the control room envelope permitted water from a heating coll to leak Into the contro

  • Loose bolts penetrating the control room envelope permitted water from a healing coil to leak into the control room and onto the control room panels. The water damaged nonsafety-related chart recorders and displays Malfunctions of reactor feed pump ventilation arid *the 2A reactor feedwater regulating valve's actuator affect Malfunctions of reactor feed.pump ventilation and the 2A reactor feedwater regulating. valve's actuator affected smooth operations and required, or will require, repair.

On May 22, 1999, whlle moving valves and pipe fittings from a lay down area to the job site for building lntak On May 22, 1999, while moving valves and pipe fittings from a lay down area to the job site for building intake canal cooling towers, a crane boom came Into proximity to nonsafety-related Line 1263 (a 34-kV line) and caused the line.

to trip. This was an additional example of a problem with vehicle/heavy equipment control onsite The maintenance work on the Unit 2 emergency diesel generator was performed correctly and within the time*

The maiatenance work on the Unit 2 emergency diesel generator was performed correctly and within the time allowed by the Technical Specifications. The licensee noted some problems in achieving cooling water now*and turbo oil pressures during post-maintenance testing and the problems were corrected Item Type (Compliance,Followup:Other), From 08/3111998 To 08/3111999

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05000237 DRESDEN 2 05000249 DRESDEN 3 05/21/1999 1999008 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05121/1999 1999008 Dockets Discussed:

05000237 DRESDEN 2.

05000249 DRESDEN 3 0512111999 1999008 -

Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05121/1999 1999008 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: MAINT Sec:

Prl: MAINT

. Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

United States Nuclear Regulatory Commission PLANfissUE MATRIX ID Type NRC POS

\\._

NRC WK NRC NEG Licensee NEG NRC POS NRC WK By Primary Functlonal Area Template Item Tltle Codes Item Description Prl: 3A Operator performance during plant evolutions and power operations was good. The operators performed the Sec:

Ter:

Prl: 18 Sec:.

Ter:

Prl: 2A Sec:

Ter:

Prl:28 Sec:

Ter:

Prl: 28 Sec:

Ter:

Prl:2A Sec:

Ter:

Operator performance during plant evolutions and power operations was good. The operators performed the correct Technical Specification actions The material condition of the Unit 3 emergency diesel generator's heat exchanger caused the licensee to ente The material condition of the Unit 3 emergency diesel generator's heat exchanger caused the licensee to enter an unplanned diesel outage. During the course of work to replace the heat exchan~ers, the licensee found cracks in one of the replacement heat exchanger's end caps. After the end of the inspection period, the licensee concluded that the cracks were th~ result of overtorquing the end bell housing onto the heat exchanger.

The material condition of the reactor water cleanup systems Impacted operations on both units.

The material condition of the reactor water cleanup systems impacted operations on both units. In one instance, one non-regenerative heat exchanger failed and leaked Into the reactor building closed cooling system. In the other instance, a resin intrusion occurred as the licensee attempted to place the JC demineralizer into service. The licensee restored the systems to service before exceeding any Technical Specification limitations.

Parts unavallable and mlscommunlcatlons delayed the replacement of the failed Instrument The licensee replaced a scram discharge volume instrument after the licensee identified that the instrument had failed. The licensee's critique of the work noted that parts unavailabilities and mlscommunications delayed the replacement of the failed Instrument while a one-half scram signal was inserted.

The licensee had performed the maintenance required by the TS on the combination safety/relief valve The licensee had performed the maintenance required by the TS on' the combination safety/relief valve The materlal condltlo_n problems of the reactor reclrculatlon systems on both units Impacted smooth full-pow The material condition problems of the reaetor recirculation systems on both units impacted smooth full-power operations.

Item Type (Compliance,Followup,Other). From 08/31/1998 To 08/31/1999

Page: 12 of 31 09/2311999 14:20:53 IR Report 3 Region Ill DRESDEN Date Source 05121/1999 1999008-02 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 OS/21/199g 1999008-03 Dockets Discussed:

05000237 DRESDEN 2 0500024g DRESDEN 3 04/07/1999 1999006 Dockets Discussed*:

05000237 DRESDEN 2 05000249 DRESDEN 3 04/07/1999 1999006 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 04/07/1999 1999006 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0212611999 1999003 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functlonal Area Prt: MAINT Sec:

Prt: MAINT Sec:

Prt: MAINT Sec:

Prl: MAINT Sec:.

Prt: MAINT Sec:

Prt: MAINT Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NCV NRC NCV Licensee Misc Licensee NEG NRC NEG Licensee NEG By Primary Functlonal Area Template Item Tltle' Codes Item Descrlptlo11 Prt: 28 Inspectors noted poor performance In areas of work package preparation and procedural adequacy Sec:

Ter:

Prt: SC Sec:

Ter:

Prt:2e Sec:

Ter:

Prl:3A Sec:

Ter:

Prl:3A Sec:

Ter:

Prt:2e Sec:

Ter:

The licensee ccimpleted planned maintenance on the control room heating, ventilation, and air conditioning system within the Technical*Specification lime limitations. However, the inspectors noted poor performance by the licensee in the areas of work package preparation and procedural adequacy. These performance issues caused the refrigeration control unit to be inoperable for approximately 1 O days without the operators being aware of it.

Inadequacies In the licensee's corrective action program during maintenance.

The licensee completed planned maintenance on the control room healing, ventilation, and air conditioning system.

within the Technical Specification time limitations. Inadequacies in the licensee's corrective action program were

  • revealed during this maintenance.

. The maintenance on the high pressure coolant Injection system took longer than planned...

  • The maintenance on the high pressure coolant injection system took longer than planned to perform due to parts unavailability and the installation of incorrect brushes in the motor gear unit and motor speed changer. The licensee captured the lessons learned for incorporation into future maintenance. (Section M4.1)

Fallure to follow work. Instructions and poor communications c;aused delays In repairing the reclrculatlon pu Failure to follow work Instructions and poor communications caused delays in repairing the recirculation pump flow sensing line. (Section M1.2)

The Inspectors noted that some'of the material condition concerns following the completion of the refueling The Inspectors noted that some of the material condition concerns following the completion of the refueling outage were associated with work performed during the outage. (Section M2.1)

The licensee experienced problems with main turbine alignment due to the removal and relnstallatlon of con The licensee experienced problem~ with main turbine alignment due to the removal and re installation of condenser support struts. Personnel performing the work did not follow station expectations by performing the work without an approved work package. (Section M4.4) llem Type (Compliance,Followup,Other), From 08/31/1998 To 08/3111999

Page:

13 of 31

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05000237 DRESDEN 2

. 05000249 DRESDEN 3 0212611999 1999003.

Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999003 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 021261199~

1999003 Dockets Discussed:.

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999003-02 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999003-03 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: MAINT Sec:

Prl: MAINT.

Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG NRC POS NRC POS

  • NRC POS By Primary Functional Area Template Item Tltle Codes Item Description Prl: 3A Five out-of-service errors occurred during maintenance work performed during the Unit 3 refuellng outage.

Sec:

Ter:

Prl:2A Sec:

Ter:

Prl:3A Sec:

Ter:

Five out-of-service errors occurred during maintenance work performed during the Unit 3 refueling outage. None of the out-of-service violations resulted In injury lo personnel or adverse impact to plant equipment. Initial corrective actions taken by the licensee In response lo the errors were not completely effective in preventing future errors.

  • (Section M4.3).

The Inspectors noted continuing Improvements In the material condition and the performance of both the Un The Inspectors noted continuing Improvements in the material condition and the performance of both the Unit 2 and Unit 3 HPCI systems. (Section M2.1)

Maintenance department personnel performed well during the outage and ou.tage work was generally free fro

  • Maintenance department personnel performed well during the outage and outage work was generally free from human performance errors. (Section M4.1)

Prl: 3A The work observed by the Inspectors during the Unit 3 refueling outage was performed correctly. The worke Sec:

Ter:

The work observed by the Inspectors during the Unit 3 refueling outage was performed correctly. The workers had the necessary procedures and were following them. No inadequacies were noted in the procedures. (Section M4.2)

Prl: MAINT.. Licensee NCV

_Prl: 3A Failure to follow procedure for signing on to the OOS Sec:

Prl: MAINT Sec:

Self NCV Sec:

Ter:

on Februal'Y. 2, 1999, the_ valve maintenance front line supervisor authorized the temporary lifting of an out-of-service wilhi>ut venfying that the temporary lift would not compromise personnel safety or cause other adverse consequences.

Prl: 3A Fallure to follow procedure for valve position Sec:

Ter:

Personnel error during the performance of a surveillance procedure resulted in a locked-in (continuously energized) main control room annunciator on Unit 3. The annunciator presented an unnecessary distraction to control room operators. (Section M4.5)

Item Type (Compliance.Followup.Other), From 08/31/1998 To 08131/1999

Page:

14 of 31 09/23/1999 14:20:53 IR Report 3 Region.Ill DRESDEN Date 01/09/1999

  • source 1998030 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01/09/1999 1998030 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01/09/1999 1998030 Dockets Discussed:

05000237 DRESDEN 2 050Q0249 DRESDEN 3 11124/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESl?EN 3

. 11124/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11124/1998 1998026-02 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT sec:

Prl: MAINT Sec:

Pri: MAINT Sec:

Prl: MAINT Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG NRC NEG NRC.

POS NRC POS NRC POS Self

~NCV By Primary FuncUonal Area Template Item TIUe Codes Item Description Prl: 2A Material condlUon Issues conUnued to adversely affect plant operations.

Sec:

Ter:

.Pr1:3A Sec:

Ter:

Pr1:3A Sec:

Ter:

Prl: 3A Sec:

Ter:

. Prl: 3A Sec:

Ter:

Prl: 3A Sec:

Ter:

~

Material condition Issues continued to adversely affect plant operations. Plant personnel responded appropriately to the equipment failures. (Section M2.1)

The Inspectors ldenUfled that contract maintenance activities resulted In making the Technical_ Support Cent nie Inspectors Identified that c:Ontract maintenance activities resulted in making the Technical Support Center air filtration unit inoperable. The contract maintenance staff had propped open an emergency door in the Technical Support Center without operations pennlsslon. The operations staff entered the appropriate DATR LCO after the Inspectors Informed the staff. The licensee counseled the contract maintenance staff and highlighted the issue throughout tlie station. (Section M4.1 r The maintenance acUvlUes observed by the Inspector's were perfonned*correctly.

The maintenance activities observed by the Inspectors were perfonned correctly. (Section M4.2)

Work actlvlUe!i on majo*r unscheduled Items were perfonned well. Routine scheduled work was usually perfo Work activities on major unscheduled items were perfonned well. Routine scheduled work was usually perfonned

  • well. However, Inadequate maintenance restoration on the circulating w.ater system required the operators to perform a rapid load drop. (Section M 1.1)

Work observed during maintenance on the low pressure coolant Injection system was perfonned In accordan Work obseived 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)

Failure to Follow Procedures Instrument maintenance technicians performed Dresden instrument surveillance "Reactor Building Ventilation Radiation Monitor Channel Calibration," and, due to personnel error, caused *an automatic initiation of the safety-related SGTS.. During the performance of the surveillance. the procedural steps correctly required that the technician adjust the TRIP CHECK ADJUST potentiometer. The instrument maintenance department technician turned the power supply knob for the radiation monitor to the OFF positio11 instead.

u.. m Tvn" 1r.nmnli:>nrp Fnllnw11n nthP.rl From 0813111998 To 0813111999

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  • 05000249 DRESDEN 3 10f0611998 1998024 Dockets Discussed:*

05000237 DRESDEN 2 05000249 DRESDEN 3 0912311998 1998023-05 Dockets Discussed:

05000237 DRESDEN 2 050002~9 DRESDEN 3 0912311998 1998023-06 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 09123/1998 1998023-02 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0811211999 1999012 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: MAINT Sec:*

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec:

Prl: MAINT Sec: OTHER Prl:ENG Sec:

United States Nuclear Regulatory Commission*

PLANT ISSUE MATRIX ID NRC NRC Licensee Licensee NRC NRC Type NEG POS NCV NCV By Primary Functional Area Template Item Title Codes Item Description

.. Prl: 3A The major work activities were performed correctly and required equipment was returned to service within th

  • Sec:

Ter:

Prl: 2A Sec:

Ter:

Prl:2A Sec:

Ter:

Prl:39 Sec:

Ter:

The major work activities were performed correctly and required equipment was relurned to service within the required tinies. 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 department (Section M1.1).

The licensee met the lnltlal goals and objectives of the Strategic Reform Initiatives associated with Improving The licensee m*et the Initial goals and objectives of the Strategic Reform Initiatives associated with Improving the.

plant material condition. Sustained Improvements In plant material condition have yet to be demonstrated (Section M6.1),

HPCI Low Flow Setpolrit Found Outside TS limit During rouiine surveillance.testing, the licensee identified that the Unit 2 HPCI low flow switch*trip setpoint was*

below the lechnical specification limll of 600 gallons per minute. The root cause of this event was determined to be setpolnt drift.

Preconditioning 125 VDC Battery for Discharge Test -

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 an equalization charge and maintenance activities to remove and clean intercen connectors were completed just prior to the test. T~e root cause of the problem was an Inadequate technical review of the modified performance test prerequisites because the technical reviewers did not

. Identify or adequately question the as-found requirement~ for service discharge test performance.*

VIO IV Prl: 1 C Two examples of a Vlolatlon ofTS 4.0.E.1 Regarding IST NEG Sec:

The licensee failed to implement the IST program as required by TS 4.0.E Ter:

Prl: 1A Inspectors were concerned with the recent high frequency of failures experienced by the station black out di Sec:

Ter:

Inspectors were concerned with the recent high frequency of failures experienced by the station black out diesels during surveillance tests. The licensee's investigation showed that a lack of software controls caused another licensee's backup software to be used to reconstitute Dresden's station blackout diesel control logic during a Y2K upgrade. Additi.onally, inadequate desi11n of the diesers ventilation system and an inadequate review of the vendo~s recommendation for control power cooling caused the operators to tnp the station blackout diesel during surveillance tests.

Item Type (Compliance.Followup,Other), From 08/3111998 To 08131/1999

Page:

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Date 0512111999 Source 1999008 Dockets Discussed:

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05000237 DRESDEN 2

  • 05000249 DRESDEN 3 04/0711999 1999006 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3

' 02126/199~

1999003 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl:ENG Sec:

Prl:ENG Sec:

Prl: ENG Sec:

Prl: ENG Sec:*

02126/1999 1999003 Prl: ENG Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01127/1999 1999004 Dockets Discussed:

  • 05000237 DRESDEN 2 05000249 DRESDEN 3 Sec:

Prl:EN9 Sec:

United States Nuclear R_egulatory Commission PLANT ISSUE MATRIX ID NRC NRC NRC NRC NRC NRC By Primary Functional Area

  • Template Item Title Type Codes Item Description NEG POS NEG NEG NEG POS Prl: 4C The Inspectors concluded that the licensee's Investigation In the LPCI pressurization Issue was not timely
  • Sec:

Tar:

Prl:4c Sec:

Tar:

Prl: 4C Sec:

Ter:

Prl:45 Sec:

Ter:

Prl: 48

  • Sec:

Ter:

Prl: 5C Sec:

Ter:*

The Inspectors concluded that the licensee's investigation in the LPCI pressurization issue was not timely The licensee performed a good, detailed Investigation to find the so~rce of Increased pressurization of the lo The licensee performed a goi:>d, detailed investigation to find the source of increased pressurization of the low pressure coolant injection (LP.ct) system.

The licensee's coricluslon for the root cause of a near miss of Technical Specification requirements for demo The Inspectors agreed with the licensee's conclusion that the root cause of a near miss of Technical Specification requirements for demonstration of the alternate method of decay heat removal during the Unit 3 refueling outage was due to a lack of involvement of the operations department. However, the inspectors noted that the licensee did not list or discuss other potential contributors in the root cause report. This affected the overall quality of the ioot cause report and differed from other root cause reports prepared by the licensee. (Section E7.1)

The llcensee's initial plans, to establish an alternate method of decay heat removal d1,1rlng the refueling outag The licensee's Initial plans, to establish an alternate method of decay heat removal during the refueling outage, did not comply with the requirements specified In the plant Technical Specifications. While the plans had not formally received a final review by the Oeerations department or station senior management, the Engineering department missed several earlier opportunities.to eatch the Inconsistency between the Technical Specification requirements and the methodology specified In the original outage pl_ans. (Section E4.1)

The licensee's Implementation of the plans to establish an alternate method of decay heat removal during the

. The licensee's Implementation of the plans to establish an alternate method of decay heat removal during the refueling outage presented a challenge to the operators. Engineering support to the Operations department in this case was not strong.* (Section E4.2)

Corrective actions were acceptable (All Sections).

Engineering Involvement In the corrective action proces En~ineering involvement in the corrective action process was good for the specific items reviewed. Corrective actions were acceptable (All Sections).

Item Type (Compliance,Followup,Other). From 08/3111~98 To 08131/1999

Page: 17 of 31 09/23/1999 14:20:53 IR Report 3 Region Ill DRESDEN Date 01109/1999 Source 1998030 Dockets Discussed:

05000237 DRESDEN 2 -

05000249 DRESDEN 3 11124/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESD_EN 3 11124/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 050_Q0249 DRESDEN 3 11/24/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024 Dockets DISCU!!SBd:

05000237 DRE.SDEN 2 05000249 DRESDEN 3 Functional

. Area Prl:ENG Sec:

Prl: ENG.

Sec:

Prl: ENG Sec:

Prl:ENG Sec:

Prl:ENG Sec:

Prl:ENG Sec:

United State!! Nuclear ~egulatory Commission PLANT ISSUE MATRIX.

ID NRC NRC NRC NRC

. NRC NRC By Primary Functlonal Area Template Item Tltle Type_

Codes Item Description POS NEG POS POS NEG POS Prt: 48 Engineering personnel were satisfactorily Involved In the_resolutlon and disposition of previously Identified Sec:

Ter:

Pr1:48 Sec:

Ter:

Pr1:48 Sec:

Ter:

Pr1:48 Sec:

Ter:

Prl: 48 Sec:

Ter:

Prl: 48 Sec:

Ter:

Engineering ~ersonnel were satisfactorily involved in the resolution and disposition of previously identified issues.

The lieensee s corrective action process adequately implemented corrective actions to resolve the issues. (Sections E8.1 -E8.6)

The heat trace system temperature controllers for the post accident monitoring system were not set correctly The heal trace system temperature controllers for the post accident monitoring system were not set correctly and were not In the routine calibration program. The design temperature specifications provided by the licensee

!egarding system operability were inconsistent. (Section E4.2)

The llcensee was pro-active In followlng up on the orlglnal plan to reduce scrams, derates, and challenges, a The licensee was pro-active In following up on the original plan to reduce scrams, derates, and challenges, and identified that progress had stalled. Corrective actions established ownership of the plan's recommendations to maintain progress In Implementation. (Section E2.1)

The Inspectors concluded that the llcensee's troubleshooting '!nd Investigation plan.for the high pressure co The Inspectors concluded that the licensee's tr~ubleshooting and investigation plan for tile high pressure coolant lnJ8ction system (HPCI) failures was thorough. Ho\\'lever, the inspectors continue to be concerned about the number o HPCI failures over the past two years. The licensee established a team to perform a point-by-point review of the HPCI system. (Section E4.1)

In one Instance, the engineering staff did not assure that the operations staff had a good understanding of th The engineers were also active In troubleshooting the systems. Usually the engineers stayed in good contact wit)l operations: However, In one Instance, the entn-eering staff did not assure that the operations staff had a good understanding of the expected performance o a 250-VDC charger. As a result, the operations staff removed the charger from service when the charger was behaving as the engineer expected.

The Involvement by engineers during maintenance and troubleshooting was appropriate.

The Involvement by engineers durin3 maintenance and troubleshootin~ was appropriate. The engineers were knoWledgeable of their systems, an _actively participated in resolving identified problems (Section E4.1 ).

Item Type (Compliance.Followup,Other), From 0813111998 To 08/31/1999

-Page: 18 of 31 0912311999 14:20:53 IR ReportJ Region Ill DRESDEN Date 0912311998 Source 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0912311998 1998023 Dockets. Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0912311998 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3

  • 0912311998 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 09123/f998 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 09123/1998 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area

. Prl: ENG Sec:

Prl: ENG Sec:

Prl:ENG Sec:

Prl:ENG Sec:

Prl: ENG Sec:

Prl: ENG Sec:

United States Nuclear Regulatory Commission ID Type NRC MISC NRC POS NRC POS NRC POS NRC POS NRC

.POS PLANT ISSUE MATRIX By Primary Functional Area Template Item Tltle Codes Item Description

. Prl: 48 Operability determinations were of good quality and provided adequate justification for the conclusions wlth Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 48 Sec:

Ter:

Prl: 48 Sec:

Ter:

Prl: 48 Sec:

Ter:

Prl:4c Sec:

Ter:

Operability determinations were of good quality and provided adequate justification for the conclusions with two exceptions. In one case, an operability determination to address condensate storage tank vortexing concerns failed to account for all condensate stora!!e tank water loss sources. In a second case, the licensee failed to complete a timely 1 O CFR 50. 59 safety evaluation to address a potential unreviewed safety question identified in an operability determination.

The modifications, temporary alterations, and engineering requests reviewed were adequately designed, eva The modifications, temporary alterations, and engineering requests reviewed were adequately designed, evaluated, installed, and tested. Two minor deficiencies were identified.

Overall, the 111aterlal condition and housekeeping of the station were satisfactory.

Overall, the material condition and housekeeping of the station were satisfactory, and the ability of engineering personnel to Identify material condition problems was acceptable. However, the learn identified a number of material,condition items such as loose or missing fasteners and screws, and various oil and water leaks. The as-built configuration of the plant was in conformance with the description in the Updated Final Safety Analysis Report..

The vast majority of the temporary alteratlons reviewed were properly approved, Installed, and documented.

The vast majority of the te'mporary alterations reviewed were properly approved, installed, and documented.

  • However, a number of deficiencies regarding*the adherence to temporary alteration procedure requirements, such as the performance of quarterly walkdowns arid ex1ended installation reviews, were identified. In addition, two examples were identified In which temporary alterations were.installed in the plant without proper approval.

Overall, the survelllance tests observed and documentation results reviewed were within the required accept

  • Overall, the surveillance tests observed and documentation results reviewed were within the required acceptance criteria. Two examples were identifi~d in which surveillance procedures were not adequate to demonstrate that equipment met technical specification requirements 10 CFR 50.59 safety evaluations were of good quality and the licensee had an acceptable program for ensurln 10 CFR 50.59 safety evaluations were of good quality and the licensee had an acceptable program for ensuring that trained and qualified personnel prepared and reviewed safety evaluations. Three examples were identified in which safety evaluations were not reported as required.

Page:

19 of 31 09/23/1999 14:20:53 IR Report3 Region Ill DRESDEN

  • Date 09123/1998
  • source 1998023 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0912311998 1998023-01 Dockets Discussed:

05000237 DRESDEN 2 05000249*DRESDEN 3 0912311998 1998023-03 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functlonal Area Prl: ENG Sec:

Prl:ENG Sec:

Prl: ENG Sec:

09123/1998 1998023-04.

Pri: ENG Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 08/1311999 1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 08/1311999 1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3

Sec:

Prl: PLTSUP Sec:

Prl: PL TSUP

  • Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MA TRIX By Primary Functlonal Area

  • Template ltein Tltle ID Type Codes Item Description NRC POS NRC VIOIV Licensee NCV Licensee NCV NRC NEG NRC NEG Prl: SA Engineering department self-assessment activities were effective.

Sec:

Ter:

Prl: 1C Sec:

Ter:

Pr1:4C Sec:

Ter:

Engineering department self-assessment activities were effective. In particular. the threshold for the identification of problems was low; identified problems were elevated to the proper levels of management for resolution; operab1hty issues were addressed; and corrective actions were adequate, timely, and properly prioritized. The engineering department self-assessment au<!Jt schedule was comprehensive and included all major engineering f~nctional areas.

Failure to Implement TALT Program In Accordance with Procedures The licensee failed to review TALTs for extended' installation as required by OAP 05-08, "Temorary Alterations". In addition, one unauthorized TAL T was identified in the plant.

lnservlce Tests Not Performed as Required

.During a self-assessment of the inservice testing 11sn program, the licensee identified four IST Code non-compliances: two related to check valves, one related to pressure isolation valve leakage testing, and one related to now instrument ranges. In addition; during a followup assessment, three additional IST Code 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.

Prl: 4A CCSW Temperature Outside Design Basis Sec:

  • Ter:

Prl:3A Sec:

Ter:

Prl: 38 Sec:

Ter:

On November 12, 1996, the llcensee identified that the CCSW inlet temperature must be maintained below 84 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 inadequate design documentation which led to confusion regarding the original design basis. In addition, inadequate management Qversight and desigr:i eontrol led to low expectations which resulted in poor identification and resolution of the design basis i~sue, and inadequate implementation of compensatory actions to address the operability. issues.

A deficiency was Identified with the method used by the radiation protection staff to ensure a package's cont A deficiency was identified with the method used by the radiation protection staff to ensure a package's contents were properly cribbed to prevent shifting during transit and discrepancies with work.sheets and checklists in the shipment procedure were noted, both which the licensee planned to address.

While the licensee developed a comprehensive audit program, limited surveillance_ activities reduced the valu

. While ihe 1.icensee developed a comprehensive audit program which was implemented sufficiently to assess safety significant aspects of the radioactive materials transportation and radwaste processing programs, limited surveillance activities reduced the value of the oversight program.

Item Type (Compliance,Followup,Other). From 08131/1998 To 0813111999

Page:

20 of 31 09/23/1999 14:20:53 IR Report 3 Region Ill*

DRESDEN Date 0811311999 Source*

1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249*DRESDEN 3 08113/1999 1999015 Dockets Discussed:

05000010 DRESDEN 1*

05000237 DRESDEN 2 05000249 DRESDEN 3 0811311999 1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 08113/1999 1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 08/13/1999 1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRE;SDEN 2 05000249 DRESDEN 3 Functional Area Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PL!SUP Sec:

Prl: PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type.

NRC PCS NRC PCS NRC PCS NRC PCS NRC PCS By Primary Functional Area Template Item Title Codes

. Item Description Prl:

Sec:

Ter: 4C*

Prl: 1C

. Sec:

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Prl: 1C Sec:.

  • Ter:*

Prl: 1C Sec:

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Prl: 1C Sec:

Tel':

Experienced vendor staff and adequate licensee oversight of processing activities ensured effective lmpleme Experienced vendor staff and adequate licensee oversight of processing activities ensured effective implementation of the radwaste management program. Waste streams were processed onsite in accordance with v~ndor and licensee PCPs and station *approved procedures, and dewatered waste streams were sampled and mdependenUy verified by station staff to ensure regulatory.limits for free standing liquid were met. Plans to reduce the generation of diy active waste were developed and reduction strategies were implemented to address licensee identified deficiencies.

licensee's program for classification of radwaste shipments was technically sound.

. The licensee's program for the classification of radwaste shipments was technically sound, effectively implemented by staff well-versed In its application and included a comprehensive program for scaling factor derivation, trending and analysis.

Radioactive material and radwaste packaging and transportation program was effectively Implemented.

The radioactive material and radwaste packaging and transportation program was effectively implemented.

Sh1ments were ap~roprlately classified and controlled, vehicle and package surveys were performed completenUy, an shipment mani ests were completed in accordance with requirements.

A November -1998 radwaste river discharge line and discharge valve flange leak was repaired.

  • A November 1998 radwaste river dischar~ li.ne and discharge valve flange leak was repaired, a decommissioning
  • file was established as required by 10 CF 50.75(g), and a radiological assessment supported the.licensee's decision to postpone area remediation pending.site decommissioning.

)

Material condition and housekeeplng_lmprovements In the radwaste building *were noted and Initiatives for ad

  • Material condition and housekeeping Improvements in the radwaste building were noted and initiatives for additional, neces~ary improvements were ongoing.
  • Item Type (Compliance,Follow.up,Cther). From 08/3111998 To 08/31/1999 v

Page:

21 of 31 09/23/199914:20:53 IR Report 3 Region Ill DRESDEN Date 08/13/1999 Source-1999015 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 08/13/1999 1999015-01 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 08/1211999 1999012 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 06/24/1999 1999011 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05127/199g 1999010 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05127/1999 1999010 Dockets Discussed:-

  • 05000237 DRESDEN 2 05000249 DRESDEN 3 Functlonal Area Prl: PLTSUP Sec:

Prl: PLTSUP

-Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC POS NRC -

NCV NRC POS NRC POS

. NRC-POS NRC POS By Primary Functlonal Area Template Item Title Codes Item Description Prl: 38 The training provided to staff Involved In packaging, preparation, and shipment of radioactive materials and Sec:

Ter:

Prl:

Sec:

Ter: 1C Prl: 1A Sec:

Ter:

Prl: 3A Sec:

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Prl: 1C Sec:

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Prl: 1C

-.sec:

Jer:

The training provided to staff Involved In packaging, preparation. and shipment of radioactive materials and radwaste satisfied Department of Transportation regulations and imparted an adequate level of knowledge to ensure effective program implementation. The licensee's training progrm also included non-required elements that enhanced the training program such as a qualification itinerary and a continuing education program for radiation protection technicians.

Radioactive material lnventory_deflclencles w'ere Identified and several containers housing contaminated too Radioactive material Inventory deficiencies were identified and several containers housing contaminated tools, equipment, and radwaste stored In satellite radiologically restricted areas were not labeled in accordance with NRC requirements, resulting In a Severity Level IV Non-Cited Violation Overall, the licensee's radiation protection staff enforced the plant's radlologli:al control standards.

  • Overall, ihe licensee's radiation protection staff enforced the plant's radiological control standards. The inspectors observed "As-Low-As-Reasonably-Achievable" briefings being held before workers entered areas where the dose was elevated. The inspectors also observed radiation protection staff in the field directing other radiation workers to low dose areas.

-Workers were followlng good radiological practices. The radiation protection personnel often spoke with an Workers were following good radiological practices. The radiation protection personnel often spoke with and provided guidance to.other radiation workers on keeping exposure low while performing tasks in the plant Overall llcensee performance during 1999 Emergency Plan exercise_

Overall llensee performance during the 1999 Emergency Plan exercise was very good Staff performance In the slmulator main control room Staff performance in the simulator main control room was effective

_Item Type (Compliance.Followup,Other). From 08/3111998 To 08/31/1999 e

Page:

22 of 31 09/23/1999 14:20:53 IR Report 3

  • Region Ill DRESDEN Date 05/27/1999 Source 1999010 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05127/1999 1999010 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05127/1999 1999010 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05127/1999 1999010 Dockets Discussed:

  • 05000237 DRESDEN 2 050oo249 DRESDEN 3 05121/1999 1999008.. *

., Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 05121/1999 1999008 Dockets Discus.sad:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: PLTSUP Sec:*

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Tltle ID Type Codes Item Description NRC POS Prl: 1C The Technlcal Support Center staffs performance Sec:

The Technical Support Center staffs performance was excellenl Ter:

NRC POS Prl: 1C Overall performance of Operations Support Center management and staff Sec:

Overall performance of Operations Support Center management and staff was good.

Ter:

NRC POS Prl: 1C Staff performance In the Emergency Operations Faclllty Sec:

Staff performance in the Emergency Operations Facility was very good. -

Ter:

NRC POS Prl: 1C Self-critiques following termll')atlon of the exercise Sec:

Self-critiques followinR termination of the exercise were generally very good. Licensee critique findings were Ter:

consistent with the N C evaluation team's findings NRC NEG Prl: 1C Fallure to compensate for an Inactive security area Sei::

The licensee identified and reported to the NRC a failure to compensate for an inactive security area. The inspectors' review of the licensee's report determined that multiple communication failures by several individuals _led Ter:

to the error.

NRC POS Prl: 1C Normally the licensee followed radiation protection procedures Sec: -

Normally the licensee followed radiation prolection procedures Ter:

Item Type (Compliance,Followup,Other). From 08/31/1998 To 08/31/1999 e

e

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23 of 31 09/2311999 14:20:53 IR Report3 Region Ill DRESDEN Date Source 05/21/1999 1999008-04 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 04/07/1999 1999006 Dockets Discussed:_

05000237 DRESDEN 2 05000249 DRESDEN"3 03/12/1999 1999007 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 03/12/1999 1999007-01 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 03/12/1999 1999007-02 Dockets Discussed:

05000010 DRESDEN 1 05000237 DRESDEN 2 05000249 DRESDEN 3 02/26/1999 1999003 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functlonal Area Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLT~UP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP

.Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NCV NRC NEG NRC STR Licensee NCV Licensee NCV NRC POS By Primary Functional Area Template Item Tltle Codes Item Description Prl: *1c The Inspectors Identified that a station laborer falled to frisk Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Prt: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

However, the Inspectors Identified that a station laborer failed to frisk while exiting the radiation protection area. The licensee responded appropriately to this issue.

The Inspectors noted Instances of poor performance by the llcensee in radiation protection.

The Inspectors noted Instances of poor performance by the licensee in radiation protection evidenced by the release of radioactive material off the site, an unplanned uptake, and the unauthorized movement of a high radiation area boundary. (Section R4.1)

Security fo.rce response tO routine and reactive security activities was conducted In an effective and tlmely m Security force response to routine and reactive secu~ activities was conducted in an effective and timely manner and were consistent with security plan requirements. ( ection S4.1)

Compensatory Measures Personnel errors by two alarm station operat~rs resulted* in the inadvertent inactivation of a perimeter intrusion ala.rm zone with no com~nsatory measure being established in a timely manner. Adequate corrective action was.

Implemented. Th s was considered a licensee identified non-cited violation. (Section S2.2)

Fallure to Maintain a Vehlcle Denial Barrier Ineffective planning ~ licensee security supervisors and inadequate monitoring activities* by security personnel resulted*ln the de11ra ation of a vehicle denial barrier for three days. When discovered, correction action was Implemented. Thrs was considered a licensee iden~!,fied non-cited violation. (Section S2.3)

Radiation Protection personnel performed well during the Unit 3 refuellng outage. The station cumulative do Radiation Protection personnel performed well during the Unit 3 refueling outage. The station cumulative dose was less than that planned for prior lo the outage. (Section R1.1)

Item Type (Compliance.Followup,Other). From 08/3111998 To 08131/1999 e

A~~

e

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24 of 31 09/23/1999 14:20:53 IR Report 3 Region Ill DRESDEN Date 02126/1999 Source*

1999005 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999005 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999005 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 0Uz6/1999 1999005 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999005 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999005 Dockets Discussed:

05000237 DRESDE.N 2 05000249 DRESDEN 3 Functlonal Area Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:*

.Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC NEG NRC POS NRC POS NRC POS NRC POS NRC POS By Primary Functlonal Area Template Item Tltle Codes Item Description Prl: 1C Weaknesses In the quality control and testing oh device fabricated by the licensee Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

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Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Weaknesses in the quality control and testing of a device.fabricated by the licensee coupled with radiation protection staff 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 monitor replace!Tlent work. While no significant radiological consequences resulted, the worker was placed at increased radiological risk (Section R1.3).

The ALARA program was effectively Implemented.

The ALARA program was effectively imrlemented. ALARA plans were generally well developed and thorough, consistent with the potential radlologica risks, and ALARA initiatives contributed to substantial dose savings.

Protective clothing requirements were routinely relaxed to address heat stress concerns, improve wo~er efficiency and thereby reduce doses, and associated ALARA evaluations were technically sound to support the initiatives Implemented (Section R1.2).

The licensee's program for the control and testing of portable high efficiency particulate air (HEPA) filtered s The licensee's program for the control and testing of portable high efficiency particulate air (HEPA) filtered systems and vacuums was generally effective. The licensee demonstrated good initiative and developed a program for chemical testing portable HEPA units (Section R2.1).

Radworker performance had Improved compared to previous outages as evidenced by problem Identification Radworker performance had Improved compared to previous outages as evidenced by problem 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 proved effective in keeping doses ALARA (Section R4.1).

Radiological postings were effectively maintained and accurately reflected the area radiological conditions Radiological postings were effectively maintained and accurately reftected the area radiological 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 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).

Prl: 38 Outage staffing and training for the radiation protection program Sec:

Ter:

Outage staffing and training for the radiation protection program was generally effective. The training of contract radiation protection staff was completed In accordance with station procedures. and adequately prepared workers for assigned outage tasks (Section R5.1 ).

ltf'm Tvne IComoliance.Followuo.Otherl. From 08/3111998 To 08/3111999

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05000237 DRESDEN 2 05000249 DRESDEN 3 02126/1999 1999005-01 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01/15/1999, 1999001 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01115/1999 1999001 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01/15/1999 1999001

. Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functlonal Area

_Prl: Pl TSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl:-PL TSUP Sec:

Prl: PLTSUP Sec:.

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC STR NRC STR NRC NCV NRC MISC NRC MISC NRC MISC By Primary Functlonal Area Template Item Tltle Codes

. lte.m Description Prl: 1C Station dose performance for the Unit 3 refueling outage Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 18 Sec:

Ter:

Prl: 1C Sec:.

Ter:

Prl: 1C Sec:

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Station dose *performance for the Unit 3 refueling outage was excellent. Effective ALARA program 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 refueling outage dose in station history

. (Section R1.1).

The licensee l~plemented a relatlvely aggressive and effective source term reduction program, The licensee Implemented a relatively aggressive and effective source term reduction program, and continued to monitor and track its.effectiveness and explore methods to achieve further station dose savings (Section R 1.4).

Isolated problems were Identified with the radlologlcal control of HEPA filtered systems and vacuums Isolated problems were Identified with the radiological control of HEPA filtered systems and vacuums. One Non-Cited Violation was Identified regarding the failure to follow a station procedure for return of filtered vacuum cleaners used in radiologically posted areas (Section R2.1 ).

  • The EP training program.appeared effective.

The EP training program appeared effectiVe. Interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. A number of plant departments appeared to have few, if any, staff fully qualified for respira!Ory protection ready to respond in the event of an emergency.

(Section PS)

Emergency response facllltles, equipment, and supplies were well-maintained Emergency response facilities, equipment, and supplies were well-maintained. Demonstration of selected 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 onshift staff in a short period of time.

(Section P2.1)

.Management'support for the program appeared strong as lndlcat~d by the successful lmplementatlon of a nu Management support for the program aepeared strong as Indicated by the successful implementation of a number of program upgrades. The EP trainer position had been filled after a* six month vacancy, putting the organization back*

m line with all other ComEd EP programs. (Section PS)

Item Type (Compliance,Followup.Other). From 08131/1998 To 08131/1999

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Page: 28 of 31 09/23/1999 14:20:53 IR Report 3 Region Ill DRESDEN Date 01115/1999 Source 1999001 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01/15/1999 1999001 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3*

01115/1999 1999001 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 01109/1999 1998030 Dockets Discussed:

<-..__05000237_ DRESDEN 2 05000249 DRESDEN 3 12/03/1998 1998029 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 12103/1998 1998029 Dockets Discussed:

05000237 DRESDEN 2.

05000249 DRESDEN 3 Functional Area Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

United States Nuclear Regulatory Commission

  • PLANT ISSUE MATRIX ID Type NRC POS NRC POS NRC
  • STR NRC MISC NRC MISC NRC POS By Primary Functional Area Template Item Title Codes Item Description Prl: 1 C The emergency Implementing procedures reviewed were clear and easy to use. The Nuclear Tracking System Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

Ter:*

Prl: 1C Sec:

Ter:

The emergency implementing procedures reviewed were clear and easy lo use. The Nuclear Tracking System was an effective method to track and close EP issues. (Section P3)

The llcensee's 1998 Site Quality and Safety Assessment EP program audit The licensee's 1998 Site Quality and Safety Assessment EP program audit and 1998 EP Self-Assessment Report were effective in identifying a number of issues and satisfying the requirements of 10 CFR 50.54(1). (Section P7)

Overall, the EP program was In an effective state of operational readiness.

Overall, the EP program was In an effective state of operational readiness. *Management support to the program was stronff. and interviewed key emergency response personnel demonstrated a good working knowledge of responsibilities and emergency procedures. (X 1 F Overall, the licensee's radiation protection staff enforced the plant's radlologlcal control standards. Howeve Overall, the licensee's radiation protection staff enforced the plant's radiological control standards. 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 inspectors' identification. (Section R1.1)

The performance of the observed fire drlll was good. A weakness. was Identified where.the offslte fire depart The performance of the observed fire drill was good. A weakness was identified where the offsite fire department had not participated in fire drills with onsite fire brigade members since 1994.

The Inspector concluded that the fire protection procedures reviewed provided adequate fire protection cont The Inspector concluded that the fire protection procedures. reviewed provided adequate fire protection controls and were adequately Implemented by station personnel.

Item Type (Compliance,Followup.Other), From 08/3111998 To 0813111999

Page: 27 of 31 09/23/199914:20:53 IR Report 3 Region Ill DRESDEN Date 12/0311998 Source 1998029 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 12/0311998 1998029-01 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11124/1998 1998026*

Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/24/1998 1998026 Dockets bis.cussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11124/1998 1998026 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/06/1998 1998028 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl:PLTSUP Sec:

Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

_ Prl: Pl TSUP Sec:

Prl: PLTSUP

  • sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC STR NRC URI

  • NRC NEG NRC NEG NRC POS NRC POS By Primary FuncUonal Area Template Item Title Codes Item Description Prl: 1C
  • Fire protection quality assurance audit reports and checklists were thorough and contained substantive find Sec:

Ter:

Prl: 2A Sec:

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Prl: 18 Sec:

Tei':

Prl: 1C Sec:

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Prl: 1C Sec:

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Prl: 1C Sec:

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Fire protection quality assurance audit reports and checklists were thorough and contained substantive findings.

Housekeeping was good and combusUble material was well con.trolled.

HousekeeplnlJ was good and combustible material was well controlled. Required fire protection features appeared to be well 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 The Inspectors Identified _an ell'!ergent_ negaUve trend In Unit 3 drywell air chemistry.

The Inspectors identified an emergent negative trend in Unit 3 drywell air chemistry. Though minor; the issue revealed a lack of coordination and communication between departments with respect to earty identification of potential drywell leaks. (Section R4.1)

The security force showed mixed performance.

The security force showed mixed performance. The security staff twice intercepted prohibited items prior to the items being Introduced to the plant. However, personnel errors within security resulted in the unplanned outage of an electronic zone. (Section 54.1)

. The licensee decontaminated a large portion of the Unit 3 torus basemen.I.

The licensee decontaminated a large portion of the Unit 3 torus basement. Unit 2 torus basement decontamination was planned._ (Section R2.1)

The REMP was well Implemented and station oversight of contractor activities was effective.

The REMP was well implemented and station oversight of contractor activities was effective. Data showed that plant operations did not have a discernible radiological impact on the environment. Sample collection, sample chan11e-out and pump calibration field practices simulated by the contractor technician were technically sound, and the individual exhibited a thorough knowledge of the sample stations and sampling processes Item Type (Compliance,Followup,Other). From 08/31/1998 To 08/31/1999

Page:

28 of 31 09/231199914:20:53 IR Report3 Region Ill DRESDEN Date 11/06/1998 Source 1998028 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/06/1998 1998028 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/06/1998 1998028 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/06/1998.

1998028 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 11/06/1998 1998028 Dockets Discussed:

05000237 DRESDEN 2.

05000249 DRESDEN 3 11/06/1998 1998028 Dockets Discussed:

05000237 DRESDEN 2

  • 05000249 DRESDEN 3 Functional Area Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC.

-.POS NRC POS NRC POS NRC POS NRC POS NRC POS By Primary Functional Area Template Item Title Codes Item Description Prl: 2A Reactor water quality was maintained wlthl~ appropriate levels during the current fuel cycles, with occaslona Sec:

Ter:.

Prl.: 2A Sec:

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Prl: 2A Sec:

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Prl:2B Sec:

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Pr1:3A Sec:

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  • Reactor water quality was maintained within appropriate levels during the current fuel cycles, with 'occasional sulfate excursions that were timely resolved. Hydrogen and depleted zinc oxide injection systems for Unit 2 were effective in decreasing corrosion and radioactive source term, respectively.' Plant personnel monitored fuel integrity appropriately, and no active fuel integrity problems were identified Quality control data Indicated that operablllty and accuracy of the In-line Instruments was excellent Quality control data indicated that operability and accuracy of the in-line instruments was excellent.* The' chemistry staff effectively maintained and calibrated the instruments, and there were no materiel condition issues Engineered safety feature atmosphere air cleaning' systems were maintained In good materiel condition.

Engineered safety feature atmosphere air cleaning systems were maintained in good materiel condition, and in-place and laboratory surveillance tests were completed as required and satisfied test acceptance criteria Overall, the quality assurance/quality control and performance of the laboratory Instrumentation 'was !xcelle Overall, the quality assurance/quality control and performance of the laboratory instrumentation was excellent, as evidenced by QC checks and QA intercomparison data. In addition, the control of standards.and reagents was effective, and.chemistry staff was testing new technologies to improve laboratory analysis capabilities.

Chemistry personnel were generally knowledgeable of departmental and Individual responsibllitles, and disp Chemistry personnel were generally knowledgeable of departmental and individual responsibilities, and displayed Improved ownership of chemistry department instrumentation. Chemistry technicians demonstrated appropriate t-LARA practices during sample collection and conducted sampling activities in accordance with station procedures The chemistry department continued to self-assess Its program and recently concluded a thorough, collabor The chemistry department continued to self-assess its program and recently concluded a thorough, collaborative assessment which disclosed deficiencies with procedures and practices not indicative of operational excellence.

Actions to address the deficiencies were underway and included mechanisms to track resolution and corrective action progress llem Type (Compliance,Followup,Other), From 08/31/1998 To 08/3111999

. Page:

29 of 31 09/23/1999 14:20:53 IR Report 3 Region 111 DRESDEN Date Source 10/16/1998 1998027 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/16/1998 1998027-01 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3

_..,. 10/15/1998 1998025 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/1511998 1998025 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/15/1998 1998025 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/1511998 1998025 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Functional Area Prl: PLTSUP Sec:

Prl:PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

Prl: PLTSUP Sec:

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX ID Type NRC POS NRC VIOIV NRC POS NRC POS*

NRC POS NRC WK By Primary Functional Area Template Item Title Codes Item Description Prl: 1C Security related activities that Involved alarm stations, security communication and personnel search equlpm sac:

Ter:

Prl: 1C Sec:

Ter:

Prl: 1C Sec:

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Prl: 1C Sec:

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Prl: 1C Sec:

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Prl: 1C Sec:

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Security relaled activities that Involved alarm stations, security communication and personnel search equipment were maintained In an effective manner and performed their functions as designed.. Security force personnel, except as noted In this report, were knowled~eable of their response duties and assignments. Security management personnel were proactive In problem identification and resolution.

Inadequate search of a hand-carried package The Inadequate search of a hand-carried package that entered the protected area. The failure was caused when a security search officer failed to recogniie 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 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 Calculation Manual and remained well below regulatory limits Overall, the liquid and gaseous effluent monitoring program was effectively Implemented.

Overall, the liquid and gaseous effluent monitoring program was effectively implemented. Effl_uenls 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 concimtrator waste tank vault, and address long term proble Positiv4:1 steps were i~~iated to reclaim the m~in concentra_tor waste tank vault, and addr.ess long term problems with the rad1olog1cal cond1t1ons In the room and with tank level instrumentation Performance and rellablllty problems with the Unit 2 service water monitor and the Unit 213 main chimney mo Performance and reliability problems with the Unit 2 service water monitor and the Unit 213 main chimney monitor have continued for several years, which the licensee recognized and recently focused additional efforts to address lte.m Type (Compliance,Followup,Other). From 08/3111998 To 08/31/1999

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30 of 31 09/23/1999 14:20:53 IR Report 3 Region Ill DRESDEN Date

'Source Functional Area United States Nuclear Regulatory Commission

/

PLANT ISSUE MATRIX By Primary Functional Area Template Item Tltle ID Type Codes Item Description 10/15/1998 1998025-02 Prl: PL TSUP Licensee NCV Prl: 1C Fallure to sample potentlally contaminated llqulds, prior to release to a clean turbine bulldlng noor drain Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024 Dockets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 10/06/1998 1998024 Dockets Discussed:

05000237 DRESDEN 2

.05000249 DRESDEN 3 09/23/1998 1998023 Doc.kets Discussed:

05000237 DRESDEN 2 05000249 DRESDEN 3 Sec:

Pi'I: PLTSUP NRC NEG Sec:

Prl: PLTSUP NRC NEG Sec:

Prl: OTHER NRC MISC Sec:

Item Type (Compliance,Followup,Other), From 08/31/1998 To 08/31/1999

  • sec:

Ter:

  • Prl: 1C Sec:

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Prl: 28 Sec:

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Prl: 4C Sec:

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A non-cited violation was identified for the failure to sample a slightly contaminated liquid, prior to discharge into a clean noor drain In the turbine building. Discrepancies in certain liquid effluent flow paths described in the Updated Final Safely Analysis Report (UFSAR) were also identified, along with a potential weakness In the effluent sampling program for the Waste Water Treatment Facility (Section R1.1 ).

The station lacked a formal pollcy regarding control of 11ersonnel secondary dosimetry outside the protected The station lacked a formal policy regarding control of personnel secondary dosimetry outside lhe prolected areas.

The Inspectors Identified a weakness in the treatment and control of electronic dosimetry (Section R4.1 ).

The radwaste facllltles were maintained to lower housekeeping and material condition standards than.the res The radwaste facilities were maintained to lower housekeeping and material condition standards than the rest of the plant (Section R2.1 ).

The llcensee had made adequate progress In the Implementation of the strategic reform Initiatives reviewed The licensee had made adequate progress In the Implementation of the strategic reform initiatives reviewed

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31 of 31 09/23/199914:20:53 IR Report 3 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 \\,l!olation NEG Negative NOED Notice of Enforcement*Discretion NON Notice ofNon-Conformance OTHR Other P21

. Part 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:

Functional Areas:

1A Normal Operations OPS Operations 1B Operations During Transients MAINT Maintenance 1C Programs and Processes ENG Engineering 2A Equipment Condition PL TSUP Plant Support 2B Programs and Processes OTHER Other 3A Work Performance 3B KSA 3C Work Environment 4A Design 48 Engineering Support 4C Programs and Processes 5A.

Identification 5B Analysis 5C Resolution ID Codes:*

N~C NRC Self Self-Revealed Lleensee Licensee EEis are apparent violations of NRC Requirements that are. 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 has 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 are unresolved items about which more information is required lo 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 Type (Compliance,Followup,Other), From 08/31/1998 To 08131/1999

.e

Page 1of1 09/27/1999 14:46:29 DRESDEN Inspection I Activity Plan 09/01/1999 -* 03/31/2000 (Ufilli) pnspectlon Activity 11 Title

  • 2, 3.

IP 83750 Occupational Radiation Exposure 2,3 2,3 2,3 2,3 2,3 2,3 IP 73753 IP 81700 IP 37001*

IP 37550 IP 40500-IP 84750 lnse~ice Inspection Physical Security Program For* Power Reactors 10 CFR 50.59 Safety Evaluation Program Engineering Effectiveness Of Licensee Process to Identify, Resolve, And Prevent Problems Radioactive Waste Treatment, And Effluent And Environmental Monitoring 2

1 5

5 5

2 ENCLOSURE 2 Planned Dates 11 Inspection Start End Type 10/04/1999 10/08/1999 Core 11/08/1999 1111211999 Core 12113/1999 1211711999 Core 01110/2000 01/28/2000 Core 01/10/2000 01/28/2000 Core 0111012000 01/28/2000 Core 0212212000 02/25/2000 Core

,9