ML17201H890
| ML17201H890 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/08/1988 |
| From: | Siegel B Office of Nuclear Reactor Regulation |
| To: | Norrholm L Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8806230334 | |
| Download: ML17201H890 (43) | |
Text
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MEMORANDUM FOR:
FROM:
SUBJECT:
June 8, 1988
- Leif J. Norr.ho l m, Acting Di rector D_lSIR-1-BUT-lON -~
- Project Directorate.III-2
<.pg_cket_F.JJ_e_jPD Rdg Division of Reactor Projects - IlI,NRC & L PDRS.L. Norrholm IV, V and Special Projects B.,Siegel w/o enclosure 2&3 T. Ross
- w~ Forney, RIII Byron L. Siegel, Project Manager E. Butcher w/o enclosure 2&3 Project Directorate III-2 C. ~oon w/o enclosure 2&3 Division of Reactor Projects - IIl,K. Desai w/o en.closure 2&3 IV, V and Special Projects D.. Muller.w/o enclosure 2&3 G. Holahan w/b enclosure 2&3
SUMMARY
OF MEETING WITH COMMONW~ALTH ~DISON COMPANY (CECO)
TO DISCU~S THE DRESDEN STATION TECHNICAL SPECIFICATION ACTION PLAN
.A meeting was held bn.June 3, 1988 with CECo at the NRC office at One Whtte Flint Nor~h in Rockville, Maryland. contains the list of meeting attendees.
The purpose of the meeting was for CECo to describe th~ir Technical Specification (TS) action plan'which is part of the Dresden Station overall improve~ent program.
Copies of the handouts are containe~ in Encl~sure 2.
The purpose of this effort 'is to correct problems identified in the c;:urrent TS and to raise.the quality and content of the Dresden TS to be consistent with, but not beyond,*the*current industry level.
l The potential overlap between the TS changes proposed by C.ECo and the_.NRC TS improvement program was al so di_'scussed.
- CECo prop,psed to.submit the 88 requested TS changes in 15. to 25 amendment
. packages between June and November 1988.
The pa~kages would include documen-tation as. to where and. when* the staff has. previously approved sim.ilar amendment requests So. the project manager could do most if hot all the reviews.
CECo
. stated they would work with the project manager to group the changes in the best way pos~ible to redu*ce the staff's -workload in the rev-iew and processing of the amendment~.
En.closure 3 identifies the *proposed TS changes; CECo ~as told the staff would review* ~he changes presented and determine what priority they would be given.
-* Enc 1 osures:
As 'stated origina 1, si'gned by Byron L. Siegel, Project Manager "Project Directorate lII-2
- Division of Reattor Projects - III, IV, V and Special Projects
- 1.
l PD: III-219 BSi_e_,Qel:ps 6/b<(/88 PD~ 02:0 OFFICE:
SURNAME:
DATE:
L~~~m 06/ i /88 230334 880608 8806 05000237 PDR ADOCK PDR
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MEMORANDUM FOR:
FROM:
SUBJECT:
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UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 June 8, 1988 Leif J. Norrholm, Acting Director Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects Byron L. Siegel, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects
SUMMARY
OF MEETING WITH COMMONWEALTH EDISON COMPANY (CECO)
TO DISCUSS THE DRESDEN STATION TECHNICAL SPECIFICATION ACTION PLAN A meeting was. held on June 3, 1988 with CECo at the NRC office at One White Flint North in Rockville, Maryland. contains the list of meeting attendees.
The purpose of the meeting was for CECo to describe their Technical Specification (TS) action plan which is part of the Dresden Station overall improvement program.
Copies of the handouts are contained in Enclosure 2.
- The purpose of this effort is to correct problems identified in the current TS and to raise the quality and content of the Dresden TS to be consistent with, but not beyond, the current industry level.
The potential overlap between the TS changes proposed by CECo and the NRC TS improvement program was also discussed.
CECo proposed to submit the 88 requested TS changes in 15 to 25 amendment packages between June and November 1988.
The packages would. include documen-tation as to where and when the staff has previously approved similar amendment requests so the project manager could do most if not all the reviews.
CECo stated they would work with the project manager to group the changes in the best way possible to reduce the staff's workload in the review and processing of the amendments. identifies the proposed TS changes.
CECo was told the staff would review the changes presented and determine what priority they would be given.
Enclosures:
As stated
~~~~~roject Manager Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects
Attendee's B. Siegel R. Ralph J. Silady D. Hoffman H. Bliss C. Schroeder E. Butcher C. Moon D. Mull er L. Norrholm G. Holahan*
K. Desai MEETING ON DRESDEN TS IMPROVEMENT PROGRAM
- JUNE 3, 1988 Affiliation DRSP/PD-3-2 CECo/Dresden CECo/Nuc. Lie.
Enclosure l CECo/Nuc. Lie. Consultant CECo/Nuc. Lie. Mgr.
CECO/Dresden Services Supt.*
NRC/OTSB NRC/OTSB NRC/PDIII-1 NRC/PD-III-2 NRC/NRR NRC/OTSB
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. t COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION TECH SPEC MEETING JUNE 3, 1988
{0059M)
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1 JUNE 3, 1988 CECO - NRC MEETING PROPOSED AGENDA A.
INTRODUCTION B.
DSIP OVERVIEW CONCERNS WHICH LED TO TECH.
SPEC. ACTION PLAN
- c.
DSIP -*rs ACTION PLAN
- DESCRIPTION
- DISTINCTION FROM GENERIC PROGRAMS SHORT TERM NEED D.
SUBMITTAL PLANS ORGANIZATION GENERAL SCHEDULE OTHER 1988 AMENDMENTS E.
DISCUSSION & FEEDBACK (0059M)
HANK BLISS CHUCK SCHROEDER DON HOFFMAN RICK RALPH ALL HEB/JAS
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DRESDEN STATION IMPROVEMENT PLAN CDSIP>
OVERVIEW NRC DIAGNOSTIC EVALUATION TEAM CDET> EVALUATION {8/87)
ACTION PLANS FOR VARIOUS STATION IMPROVEMENT EFFORTS WERE UNDERWAY, BUT THERE WAS A LACK OF INTEGRATION IMPROVEMENTS WERE NEEDED IN SEVERAL KEY AREAS CE.G. MAINTENANCE, IST, OPERATOR TRAINING)
DRESDEN ADDED NEW SUPERINTENDENT OF PERFORMANCE IMPROVEMENT TO MANAGE THE OVERALL IMPROVEMENT PROCESS Cl0/5/87)
CECO PRESENTATION TO MR. V. STELLO AND MR. A. B. DAVIS ON OCTOBER 28, 1987 ADDRESSED MANAGEMENT SYSTEM IMPROVEMENTS, INCLUDING TECHNICAL SPECIFICATION IMPROVEMENT REVIEW NRC ISSUED D1AGNOSTIC EVALUATION REPORT NOVEMBER 25, 1987 (0059M)
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PURPOSE OE MEETING TO DESCRIBE THE DRESDEN STATION IMPROVEMENT PROGRAM TECH SPEC ACTION PLAN NEED SCOPE, AND SCHEDULE TO OBTAIN NRC FEEDBACK TO STREAMLINE THE SUBMITTAL/REVIEW PROCESS HEB/JAS (0059M)
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DRESDEN STATION IMPROVEMENT Pl AN CDSIP> CCONIINUED)
- OVERVIEW DRESDEN STATION IMPROVEMENT PROGRAM CDSIP) CREATED PURPOSE INTEGRATE ALL DRESDEN IMPROVEMENT ACTIVITIES UNDER ONE PLAN DEVELOPMENT REVIEW PERFORMED OF RECENT DRESDEN EVALUATIONS, INSPECTIONS, AND ASSESSMENTS <INCLUDING DET>
DETERMINED PROBLEM AREAS COMMON THREADS SIGNIFICANT ISSUES COMBINED RESULTS, EVALUATED, PRIORITIZED DEVELOPED LIST OF NEEDED IMPROVEMENTS AND CORRESPONDING ACTION PLANS CORPORATE STRATEGIC PLAN FOR EXCELLENCE IN NUCLEAR OPERATfON~
(1988-1992) MANDATED THE DEVELOPMENT OF ADDITIONAL ACTION PLANS
- DSIP IS A COMPILATION OF THE ABOVE ACTION PLANS cws (0059M}
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DRESDEN STATION IMPROVEMENT PLAN CDSIP> CCONIINUEQ)
OVERVIEW CORDELL REED LETTER TO MR. V. STELLO Cl/22/88) SUBMITTED RESPONSE TO NRC DET REPORT INCLUDED THOSE PARTS OF DSIP RESPONSIVE TO DET CONCERNS SPECIFICALLY ADDRESSED ACTIONS PLANNED TO IMPLEMENT IMPROVEMENTS IN DRESDEN TECH SPECS CECO PRESENTATION TO MR. A. B. DAVIS, NRC *REGION III SENIOR MANAGEMENT, MR. D. MULLER AND MR. B. SIEGEL (4/19/88)
PROVIDED UPDATE ON DRESDEN PEFORMANCE IMPROVEMENT RESULTS PROVIDED STATUS OF ACTIONS TO IMPROVE DRESDEN TECH SPECS cws
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IlS.lf. - TECH SPEC ACTION PLAN EXCEL SERVICES CONSULTANT HIRED TECH SPECS REVIEWED IN-DETAIL BY:
~ STATION SRO-LICENSED INDIVIDUALS SUPT. PERFORMANCE IMPROVEMENT EXCEL SERVICES REPRESENTS AN ORGANIZED APPROACH TO ADDRESSING KNOWN PROBLEMS WITH TECH SPEC AMBIGUITIES AND DEFICIENCIES BY RAISING QUALITY/CONTENT OF DRESDEN TECH SPECS TO CURRENT INDUSTRY LEVEL DOES Hill CONSTITUTE CHANGES BEYOND TECH SPECS CURRENTLY IMPLEMENTED
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{0059M)
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DESCRIPTION OF DSIP - TECH SPEC ACTION PLAN DRESDEN T.S. REPRESENT LATE 1960'S REQUIREMENTS COMPILED PROBLEMS IDENTIFIED BY PLANT PERSONNEL REGULATORY PROBLEMS INTERPRETIVE PROBLEMS ITEMS NOT ADDRESSED TECH SPECS NOT REFLECTIVE OF CURRENT NRC POSITION BALANCED APPROACH
- 3.0/4.0 SCRAM DISCHARGE VOLUME LCO
- WILL ADDRESS REGULATORY ISSUES MINIMUM HPCI TEST PRESSURE APRM DOWNSCALE/COMPANION IRM UPSCALE GENERIC LETTER 87-09 DRH (0059M}
DISTINCTION BETWEEN DSIP - TECH SPECS AND ISIP
- TSIP TARGETED TO GENERIC CHANGES
- TSIP EFFECTS WHOLESALE REWRITE DRESDEN IS SITE SPECIFIC TO RAISE QUALITY/CONTENT OF OUR TECH SPECS TO BE CONSISTENT WITH CURRENT INDUSTRY LEVEL e
MANY CHANGES HAVE PRIOR NRC APPROVAL ON OTHER DOCKETS DRH (0059M)
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- f OSIP - TECH SPEC IS SHORT TERM NEED NRC DESIRED CHANGES UNIQUE RESTRICTIONS HAVE CAUSED POWER REDUCTIONS
- WILL CLARIFY INTERPRETATION PROBLEMS DRH (0059M)
ORGANIZATION OF TECH SPEC CHANGE SUBMITTALS SORTED BY SUBJECT INSTRUMENTATION TABLES
- - MULTIPLE TESTING SECONDARY CONTAINMENT
.OTHERS PAGE SUBMITTED ONCE AVOIDS CONFUSION AND ERROR
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- MULTIPLE TESTING/SECONDARY CONTAINMENT ORDER OF SUBMITTAL SUBSTANTIVE CHANGES INTERPRETIVE AND CLARIFYING CHANGES (0059M)
ROR
GENERAL SCHEDULE lST SUBMITTAL IN LATE JUNE (3.0/4.0}
AS MANY AS 25 AMENDMENT PACKAGES TO BE SUBMITTED THROUGH APPROXIMATELY NOVEMBER, 1988 e
NUMBER OF PACKAGES COULD BE REDUCED TO AS FEW AT 15 NEED STAFF INPUT BEFORE COMBINING SOME PACKAGES, I.E. WILL IT STREAMLINE OR COMPLICATE PROCESS?
ROR (0059M)
OTHER 1988 AMENDMENTS IN PROGRESS PRIOR TO THIS INITIATIVE
ROUTINE CE.G. RELOADS)
(0059M)
OTHER £XAMPLES INCLUDE THE FOLLOWING:
RG 1.97 INSTRUMENT CHANGES
- *APP. G & H CONTROL ROOM VENTILATION ROR
182Sb COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION PRESENTATION TO:
MR. V.
- S.TELLO EXECUTIVE DIRECTOR FOR OPERATIONS U. S. NUCLEAR REGULATORY COMMISSION AND MR. A. B. DAVIS REGIONAL ADMINISTRATOR REGION Ill U. S. NUCLEAR REGULATORY COMMISSION OCTOBER 28, 1987 WASHINGTON, D~C.
AGENDA INTRODUCTION BIDE THOMAS PURPOSE OF MEE.flNG
- REVIEW INPO EVALUATIONS OF CORPORATE AND DRESDEN
- COMPARE WITH NRC DIAGNOSTlt EVALUATION
- REVIEW CORRECTIVE ACTIONS CORPORATE ORGANIZATION CORPORATE INPO EVALUATION CORDELL REED FINDINGS DRESDEN INPO EVALUATION JOE EENIGENBURG FINDINGS COMPARISON TO NRC DIAGNOSTIC EVALUATION CORRECTIVE ACTIONS UNDERWAY ORGANIZATIONAL CHANGES DENNY GALLE JOE EENIGENBURG LOU DELGEORGE IMPROVEMENT CATEGORY DEVELOPMENT 3 MINUTES 10 MINUTES 10 MINUTES 20 MINUTES IMPROVEMENT CATEGORIES -
SUMMARY
OF KEY ELEMENTS
- EQUIPMENT PERFORMANCE o
SSOMl/SSFI/SSFT
- -PERSONNEL PERFORMANCE
- MANAGEMENT SYSTEMS PERFORMANCE
- FACILITIES IMPROVEMENT PROGRAM
SUMMARY
AND CONCLUSIONS 1825b
Ill.
IMPROVEMENT.TEGORIES -
SUMMARY
OF 19~ KEY ELEMENTS (CONTINUED)
MANAGEMENT SYSTEM IMPROVEMENTS REGULATORY ASSURANCE RESOURCE COMMITMENT PROCEDURES UPGRADE IN SERVICE TESTING PROGRAM TECHNICAL SPECIFICATION IMPROVEMENT REVIEW SCRAM REDUCTION INTEGRATION OF NEW INITIATIVES WITH EXISTING PROGRAMS FORMALIZATION OF ACTION PLANS 1825b EXPANDED MONTHLY MONITORING REPORT TO HIGHLIGHT UNDESIRABLE TRENDS
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 205515 November 25, 1987 Doc~~t Nos. 50-237 50-249 Mr. Cordell Reed, Senior Vice President Nuclear Operations Connonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690
Dear Mr. Reed:
SUBJECT:
DIAGNOSTIC EVALUATION AT THE DRESDEN NUCLEAR POWER STATION ON AUGUST 17-28, 1987 This letter forwards the report of the Diagnostic Evaluation performed by a U.S. Nuclear Regulatory Commission (NRC) evaluation team over the period
. August 17 to August 28, 1987, involving activities authorized by NRC Operating license Numbers DPR-19 and DPR-25, for the Dresden Nuclear Power Station. This
- evaluation was conducted by a teaJD of NRC headquarters and regional inspectors, and team leadership and support was provided by the Office for Analys.is and Evaluation of Operational Data (AEOD).
As you are aware, this is a new.NRC assessment tool that is intended to provide an independent assessment of licensee performance, and as such, its principal focus is on safety performance and not compliance with regulatory requirements.
Following the conclusion of the onsite evaluation, the findings were discussed at an exit meeting with you and members of your staff on September 23, 1987. Additionally, you and other Commonwealth Edison Company officials met with me and memllers of lllY staff on October 28, 1987 to describe your overall plans for improving the safety performance at Dresden.
The NRC effort involved an assessment of Dresden's performance including personnel attitudes toward safety, *nagement fnvolvement in station operations, and t.he**ffect of recent i11Prov111ent initiatives on station performance and personnel attitudes; and to determine, to the degree possible, the fundamental or probable causes that lllY underlfe perfol"lllnce Pl"'.Oblems.
Particular attention was directed on the conduct of operations and the interfaces between operations and the functional areas of uintenance,
- surveillance testing, operator training, quality programs, and radiological controls.* Additionally, the programs for assuring quality in these areas were reviewed to determine their effectiveness.
Despite past and present improvacnt programs, a number of 111jor weaknesses were identified. These included 111intenance (particularly of 110tor-operated valves), fnservice testing (IST), communication, and operator training.
Because of a history of poor maintenance and testing practices, the team concluded that wear, aging, and the resultant accumulation of equipment deficiencies could cause system/component unreliability. Further, the team found that communication was poor across the organtzatton and that the operator requalfficatfon program remains unsatisfactory.
In addition, an immediate
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Mr. Cordell Reed safety concern associated with excessive operator overtime was identified by the team, and corrective actions were promptly taken by station management.
Based upon the extensive team assessment, both onsite and through subsequent analysis, ft was concluded that the.fund&llental or root causes of Dresden's frequently low and flyctuating performance history were:
(a) Dresden had not received strong and f ndepth corporate attention in the past, (b) an attitude and,approach existed that had-not been directed at achieving or 81fntafnfng.a hfgh. standard of safety performance, and (c) past f11provement fnftfatfves had bHn--largaly a reaction to findings by INPO and the NRC, and had not been develop,~.J~
- specific and complete way to overcome Dresden deficfencfes. In addftfort.'* 81jor*weaknesses fn aafntenance, fnservfce testing, comunfcatfons and*trafnfng were sfgnfficant contributors.
The evaluation results which include: (l) major findings and conclusions, (2) specific findings and conclusions, and (3) root cause determinations are included fn Section 2 of the enclosed report. Section 3 of the report provides the detailed evaluation findings.
Some of these items may be potential enforcement findings.
Any enforcement actions will be identified ~Y ouru
'- Region III Office. r.
In summary, Dresden's performance is currently judged to be on the low side of average with a slowly improving trend. However, confidence fs not high that, without additional major corporate involvement, Dresden's performance will show significant and sustained improvement. This view is due to Dresden's fluctuating past performance history, the weaknesses fn the present improvement initiatives, a lack of improvement initiatives in sev~ral critical areas, and limited financial and human resources.
During the week of November 16, 1987, I met with senior NRC managers and discussed the results of this Diagnostic Evaluation as well as other current information concerning the regulatory and operational performance of Dresden.
During our discussions ft became apparent that the overall results of this Diagnostic Evaluation substantiated NRC senior 81nagement concerns that the Coanonwealth Edfson Company needs to 81ke a substantial coanitment to additional improvement initiatives. These f nitiatf ves are necessary f n order to assure sfgnfficant and sustained f11prove11ents fn Dresden's safety perfonnance. --J request that you evaluate.the. enclosed report aiad. that wfthi n 60 days Of thti'.'*date of tflfl letter~* you provfde llY Offfce wftfl-an fntegr*ted 11prov*ant *progra wfth schedules, goals, objectfves, action plans w;fth.
- f1estonn9* ancl"~ractfng &nd asses... nt *tbOdl;.. Tbfs progr* should not only address -the *jor weaknesses and. roo~.causes.1dentfffe4 by *the Dfagnostfc Evaluatfon, buf.,.1hould**l10 include pf'OYisfons.for 1dentfty1ng and correcting other.. probable* causes that 111.Y.**andel'."lf* perfonaance pl'Oblas.-*
- Gfven the n&11erou1*,walcne1ses fdentfffed.wftla.)'OUI" ~ni* _..,.. *past.. perforunce. p~grams, your re1p0nse*~should. lpecffically describe your plans and *thods for p~vfdfng greater assurance that this progru wfll Nsult in a sustained overall*
f11provement f n the safety perfo1"118nce at Dresden.
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Hr. Cordell Reed In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this evaluation, we would be pleased to discuss them with you.
Enclosure:
Diagnostic Evaluation Team Report for Dresden Nuclear Power Station Distribution (w/encl) ocs PDR LPDR EDO R/F w/o encl.
AEOD R/F Distribution (w/o encl)
EWordan CJHeltemes DOA R/F
- RLSpessard DEIIB R/F SDRubin.
HBailey RPerch RFreeman Rlloyd AHowell DA111son JTaylor JJohnson
-=-
'-MTroskoskf OSP TEHurley WDavfs, RU I RHartf n, RIV JMartin, RV NGrace, RII WRusse 11, RI
- SEE PREVIOUS CONCURRENCE Sfocerely, O!"i&1cd signed by
- Viet.or St.tilo Victor Stello, Jr.
Executive Director for Operations NAME :Rfreeman
- HBailey
- SDRubin
- RLSpessard :CJHeltemes :ELJordan DATE :11/5/87*
- 11/5/87
- 11/ /87
- 11/5/87
- 11/ /87
- 11/5/87
- e.
4.0 EXIT MEETING The Director of AEOD, Region III Administrator, team Manager, team leader, and other NRC personnel met with CECo and Dresden management officials at the CECo offices on September 23, 1987, to brief them on the results of the Dresden diagnostic evaluation.
The list of attendees is given at the end of this section.
The briefing which consisted of the teams preliminary findings and conclusions was led by E. Jordan, Director, AEOD.
A copy of the briefing notes used during the meeting is included as Appendix A to the report.
The CECo response at the exit meeting, which was very receptive and positive, reinforced the team's preliminary findings and conclusions regarding upper aan~gement's attitude, involvement, and connitment.
C. Reed, Senior Vice-President, CECo, led the CECo response.
He acknowledged and accepted the NRC's findings, conclusions, and root causes and stated that he wanted to assure V. Stello, the Executive Director for Operations"(EDO),
that CECo is committed to putting resources in place to achieve the goal of excellence at Dresden and at the other CECo facilities. It was agreed that a meeting would be set up between Mr. Reed and Mr. Stello.
- Mr. Reed was surprised by the team findings with regard to the operator requalification training program.
D. Galle, Vice President-BWR Operations, commented that CECo was putting changes in place to meet the 1986 INPO guidelines. This was contrary to what the team had been told at Dresden.
The team concluded that this corporate initiative had not yet been communicated to Dresden management.
Mr. Reed acknowledged that resource limitations have played a part in Dresden's condition and past perfol"'lllance.
However, he reported that the Dresden 1987 budget expenditures will exceed the guidelines of the CECo Strategic Plan.
According to Mr. Reed, many of the team's preliminary findings were parallel to INPO findings, and this served to emphasize the urgency of augmenting the Dresden organization with additional staff.
He then went on to highlight the following recent INPO corporate assessment results.
CECo was urged to look at how other nuclear utilities conduct business as a way to reduce a parochial perspective at CECo.
There are plans for corporate/station managers to visit other utilities in response to this INPO assessment.
Outside management development was recoanended.
The strategic plan is good, but lacks accountability.
Management is ineffective in communicating objectives and expectations to the lower levels of personnel.
76
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Hr. Reed then convnftted to provide the INPO corporate assessment results for Dresden, Zion, and CECo to the NRC when CECo makes a final decision on how ft wf 11 respond to the results.
At the conclusion of the meeting, Mr. Reed indicated that CECo intended to re-spond formally to the NRC and to address actions to be taken as a result of the team (and INPO) findings.
INPO and CECo ~ams were perfor11ing a maintenance assess11ent at the ti11e of the exit meeting.
CECo is coanitted to determine root causes of problems and to develop appropriate corrective actions. Maintenance programs from other nuclear utilities wf 11 be studied for possible improvements to be made by CECo.
CECo wants to make a ustep change* to address equipment/material problems at Dresden.
An aggressive plan that includes the following actions is already under way.
)/.
Add;tfonal personnel with systems exp~rtise (6-10 people) were to be hired by.the end of October 1987.
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A new position will be created to oversee an integrated improvement pro-gram.
The person ffllfng this position will report directly to the Station Manager, wfll have a staff of 15 to 20 people, and wfll interact with the line organizations implementing.. the improvement fnitfatfves *
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...,;'-.:, -4 A new Inservice Testing (IST) Manager at Dresden will be hired from out-side CECo.
An upgraded motor-operated valve preventive maintenance program wf 11 be exped;ted.
A technical specfffcatfon review and i111>rovaent program wf11 be initiated.
77
Commonwealth Edison One First National Plaza. Chicago. Illinois Address Aeply to: Post Office Box 767 Chicago, lllinOJs 60690
- 0767 Mr. Victor Stello, Jr.
Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Stello:
January 22, 1988
Subject:
Dresden Station Units 2 and 3 Commonwealth Edison's Response to NRC Diagnostic Evaluation NRC Docket Nos. 50-237 and 50-249 References (a): v. Stello, Jr., letter to Cordell Reed dated November 25, 1987 (b): J.A. Silady lett~r to A.B. Davis dated OCtober 2, 1987 (c): c.E. Norelius letter to Cordell Reed dated September 4, 1987 transmitting the July-10, 1981 Task Force Report.
We are submitting as an attachment to this letter, our review of the Report of the NRC Diagnostic Evaluation Team (DET) (see Reference (a)) that conducted an assessment of our Dresden Station's performance in 1987.
This attachment addresses, in summary fashion, the Major Findings and Conclusions, as well as the Specific Findings and Conclusions discussed in the DET Report
-(see Attachment,Section II). As discussed in an earlier letter (Reference (b)), the attachment also addresses (in Section Il.B) the findings in the NRC's report of the Task Force Review of Equipment Performance (Reference (c)).
In addition, we are developing detailed evaluation packages for each of
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- v. Stello, "Jr. January 22, 1988 the observations made in the DET Report.
These packages will be completed by February 15, 1988, and will be available at *Dresden Station for review by the WRC Staff.
As you are aware, we have developed a comprehensive initiative at Dresden to assure that recent improvements in the performance of Dresden Station are sustained, and that excellence in nuclear operations is achieved.
This.Dresden Station Improvement Plan (DSlP) integrates*all of our initiatives at self-improvement into a single program under a senior manager who reports directly to the Dresden Station Manager.
This newly created position of Superintendent of Performance Improvement is intended to assure that this important activity has the highest possible level of management attention without imposing an additional burden on the line st~~:c~ management.
The DSIP is discussed at some length in Section III of th~ Attachment.
Also included in the.Attachment are the Action Plans that are in progress that address findings made by the DET in its report.
These actions constitute only a part of the DSIP, but clearly reflect our approach to managing the process of improvement at Dresden.
The Action Plans identify Measurement Standards by which we will gauge o~r progress and, wherever possible, identify Performance Indicators to assess trends in the
- underlying programs that are the subject of the Action Plan.
Ve expect to refine this ~ction Plan evaluation process as-we implement the DSIP and will establish objective target goals for performance wherever possible. Those areas not amenable to objective assessment will be evaluated periodically by qualified Edison personnel or consultants not involved directly with the Dresden DSIP to provide added confidence that our improvement objectives are
. being achieved.
The DSIP program 1s aggressive and is intended to achieve both short and long term perfonnance improvement objectives.
We expect, as a result of this initiative, to interact with your staff regularly as we track our progress.
Ve will* advise the Staff of any actions necessary by them to support the completion of our program, such as the review of.modified testing programs and amendments to technical specifications.
I recognize the responsibility I have to assure that both adequate resources and management attentiQn are provided to restore Dresden Station as a performance leader in the nuclear industry.
I believe our efforts at Dresden will demonstrate our commitment and. ability to.achieve excellence, and that all of our nuclear facilities should and will meet our goals of excellence in nuclear operations.
('* '
- v. Stello, Jr.
3 -
January 22, 1988 If we can be of any service by clarifying or supplementing the materials submitted by this letter, please have your staff direct questions to our Nuclear Licensing Department.
Ve expeet to establish with the NRC.Region Ill Staff, a mechanism for the periodic review of our progress at Dresden Station.
I continue to be available in the event you need any further information in this regard.
Very truly yours,
. COrde 11 Reed Senior Vice President C
lm
(
- l.
(
Attachment cc:
A. B. Davis - Reg. Admin. (RlII)
M. Grotenhuis - NRR NRC Resident Inspector - Dresden 412SK
r**
(
c c
(
PBLI OP CONTENTS I. Introduction and overview II. Responses to General Findings A.
B.
Operations Mdntenance
- c.
Testing D.
Operator Training E.
QUality Programs F.
Radiation/Chemistry G.
Management I Union Interactions H.
Conununications I.
Plant Material Condition III.
Dresden ~tation Impro~ement Plan A.
B.
- c.
Purpose Organization Program Description IV. Other Dresden Initiatives A.
B.
- c.
D.
E.
Scram Reduction Fac111t.1es Improvements Tech Spec Upgrade Procedures Upgrade Other Initiatives
- v.
conclusion Tables:
- 1. List of Assessments
- 2. List of Improvement Action Plans
- 3. List of Action Plans Responsive to DET
- Appendix A:
Action Plans Responsive to DET 4125K 2
3 3
6 6
7 9
10 11 12 13 13 13 14 16 16 17 17 17 18 19
17 -
B.
FACILITIES IMPROVEMENT A number of facility improvement initiatives have been undertaken at Dresden.
The most extensive has been the overall plant cleanup and painting project.
Other significant facilities improvement projects scheduled to begin in 1988 include the following~
- 1.
Relocate Protected Area (PA) security fence to include Administration Building inside the PA.
- 2.
Complete Control Room ceiling and HVAC work.
- 3.
Install new makeup demineralizer system.
- 4.
Upgrade liquid radwaste system.
- 5.
Install new roofing on Turbine and Reactor Buildings.
C.
TECH SPEC UPGRADE Problems have been.encountered in the past in the past in the process of interpreting various Limiting Conditions for Operator (LCO) and Surveill_ance requirements.
A detailed review of the Dresden Tech Specs was deemed necessary 1n order to resolve the following issues:
- 1.
LCO and Surveillance wording that has been shown to be ambiguous, inconsistent, confusing, and subject to multiple interpretations.
- 2.
Operational *traps", configurations, and errors that result in the high likelihood of violating Tech Spec requirements.
- 3.
Surveillance requirements that are redundant, excessive, and do not relate to the present NRC philosophies regarding equipment testing.
A consultant has been hired to assist the Station in performing a detailed review of the Tech Specs, and to provide technical justifications for Tech Spec change submittals. It is our intent to convnence the submittal of Tech Spec changes by April, 1988:
D.
PROCEDURES UPGRADE In October, 1987 a Procedures Upgrade Coordinator was added to the Station in order to manage the overall procedures improvement program.
Action plans have been developed, and the following items are scheduled to be addr.essed in 1988:
- 1.
Re-write and upgrade of the Dresden Administrative Procedures concerning procedure generation, review, and approval.
1988 ANNUAL GOALS DRESDEN STATION DESCRIPTION OF GOAL Implement improvements in the Dresden Technical Specifications.
ACTION PLAN:
WHAT I.
Work with Corporate Nuclear licensing/Regulatory Assur*nce to hire
- consultant for reviewing the Dresden Technl~I Specifications.
- 2. Establish a schedule to ccmplete the review *nd submit the proposed changes to Corp.
- 3.
Provide station assistance to contractor. Request operability definition assistance from BWRED.
- 4. "Complete the submittal of proposed revisions to the Tech Spec's to CSR.
- 5. Complete the submittal of approved revisions of the Tech Spec's to Offsite Review *nd the NLA.
- 6.
Assist Offsite Review *nd the NLA to ensure proposed revisions are submitted to.ffle NRC.
MEASUREMENT STANDARD Review c:cmpleted and all proposed changes submitted to the NRC by 12/15/88.
Performance Indicators:
None RESPONSIBILITY OF:
E. Armstrong coHPLETION EXPECTED BY: 12/15/88 GOAL NO. RA-3 DUE DAT~
02/01/88 02/15/88 03/01/88 10/03/88 11/01/88, 12/16/88
DRESDEN NUCLEAR POWER STATION PERFORMANCE IMPROVEMENT RESULTS APRIL 19, 1988
DRESDEN NUCLEAR POWER STATION PERFORMANCE IMPROVEMENT RESULTS APRIL 19, 1988 AGENDA
- 1.
INTRODUCTION/PURPOSE CORDELL REED
- 2.
DSIP OVERVIEW LARRY GERNER
- 3.
OPERATIONS JOE EENIGENBURG MAINTENANCE
- 4.
RAD CHEM CHUCK SCHROEDER HOUSEKEEPING TRAINING
- s.
FIRE PROTECTION PAUL KUHEL
- 6.
TECHNICAL SUPPORT DENNY GALLE
- 7.
QUALITY PROGRAMS LOU DELGEORGE
- 8.
RESOURCES/LABOR RELATIONS CORDELL REED
- 9.
NRC FEEDBACK ALL 1270a
127la
- 6. TECHNICAL SUPPORT DENNY GALLE VICE PRESIDENT BWR OPERATIONS
TECH SPEC UPGRADE CONCERNS PROBLEMS WITH CLARITY, ACCURACY, AND INTERPRETA-rION OF REQUIREMENTS CERTAIN REQUIREMENTS DIFFER FROM NEW PLANT TECH SPECS ACTIONS TAKEN CONSULTANT HIRED TO WORK WITH STATION AND REVIEW DRESDEN 2 & 3 TECH SPECS.
o RECOMMEND CHANGES o
DEVELOP CHANGE SUBMITTAL PACKAGES PER~ON ASSIGNED FROM STATION REGULATORY ASSURANCE (SRO} TO MANAGE THE UPGRADE PROJECT ACTION PLAN FOR PROJECT WAS WRITTEN IN DSIP RESULTS ACHIEVED 127la TECH.SPECS HAVE BEEN THOROUGHLY REVIEWED AND NEEDED CHANGES HAVE BEEN IDENTIFIED CHANGES HAVE BEEN PRIORITIZED DRAFT TECH SPEC CHANGE SUBMITTAL PACKAGES HAVE BEEN WRITTEN FOR HIGH PRIORITY ITEMS.
OTHERS TO FOLLOW.
o PRIORITY CHANGES TO BE SUBMITTED STARTING 6/88 o
SUBMITTAL COMPLETION BY 12/88
iNT DRESHORT SORTED BY PRIORITY PASE ID PRI TS NUMBER TS PASE b A 3.0 3.0-1 38 A
4.5.E.2 3/4.5-10 40 A
4.5.F.1 3/4.5-11 30 A
4.5.A.2 3/4.5-2 33 A
4.5.B.2 3/4.5-5 35 A
4.5.C.2 3/4.5-7 34 A
3.5.C.1 3/4.5-7 37 A
4.5.D.2 3/4.5-8 44 A
3.6.F 3/4.6-7
.78 A
3.7.A.5.b 3/4.7-15 DRESDE~HNICAL SPECIFICATION PROGRAM TS TITLE PROBLEM DESCRIPTION LCD-Generic Specification 3.0.A is more limiting than the siailar STS requirement.
These li1itations pose additional operating restrictions on the *Dresden Plant. Other 3.0 and 4.0 provisions of the STS allow operational flexibility not currently included in the Dresden TS.
Isolation Condenser Testing of the HPCI subsystem should not be required when the isolation condenser is inop.
DATE 06/01/BB Page DG Inop-Surveil of Surveillance 4.5.F.1requires1ultiple testing of all low press core cooling and containment cooling subsyste1s when either the unit or shared DG is inop. This testing should not be required.
Core Spray and LPC!
"ultiple testing of other systems should not be required when one core spray syste1 or one LPCI pump (4.S.A.41 or one LPCI subsyste1 (4.5.A.51 is inop.
Containment Cooling Multiple testing of other syste1s should not be required when one containaent cooling service water puap 14.5.B.21 or subsystem (4.5.B.31 is i nop.
HPCl Subsystem Multiple testing of other systems should not be required when the HPCI subsystem is inop.
HPCI Subsyste1 HPCI is required to be operible whenever Rx Press is ST 90 psig.
However, HPCI isolates at 100 psig. Test pressure for HPCI when *in Rx Startup should be specificied. Prefer 300 psig.
Automatic Pressure Testing of the HPCl system should not be required Nhen one relief valve is inop 14.5.D.21 or when 1ore than one is inop (4.5.D.31.
Structural Integrity The structural integrity of the pri1ary system boundary is required to be maintained per ASKE Section XI requireaents.
Adding a motherhood
!Section 3.0/4.01 statement endorsing the IS!
program could allow deletion of detailed require1ents in the TS.
Containment This TS states that deinerting 1ay co1mence 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to a shutdown but limits are not specified. If the 4Z Oxygen require11ent is violated, then 3.0.A is entered.
A Page 2
--~-----------------------------------------------. --------------------------------------------""-----------------------------
ID PR!\\
TS NUMBER TS PASE TS TITLE PROBLEM DESCRIPTION 52 A
3.7.A.6 53 A
3.7.B.1.a 58 A
3.7.C.1 79 A
4.7.C.1.c 61 A
4.7.D 63 A
- 4. 7. D. !.d 2
Bl I. 0. R 72 Bl 3.12 20 Bl 3.3 46 Bl 3.6. I.2 75 Bl 3.7.D.2 3/4.7-15 Contain1ent 3/4.7-19 Standby Sas 3/4.7-25 Secondary 3/4.7-26 Secondary 3/4.7-27 Pri1ary Containaent 3/4.7-28 Primary Contain1ent 1.0-3 Pri1ary Containment 3/4.12-1 Fire Protection 3/4.3-5 Scra1 Discharge 3/4.6-15 Snubbers 3/4.7-2B Pri1ary Contain1ent This LCO is not in the QC TS.
LCO 3.7.A.6.a states that the inerting syste1 shall be operable if required by post LOCA conditions.
Does the FSAR take credit for nitrogen injection post LOCA?
Nitrogen Makeup is isolated on a LOCA signal.
Since the inlet valves for nitrogen purge perform both an isolation and a purge function, the actions for both these functions should be compatible.
Testing of the other SBST system should not be required when one system is inop.
Lack of provisions in the LCO and Actions requires use of 3.0.A.
Need to specify if Secondary Contain1ent Integrity can exist with less than 1/4' water vacuum.
Soae of the surveillance requirements seem to duplicate !SJ prograa requireaents.
This SR was deleted by QC.
Do not need to perform a partial closure of the aain steamline power-operated isolation valves twice per week.
The definition for Priaary Contain1ent Integrity requires all auto1atic contain1ent isolation valves to be operable or be deactivated in the isolated position. This is in conflict with the require1ent of TS 3.7.D on Pri1ary Containmeht Isolation Valves which in 3.7.D.2 allows power operation to continue provided at least one valve in each line having an inoperable valv~ is in the isolated co~dition.
The fire protection TS should be deleted per Seneric Letter 86-10.
There is no LCO for SDV Vent and Drain Valves.
LCO on Snubbers, 3.6.J.2 and 3, requires reactor shutdown if snubbers are not 1ade operable. This require1ent should be changed to declare the affected systea inop and follow the actions of the System LCO.
Consider startup restrictions relative to snubber operability.
When an isolation valve is inop, reactor power operation 1ay continue provided one valve in the line is in the isolated position. -This LCO is not clear is stating that the valve in the isolated position can be the inop valve.
3 B2 2.1.H 112.1-5 7
82 T3.1.1 3/4.1-5 13 B2 i3.2.3 3/4.2-12 16 B2 T3.2.6 3/4.2-17 9
B2 3.2.C.2 3/4.2-2 12 B2 T3.2-1 3/4.2-8 24 B2 4.3.C.2 3/4.3-11 25 B2 3.3.D 3/4. 3-11 LSSS-"ain Steamline RPS Instrumentation Rod Block Post Accident Control Rori Block Priaary 'Containeent Control Rod Scram Control Rod Present "ain Stea1line Pressure initiation of main stea1line isolation valve closure is 6T/E 850 psig.
QC has changed to 825 psig.
RPS Instr Table 3.1.1 is not user friendly.
Shutdown Mode is not included in the table.
The APR" DoMnscale/IR" High co1panion trip does not belong in the table.
The High DryMell Pressure Scram of 2 psig does not reflect the DW to WetMell operating dp of 1.0 psid.
The DW 2 psig setpoint is too loM to alloM recovery fro1 loss of DW coolers.
The title 'Turbine Control-Loss of Control Oil Pressure' is not technically accurate.
Table is not operator friendly. Lacks Op Cons.
For definition of trip syste1s, the operator must go to the bases. 6eneric problem, need to look at all tables.
Instru1ent range column is not needed and 1ay hinder use of instruments that do not aeet exact stated range.
Note 1 requires the reactor not to be started up if it is in SD for longer than 72 hrs unless ail Main Steae RV and SV position indication is restored. This require1ent has no basis and should be revised.
There is no basis for allowing RB" channels to be out of service for no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 30 day period.
Table lacks Op Cons to define Mhen the instr are required to be operable. Hi OW Press trip of 2 psig is too loM since DW/Wetwell dp is already set at 1 psid. "in I of op channels per trip system for Hi FloM Main Steam Line seems to require ali 16 channels to be op.
LoM Press in "ain Steaaline Tunnel trip.at ST/E 850 psig could be reduced to allow 1ore ops flexiPility. Table lacks AOT for testing.
Present control rod surveillance requires that at 16 week intervals, at least SOI of the control rods shall be scra1 tiae tested and that all rods will be tested every 32 weeks. This require1ent is more stringent than STS require1ents.
Present wording is that 'a rod accu1ulator 1ay be inop provided that no other control rod in the nine-rod square array around this rod' is inop.
This nine-rod square array terminology is confusing. "ay need 1ore Action require1ents for inop accu1ulators to avoid 3.0.A.
- ' 1 *_.
e Page 4
- -~-3-----~-------------------------------------------------------------------------------------- ------------------------------
ID~
PR! '
TS NUllBER TS PASE TS TITLE PROBLEll DESCRIPTION 19 B2 3.3.A.2.a 22 B2
- 3. 3.B.1 28 B2 3.4 Bl 82 4.5.F.2 29 82 4.5.A.1.c 41 82 3.5.L 36 B2 3.5.D.!
45 B2 4.6.!.2.a 77 82 3.7.A.6.e 3/4.3-2 3/4.3-4 3/4.4-1 3/4.5-11 3/4.5-2 3/4.5-26 3/4.5-8 3/4.6-16 3/4.7-17 Reactivity Having to determine if the cause of failure of a control rod drive is due to a failed collet housing is an outdated requirement. Bases 3.3.2 discusses this BWR concern which has been corrected with cosponent 1aterial changes.
Control Rod Coupling LCO states that 'the rod shall be declared inop, fully inserted and the directional control valves electrically disarmed." This is in conflict with 3.3.A.2.c which states that drives which are fully inserted and electrically disar1ed shall not be considered inop.
Standby Liquid Review present SLCS TS versus latest NRC approved version for possible relaxations.
Dresden This surveillance assures that the plant can be safely shut down in case of the Dresden D~1 failure. This surveillance does not support the LCD on minimun Core and Containment Cooiing System availability.
Core Spray Subsystem Pump operability (once/month! and llOV (once/month) testing (4.5.A.1.di should foiloM the !Si quarterly requirements.
Condensate Pump Roon The LCOs and SRs for the Condensate Pump Room Flood Protection sees to be located in the wrong part of. the TS, following llCPR.
Also, the alarm function require1ent~ for the condenser pit water level switches need to be reviewed to deteraine if changes can be made to prevent misinterpreting (or aissingl the requirements.
Delete "is' in fir~t line of 3.5.L. !.
Autogatic Pressure Snubbers Contain1ent The Autoaatic fress Relief Subsyste1 is required to be operable whenever Rx Press is ST 90 *psig and irradiated fuel is in the Rx vessel. ls the 90 psig value correct or can it be raised? Also SR Bases 4.5 indicates that valve operation below 150 psig is limited by the.spring tension exhibited by the relief valves.
For each unit and subsequent unit found inop an addional 10% of the hydraulic snubbers are required to be tested.
The 111-4 Working 6roup of the ASllE has changed this retest group to 5%.
llay not have any safety related hydraulic snubbers in the plant.
The purpose of LCO 3.7.A.6.e on maxi1u1 contain1ent repressurization using the inerting system is not clear.
Page 5
--~-*--------------------------------------------- ______________________________________________ Jllllr ____________________________ _
ID<>
Pli:P TS NUMBER TS PASE TS TITLE PROBLEM DESCRIPTION 54 82 4.7.B.2.a 57 B2 3.7.B.2.a 62 B2 4.7.D.l.c 64 82 3.7.D.5 49 B2 4.7.A.2.f
'Q
- b.
B.,
- i.
3.9.B.4 67 82 3.9.B.2 B3 1.0. B 56 83 F3.6.l 47 83 3.7.A.!.
48 83 3.7.A.l.d 65 B3 3.8 73 B3 5.0 3/4.7-20 3/4.7-21 3/4.7-28 3/4.7-29 3/4.7-9 3/4.9-4 3/4.9-4 I. (i-1 314.6-20 3/4.7-1 3/4.7-3 3/4.8-1 5-1 SB6T Testing is required of the SBST system following painting, fire or chemical release, but the a1ounts that would necessitate testing are not specified.
SBST Charcoal adsorber efficiency should be 99I instead of 90I.
Priaary Contain1ent This SR requires the "ain Stea* Isolation Valves to be tripped with reactor power LT soi of rated.
The surveillance can be perforaed at higher power.
Priaary Containaent The wording of this LCD on the te1perature limit for main steaeline air pilot valves is cu1berso1e and could be i1proved.
Also 3.7.D.6 could be reworded to follow the plant SD requirenents of 3.7.D.5.
Add 'isolation valve* after "main s teaml i ne *.
Pri Cont-Continuous The Continuous Leak Rate "onitor SR was deleted by QC.
Auxiliary Electrical The requirement that each 125 or 250 volt battery may be inop for 7 days per operating cycle for maintenance and testing needs to be changed to allow more flexibility.
Auxiliary Electrical With one DG inop, the operable 06 is tested at least once per day up to the allowed 7 day out of service tine.
D6 testing should be reduced.
Core Alteration Core Alteration definition does not allow noraal 1ove1ent of the SR"s, IR"s, T!Ps and special movable detectors.
X-axis should be Average Bulk "oderator Temperature for Dresden Units 2 and 3 TS.
Pri Cont-Suppression The 1axi1u1 and mini1u1 suppression pool water volume specified in the LCD need to be related to a water level and to the dp between the OW and Wetwel I.
Pri Cont-Suppresion Maxi1u1 and "ini1um downcomer subaergence is not directly 1easurable.
Radiological RETS needs to be reviewed versus latest NRC approved version to determine if i1prove1ents can be proposed.
Design Features The design features section needs to be reviewed to determine if any STS or later NRC approved changes at other plants can be 1ade for Dresden.
--~:. __ *~~-:~-------------------------------------*---------------------------------------------------------~:~:-----~------
!~
,Pill;,.
TS NUllBER TS PASE TS TITLE PROBLEll DESCRIPTION 74 B3 6.0 6-1 18 B3 F4.2.2 83/4.2-38 87 c
- 2. !.D 1/2.1-4 4 c 2.1. I 1/2.175 70 c
4.10.F.2 3/4.10-6 71 c
3.11 3/4.11-1 14 c T3.2.4 3/4.2-14 15 c T3.2.5 3/4.2-15 17 c
T4. 2.1 3/4.2-19 BO C
3.2.F.4 3/4.2-5 10 c 3.2.6.3
' 3/4.2-6 Ad1inistrative Surveillance The Ad1inistrative Controls section needs to be reviewed to deteraine if any STS or later NRC approved changes at other plants can be 1ade at Dresden.
Test interval versus syste1 unavailability curves are not used.
LSSS-ECCS Initiation The terminology should be changed from reactor "low* water level ECCS initiation to reactor 'low low" water level.
LSSS-Scram on Loss Spent Fuel Cask High Energy Piping Radioactive Liquid Radioactive Saseous Present wording describing Turbine Control Valve Fast Closure Scraa on loss of control oil pressure is not technically correct since the scram is initiated fro1 loss of EHC oil pressure and not fro1 valve movement.
The restrictions iaposed before August 30, 1976, are no longer applicable.
The High Energy Piping Integrity LCO and SRs were added to the TS to enhance the detection of piping system defects during plant operation.
These SRs were to continue until plant modifications were co1pleted.
"f' footnote indicates that flowrates are to be determined by appropriate pump curves.
This method is not used.
Hobile Voluae Reduction System !llVRSI is not being used at Dresden.
Generic-Surveillance The surveillance frequencies of "once every 18 1onths* and 'Refuel Outage* are confusing in that two ter1s are used to denote one intended frequency.
Radioactive Liquid Reference to Specification 6.6.B.2 should be changed to 6.6.B.
Radioactive Gaseous The wording "Exert best efforts* to return the radioactive gaseous effluent 1onitoring instruments to operable does not give specific, defined tasks to perfor1.
--~-:--=~~~-*-------------------------------------*---------------------------------------------------------~:~:-----~------
ID
.,P.~I:>-
TS NUl'IBER TS PASE TS TITLE PROBLEl'I DESCRIPTION
,I:
11 C
3.2.6.4.d 3/4.2-7 Radioactive Gaseous The require1ents of 3.2.6.4.d are redundant to the 26 c
3.3.E 3/4.3-12 Reactivity.Anomalies 27 c
4.3.6 3/4.3-13 Economic Generation 21 c
4.3.B. l.b 3/4.3-5 Control Rod
... ~
L:)
c 3.3.B.3.b 3/4.3-8 Rod Worth Minimizer 39 c
- 3. 5.F.1 3/4.5-11 l'lini1um Core and 32 c 3.5.A.7 3/4.5-4 Core Spray and LPCI 31 c
3.5.A.6 3/4.5-4 Containment Cooling 42 c 3.6.B. l 3/4.6-2 Pressurization 43 c 4.6.D.2 3/4.6-6 Reactor Coolant 82 c
3.6.E.1 3/4.6-7 Safety and Relief provisions contained in 3.8.A.1.a, b, and c.
3.2.6.4.d requires an orderly load reduction of the unit if the provisions of 3.8.A.1.a, b, or c cannot be 1et. HoMever, 3.8.A.1.c also requires the release rates to be decreased Mithout delay to bring the dose rates Mithin the limits. Change 6.6.B.2 to 6.6.B.
"Reportable occurrence* ter1inology is not correct.
The "E6CS operating para1eters 1 to be revieMed are not defined.
This surveillance requirement is Morded like a Bases and should be changed to reflect concise*
performable requirements.
Use of the ter1 'qualified technical person' is not consistent throughout the TS.
"Nuclear engineer~ is used in 3.3.B.3.b and "engineer" is used in 4.3.B.3.b.
LCD 3.5.F.1 is concerned Mith an inop diesel generator and actions* to be taken. This LCO should be in Section 3.9 on Auxiliary Electrical Systems.
The phrase 'the reactor may be placed in Refuel' is not technically correct.
The use of the term "Containm~nt cooling spray loops" does not explain if this is both DryMell and Torus Sprays.
Wording for this LCO is confusing in that it seems to require the reactor vessel to be vented at LT 149 degrees F. Deviation reports have been Mritten on this subject.
Also the requirement that Figure 3.6.1 be applicable through 6 effective full poMer years has been 1et and neM curves submitted.
This surveillance requirement is applicable until the recirc *piping indications have been resolved.
Resolution should be complete since Unit 3 replaced recirc piping and Unit 2 Ment Mith Meld overlay and hydrogen addition.
The terminology of solenoid activated pressure valves should be changed to solenoid activated pressure relief valves.
~
A Page 8
--:~*.. --~~--~~--------------------------------------------------------------------------------------------------------------
ID
,PRLi-TS NUMBEF:
TS PASE TS TITLE PROBLEM DESCRIPTION i.;J' 50 C
- 3.7.A.3 51 C
3.7.A.5.a 76 C
3.7~A.6.d 84 C
3.7.B 85 C
4.7.B.2.b 55 C
4.7.B.4 59 C
4.7.C.1.a 60 c 3.7.C.2 86 c T3. 7.1 66 c
4.9.A.1 68 c 3.9.B.2 5 c B.2.1.I 3/4.7-10 Pri Cont-Reactor 3/4.7-14 Pri Cont-Oxygen 3/4.7-17 Containment 3/4.7-19 SBST-Terminology 3/4.7-22 SBGT-Surveillance 3/4.7-23 SB5T 3/4. 7-26 Secondary Cont The Rx Bldg Vacuum Breakers are not specified as check valves or air operated valves in the LCO and SR.
Need to clarify the vacuua breaker ter1inology used in the TS.
The 4% oxygen concentration specified should be clarified to be 4% oxygen by volu1e.
LCD 3.7.A.6.d contains requireaents on the oxygen sampling system, but this LCD is located in the nitrogen purge LCO section.
Ter1inology of 'circuit' for SBST is 1isleading and could be confused for only the electrical.
circuit in the systea.
The SBGT surveillances are required at least once per operating cycle, but not to exceed 18 1onths.
This terminology excludes the 25! and 3.25 allowance for perforaing surveiilances.
The equipaent modifications to the SBGT. system as discussed in Note 1 on page 3/4.7-24 have been completed.
Preoperational secondary containment capability test per SR 4.7.C.1.a has been completed.
Additional first cycle tests per SR 4.7.C.1.b also have been co1pleted.
The one time exception in SR 4.7.C.l.d to allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period of Reactor operation has been used.
3/4.7-27 Secondary LCD 3.7.C.2 and SR 4.7.C.2 requirements on the doors of the core spray and and LPCI pump compartments are located in the Secondary Containment TS section.
3/4.7-31
.Primary Containment The Primary Containment Isolation valves listed on Table 3.7.1 eay not include all the valves listed in the FSAR as Primary Contain1ent Isolation valves.
3/4.9-1 Auxiliary Electrical SRs 4.9.A.1, 2 and 3 on Station Batteries do not line up with the Station Battery LCO.
3/4.9-4 Auxiliary Electfical The one time exception to allow coapletion of 1odifications to the 2/3 06 has been used.
B 112.1-16 LSSS-Bases-Scra1 on Title of LSSS Bases 2.1.l 'Turbine Control Valve Fast Closure Scra1 1 is not technically correct since the scra1 is initiated fro1 loss of EHC oil pressure. Scram setpoint of 900 psig is not explained very well.
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ID.
.PW" TS NU"BER TS PASE TS TITLE PROBLE" DESCRIPTION 8 C F4.1.1 B3i4.1-1B Surveillance The curves shown in Bases Figure 4.1.1 as a 83 C
83.6.F 83/4.6-30 88 R
3.S.F.4 3/4.S-12 Bases-Structural Graphical Aid.in the Selection of an Adequate Interval Between Tests are not used and are out.of date (see Ref. 6>.
The requirement to sub1it a program to the NRC after five years of operation, for in-service inspection, has been completed.
Nhen in Refuel the low press core and contain1ent cooling subsystems should be allowed to be inoperable, with a drained torus, as long as water level is 1aintained and provisions are taken to prevent draining the vessel. -0-