Text

SALP Repts 50-237/87-01 & 50-249/87-01 for Oct 1985 - Dec 1986
	ML17199G046
Person / Time
Site:	Dresden
Issue date:	04/06/1987
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML17199G045	List: ML17199G043; ML17199G046;
References
	50-237-87-01, 50-237-87-1, 50-249-87-01, 50-249-87-1, NUDOCS 8704130324
	Download: ML17199G046 (38)
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{{#Wiki_filter:I, .. ' . . ~ ... SALP BOARD REPORT NUCLEAR REGULATORY COMMISSION REGION .*III . SYSTEMATIC ASSESSMENT OF LICEN~EE PERFORMANCE 50-237/87001; 50-249/87001 Inspection Report Nos. Commonwealth Edison Company Name of Licensee Dresden* Nuclear Power Station Units 2 and 3 Name of Facility October 1, 1985 through December 31, 1986 Assessment Period . 36324.-87.0406 87041 DOCK 05000237 PDR A PDR G . .. *;..***. . .. -*: **:**.*

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SALP 6 ,::*

I. INTRODUCTION I I. CRITERIA III. SUMMARY OF RESULTS IV. PERFORMANCE ANALYSIS A. Plant Operations B. Radiological Controls C. Maintenance D. Surveillance TABLE OF CONTENTS E. Fire Protection/Housekeeping F. Emergency Preparedness G. Security H. Outages

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L Quality Programs and Administrative Controls Affecting Quality J. Training and Qualification Effectiveness K. Licensing Activities V. SUPPORTING .DATA AND SUMMARIES Page No. 1 2 4 5 5 7 10 13 14 16 18 19 21 24 26 29 A. Licensee Activities . . 29 B. Inspection Activities * 31 C. Investigations and Allegations Review 33 D. Es ca 1 ated Enforcement Ac ti ans 33 E. Licensee Conferences Held During Assessment'Period 33 F. Confirmatory Action Letters (CALs)

34 G. Review of L i.censee Event Reports and _ -34 10 CFR 21 Reports Submitted by the Licensee H. Licensing Actions 35 . ~. *>* : *. *.~' .; ... ; ..

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0 I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation. An NRC SALP Board, composed of staff members listed below, met on March I7, I987, to review the collection of performance observations and*data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter OSI6, "Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation cri~eria is provided in Section II of this report. This report i.s the SALP Board's assessment of the licensee's safety performante at the Dresden Nuclear Power Station for the period October I~ I985 through December 3I, I986. SALP Board for Dresden Nuclear Power Station: Name Title

J. A. Hind, SALP Board Chairman, Director~ Division of .Radiation Safety

and Safeguards .

C. E. Noreliu~, Director, Divi~ion of Rea~tor Projects
C: W. Hehl, Chfef, Operations Branch, DRS

.*R. F. Warnick, Chief, Reactor Projects Branch I

L. G. McGregor, Senior Resident Inspector, Dresden
M. Grotenhuis, Project Manager~ NRR

A. B. Davis, Acting Regional Administrator C. J. Paperiello, Actfog Qeputy Regional Administrator W. G. Guldemond, Chief Reactor Projects Branch 2 M. A. Ring, Chief, Reactor Projects Section IC J. W. McCormick-Barger, Actfng Chief, Technical Support Staff, DRP G. C. Wright, Chief, Test Programs Section, DRS * G. L. Pirtle, Acting Chief, Safeguards Section, DRSS .

L. R. Greger, Chtef, Facilities Radiation Protection Section, DRSS

M. Schumacher, Chief, Radiological Effluents and Chemistry Section, DRSS R. N. Gardner, Chief, Plant Systems Section, DRS W. Snell, Chief, Emergency Preparedness Section, DRSS D; E. Miller, Senior Radiation Specialist, Facilities Radiation Protection Section, DRSS J. A. Holmes, Reactor Inspector, Plant Systems Sectio_n, DRS A. Gautam, Reactor Inspector, Plant Systems Section, DRS N. V. Gilles, Reactor Inspector, Reactor Projects Section IC

Voting Members

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.. II. CRITERIA The licensee performance is assessed in selected functional areas depending on whether the facility is in a construction, preoperational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations. Special areas may be added to highlight significant observations. One or more of the following evaluation criteria were used in assessing each functional area. 1. Management involvement in assuring quality 2. Approach to resolution of technical issues from a safety standpoint 3. Responsiveness to NRC initiatives 4. Enforcement hi story 5. Operational and Construction events (including response to, analysis of, ~nd corrective actions for) 6. Staffing (including management) However, the. SALP Board is not limited to these criteria and others may have been used where appropriate. Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:

Category, 1 : .Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety or construction is being achieved. Category 2 : NRC attention shou1d be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved. Category 3 : Both NRC and licensee attention should be increased. Licensee management attention or involvement is acc*ptable and considers nuclear safety, but weaknesses. are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safe.ty or construction is being achieved. ..... _ ** ..

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.: . *.,,.*.* Trend:-* The SALP Board may determine to include an appraisal of the performance trend of a functional area. Normally, this performance trend is only used where both a definite trend of performance is discernible to the Board and the Board believes that continuation of the trend may result in a change of performance level. The trend; if used, is defined as: a. Improving b. Licensee performance was determined to be improving near the close of the asse~sment period. Declining Licensee performance was determined to be declining near the close of the assessment period. .. :.*; .-*.*. -

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. . * .. *' ) ' *. <: *-** .. **--* . III. SUMMARY OF RESULTS Overall, the licensee's performance was found to be acceptable but exhibited a declining trend since the last SALP assessment period. Of 11 functional areas rated during this assessment period, licensee performance in 3 areas declined; 2 areas declined from a Category 2 to a Category 3 (Fire Protection/Housekeeping and Quality Programs and Administrative Controls Affecting Quality) and 1 area declined from a Category 1 to a Category 2 (Emergency Preparedness). In addition, while the area of Plant Operations sustained a Category 2 rating, a declining trend was noted at the end of the assessment period. Of the remaining 8 functional areas, 5 sustained Category 2 ratings, 2 which were not rated previously received Category 2 ratings, and the.area of Licensing ~ctivities sustained a Category 1 rating with continued good performance .. Rating Last Rating This Functional Area Period Period Trend A. Plant Operations 2 2 Declining B. Radiologica1 Controls 2 2

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Maintenance** 2* 2 D. Surveillance 2 2 E. Fire Protection/ Housekeeping 2 3 F. Emergency Preparednes~ 1 2 G. Security 2 2 H. Outages

2 I. Quality Programs 'and Administrative Controls Affecting Quality .. 2 3* J. Training and Qualification Effectiveness

2 K. Licensing Activities 1 1

Not Rated (new functional areas for SALP 6)
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"Modifications" which has been moved to the new "Outages" funttional area. 4* . . * .. ~*:

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. . . ~ .: ;: . . IV. PERFORMANCE ANALYSIS A. Plant Operations

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1. Analysis

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Evaluation of this functional area was based on the results of routine inspections conducted by resident inspectors. During the assessment period, the average availabilities of the units were approximately 74% for Unit 2 and 28% for Unit 3. The low availiability of Unit 3 can be largely attributed to the Reci.rculation Pipe Replacement (RPR) outage which lasted for ten months of the assessment period; .Enforcement activities in this area represented an improvement over the licensee's past performance. During this 15 month* assessment period, 1 violation (severity clevel to be determined) of Technical Specification Limiting Conditions for Operation (LCO) was identified just prior to the end of the assessment period. Over the 16 month SALP 5 period, 13 violations (8*Severity Level IV and 5 Severity Level V) were identified. The significance of the one violation- identified during this period indicated a major weakness in the perform- ance of the licensee's operations management staff in that . the operations staff did not realize an LCO had been exceeded until several hours after the Technical.Specification time

limit had run out.

In addition, after the licensee exceeded the .24 hours provided by the LCO for deinerting containment prior to shutdown, they did not begin a controlled shutdown, but r~ther, *continued to operate th~ unit to complete a special test of the High Pressure Coolant Injection (HPCI) System before shutting down. This matter is presently under

investigation by the NRC.

Operational events which occurred during this SALP period have indicated*slightly below average performance in this area, although performance has improved since the previous SALP period. The licensee experienced a total of 16 unscheduled r_eactor scrams during this assessment period (9 on Unit 2 and 7onUnit.3), compared to 35 unscheduledreactor scrams which occurred during the previous assessment period. It should be noted,. however, that after Unit 3 was returned to operation in August 1986, 5 scrams occurred in the last 4 months of this assessment period. Ten scrams du~ing this assessment period were due to personnel error, of which only 2 were caused by licensed operators. During the SALP 5 assessment period, 9 of the 35 scrams resulted from personnel errors with licensed operators causing 5 scrams. Of the 16 scrams which occurred during this assessment period, 5 scrams occurred during shutdown condition with no control rod movement. During the latter portion of the SALP 5 assessment period, the licensee formed a scram reduction committee due to an excessive number 5 ...... *:.

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.. *\\ ..... *** ,' .. of scrams experienced at that time. Although the committee was temporarily effective when first formed, efforts to reduce* unnecessary scrams were not as effective as they could have been as evidenced by the continuing high rate of scrams during this assessment period. -There were 72 Licensee Event Reports (LERs) (4.8 per month) issued during this SALP period, of which 41 were caused by personnel error. Eighteen of the LERs were attributable to personnel errors by the Operations Department. During the SALP 5 period, 93 LERs (5.8 per month) were issued with 38 involving personnel errors. While the total number of LERs and the rate of LERs issued has decreased during the assessment period, the number of events remains high as does the percent- age of events caused by personnel error, which has increased from 41% (SALP 5) to 57% (SALP 6). The licensee's response and subsequent corrective actions associated with operational events were gene~ally found to be adequate.

Management involvement to assure quality operation was not totally effective, as demonstrated by the high number of overall personnel errors and-personnel errors associated with the Operations Department. In addition, the LCO violation described previously was further evidence of management weaknesses in assuring quality operations. J.n contrast, management i nvo 1 vement was. evident by, the 1 i censee 's efforts and cooperative attitude throughout the review of two events, . one concerning the inability to reset a reactor scram and the other concerning the followup evaluation of.the Standby Liquid Control squib valve trigger wire problems. Management concerns for the frequency of reactor scrams and personnel 'errors were evident as indicated by the licensee's efforts to establish a scram reduction program and the implementation of a personnel error reduction program during the last quarter of this assessment period. In addition, the licensee'has implemented an error-free startup program which has improved operating performance during startup and low power operations. Recent changes in the operations staff to strengthen performance, including instatement of a new station manager, were found to be adequate. Authorities and responsibilities were generally well defined and usually adhered to. Licensed personnel were experienced and knowledgeable of the plant systems and its characteristics. Control room conduct was usually business like, and professional; however, at times, an excessive number of personnel congregated in the control room, which led to unnecessary noise, conversation, and other distractions. ....... -**:*~:-*:-*:-*.* ... *,r***.:**":'***7*; **-... -:*;*, - **- .-.~~: ~~*::**~ ... :-~_-,-*-.-,*.. . . .. \\ ..

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2 *.. CollGl-u-s ion The licensee's performance was rated Category 2 in this area, with a declining trend at the end of the period. The licensee was rated Category 2 during the previous assessment period. 3. Board Recommendations Subsequent to the assessment period, the licensee had an event in which the plant was allowed to drift from a cold to hot shutdown condition without the knowledge of the operators. This event, along with the event described in the analysis and the high number of scrams*on Unit 3 at the end of the* asses.sment period indicates a dee lining trend in performance. Increased attention.to operations by Commonwealth Edison management and the NRC staff is appropriate *. B. Radiological Controls .:**,:***.*. :** *: . --~ **-: -..--: *: .... 1. Analysis Evaluatibn of this functional ar~a was. based on the results of eight inspections perfonned during the assessment period by region-based specialists and routine inspections conducted

by the resident inspectors.

Enforcement history in this a~ea remained about the same as during the last assessment period. Five violations were identified during this assessment period. One was a Severity Level III violation issued for delivery of a radioactive. package with contact radiation levels greater than allowed. No civil penalty was assessed because of prompt implementation of correttive actions. A second violation of transportatio~ requirements was issued (Severity Level IV) concerning delivery of an inadequate package for burial. Of the remaining, one* was Severity Level IV and two were Severity Level V violations. These violations were in~icative of minor programmatic '. breakdowns..- Licensee corrective actions were adequate and timely except for one...Qf_the Severity Level V violations where initial licensee measures were- considered inadequate to prevent recurrence. Five violations were identified during the last assessment period. Staffing in this functional area remained adequate. Significant management changes involving replacement of the Rad/Chem Supervisor and the Lead Health Physicist occurred during this period. The changes were implemented with no noted detrimental effect on rad/chem department performance. The health physics program for the Unit 3 RPR was developed and implemented by a contractor under the direction and oversight of CECo; performance under the program was good. Two contractor he~lth physicists were retained 7 . *.*.** .:::* .. *- ..... :***:-..** .. . *::-::*.:JI.. ....

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. . . . . . . . . : . after RPR completion to temporarily augment the station's rad/chem department and to perform post RPR related tasks and initiate rad/chem improvement programs. The chemistry staff has stabilized since the previous assessment period with each staff member responsible for specific assignments. "The licensee indicated that its policy of rotating Radiation/ Chemistry Technicians (RCTs) between the Health Physics and Chemistry Group will be changed, pending union agreement, to assign RCTs to one o.f the groups on a permanent basis in the near future. This policy of rotation has resulted in long absences between laboratory assignments, thereby requiring close supervision of the RCTs~ This has been a long standing concern of the Region because it detracts from RCT performance. Licensee management involvement in assuring quality in this functio~al area has generally been good; however; progress in resolving some longstanding radiological problems has been slow. Audits and associated licensee responses have generally been satisfactory. Several licensee programmatic improvement initiatives i.n the radioactive material handling and chemistry/ radiochemistry areas were being implemented in response to various audit findings. The licensee's identification and implementation of corrective actions for radiological events

has significantly improved.

Increased corporate oversight of the environmental monitoring program has re~ulted in

improvements. Corporate health physics program involvement in th~ station's health physics program and incident investi- ~ation has improved performance. The chemistry/radiochemistry . QA/QC program has improved considerably with better implementa- tion o*f RCT proficiency* testing, interlaboratory comparisons, and instrument performance trending. The licensee's responsiveness to NRC initiatives was generally adequate. Improv.ements were implemented for NRC-identified weaknesses in Radiological Environmental Monitoring Program (REMP) results, documenting the Offsite Dose Calculation Manual (ODCM), confirmatory measurements, and operation of the Post Accident Sampling System. An exteniive site contamination and housekeeping improvement program initiated during the previous SALP.assessment period in response to NRC concerns had been discontinued during the assessment period due to the RPR workload. After repeated NRC admonishments, the licensee reinitiated the contamination reduction and housekeeping improvement programs. Progress was evident by the end of the assessment period. The licensee was initially slow to respond to inspector concerns relating to laboratory QC weaknesses, several of which were also identified by licensee audits. Considerable improvement was seen during the latter half of the assessment period. The licensee was also slow in submittal of a 10 CFR 20.302 request to NRR concerning disposition of contaminated soil.

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The licensee's approach to resolution of technical issues generally resulted in sound and timely resolutions with appropriate emphasis on radiological safety. The licensee, however, has experienced large numbers of personnel contamin~ ation events during this assessment period. The licensee recorded, trended, and investigated these events but had not been able to identify programmatic root causes or effect appropriate corrective actions. An inspector observed that contamination from a leaky valve near the Unit 2 cleanup filter had been identified and posted for several weeks without corrective action. Total worker dose was about 1500 person-rem in 1985 and 2500 person-rem in 1986. About 2000 person-rem was received during performance of the Unit 3 RPR project (fourth quarter 1985 through third quarter 1986). Because of the RPR project, it was difficult to make a comparison with average doses received at operating BWRs during this assessment period; however, the licensee's_total dose was not excessive. The licensee's ALARA program was.functioning to limit doses, as was evidenced by the dose history from the past several years. Continued emphasis is needed in this area to improve further. No unplanned liquid or gaseous releases were reported. However, a break in a new liquid radwaste effluent release line contaminated soil within the owner controlled area; disposition of the soil is yet to be resolved. The planned major reconstruction of the liquid radwaste processing sys*t.em to improve operability and radiological impacts reflected good licensee performance. The licensee is implementing and improving a water chemistry control program based on the BWR Owners Group guidelines. There was decided improvement in water quality, particularly during the latter half of 1986. The licensee has undertaken an ambitious program of modifications to improve water quality controls including upgrading of in-line monitoring of chemical* parameters.

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The station has made considerable progress-:i-n.. nonradiological laboratory QA/QC including the use of control chart trending of instrument performance, testing of the RCTs' laboratory proficiency through the use of blind and spiked samples~ and participation in an interlaboratory nonradiological chemical analysis program managed by the Corporate Technical Center. This gave management a much better understanding of laboratory performance and where improvement was most needed. Licensee management appeared supportive of this program. The licensee implemented a satisfactory counting room QA/QC program with control charts on each counter based on daily performance checks to track counter reliability over time. 9

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An experienced radiochemist provided effective oversight of gamma spectroscopy. In the confirmatory measurements split sample program with the NRC, the licensee obtained 57 agreements out of 62 comparisons. This was a slight decline in performance since the previous assessment period. 2. Conclusion The licensee was rated Category 2 in this area. The licensee was rated-Category 2 in the previous assessment period. 3. Board Recommendation None C. Maintenance 1. Analysis E~aluation of this functional area was based on the results of routine inspections conducted by resident: and region-based. inspectors. This functional irea previously included main- tenance and modifications. Modifications are now evaluated under the Outage functional area. Enforcement history in this area represented relatively .unchanged licensee per.formance. Three violations with no major safety.significance were identified during this assess- ment. period (one Severity Leve 1 IV and two Severity Leve 1 V) compared to two violations of minor safety significance identified in the area of maintenance during the previous SALP period (Severity Level V). Management involvement to assure quality in ~his functional area was not totally effective. Increased attention to the preventive and co~rective maintenance areas is needed to reduce the number of unnecessary reactor scrams, the time spent operating under LCOs, and the long list of degraded equipment. In addition, the licensee lacked an extensive and systematic preventive maintenance program an~ did not have an adequate method for establishing priorities for refurbishment and replacement of components ~hich are relching their end-of-life. Operational events attributable to this functional area indicated weaknesses in the licensee's control of maintenance activities. While only 9 of the total of 40 personnel errors were attributable to the maintenance department, 4 of these personnel errors resulted in reactor scrams and 3 caused

Engineered Safety Feature (ESF) actuations. Further evidence of possible deficiencies in the area of maintenance was identified when the licensee discovered lQ_

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one third of their program.

The maintenance department established a goal of maintaining a ba~kl9g of less than 1100 work requests for non-outage corrective matntenance. The licensee had an average backlog of approximately 2200 work requests in 1986. This is slightly above the average backlog of work requests for all Region III multi-unit sites which was approximately 2000 in 1986. However, the. preventive maintenance program requires more attention to achieve an effective system. For example, during the review of maintenance activities required to be perfonned on 10 CFR 50.49 designated limitorque actuators, various deficiencies were identified that were not reflected on the signed off checklists for.these activities. These deficiencies*--- .. were considered indicative of improper installations and inadequate maintenance activities. In some cases, the only preventive maintenance performed was that required by surveillances. The preventive maintenance procedure was revised in July 1986, to reflect the maintenance reorganization and the licensee's assertive approach to preventive maintenance as opposed to corrective maintenance. The trending of plant indicators for plant reliability such as LERs, Deviation . Reports (DVRs), and QA reports was completed on a quarterly basis by the Station On-Site Review Committee. The committee trended and discussed personnel errors and equipment failures to provide management tools ~o better recognize early warning signs and to determine any necessary changes in the periodic or planned maintenance programs. 11

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. : --* . . _. ~* ,. Further examples of licensee responsiveness were exhibited by a positive and cooperative attitude in resolving concerns involving scram solenoid malfunctions, squib valve trigger wire problems, and Source Range Monitor (SRM) and Intermediate Range Monitor (IRM) power fuse problems. In addition, the licensee was considered quite responsive to concerns identified by the NRC during an assessment of the Operational Analysis Department (OAD) maintenance/modification program~ In respons~ to the NRC concerns, the licensee revised several aspects of * the program by which OAD relates to the Dresden site. One instance was noted where the licensee's corrective action in response to an NRC concern was not totally effective . . During the SALP 5 assessment period a violation was identified concerning failure to complete work request packages in accordance with approved procedures. An inspection performed during the early part ~f this assessment period followed up on this violation and determined that progress had been made by the licensee to correct the problem. However, complete imple- mentation of corrective actions had not been achieved and not all deficiencies had been resolved completely. Examples of work requests coult:I still be found which were missing information or signatures. The NRC will again review this item when all corre~tive actions have been implemented. The maintenance area appeared to be adequately staffed,* although there were a number of maintenance siaff personnel changes during the last quarter of 1986. *The personnel were , , experienced and knowl~dgeable in these areas with respons- ibilities and. lines of authority well defined. Generally, the mainten~nce procedures were adequate and adhered to by personnel. 2. Conclusion The'.licensee's performance was rated Category 2 in this area. The licensee was rated Category 2 during the previous assess- ment period. 3. Board Recommendations .. **. *** ~ --* .... S~bsequent to the asse~sment period, the licensee encountered .problems when all three shutdown cooling pumps (non safety- related) became inoperable~ One pump had been out of service for about a year with bearing/motor damage. A second pump was taken out of service after a bearing failure and subsequent oil fire, and the third pump was removed from service following an inspection which showed degradation of oil quality. Problems such as this are.indicative of a lack of attention to balance of plant equipment maintenance. Increased management attention is warranted in this area to assure availability of all equipment needed for safe and reliable operation of the Dresden units. 12 . : ' . . . . ***:._: .~ *. . : *: ; ... *~-. " .... ,; ". \\'-'

.. .: .... . ,*': D. Surveillance 1. Analysis Evaluation of this functional area was based on the results of several routine inspections conducted by resident inspectors and two inspections conducted by region-based inspectors. Enforcement history was considered to be very good in this area where no violations were identified during the assessment period. This was a noted improvement over the previous SALP period where six violations were identified (one Severity Level IV and five Severity Level V) involving all areas of the surveillance program, indicative of a prograJTUTiatic weakness in this area as discussed below. Management involvement in assuring quality in this area was evident and generally adequat.e during the period. Surveillance activities received prior planning in ample time with priorities assigned. Improvements were visible in that weaknesses which were indicated during the last SALP period have been corrected.

Vidlations identified during the last SALP period included

failure to adhere to procedures, failure to trend and evaluate inservice test data, and failure to use calibrated measuring and test equipment during surveillances. These violations indicated a relaxed attitude and inattention to detail in the area of surveillance testing showing evidence -0f prograJTUTiatic weaknesses in this area. Similar problems have not been identified during this assessment period indicating corrective . actions have been~effective. The license* had shown adequate responsiveness to NRC initiatives. as demonstrated by responses to concerns identified during the inspection of balan~e of plant piping systems and the Mark I containment thinning, as well as the normal inservice inspections. In general, the licensee had knowledgeable personnel with . clearly defined responsibilities to ensure that surveillance activities were properly accomplished with records well maintained. The licensee had sufficient staffing at this facility to administer and implement the inservice testing program with additional personnel available from nearby CECo sites. Surveillance activities were performed in a very professional manner and found to be well managed by the operating personnel. Three missed surveillances were identi- fied during this SALP period. Observation of inservice inspection activities indicate that personnel had an adequate understanding of work practices and that procedures were adhered. to. 13 *-

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.. * .*., ,f:. 2. Conclusion The licensee's performance was rated Category 2. The licensee was rated Category 2 during the previous assessment period. 3. Board Recommendations None E. Fire Protection/Housekeeping 1. Analysis Evaluation of this functional area was based on the results of routine inspections conducted by resident inspectors and two special inspections conducted by region-based inspectors, including an inspection of a fire that occurred in the drywell expansion gap on Jam.Jary 20, 1986. Enforcement history in this area represented a decline in licensee performance during the as$essment period. Although there were the same number of violations issued during this assessment period (two Severity Level IV) as during the previous SALP period, the violations issued during this assessment period were of greater significance. One violation concerned failure to followup on and implement a license condition to install an early warning automatic fire detection system for the refueling floor area. This violation was viewed as indicative* of a programmatic breakdown that resulted in a reduced level of fire protection. An enforcement conference was held concerning*this subject on November 19, 1985. The second violation concerned failure to consistently and effectively comply with the staffing requirements for fire protection program implementation and was viewed.as additional evidence of a programmatic breakdown.*. While no viol~tions or deviations were identified during the inspection of the drywell expansion gap fire, the licensee was req~ested to formally respond to 12 speci.fic NRC concerns originating from this event, prior to Vnit 3 restart. The NRC Office of Nuclear Re.actor Regulation (NRR) reviewed the licensee's response to these concerns and determined that the re5ponses to all but one item were acceptable. NRR has requested additional information from the licensee regarding NRC concerns. The need for greater involvement of licensee management in overall fire protection program implementation was evident, as demonstrated by the violation of a license condition. Five other open items were identified which were representative of weaknesses in the fire protection program. Furthermore, while it was determined that the licensee took positive actions 14 ~ . . . *~ ..... * .. . .. . ~ . . ..::;_; .. ~ , . : : : .. ~' - : . -~

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in extinguishing the drywell expansion gap fire, the potential impact of the fire was not given a high priority at the time the fire occurred and immediately thereafter. In the area of housekeeping, management involvement' to assure quality has improved. This was evidenced by a comprehensive cleanliness program that was in progress and being monitored by station management as well as Commonwealth Edison corporate officials. It should be noted, however, that plant conditions at the beginning of the assessment period were unsightly and although much progress has been made to improve conditions, continued efforts are needed to bring general plant conditions to an acceptable level. A management meeting was held on June 2, 1986, to discuss the state of housekeeping at Dresden and to discuss a housekeeping program developed by the licensee to improve conditions. The licensee's approach to resolution of technical issues from a safety standpoint was viewed as marginally acceptable. The licensee's discovery of smoldering material inside*the drywell expansion gap did not alert the licensee to* the potential impact of the fire and the presence of the polyurethene foam material~ In most cases, the licensee was responsive to NRC initiatives and cooperative with NRC personnel. However, the response time to some concerns raised.by the NRC involving fire protection issues was lengthy. This may have been due to the complex technical nature -0f the issties raised and the li~erisee's establishment~f priorities during the Unit 3 refueling outage. On the other hand, the licensee's response to NRC concerns and subsequent ~orrective actions involving housekeeping issues were approached in a positive manner. . Plant tours by the resident inspectors had identified numerous general access areas within the turbine and reactor buildings that were contaminated which resulted in restricted a~cess for plant operators and maintenance personnel.~ Radioactive waste material, oil, and soil were stored or placed in outside areas as well as within the plant. It was apparent by the licensee's actions with regard to the reduction of radioactive waste with dedicated funds, additional man hours to reduce contaminated areas, and improvements in general plant cleanliness that the program for plant improvement is an on going effort. Continuation of this effort is needed to improve plant conditions further and to avoid allowing a return to conditions like those at the beginning of the assessment period. Improvement is needed in staffing levels and training in this area. In addition, involvement of qualified and knowledgeable personnel in the implementation of overall fire protection 15 .. ~ Jl

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program requirements needs to be extended. Efforts to acquaint personnel with required aspects of fire safety and regulatory requirements were inadequate in that fire protection program responsibilities did not appear to have been carried out as a result of inadequate staffing. 2. Conclusion The licensee was rated Category 3 in this area. The licensee was rated Category 2 in the previous assessment period. The decline in rating can be attributed to the licensee's lack of responsiveness concerning fire protection issues and the lack of timely attention to general plant material conditions. 3. Board Recommendations More attention by the licensee to implement a comprehensive management focus on responsibilities in the area of fire protection is neededj This focus should concentrate on effective implementation of all aspects of fire protectiqn program requirements and evaluation of the plant specific performance based fire safety goals. Continued attention is needed to assure that th~ material condition of the plant continues to improve. F. Emergency Preparedness . ~ . ' 1. Analysis Evaluation of this functional area was based o~ five inspections conducted by region-based inspectors, which included an evalua- tion of the licensee's 1986 annual emergency preparedness exercise.

Enforcement history did not indicate any significant* regulatory concerns in this area. No violations were identified during this assessment period. There were also no violations identified dur.ing the previous SALP period. The licensee had generally provided sound resolutions to known technical problems, but had not consistently taken the initiative to resolve these problems until they had also been identified by the NRC. For example, the licensee was aware for several months that the Post Accident Sampling System and the microwave communications link for emergency communications were not fully operational. However,*sufficient management attention to correct these problems was not provided until after both problems were brought to the licensee's attention by NRC inspectors. The licensee was also aware for several months that the onsite emergency organization was not adequately staffed by qualified personnel in two positions. Again, the licensee did not take adeq~ate correttive action until after the shortage was identified by the NRC. 16 . . ~ . . . . . : *, . *;-.. :,,, ... , . *.*** .:-,*.:

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Response to NRC initiatives and subsequent corrective actions were generally timely and adequate, once the problems were brought to management's attention by the inspectors. However, in one case, a relatively simple improvement to one Emergency Action Level took over six months to be approved and implemented.

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Management involvement in assuring quality was adequate as demonstrated by an acceptable level of proficiency during the emergency preparedness exercise. Emergency response organization positions were well defined, authorities and responsibilities specified, and personnel were generally capable of implementing their assigned tasks. However, four weaknesses were identified during the exercise. These included inadequate radiological control practices that could have led to the spread of contamination and/or unnecessary radiation exposure to members of the public during an actual event, and an excessive amount of time passed prior to initiation of onsite assembly. The training program was adequately defined and impl~mented with dedicated resources, and included the use of a simulator . . The adequacy of the training program was demonstrated by most participants' performances during the exercise and interviews. Personnel have typically shown an adequate understanding of emergency preparedness procedures with a minimal number of errors. *Corporate emergency planning staff had typically interfaced with the station on special activiti~s such as the ~nnual exercise, medical dril~s, and revisions to the station specific annex to the generic emergency.~lan. Records of fourteen.activations of the licensee's emergency p 1 an were e1ia 1 uated during this assessment period. Except for one activation still under review, the abnormal situations were prop~rly classified and all required o~fsite nbtifications were completed in an acceptable manner .. 2. Conclusion The licensee is rated Category 2 in this area. The licensee was rated Category 1 during the previous assessment period. The licensee's performance declined in this area primarily due to a lack of management attention to th~ emergency preparedness program. This resulted in a poor licensee * response to self-identifi~d concerhs and a degradation in performance during the annual exercise. 3. Board Recommendations

None

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Security 1. Anaiysis

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Evaluation of this functional area was based on the results of four routine security inspections conducted by region-based inspectors and inspections conducted by resident inspectors to routinely observe security activities. Enforcement history in this area represented a decline 1n licensee performance since the previous assessment period. Four Seve~ity Level IV violations were identified during this SALP period, compared to two violations (one Severity Level IV and one Severity Level V) identified during the previous assessment period. A repeat violation for failure to protect Safeguards*Information occurred during this assessment period. The licensee's responses were generally thorough and tech- nically sound. Additionally, the corrective actions were usually prompt and effective. However, in the case of the first Safeguards Information violation, the initial corr~ct1ve action was not effective at correcting the root cause of ~he problem, as indicated by the repetition. Events reported under 10 CFR 73.71 were identified and reported in a timely manner. In the middle part of the SALP period, the number of reportable*events was high, due to repeated prob 1 ems with the -1 i ten see' s *security computer. The computer was repaire~ and the number of reportable events decreased significantly in the latter part of the SALP period. The licensee's responsiveness to NRC concerns was timely and generally satisfactory. During the last SALP period, a concern was identified regarding the lack of timely action by the .electrfcal maintenance department to repair security-related equipment. Additionally, the licensee had no preventive maintenance program for the security-related equipment. * Currently, the licensee has implemented an adequate preventive maintenance program for security-related equipment. Also, the licensee had significantly improved the timeliness of main- tenance work conducted on security-related equipment by all maintenance departments. Staffing in this area was adequate. In August 1986, . the guard force contractor was changed. No significant problems were noted as a result. The training and qualification program of the guard force was adequate and contributed to an adequate understanding of the work and adherence to procedures. Positions within the security organization were identified and responsibilities were defined. Management involvement to assure quality in this area increased and was found to be at an acceptable level. Senior .* ... *. ,.,***.*

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.. :_ ** :* .: .. ) . . ~.. . . : . - . . . 1.: _*,.** * management support of security operations was made evident by the significantlY. increased attention to security-related maintenance and installation of all new closed circuit television cameras and new metal detectors. Corporate manage- ment was frequently involved in site activities. Good communications existed among corporate, site security, and Region III. . 2. Conclusion The licensee was rated a Category 2 in this area. The licensee was rated Category 2 during the previous assessment period. 3., Board Recommendation None H. Outages 1.. Analysis This is a new functional area that combines the previous Refueling area and the modifications portion of the previous Maintenance area with the a~sessment of all outage activities. Evaluation of this functional area was based on the results*of inspections conducted by resident*and region-based inspectors and a special team. inspection. Three inspections by regioh- based inspectors involved examining* activities related. to the Recil".culation Pipe Replacem.ent project. Also, a special NRC team from the Office of Inspection and Enforcement (IE) Division of Inspection Programs conducted a Safety Systems Dutage Modification Inspection (SSOMI) on Unit 3. A followup to this inspection was conducted by region-based inspectors to. determine if similar problems were present on Unit 2. Enforcement history in this functional area demonstrated a need for improvement in the area* of control of modifications. Multiple examples of potential violations were identified during the SSOMI and followup inspection. A number of these examples illustrated weaknesses in implementation of the modification program. These violations are ~urrently being examined ~or potential escalated enforcement action. Subsequent to the assessment period, on February 26, *19s7, * an enforcement conference was held concerning these issues. Management involvement to assure quality in this functional area was adequate, except in the area of implementation of the modification program as indicated by the SSOMI and followup inspection findings. In general, outages are well planned and priorities are assigned. A noteworthy example of the licensee's performance in the area of outage planning and execution was the Unit 3 refueling outage which began in 19 .. , ,' ".' .*.*.

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October 1985. In addition to the routine refueling and maintenance activities, the licensee also undertook a major Recirculation Pipe Replacement (RPR) project. Proper management a~tention contributed significantly to the success of the RPR project. Management control systems were effective in that activities had received prior planning and priorities had been assfgned. Corporate management was involved in all major site activities and decision making was usually at a level that ensured adequate management review. Similarly, good performance was noted in the area of refueling activities during the Unit 3 outage. Communications between personnel involved in fuel handling activities and control room operators were well established. Also, good housekeeping and radiological control practices were demonstrated by personnel in the refueling area.* The licensee's approach to resolution of technical issues from a safety standpoint in this functional area was generally.

adequate, with the exception of problems with a number of

modifications as identified by the SSOMI. The licensee completed over 100 modifications, overhauled the turbine including replacing three low pressure turbine rotors, and comp 1 ete ly *rep 1 aced the Unit 3 reactor reci rcul.at ion system piping during eight months of this assessment period. Most of the modifications. were directed toward improving plant operations. However, several modifications were diretted toward enhancing plant safety and were in response to recommendations made by the licensee's Safety Review Board and several modifications were fn response to NRC concerns. Staffing in this area was adequate. Key positions in the piping repl*cement org~nization were established and filled. Discussions with licensee and contractor personnel during the RPR indicated that they were knowledgeable in thejr jobs. During the RPR, observations indicated' that personnel had an adequate understanding of work practices and that procedures were followed. However, this was not observed during the SSOMI, where it was noted that personnel often had an inade~uate understanding of work .practices and procedutes were often not followed. During refueling* activities, manning of fuel handling operations was adequate and personnel operating the Refueling Bridge had completed the required training .. 2. Conclusion The licensee's performance was rated Category 2 in this area~ The.licensee was not rated in this area during the previous* assessment period. 2Q . - *"."* * *I.:.:.: * . *: .*. ~ . '***.* .. *.* ~*; *-*. .

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3. Board Recommendations .The Board experienced some difficulty in deciding~ single rating in this functional area because of the diversity in performance in different areas. The major Recirculation Pipe Replacement project was handled very we 11 . On the other hand, multiple problems were evident in the other more routine modifications. I. Quality Programs and Administrative Controls Affecting Quality 1. Analysis Evaluation of this.functional area was based on the results of routine inspections conducted by resident inspectors and two inspections conducted .bY region-based inspectors. Also, the results of the SSOMI discussed in Section IV.H and an Equipment Qualification (EQ) inspection conducted by IE contributed to evaluation of this functional area. Enforcement history in this area indicated a decline in performance during the assessment period. Two violations (Severity Level V) of minor safety significance were issued during the assessment period; however, several potential violations were identified during both the SSOMI and the EQ inspection that related to the licensee's Quality Assurance (QA) program and administrative controls affecting quality* in these areas. The violations identified during the SSOMI were considered significant in that the number of examples of the violations covering each area of the modification program (Design, Procedures, Drawings, Installations, Quality Control, and Testing) indic~ted a breakdown in the licensee's management control related to modifications. The results of the EQ inspection r~vealed six deficiencies with respect to the licensee's EQ program implementation, demonstrating less than adequate quality control in this area. The violations identified during both the SSOMI and EQ inspection are currently being examined for escalated enforcement action. Four violations (two Severity Level IV and two Severity Level V) were issued during the previous assessment period.* None were of major safety significance. Weaknesses are evident in ~anagement's involvement to a~sure quality in this functional area. *The results of the SSOMI contained approximately 95 examples of violations relating to ~11 aspects of the modification program, including inadequate implementation of th~ QA program, indicating a programmatic breakdown in the area of modifications. In addition, some of the deficiencies documented in the EQ inspection report

identified corrective maintenance needed for items which the

licensee had inspected and environmentally qualified. Also, semi-annual review and preparation of the EQ Equipment Main- 21 . ~"* ... . . . . . :* *. '. .. ~::

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tenance Annual Summary Report, to identify to plant management EQ experience, was not accomplished. Subsequent to the EQ inspection, the licensee was required to shut down Unit 3 in December 1986, to repair electrical splices which did not pass EQ tests. Other documented equipment modifications required corrective maintenance actions or verification inspections to prevent the plant from being placed in an LCO. During and subsequent to the SSOMI, the licensee undertook several corrective action measures including the formation of a special Modification Task Force. This Task Force issued a report on September 23, 1986, detailing their review of the modification problem areas and outlining corrective action steps. Two management meetings were conducted to discuss the findings from the SSOMI and followup inspection and the licensee's corrective action measures. The NRC believes that the actions planned and implemented by the licensee regarding modification deficiencies should significantly reduce the problems encountered in this area*. However, the effectiveness of the implementation of these actions has not yet been examined in a 11 .areas. Additional evidence of weaknesses in management involvement to assure quality can be. seen by the high number of personnel errors which occurred.during this assessment period; the licensee's slow response in resolving longstanding radiological concerns; and the lack of responsiveness to fire protection issues. Similarly, events such as the LCO violation on the deinerting of primary containment discussed in Section IV.A illustrate a need for improvement in programs and controls designed to assure quality operations. Examples such as these -indicate that the licensee has been. ineffective in disco~ering and correcting their. own weaknesses. In con'trast to the weaknesses noted above, management involve- ment in some activities, such as the performance of QA audits, was evident. Audits were performed on schedule, reports and corrective action for ~udit findings were completed on a timely basis, and management at both the site and corporate levels were frequently involved in this activity. In addition, management involvement to assure quality was demonstrated throughout the Unit 3 RPR project, leading to a successful project with minimal problems. The licensee's approach to resolution of technical issues from a safety standpoint was often lacking in thoroughness, as demonstrated by the results of the SSOMI and EQ inspections. The multitude of examples of violations identified during the

. SSOMI, although not of major safety significance when considered

individually, are a strong indication that modifications made to the plant generally did not receive a thorough and in depth review. With regard to the licensee's EQ program, although 22*

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a clear understanding of issues was demonstrated and a conservative approach was routinely exhibited, in some cases analyses in the documentation file did not adequately demonstrate qualification by similarity. In addition, installed configuration of some components was not the same as qualified by the type test. Management*s responsiveness to NRC initiatives was adequate. The findings identified during the SSOMI and discussed in Section IV.H indicated a major breakdown in management 1 s control of plant modifications.* However, corrective actions taken by the licensee in response to the NRC concerns, although not yet completely examined, appeared to be adequate. Like- wise, concerns identified during the NRC EQ inspection_ were promptly responded to in writing, and responses were generally sound and thorough.

Staffing in this functional area was adequate. Key positions were identified and responsibilities were defined. However, there were some deficiencies noted. During the EQ inspection, records could not establish compliance with certification requirements for one QA inspector. Also, two EQ training. programs, one covering site specifics, the other a general program prepared by the Electric Power Research Institute (EPRI), had not been attended by site QA staff personnel. Conclusion The licensee was rated a Category 3 in this area. The licensee was rated Category 2 in the previous assessment period. The decline in rating can be largely attributed to insufficient involvement of licensee management which led to poor

performance, especially in the areas OT modifications and equipment qualification. In addition, several other factors contributed to evidence that quality programs and administra- tive controls have not been effective in producing quality performance. Board Recommendations It is recogriized that the lice~see has already made tonsiderable efforts to improve the modification program. In addition, recent management changes at Dresden indicate the licensee 1 s desire to improve performance in all *areas-of operation. Continued efforts by both the licensee and the NRC will be necessary to assess the implementation of these and other changes at Dresden.

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J. Training and Qualification Effectiveness

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1. Analysis Evaluation of this functional area was based*on routine inspections conducted by resident and region-based inspectors. In addition, an inspection was conducted to evaluate the effectiveness of the licensed and non-licensed personnel training programs. Enforcement history in this area represented licensee performance that *Conformed to NRC regulations. No violations were identified during this assessment period. While management involvement in this area was evident, performance varied. During performance based inspections of licensee activities, personnel were found knowledgeable and effective in *implementing their duties. The licensee's formal training program for operations personnel had been accredited by INPO. Licensed instructors were assigned to an operating shift for a minimum of six days per year. In addition, some* licensed ins~ructors participated in the Company's Supervision* on Shift (SOS) program. There was a good feedback path betwe~n operations and training. Operators were awar~ of the opportuni- ties available to them to provide suggestions for future revision to the training program. Inadequate training could occasionally be traced as. part of the cause of events occurring during this rating period but ~as not considered a significant * programmatic weakness. While the Dresd~n operator training program was considered satisfactory for the rating. period, one generic weakness identified by examiners was the candidates' apporent reluctance to refer to and use operating procedures during operator exams. On several occasions during and subsequent to reactor scram events on simulator.exams, the scram procedure was not properly followed and in at least one instance, led to operator error. The tendency existed for operators to respond to alarms without the benefit or awareness of the appropriate procedure. In another instance, an SRO candidate specifically instructed an RO candidate not to refer to an operating order during a power increase. The results of requalification exams administered in late January 1987, subsequent to the end of the assessment period, indicated that the licensee's efforts to reduce the candidates' reluctance to refer to operating procedures and to correct other operator training weaknesses have not been effective. Fifty percent of the operator~ failed some portion of the requalification

exams.

As a result of a Confirmatory Action Letter issued by the NRC in response to the failures, the licensee is formulating a corrective action plan to improve operator training in identified weak areas. The licensee was responsive to the NRC recommendations for improvements tQ their training program, as follows. During 24* .... ~ . .-

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.. . '. *: . ~ ... the assessment period, the NRC admini.stered six senior reactor operator and eight reactor operator examinations at Dresden. Tnese examinations were administered, in two groups. The first group had an overall pass rate of 86% which compared favorably to the national average. The second group fared poorly, achieving a pass rate of only 29%. This was atypical for Dresden where the pass rate generally is above the average. The Dresden Training Program for operators was revised to * enhance retraining efforts for candidates who failed to pass the initial NRC exam. The licensee had solicited input from General Electric Corporation and the Commonwealth Edison Production Training Center to help identify operator training weaknesses. Four of the five candidates who failed the exam in June of 1986 were retested in late January 1987, and three of the four passed the exam. The remaining seven training programs (Shift Technical Advisor, Instrument Maintenance, Electrical Maintenance, Mechanical Maintenance, Radiation Protection, Chemistry and Technical) have been submitted to INPO for accreditation. Full accredita- tion of all ten programs is expected by the .Spring of 1987. The training program appeared to be adequately implemented for the maintenance groups. Inadequate training could occasionally be traced as part of the cause of events occurring during thts rating period but, again, was not.a significant programmatic concern. The maintenance on-the-job training (OJT) program was directed. toward the application of pre~iously taught knowledge and skills to maintain plant equipment. There was . ..

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a good feedback path from maintenance to the training department. The majority of maintenance personnel were* aware of their opportunities to provide suggestions for possible revisions to the tr*ining.program. The licensee's approach to resolution of technical issues in th~ area of training was good. In cases*~here abnormal incidents had.occurred at the plant, the licensee prepared a Deviation Report (DR). The licensee's review of the event in the DR not only evaluated whether personnel error contributed* to the event, but in cases where it did, the tause of the personnel .error was also evaluated. In all cases, completed DRs were forwarded to the Training Department for their independent evaluation to determine if the formal training program could be impro~ed to prevent recurrence of the incident. The licensee's training program provided several means of disseminating information related to operating deficiencies and events to licensed operators. The Training Department issued and controlled the required reading program and incorporation of lessons learned from past events into classroom training topics. One weakness in the training of maintenance p-ersonne 1 was noted during the EQ inspection in ~ that the preservation of qualified status for motor operators . ****: *.* 25 .... . . **:_.:. \\

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was not adequate due to lack of training of maintenance/ inspection personnel. In the area of technical staff training there were also some weaknesses noted. The training effectiveness of efforts to acquaint personnel with required aspects of fire safety and regulatory requirements have been inadequate as discussed in Section IV.E. In addition, the site QA staff failed to attend two EQ training prograJTIS, as discussed in Section IV.I. 2. Conclusion -*The licensee's performance is rated Category 2 in this functional area. This functional area was not rated separately in the previous assessment period. 3. Board Recommendation None K. Licensing Activities 1. Analysis Evaluation of this fuhctional area was based on the licensee's performance in support of ljcensing actions. During this assessment period, 66 licensing actions wer~ completed. One important licensing activity was the licensing of a mobile incinerator.at the Dresden site to reduce radwaste.* This was a first time concept and the first mobile incirierator licensed for use at a nuclear power plant. The licensing . for ~se at Dresden provides a basis for the licensing at other Commonwealth Edison plants. However, the incinerator has not yet been delivered to the Dresden facility. The Mcensee's management has demonstrated a very active role , in assur-ing quality in licensing-related activities. Strong management involvement was especiaily evident where issues h~d potent i a 1 for substant i a 1 safety imp act a_nd extended shutdowns. Licensee management actively participated in an effort to work closely with NRR to promote a good working relationship. The majority* of submittals w~re consistently clear and of high quality. Licensee management frequently participated in meetings.in Bethesda on short notice. One area which indicated a lack of management attention was the setting of priorities to r~solve open items from the Integrated Plant Safety Assessment Systematic Evaluation Program. This problem and other communication problems between the NRC and the licensee were brought to the attention of the licensee's management. The licensee's management worked out the internal . * ....... *- .. ;.*:- .*.

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problems and worked closely with NRR in the last two months of the assessment period to correct these problems. We recognized, .a strong improving trend. The licensee's app~oach to resolution of technical issues from a safety standpoint was technically sound and thorough. The 1 i censee gen er.ally demonstrated a strong understanding of the technical issues involved in licensing actions and proposed sound and timely resolutions. This was evident in several areas, including control of Intergranular Stress Corrosion Cracking (IGSCC), Fire Protection, Combustible Gas Control, and Radwaste. The licensee is an industry leader in the area of hydrogen water chemistry to prevent IGSCC. In the area of fire protection, the licensee generally proposed sound technical solutions to.meet Appendix R requirements. The licensee is also heading a mini owners group to resolve the problem of combust~ble gas control in Mark l Containments. With the large number of licensing actions completed in the assessment period, the licensee generally made timely responses and submittals to meet licensing deadlines. The licensee actively participated in meetings at Be~hesda, its corporate office, or at the site to assist in resolving. issues. These meetings were generally well conducted, well prepared for, and a~sisted in resolving the issues. This was especially true for the meetings concerning Appendix R issues. However, there were issues where, although the* licensee's approach was good, the licensee did not thoroughly . understand NRR staff guidance. Once th* staff guidance was understood, the licensee proposed timely solutions which were ~echnically sound and exhibited proper consetvatism. For a few issues, full explanation of the staff guidance required an above average amount of staff effort. Examples of such issues were the Systematic Evaluation Program (SEP) tbpi~s. It should be noted, however, that these issues were evaluated early in the assessment Qeriod. During the last two months of the assessment period: the licensee demonstrated a clear understanding of the issues. An appropriate amount of conservatism was used when the potential for safety signifi- cance existed, and generally sound and thorough approaches were taken. This reflected positively on Commonwealth Edison's willingness to work closely with the staff. The licensee was res~onsive to NRC initiatives. During .the rating period,. the licensee made reasonable efforts to meet* commitments. Responsiveness by the licensee facilitated timely completion of staff review of a large number of licensing actions and thus substantially reduced the licensing backlog. The quality of license amendment requests, especially the "no significant hazards consideration determination," improved significantly after the "counterparts" meeting held*on January 30, 1986, where this topic was discussed in detail. 27

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The licensee responded promptly and accurately to various surveys conducted during.the reporting period. In addition, the licensee, at NRR's request, provided submittals for NRR in a very short turnaround time. This was especially evident in the licensee's response to NRR's request for additional information concerning Appendix R review, where the licensee was required to review a va~t amount of documentation. The licensee's response was timely and of high quality. Staffing in this area appeared adequate. T~e licensee maintained ample licensing staff to assure timely response to NRC needs. Positions were identified and authorities and responsibilities were well defined. 2. Conclusion The licensee's performance was rated Category 1 in this area. The licensee was rated Category 1 during the previous assess- ment period. 3. Board Recommendations None 28 . ,'*' :.**. .... *.*

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V. SUPPORTING DATA AND SUMMARIES A. Licensee Activities 1. Unit 2 Dresden Unit 2 began this assessment period while in a planned maintenance outage. The work that was conducted during this outage included required environmental qualification modifica- tions. After the outage Unit 2 engaged in routine power operation for extended periods throughout the assessment period. Additional outages/major events which occurred during this assessment period are surmnarized below: a. January 22-23, 1986: Unit 2 experienced an unscheduled outage as a result of a scram. The unit remained in cold shutdown for repairs on a corroded and grounded Main Steam Isolation Valve (MSIV) position switch and the 2C Main Feedwater Pump * . b. January 24-25, 1986: A manua 1 reactor shutdown was performed on Unit 2. The unit had encountered main condenser vacuum problems ever since the* unit *restarted on January 23, 1986. The licensee determined the problem was plugs which had blown out on a relief valve on the gland seal system header. New steel plugs were installed to replace the - previous plastic plugs and the unit was returned to service on January 29, 1986.

c. February 4-9, 1986: Unit 2 was manually shutdown to investigate and ~epair a stea~ leak located in. the main steam tunnel.

**

d. April 1-5, 1986: *Unit 2 was shut down from 100% power to . investigate control room panels~ It was,determined that main control room panels were not installed according to design drawings and that certain panels had to be seismically anchored. e. May 18 - June 10, 1986: The licensee conducted a Unit 2 routine scheduled maintenance outage. Major work completed included overhaul of the 2/3 diesel generator (5 year main- tenance inspection), completion of electrical modification to diesel 2/3 bus distribution, 6 month snubber visual inspection, replacement of the reactor mode switch, and many other required maintenance and testing activities. f. July 12-13, 1986: Unit 2 was shutdown to repair a faulty relay in the MSIV control circuit and several contacts on the MSIV test push button in the control room.

, .. ..... ~ .. ' . ' ' h. September 17-19, 1986: Unit 2 was shutdown (unplanned outage) to clean a fouled center water box on the main steam condenser. Condenser tubes had become partially blocked by clams/clam shells. i. November 29, 1986: Unit 2 was shutdown for a planned refueling outage. Major items scheduled for that outage were to repair and/or replace approximately 80 control rod drives, turbine overhaul, rater replacement of the B and C turbines, re-tube 28 Low Pressure Coolant Injection (LPCI) heat exchanger, Reactor Water Cleanup overlays,, . RPIS cable modification, SRM and IRM cable replacement, * Recirculation System structural beam modification, Standby Liquid Control System modification, drywell Limitorque EQ inspections, and Feedwater Level Control -system modification. The unit is scheduled to be* resynchronized to the grid on March 21, 1987. The average unit availability during the assessment period was approximately 74%. Nine scrams occurred during this assess- ment period. Six of these scrams were due to procedural inadequacies or personnel errors, 1 scram w~s due to mechanical/equipment problems*, and 2 scrams were the result of equipment fajlures. Unit 2 experienced three Engineered Safety Features (ESF) actuations. 2. Unit 3 Du~ing this ass~ssment period Dresden Unit 3 engaged in routine power operation for o'nly a limited period. Outag.es/ major events which were*initiated during this assessment period are summarized below: a.:* October 29, 1985-August 31, 1986: * Unit 3 was in a planned maintenance and refuelirig o~tage. During this outage workers replaced recirculation pipes, ve~ified core loading, installed a new Feedwater Control System, verified thermal *expansion characteristics of the new recirculatiQn piping, and other maintenance activities. b. July 19-27, 1986: Unit 3 successfully completed a 4 hour 110% hydrostatic test of the primary system. c. July 29, 1986: Unit 3 successfully passed the Integrated Leak Rate Testing (ILRT) activities~ d. October 14-16, 1986: Unit 3 was operating at 100% power when it experienced a reactor scram, as a result of a high flow signal. The licensee remained* shutdown to examine the cause of scram and to make a drywell entry to inspect the "3B" relief valve pressure switch. 30- ., * ... . :.;* .. -. >-** : .. **:: . :- ;*: -*. : .. -

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e. November 10-11, 1986: Unit 3 was operating at 93% power_ when it experienced a scram as a result of an MSIV not fully opening and Standby Gas Treatment System (SBGTS) failure. The licensee remained down to investigate the cause of the SBGTS failure to start. f. December 5-9, 1986: Unit 3 was shutdown to repair drywell electrical splices which did not meet Environmental Qualifications (EQ). The average Unit 3 availability during the assessment period was approximately 28%. Seven scrams occurred during this assessment period. Five of these scrams were due to procedural inadequacies or personnel ~rrors and 2 were due to mechanical/equipment problems. Unit 3 experienced 13 . Engineered Safety Features (ESF) actuations. B. Inspection Activities There were 52 inspections conducted during ihis assessment period, October.I, 1985 through December 31, 1986~ Major or si~nificant inspection activities are listed in Paragraph 2 of .this Section, Special Inspection Summary. 1. Inspection Data Facility Name: Dresde~ Unit: 2 Docket No.: 50-237 Inspection ~eport NQs.: 85001, 85030, 85033 thru 85037, 85040 thru 85041, 86001 thru 86027, 86029. Unit: 3 Docket No.: 50-249 Inspection Report Nos.: 85001, 85025 thru 85026, 85029 thru * 85033, 85035, .85037 thru 85038, 86001 thru 86008,

86010 thru 86023, 86025 thru 86032, and 86034 thru 86035~

31 ** ...... * .... /*.:: .-..

-1*. ,_,. . ' . ' . . .. ' .... * .

.....: ....; >: .. *

Table 1 Number of Violations in Each Severity Level Unit 2 Common to Both Functional Areas. I II I II IV V Unit 3 111 III IV Y. 1 11 III IV Y.*

A. Plant Operations B. Radiological Controls 1 C. Maintenance 1 2 1 1 2 D. Surveillance E. Fire Protection/ Housekeeping 2 4 F. Emergency Preparedness G. Security . H. Outages I. Quality Programs and Adminis. Controls Affecting Quality 1 .. 1 J. Training & Qualification Effectiveness K .. Licensing Activities . . *: . -~ ***** TOTALS Unit. 2 * I II I II IV V

y

Unit 3 I II II I IV V ---.-1* Both I II III IV V ---1-94 2. Special Inspection Summary , a.. October 18, 1985: : Specia*1 review of main steam activities, ~ransient monitoring system (237/85034). b.. November 12, 1985:: Special inspection to *observe refueling preparations and activities (249/85031). c. December 2, 1985 - January 23, 1986: Special Safety System Outage Modification Inspection (SSOMI) - Design. (249/86009). d. February 6, 1986: A NRR Team inspected inside the Dresden* drywell and obtained information to assist in evaluating 'the effects of the insulation fire of January 20, 1986. e. February 13, 1986: Special safety inspection to review potential damage to the .facility originating frdm a drywell fire (249/86006). f. May 19-23, 1986: SSOMI Regional Followup (237/86015; 249/86017). g. April 21 - July 16, 1986: SSOMI - Installation and Test (249/86012) 32 ... : *- ... ;..* '."* ... .;:""-.. *~ . . . . .

. *'**** . * ...

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~. . . .

C. Investigations or Allegations Review Allegati~n Review Eleven allegations relating to Dresden consisting of 21 concerns were received in Region III during this assessment period. Five of the 11 allegations and 11 of the 21 concerns remained open at the end of the assessment period and will be reviewed by Region III.in the near future. No significant safety concerns or violations were identified during the NRC reviews of allegations. D. Escalated Enforcement Actions Civil Penalties No civil penalties were issued during the assessment period. However, a Severity Level III violation was issued for improper radiological controls when a*box containing radwaste was found to have holes; however, there was no leakage. In view of this, no civil penalty was issued (010/86005; 237/86008; 249/86010; 237/86016; 249/86019). Reviews relating to the various Safety Systems Outage Modifications Inspection (SSOMI) findings of programmatic deficiencies and Environmental Qualification problems indicate the possibility of Escalated Enforcement Actions in the areas*of design, quality assurance, inadequate procedures/instruc~ions, aQd maintenance. These reviews continued at the*end of the assessment period and have*ryot been finalized (i.e., nb escalated enforcement.actions hav~* been issued).

E.

Licensee Conferences Held During Assessment Period 1. November 19, 1985 - Region III Office: Enforcement conference to discuss the licensee's failure to implement certain fire protection license conditions at the Dresden facility.

2. January 10, 1986 - Region III Office: Management meeting with Commonwealth Edison Company (CECo) representatives to discuss the results of the Systematic Assessment of Licensee* Performance (SALP 5). 3. May 21, 1986 - Region I II Office: Management meeting with CECo representatives to discuss the modification concerns identified during the SSOMI by the Reactor Construction Programs Branch and implications for other CECo stations. 4. June 2, 1986 - Region III Office: Management meeting with CECo representives to discuss a housekeeping program to improve plant conditions at Dresden. 5. July 2, 1986 - Region III Office: A Commonwealth Edison Company presentation of Dresden's plant modification Progra~ upgrades. 33* ~- . .,..... . *- . ~* . .~:.

.~**-;*!."".:* :**:*-*:.-***.-~ .... -~*.l*:*-'* ... *.* ... ::: . .,****.'.'"'. ***:.*.-.... - .*.***:*.**.**:**-=.* ............ .

- ......

..

. *. .:.:* * 5. August 11, 1986 - Region III Office: Enforcement conference with CECo representatives to discuss a radioactive materials trans-. portation incident at the Dresden station, and the licensee's * corrective actions and enforcement options available to the NRC. F. Confirmatory Action Letters (CALs) No Confirmatory Action Letters (CALs) were issued during this asses_sment period. G. A Review of Licensee Event Reports, and 10 CFR 21 Reports Submitted by the Licensee .. ~ .. 1. Licensee Event Reports ( LERs) Dresden Unit 2 Docket No.: 50-237 LER Nos.: 85036 through 85044 86001 through ~6027 Dresden Unit 3 Docket No.: 50-249 LER Nos.: 85021 through 85025 86001 th~ough 86024 Seventy-two LERs were issued during the assessment period: 41 LERs were the result of personnel errors; 9 lERs were the result of pr6cedure inadequacies; 5 LERs were th~ results * of component/equipment fail.ures: 2 LERs were related to design problems; and 15 LERs fe 11 in the "other" cause code. This * SALP 6 total of 72 LERs declined from the SALP 5 total of 93. However, personnel errors contin~ed*to represent a significa~t percentage of the total a.t 57%. Cause Codes Areas LERs

Personnel Error

41 Design Deficiency 2 External Cause

0

Procedure Inadequacy 9 Component/Equipment 5 Others

12

Unknown 3 NOTE: The above information was derived from reviews of Licensee Event Reports performed by NRC Staff and may not completely coincide with the unit or cause assignments which the .licensee has made. In addition, this table is based on assigning one cause code for each LER and does not necessarily correspond to the 34 .... ., *,:: ,.*-;***:. *-**>.*.*" . . ,r.* .. ,**:,1.::

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.... *.'

. -***

.. **:

.. *,* . . . ~ .* ' . : . ; .. ** ;_, ". :". ..

.

H. .*

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" .. . ~' . . . . * identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each LER. 2. * 10 CFR 21 Reports No 10 CFR Part 21 Reports were submitted by the licensee during thi~ assessment period for Dresden. 3. Analysis and Evaluation of Operational Data (AEOD) The results of the AEOO detailed review of Dresden LERs for this assessment period indicated an improvement in the quality of the licensee's issued LERs. AEOD gave an overall average score of 8.9 out of a possible 10 points, compared to Dresden's previous score of 7.2 and a current industrial average scor~ of 8.1 points. Strong areas identified during AEOD's review included the licensee's discussions concerning the root and intermediate cause; the assessment of the safety consequences and implications of the even~; personnel error; and the mode, mechanism, and effect of fatled components. AEOD stated that improvements in indicating the manufacturer and model number in the text for components could be made. Licensing Activities 1. NRR Site Visits/Meetings/Licensee Mana~ement Conf~rences Appendix R Site Audit Plant Orientation 2. Commission Meetings None 3. * Schedule Extensions Granted None 4. Relief Granted None 5. Exemptions Granted None 6. License Amendments Issued Amendment Title 07/08/86 07/11/86 10/20/86 - 10/21/86

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85/91 Storage of New & Spent Fuel in the High Density Fuel Storage Racks 35 . -* .... *.

.

Date 12/12/85 . .

~ '

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*** $.,.
... *

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*

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. . .:. . .. . . .: ... :_.*~: ... 92 86 87 88/93 89 90/94 7. Order None 8. Issues None . *-** ... . ~* .* *

. : : . *

Issued Pending

Temporary Extension of Diesel Generator 04/28/86 Allowable Outage Period Isolation Condenser Return Line Flow Setpoint Revision Cycle 10 Dresden Unit 3 Reload Mobile Volume Reduction System Instrument Surveillance Requirement Miscellaneous Changes 36 05/27/86 07/24/86 08/18/86 09/02/86 11/10/86 }}

ML17199G046

Text

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