ML17201Q405
| ML17201Q405 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/31/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17201Q404 | List: |
| References | |
| 50-237-89-01, 50-237-89-1, 50-249-89-01, 50-249-89-1, NUDOCS 8904180078 | |
| Download: ML17201Q405 (34) | |
See also: IR 05000237/1989001
Text
SALP BOARD REPORT
'
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
. 237/89001; 249/89001 .*
Inspecti~n Report Nos~
Commonwealth Edison Company
Name of Licensee.
Dresden Station
Name of Facility
February 1, 1988, through Jan~ary 31, 1989
Assessment Period
8904180078 8~~37
ADOCK 0
PNU
G.
SAlP 8
TABLE OF CONTENT~
I.
INTRODUCTION
II .. SUMMARY OF RESULTS
A.
Overview
B..
Other Areas of Interest
I I I. CRIT~RIA
IV,
PERFORMANCE ANALYSIS
v.
A.
Plant Operations
B:
Radiological Co0trols
C.
M~intenance/Surveillance
D.
E.
Security
F.
- Engineering/Technical Support .
.
G.
Safety Assessment/Quality Verificat~on
SUPPORTING DATA AND SUMMARIES
A.
. Licensee Attivities
B. * Inspection Activities
C.
Escalated Enforcement Actions
D.
Confi~matory Action Letters (CALs)
E.
License Amendments Issued
F.
Review of Licensee Event Reports Submitted
by the Licensee
Page
1
3
3
3
4
6
6
9
. 11
No.
15
17 .
18
21
27
27
28
30
30
31
31
_,,.
'*
.:.
- .**:
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is ~n
integrated NRC staff effort to collect available observations and data
on a periodic basi~ and to evaluate licensee performance on the basis
of this information.
The program is .supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulati-0ns.
SALP is intende.d to be sufficiently diagnostic to provide a rational
basis for ~llocating NRC resources and to provide meaningful feedback
to the licensee's management regarding the NRC 1s assessment of their
facility's performance in each functional area~
An NRC ~ALP Board, composed ;f ihe staff members listed below, met on*
- March 22, 1989, to review the observations and data on performance,
and to assess licensee performance in accordance with the guidance
in NRC' Manual. Chapter 0516,
0 Systerriat i c Assessment of* Licensee
Performance.
11
The gUi da.nce and eva 1 uati on criteria are summarized in.
Section III of this report.
The Board's findings a'nd recommendations
were forwarded to.the NRC Regional Administrator for approval and
issuance.
This repor~'is the NRC 1 s asses~ment.of the licensee's safety perfdrmance
at the Dresden Station for the period February 1,
1988~ through
January 31, 1989.
SALP Board for Dresden Station SALP 8 assessment was composed of:.*
Name
- H. J. Miller
- C. E. Norelius
- W. L. Forney
E. M. McKenna
G. c. Wright
- L. R.
Greg~r
- J. J. Har.risen
- M. A. Ring
- F. J. Jablonski
- M. Phillips
M. Schumacher
J. Creed
- D. R. Muller
- B. I-. Siegel
- S. G. DuPont*
Tit 1 e
SALP.Board Chai~man, Director, Division
of Reactor Safety (DRS)
Deputy Regional Administrator
Deputy Director, Division of Reactor Projects,
(DRP)
Chief, Reactor. Projects Branch 1 (DRP)
Chief, Operations Branch (DRS)
-Chief, Reactor Programs Branch {DRSS)
Chi~f. Reacto~ P~ojects Section lB (DRP)
Chief, Reactor Projects Section 3B (DRP)
Chief, Maintenance and Outage Section (DRS)
Chief, Operational Programs Section (DRS)
Chief, Radiological Efflu~nts and Chemi~try *
Section (DRSS) *
.
.
Chief, Safeguards Section (DRSS)
Director of Project Directorate III-2, NRR
Project Manager, NRR
Dresden Senior Resident Inspector
,<J
Name
D. *E. Miller
T. J. Plosk.i
D. E. Jones
W. J. Kropp
T. Vandel
J. Holmes
D. Funk.
R. B .. Landsman
- Denotes voting members.
Title
Senior Radiation Specialist (DRSS)
Emergenty Preparedness Specialist (DRSS)
Project Inspector, Sectioh lB (DRP)
Rea~tor lnspector (DRS)
Reactor Inspector (DRS)
Reactor Inspector (DRS)*
Security Specialist (DRSS)
Reactor Engineer (DRP)
- Voting Security, R~diological Controls, Emergency Preparedness Only
- Voting M~intenance/Surveillance Only
- Voting Engineering/Technical Support Only
2
"II.
SUMMARY OF RESULTS
A.
Overview
Overall, the licensee's performance was found to be acceptable
and improved since the last SALP assess~ent period.
Of the .
. seven functional areas rated, during this assessment peri6d
licensee performance in four areas improved; Plant Operations
from a Category 2 and improving rating to a Category 1 rating,
Emergency Preparedness from a Category 2 and improving rating
to a Category 1 rating, Security from a Category 2 to a
Category 2 and improving, and Maintenance/Surveillan_ce from a
Category "3 rating in Maintenance to a Category 2 rating.
All of
the remaining functional areas sustained Categoty 2 ratings with
an improving trend noted in Safety Assessment/Quality Verification.
- .
.
-
.
.
Whi 1 e there has been performance* improvement, ; ncreased. management**
. attentio~ is needed in areas of identified weakness to.assure this
perform~nce is sustained.
For example, the NRC Ma{ntenance Team
Inspection (MTI) identified several areas requiring increased
management involvement, including:
the Electrical Preventive
Maintenance Program and the over a 11 trending of adverse system
equipment, and component performance.
The performance rat{ngs during the previous assessment period and
this assessment period according to functional area are given below:
Functional Area
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engi~eering/Techhical Support
Safety Assessment/Quality
Verification
N/R - Not Rated
8.
Other Areas of Interest
None;
3
Rating Last
Period
2
2
3/2
2
2 2*
N/R
Rating This
Period
- Trend
1
2
2
1
2
Improving
2
- 2
Improving
II.I. CRITERIA
Licensee pe~formance is assessed in selected functional areas.
Functional areas normally repres~nt areas signiffcant to nuclear
safety and the environment.
Some functional areas may not be assessed
because of little 6r no licens~e activities* or lack of meaniMgful
observations.
Special areas ~ay be added to highlight significant
observations.
The following. evaluation c~iteria were used to assess each functional
.area:
1.
Assurance of quality, including management involvement and
control;
2.
Apptoach to the resolutton of technical issues from a safety
standpoint;
3.
Responsiveness to NRC initiatives;
4.
Enforcement history;
5.
Operati9nal events (including response to, analyses of, reportfng
of, and corrective actions for);
6.
Staffing (including management); and
7.
Effectiveness of ~raining and qualification program.
Howev~r, the NRC is not limited to.these criteria and others may h~ve
been used where appropriate .
. On the basis of the NRC assessment, each functional area evaluated is
rated according to three performance categories.
The definitions of
these performance categories a~e as follows:
Category 1:
Licensee management attention and involvement are readily
evident and.place emphasis on superior-perfor~ance of nuclear safety
or safeguards ac~ivities, with .the resulting performance substantially
exceeding ~egulatory require~ents. Licensee resources are ample and
effectively used so that ~ high level of plant and persohnel
performance is being achieved.
Reduced NRC attention may be
appropriate.
Category 2:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good.
The
licensee has attained a level of performance above that needed to meet
regulatory requirements.
Licensee resources are adequate and
.
reasonably allocated so th~t good plant and personnel performance is
being achieved.
NRC attention ma~ be maintained at normal levels.
4
- .
.,
Category 3:
Licens~e managemeht attentioh to and involvement in
the performance of nuclear safety or safeguards activities are not
sufficient.
The licensee's *performan~e does not significantly exceed
that needed tp meet minimal regulatory requirements.
Licensee
resources appear to be strained or not effectively used.
NRC
attention should be increased above nor~al levels.
The SALP report may include an appraisal of the* performance. trend in a
functional area for use as a predictive indicator if near-te~m
performanc*e is of interest.
Licensee performance during the last
quarter of the assessment period shou'd be exa~ined to determine
whether a trend exists.
Normally, this performance trend should only
b~ used if both ~ definite trend is discernable and continuation of
the trend may result in a change in performance rating.
The trend, if used, is defined as:
- Improving~
Lic~nsee performance wai determined to be improving near
the close of the assessment period.
Declining:
Licensee performance was dete~mi~ed to be declining near
the close of the assessment period; and the.licensee had ncit taken
. meaningful steps ~o address this patte~n.
5
IV.
PERFORMANCE ANALYSIS
A.
Plant Operaticins
1.
Analysis
Evaluation of this functional area was.based on the. results
of nine inspections ccinducted by th~ resident and regional
insp~ctors and an emergency operating procedure (EOP) inspection
conducted by Region I.
Enforcement history in this functional area was good and indicated
an improvement in performance.
Two Severity Level IV violations
were identified durihg this assessment period compared with
one Seve~ity Level III and two Severity Level V violatitins
identifi.ed d~ring the previous assessment period.
During the
previous ass~ssment period, the Severity Level III violatio~ and
one of th~ Seve~ity level V violations w~re due to personnel*
errcirs; however, during this assessment period, no violations
due to personne 1 errors occurred.
One of the Severity Leve 1 IV
violations during this .assessment period was associated with*
outage activities. This activity was not evaluat~d in this.
functional area, but in the outage functional area during the
previous assessment period.
During this a~sessment period only one reactor scra~ occurred,
compa~ed with ten during the previous two*assess~ent periods~
indicating a significant improvement* in perfofmante.
With regard to this functional area, there was a positive trend
in both the total number of licensee ~vent.reports (LERs) issued
and the number att~ibuted to personnel error~ During this
assessme-nt period 11 LERs were issued that were attributed to
operations; of these 6nly 2 were attributed to personnel error.
During the previous assessment period, seven LERs were attributed
to personnel error.
Management attention and effort directed toward the reduction of
operational events was very good and significantly successful
. in reducing th~ number of scrams.
In addition to a reduction
- in the total number of reactor scrams, Dresden set a world
record for~ dual~unit boiling-water reactor (BWR) of 403 days
without a ~cram on either unit.
In July 1988, manag~ment
applied the lessons learned from the scram reduction program to
engineered safety feature (ESF) actuations.
Thfs ~ffort resulted
in ~-reduction in ESF ~ctuations from seven du~ing the first
half to fou~ durin~ the second half of the.assessment pe~iod.
The operating staff demonstrated e~cellent professionalism in
the control room and efficient supervision of plant activities
durin~ routine opera~ions and two refueling and maintenance
.6
outages.
The operating staff was directly and extensively
involved in the licensee's ongoing detailed control room
design review (DCRDR) program and the control room lighting
and ventilation modification.
The licensee has been successful
in achieving a black-board concept by reducing the total number
of annunci~tor alarms for both unit~ from an a~erage of 16
alarms per month during the previous period to only 2 per ~orith
- during the last half 6f-this assess~ent period.
Since August
1988, complete black-board c6nditions (zero annunciator alarms)
were achieved on each unit on several occasions.
Another
noticeable impro~ement was teamwork between the facility
department~. During the previous assessment period, the lack
of effective teamwork was noted as a major contributor to the
generally low morale and operational performance.
During the
curre~t Unit 2 .refueling outage, both the operations and
maintenance departments demonstrated superior teamwork.
This
was demonstrated by repair of the main service water system
isolation val~es. The service water system at Dresden is a
fully cross-connected system, and, as su~h, required both units
to be in an outage dufing the replacement of the isolation valves
and the development of an a1ternate cooling path to provide fuel
pool and shutdown cooling for both units.
The coordination and
planning efforts of onsite and corporate organizations resulted
in a well-controlled and trouble-free evolution that was completed
in a timely and safe manner.
Teamwork among operators was
also evidenced by performance during EOP inspection simul~tor
drills; notwithstanding problems identified with the procedures,
operators placed the plant in a known safe, stable condition
following simulated upsets.
Outing this assessment period, both units demonstrated significant
- improvements in plant operations ind safety.
Unit ~ had a
forced-outage rate of 0.1% and was available 78.9% of the tim~,
and Uriit 3 had a forced-outage rate of'0.0% and was available
71.5% of the time.
During the previous assessment period,
Unit 2 had a forced-outage rate of 8.5% and was available 61.0%
of the time, and Unit 3 had a forced-outage rate of 24.0% and
was available 75.3% of the time~ During this assessment period,
the facility experienced several deratings affecting availability
during the summer months because of the extreme drought and
severe temperatore conditions.
In addition to the improved
performance associated with the forced-outage rates and
availabilities~ the facility completed two continuous runs ~f.
dual-unit operation that lasted 156 and 111 d~ys. During the *
assessment period, two events occurred that were initially* *
classified as significant~*. Both of these ev~nts, the failure
of MSIVs to close during special testing and the Unit 2 excessive
drywell temperatures, were subsequently assessed by either a NRC
augmented or special inspection as having low safety significance.
Additionally, in the previous assessment period, there*were 12
safety system failures compared with 6 during this assessment.
Housekeeping conditions within the plant were good throughout
this period with a steady improving trend.
The control room
- also was subjected to a modification pr6gram that included
7
~ainting and color~cotje shading of panels to aid operators
in system identification ..
Management's inv~lvement in ensuring* quality in plant operatioris
was evident and good during this assessment period.
Management
inv6lvement has improved significantly compared with the previous
asses~m~nt period during which a Severity Level III violation
was identified that was attiibut~ble to the lack of effective
management involvement in routine operational activities.
During this assessment: period, two events occurred that were
. attributable to inadequate administrative controls: 'high
temperatures in the Unit 2 drywell and the inoperability of
the Regulatory Guide 1.97 primary oxygen monitor.
The high
temperatures in the Unit 2 drywell resulted from the use of
in~dequate operating procedures.
In both cases, management
aggressively reviewed the events and took immediate corrective
actions.
Frequent tontrol room observations and ~lant walkdowns
by management and supervisory staff, including attendance at
plan-of-the-day meetings and participation in. le~sons-learned
. and root-cause-analysis meetings, have resulted in effective
assurance of quality in plant operation a~d performance:
These
actions have reduced operational events, personnel errors, and.
inoperability of control room equipment, instrumentation, and
.
.
.
.
Managers take a conservative approach from a safety standpoint
- when. reiolvihg technical iisues and classifying operational
events such as the voluntary inoperability of _the high pressure
coolant injection system to conduct plahned preventive
maintenance.
The licensee has been very responsive to NRC. initiatives ..
Outing this assessment period, the licensee met frequently
with the.NRC to discuss improvement programs and task forces
responding to NRC initiatives,
An example of th~ resolution
of technical issues was the successful resolution during this
assessment period of NRC Diagnostic Evaluation Team (DET)
concerns related to plant operations.
.
Staffing for plant operations was very good with no violations
related to overtime requirements. *This was a specific problem
noted during the previous assessmerit period, resulting in a
violation regarding control of overtime.
The stafffng of t:he
operations department was maintained at an efficient level.
During this assessment period, the licensee added a nuclear*
station operator (NSO) to the contr~l room staff increasing
th~ control room staff to four NSOs, two shift foremen (SF), a.
8
Management was also directly involved in operator qualification.
Several
improvem~nts that resulted in an overall increase in
the quality of training were initiated during this assessment
period.
Both of two senior reactor operator (SRO) replacement
. candidat~s passed examinations during this as~essment period.
2.
Performance Rating
The licensee's performance is rated. Category 1 in.this area.
The licensee's performance was rate.d Category 2 in the
previous assessment period.
3.
Recommendations
None.
s:
Radiological Controls
1.
Analysis
Evaluation of this functional area was based on the results
of three inspections by regional specialists and observations
by the resident inspectors.
Enforcernent history improved during this assessment period;
One Severity Level JV violation was identified compared with
two violati6ns with possible escalat~d enforcement ramificati6n
du~ing the previous assessment period.
The violation. failu~e
to analyze ehvironmental sam¢les in 1986, reflected management.*
laxhy.but not programmatic breakdown.
-
Staffing remai~ed generally adequate.
Professional staff
stability ~ai improved and overall experience level has increas~d.
The chemistry and health physics functions were ~eparated into
two groups each reporting independently to the Assistant
Superintendent Technical Services.
Technicians no longer
rotate between the two groups and new*technicians are being
trained to supplement both groups.
All technicians are involved .
in a continuing training *program and will .be annually recertified
in their specialities~ Training for cohtract radiological
workers and technicians appears to need improvement based
on radiological performance problems occurring during the
most rec~nt o~tage:
. Management involvement in. ensuring quality was generally good
although supervisory weaknesses were noted during the outage
that.occurred near.the end. of the assessment.period.
Thi~
weakness was evidenced by an event involving internal
9
..
contamihation of three men performing work on Unit 2 feedwater
Reduction of outage duration may have been a
factor in this event and the lessened adherence by workers to
good health physics practices.
Good performance was noted in
licensee audits and responses, including the area of primary
chemistry which was assigned to an auditor who is well _
quilified by eduction, expe~ience, and training.
Cdrporate
- support and ~ssist~nce for the radiatibn protection program
remained.strong.
~he li~ensee's responsiveness to NRC i~itiatives was generally
good .. Licensee actions concerning the contamination survey
program, the investigation of events involving contamination
of personnel, and the.radwaste handling and packaging facilities
have re~ulted in
itjentif~able improvements in these areas.*
The licensee's approach to resolving radfol~gical technical
issues was generally timely and sound.
The total station
dose for 1988 (about 1405 person-rem) exceeded the station
goal (1260 person~rem) owing to unforeseen work ~uch as drywell
electrical cable repair and MSIP.
The dose was higher than
typical US BWRs but r~asonable because it included two major
r~fueling and maintenance outages.
Improvements during this
assessment period included the use of control rod drive shields
and removal/installation machines, ~nd increased use of mock-ups.
. The ALARA program appeared to be adequately implemented for
high dose rate, high dose, and critical path outage work:
However, for other radiologi~al work, adequate notice was not
always provided to ALARA personnel and therefore, extensive*
ALARA reviews were not always made.
Also, tool equipment, and
staging requirements are not always included in ~ainte~ance
procedures to ensure that wor~ performed in radiological areas
is efficiently performed.
Personal contamination events have
continued to decrease, and are no longer excessive.
The extent
of contaminated areas was considered low.
No unplanned liquid or gaseous releases were reported, Through
licensee efforts, the volume of radwa~te generated this period
has been reduced as has the backlog of radwaste awaiting
packaging and shipping.
However, contaminated soil from
past years remains onsite with no disposition established.
The.re were no transportation incidents.
Results of the radiological confirmatory measurements were
very good with only 1 disagreement in 75 comparisons made on
. six routinely used measurements* and one Post Accident
measurement.
2.
Performance Rating
The licensee's performan~e is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous
assessment period.
10
3.
Reco1T111endations
None.*
C.
Maintenance/Surveillance
L
Analysis
Evaluation of this functional area was based on the results
of eight routine inspections perfonned by the resident inspectors,
three routine inspections by regional inspeetors, a special NRC
augmented inspection team (AIT) inspection, and a maintenance
team inspection (MTI)~ Maintenance and surveillance were
.separate functional areas in the previous assessment period, but
have been combined as one functional area for this asse~sment.
Enforcement history indicated a decline in performance.
Three
Severity Level iV and one Severity Level V violations were
identified during this assessment period.
No violations were
identified in the chemistry area.
The MTI identified two
additional violations but had not determined the severity
levels during this assessment.
During the previous assessment
period, there weie no violations in the maintenance area and one
deviation in the *surveillance area .. However, two of the Severity
Level IV violations issued during this assessment period were
addressed during the previous assessment period.
Additionally~
the increase i.n the total number of violations refletted the
increased attention to this functional area by the resident
and regional inspectors.
Only one surveillance specified by the Technical Specifications
was missed during this assessment period compared with three .
during the previous period.
The licensee detected a deficiency
in the scram testing pro.cedure for Unit 2 that invalidated the
previous scram insertion timing data for five control rod drives
(CRDs).
The licensee imnediately .revised the procedure and
retested the affected CRDs.
The affected CRDs were within the
required Te~hnical Specification insertion times and had n6
resulting safety significance.
During this assessment peri-0d, one operational event was* attributed
to ~ither maintenah~e or surveillance activities compared with
eight during the previous assessment period.
The Unit 2 main
steam isolation valves (MSIVs) failed to close during a special
test. This event .resulted in the only forced outage relating*.
to Unit 2.
The NRC initiated an AIT and issued.a Confirmatory
Action Letter (CAL) relating to the licensee's corrective
actfons. The AIT detennined that the event was of minor safety
. significance and that the root-cause of the MSIVs' failure to
close was the excessive friction forces induced by overadjustments
of the tightness of the Chevron-type valve packing.
11
During this assessment period-, the licensee issued 21 LERs
felated to this functional area compared with 30 during the
pievious as~essment period.
During the previous assessment
period, 22 LERs attributed to component or equipment failure
indicated a weak preventive maintenance program~ During this
assessment ~eriod 15 LERs attributed t6_tomponent or_eq~ipment
failufes indicated a slight improvement in the effectiveness of
preveniive ~ainten~nce. Additionally, ~ix failures of the hi~h
pressure coolant injection (HPCI) system were identified duri~g
the previous assessment period compared with only one failure
during this period.
There were no reactor scrams attributed to
surv~illance or maintenance attivities during this assessment
period compared with six during the previous assessment period.
During the-previb~s assessment period, sev~ral weaknesse~ were
observed in the maintenance. area including incomplete maintenance
improvement and preventive maintenartce prog~ams, the number of
reactor icrams caused by maintenance errors, and the number of
plant oil and water leaks.
Specific problems noted were:
problems with the root-cause and failure analysis, the trending
of component faiiures, the lubrication and oil analysis, and the
number of failures associated with the HPCI and feedwater systems.
During this assessment period, the lic_ensee was very responsive
to NRC concerns to identify and correct programmatic and
procedural defic1eni:ies in this functional area by initiating
a M~intenance Improvement Program (MIP).
These actions resulted.
in noticeable improvements in plant perfor~ance, reliability,
and safety.
A noticeable improvement was the implementation of
the Model
Syst~m concept.
On the basis of a time series analysis
its importance arid historical high failure rate.
During this
assessment period, the HPCI system performance improved with
only one failure.
Another significant improvement was the
intre~sed reliability and safety of the station emergency*
diesel generators, which during the previous assessment peri~d;
had a tumulative unavailability factor of 4.5% comp~red-with
0.5% during this assessment .period.
Development of the new
inservice testing (IST) progfam issued on April 15, 1988, was
in exam~l~ of another noticeable improvement.
The program
resolved concerns identified during the 1987 NRC DET.
The MTI found that management was vigorously involved with
the MIP.* The current eff~ctiveness of the MIP was due, in part,
to the periodic assessments.by corporate evaluators and subsequent
implementation of corrective actions at the station.
Other
examples of management's effectiveness intluded the establishment
of a clear long-range maintenan_ce plan, "Conduct of Maintenance
Program," the upgrading of systems that were performing poorly,
and overall improvements in maintenance procedures.
Improvement
was rioted by the reduced number of LERs, low forced-outage rate,
12
and increased reliability of systems.
The MTI found the quality.
of the motor-operated valve (MOV) procedures and the writers
guide for procedures to be strengths.
Additionally, several
attributes of the preventive maintenance program were considered
to be very good, such as the trending of instrument setpoint
drift, overall preventive .maintenance of the security systems,
the MOV program, and activities asso~iated with the safety
relief valves.
However, *the team also f6urid several areas
it considered weak and still in need of increased management
involvement.
These areas were preventive maintenance for
250-vdc motor control centers and 4.16-kV circuit breakers,
establish~ent of additional effective maintenance performance
indicators, completiori of system walkdowns for establishing
as-built conditions, compilation o1 usable machinery histories,
~nd establishment of an effective trending program.
Maintenance staffing appeared adequate as evidenced by the.
manageable size of the maintenance wo~k request backlog~ Based
- on a .review of licensee records, the inspectors determined that
open non outage Corrective Maintenance Work Requests (CMWRs)
decreased from about 1300 in January 1988 to 938 on January 2~,
1989.
There had bee~ a decreasing trend throughout most of the
year.
Development of the MOV team concept was an excellent
example of the use of maintenance staff to effectively complet~
maint~nance activities .. The aggressive management of the
backlog of maintenance work requests, the lbw number of forced
outages du~ to equipmerit. failures, and the overall plant
forced-outage rate indicated that the overall performance of
maintenance at Dresden wa~ good.
The backlog o~ maintenance
work requests was considered low and manageable.
The number of
work requests affecting activities in the control room was ~lso
considered low and manageable.
Ai noted in the Plant
Operations section, the number of forced outages due to
equipment failure was small and the overall forced-outage rate*
of 1ess than 0.1% was ve~y good.
The mechanical and instrumentation maintenance staffs were
considered effective, but the electrical maintenance staff
appeared weak.
Staffi~g levels and qualification~ were adequate
to implement the routine chemistry programs.
The management
for the chemistry group was extensively reorganized during this -
period, and the chemistry supervisor now reports directly to an
assistant superintendent.
The technicians ho longer perform
both radiation protection and chemistry functions .. The
techhicians were all qualified under American National
Standards Institute Standard Nl8.l-1971.
Mainten*ance training and the qualification program for the
station maintenance staff were considered very effective.
teams received excellent training and acquired a high level of
expertise.
The use of a maintenance personnel qualification
matrix, mockups, and photographs of the actual work.area and
components contributed to this effectiveness.
13
The licensee's quality control organization was effective in
identifying problems in mechanical and instrument maintenance
acti~ities, but was less effective in electrical maintenance.
Because of the inconsistent use of the deficiency identification
program, the licensee was not totally eff~ctive in ensuring that
plant material deficiencies were identified.
The inconsistent
use of the program aiso placed an additional burden on the
maintenance staff be~ause a high percentage of ~ork requ~sis
were duplfcated and there was~ general inability to fully
assess the material condition of various systems and equipment.
This was considered a weakness in both the identification and
trending of plant material defici~ncies, even though no actual
concern about the operability of the systems and equipment *
existed.
Licensee manageme~t involvement in en~urihg qualit~ in the area
of chemistry was miXed .. The water chemistry program conformed
with the Electri~ Power Research Instit~te (EPRI) BWR Owners
Chemistry Guidelines, and licensee data indicated that water
chemistry variables were under good control.
The makeup water
system is being rebuilt to improve the quality and quantity of
makeup water.
The.1i~ensee injects hydtogen into the Unit 2 *
primary water to improve water chemistry.
However,
th~s program
appeared deficient in that the licensee had not been able to*
optimize the hydrogen flow to balance cdrrosiveness against
increased radiation .. levels (ALARA) because the electrochemical
potential (ECP) m6nitor (which estimates corrosiv~ness) was .ndt
operational and had not been for about two year~. The licens~e
~as planning to install a ne~ monitor, but it will not be
operational for ~bout another 18 months.
The. licensee's response to NRC initiatives. in the chemistry.
area was good.
The licensee has been receptive to the_NRC
nonradiological confirmatory measurements program and is *
impr6ving the quality assurance/quality tontrol (QA/QC)
program in the laboratory.
The laboratory facilities were recently refurbished, and
state-of-the-art instrumentation, including four computer-controlled
ion chromatographs for low-level trace materials analyses have
been added.
The quality of the nonradiological confirmatory
measurements co~parisons declined with only 11 of 26 initial
analyses in agreement (42%), compared with the previous year's
rate of 89% agreement.
The disagreements appeared to be due
mainly to deficiencies in the procedures for preparatio~ of.
calibration and check standards, which the licensee corrected
in a timely manner.
The licensee achieved all agreements in
seven split samples compared with Brookhaven National
Laboratory.
14
2.
Performanc~ Rating
The licensee's perfo~m~nce is rated Category 2 in this area.
The licensee's performance was rated Category 3 in.the
maintenance fun ct i ona l area and. Category 2 in the* su.rvei 11 ance
- functional area in the previous asiessment period.
3.
Recommendations
None.
D. * Em~rgency Prepar~dness *
1.
. Analysis
Evaluation of this funct~orial area was based on t~o inspectioris
conducted by regional inspectors. These inspections were an
exe~~ise observation and a routine inspection of the p~ogra~.
During this assessment period, enforcements history.improved in
that no violations of NRC requirements were identified,
compared with one violation identified during the previous
assessment period.
Management involvement in ensuring quality was good.
An indepth
evaiuation of the onsite program in May 1988 by corporate staff
and several emergency planning.specialists from other nuclear
stations identified a number of progr~mmatic improvements.
These improvements were complete or underway by the end of this
assessment period.
The principal improvement resulting from
this self-evaluation was the tomplete rewrite and expansion of
the emergency plan implementing procedu~es (EPIPs), which* are
scheduled for completion in the next SALP period.
The licensee's approach to resolving technic~l issues was good,
T~e station's tracking system was used effectively to track
.progress on items identified during NRC inspections, the
corporate evaluation of the program, ~uality assu~ance audits,
and drill critiques. All required emerg~ncy preparedness
drills, ~quipment tests, and supply inventories were completed
as scheduled during this assessment period.
A complete ~et of
upgraded EALs has b~en developed as part c:if a long-te~m project
to correct inconsistencies i~ the organization and interpretation*
of EALs in use at all of the licensee's nuclear station~.
.
Another potential problem was resolved with the de~elop~ent and
successful ~ompletion of surveillance procedures for the
Technical Support Center's ventilation and radiation monitoring
system.
The emergency response organization has re~ained well staffed,
with nc:i individual holding multiple positions.
Primary and
15
support- positions remained well defined.
Successful, quarterly*
off-hours drills demonstrated that the licensee was able to
augment onshift personnel in a timely manner.
A part-time
interi~ emergency planning c~ordinator was appointed to manage
the program while the regular coordinator was unavai]a~le because
of a lengthy illness. A full-time aide was ap~ointe~ after the
regular coordinator returned to work in the Spring of 1988.
The onsite emergency preparedness training program has remained
clearly defined.
Recordkeeping was improved during this
assessment period.
Lesson plans and oth~r training materials
were being revised as a result of the ongoing EPIP revision
project.
lnterviews with a small sample of members of ~he
emergency organization indicated some minor weaknesses
concerning emergency preparedness training for persons who
cou.ld be assigned .to inplant repair teams;_however, the' overall
performance during these intervtews and the March 1988 exercise
indicated that training of the on~ite emergency response
organization was good.
The licensee's respons~veness to NRC initiatives has generally
been good.
The 1988 scenario addressed the items identified
during the previous exercBe.
One Emergency Ac-tion Level (EAL}
was adequately revised to resolve a relatively longstanding
co~cern regarding t~e notification of State and NRC offtciils
. in the event of an onsite fire.
Onshift personnel activated the emergency plan* on ~ight
occasions during 1988.
All situations were properly
classified, State and NRC -0fficials were always notified within
the regulatory time limits.
Licensee evaluatioris of r~cords
generated during these activations were well done.
The March 1988 utility-only exercise involved a hi~h-quality
scenario that was challehging and addressed the few
deficiencie~ that were identified during the previous
exercise.
Overall performance during the exercise was good,
with only a few w~aknesses identified.
These included a poor
demon~tration of collecting, bagging and labeling of smear
samples, and s~owness in the evaluation and iricorporatiori of
meteorological information into the protective action
decisionmaking process.
Although these weaknesses are not
normally indicative of good performance, the high-quality and
challenging scenario that played a role in identifying these
program deficiencies reflect strong management initiatives t6
enhance their response capabilities.
2.
Performance Rating
The licensee's performance is rated Category 1 in this area.
The 1 i cen se-e 1 ~-performance was rated Category 2 and improving
in the previous assessment period.
16
3.
Recom~endations
None.
E.
Security
1.
Analysis
Evaluation of this functional area was based on the results
of two routine inspections and one reactive inspection conducted
by regional physical security inspectors and by the resident
inspectors' routine observations of security activities.
"The enforcement hi story represented an improvement i f'.I the
licensee's performance.
Two S~verity Level IV violations
were identified during.the a~sessment period.
Bot~ violation~
occurred within the {irSt half of the assessment period.
One
Severity Level III and two Severity Le~el IV violations were
noted during the previous assessment period.
One violation.
during this assessment period was issued for the failure to
ensure positive access control, and the second violation was
issued for.the failure to conduct an adequate ingress search.
Although the security ~anagement staff initiated effective
and timely corrective actinhs, the violati6ns reflected
~eakriess in the licensee's program.
Security events reported under 10 CFR 73.71 were properly*
identified and analyzed.
~bwever, a generic concern with the
nonconservative reporting of loggable events remains open at
the corporate level .. The licensee had one reportable security
event during ~he* assessment period which involved the failure
of an individual .to declare a weapon during ingress screening.
Management involvement in assuring quality has improved during
this assessment period.
This was demonstrated by the licensee's
development and successful. implementation of both a perforMance
indicator program and preventive maintenance program.
Management
was actively involved in root-cause analysis and the mbnitoring
of performance trends and, as a result, there were very few
outstanding security issues.
However, several weaknesses in
"the area of access control e~isted throughout the period.
.
.
.
The pr~vious.assessment was critical of the adequacy of the
annual quality assurance security audit.
Thi~ issue.has been
resolved.
The lastannual audit was both thorough and
performance based.
Respbnsiveness to.NRC concerns ~as developed i~to a strength
of the security pr6gra~. Enforcement i~sues, licensing matters,
and inspection findings were addressed in a timely manner and
r~solved in a technically competent fashion.
Communications
- 17
with NRC Region III staff have been frequent and effective,.
and the Security Director has developed an awareness of issues
of regulatory interest.
Although an allegati6n of excessive
overtime was substantiated, the licensee efficiently and
effectively addressed NRC concerns.
Staffing was ~ppropriate. Although the security cbntractor
was changed during -this assessment period, the transition was
well planned and coordinated with no adverse security affects.
Positions and responsibilities within the licensee and contract6r
security organization ~ere well defined.
The licensee added an
additional position to the training staff.
The individual is
responsible fo.r collecting, analyzing, and disseminating security
data.
The analysis has enhanced the proactiveness of the
security program through the early identificatibn of potential
prob 1 ems.
The licensee's security force was adequately supervised and
triined.
Generally, the licensee's proced~ral guidance for
the security for~e was sufficiently detailed to ensure that
personnel ar~ knowledgeable of their responsibilities.
The
training and qualification program used by the licensee was
. considered acceptable and met the 1icen~ee's commitments.
The tacticil contingency traihing program developed in r~sponse
to the upcoming regulatory effectivene~s review exceeded the
licens~e's commitment.
2..
Performance Rating
The licensee's peiformance was rated Category 2 with ah
improving trend in this area.
The licensee's performance
was rated Category 2 in the previous assessment -period.*
3.
Recommendations
None.
F.
Engine~ring/Techhical S~pport
1.
Analysis
Evaluation of this functional area wa$ ba~ed on the results
of four rout.ine inspections by regional inspectors, several
inspections by the resident inspectors, a Maintenance Team
Inspection (MT!), a Region I team inspection of EOPs ahd an
NRR special team inspection to review licensee corrective
actions regarding the safety system outage modification
inspection (SSOMI).
Enforcement history during this assessment period declined
slightly. Three Severity Level IV violations were identified
18 .
'
)
during this assessment period compared with two Severity Level IV
violations identified during the previous assessment period.
The three ~i6lation~ reflected a weakness in the implementation
of the fire protection program.
Three design-error LERs
attributabl~ to this area were issued during this assessment
period* compared to nine duririg the previous assessment ..
Manag~ment involvement to ensure quality was mixed .. Management
and the e~gineering staff have taken sigriificant actions to
improve quality and saf~ty. During this assessme~t period,
the Jicensee initiated a system engineering concept that led
to the use of, in addition to system engineers, operations
department personnel as cognizant individual~ for each system.
The new concept has been effective in developing teamwork and
in promoting the exchange of information between the oper~ting
and technical depart~ents. The effectiveness of the sy~tem
engin~ering concept has not been totally ~ffective because of
the relatively recent implementation and the less than full
usage of the concept.
The licensee has corrected a weakness identified in the previous
assessment period dealing with the timeliness of support for
modification work as evidenced by the fact that most of the
engineering ~a~ completed several mbnths-before the outage.
In addition, most of the deficiencies identified during the
SSOMI were resolved.
Adequ~te planning _and assign~ent of
priorities were evident throughout the ~curse of the cor~ective
~ction programs that addressed the deficienci~s in drywell
structural steel connections, embedded plate_ anchor straps,
and flued head anchor structures.
Exampl~s of less tha~ adequate perfor~ance in~ol~ed commercial
grade dedication and fire protection.
The dedication of
commercial-g~ade components for safety~r~lated applications
consisted mainly of a review of purchasing specifications
and the use of vendors' certificates of conformance.
The
engineering staff was not identifying critical. characteristics
for component~ installed~ nor were appropriate receipt insp!ction
requifements specified.
Similafly, activities associated with
the fire protection area have b~en weak.
For example,
administrattve controls for comb~stible. materials and for
cutting and welding were not eff~ttive. The latter resulted*
in a fire in the Unit 3 drywell expansion gap.
The licensee's approach to the identification and resolutiori
of technical issues was mixed.
In most cases, the licensee
used conservative approaches to resolve pciteritially safety-
significant problems.
When specific problems arose, the
licensee conducted comprehensive reviews.to determine generic
appli~ability. An example of this was the eff6rt im~lemented
at Dresden as a result of the grounding fault identified at
19
Quad Cities.
The engineering and safety evaluations prepared
for most modifications were thorough* and technically sound.
The licensee's action to correct the swing bus transfef design
deficiency was technically ~cceptable. Engineering and
technicil support staff provided prompt, technically complete
res6lution of issues su~h as integranular stress cor~osjon
cracking (IGSCC), high drywell temperature, and the main
steam isolation valves failures.
.
Although most of the root-cause determinations by the engineering
staff have been effective, the total effectiveness of root-cause
. determinations still needs improvement.
As previously stated,
the MTI team identified two Deviation Reports (DVRs) regarding
the 4.16 kV breakers and the 250 volt DC system in which the
failure to adequately-address the ro6~ causes resulted in a*
failure to resolve potentially significant prob)ems.
Because of
the inconsistent documentation of initial failu~e conditions,
many of the failure evaluations may not'be valid. -During its
- -inspection, the EOP team found deficiencies associated with the
control of procedural deviations from the BWR Owners Group
guidelines and the Dresden-specific guidelines without apparent
documented justification.
Most of these deficiencies were noted
because engineeiing calculations supporting the procedural
assumptions were lacking.
These deficiencies were subsequently
reiol~ed when c6rporate engineering staff provided the engineering
justificitioris and as such, are considered to be programmatic in
nature.
The EO~ team also concluded that the actual performance
of the procedures would mitigate the ~lant upset conditions and
place the plant in a known safe, stable condition.
Additionally,
the licensee aggressively upgraded the EOP program a~d the
Unit 2 control room and simulator to acc6mmodate human factors.
The licensee's responsiveness toNRC initiatives was good.
The onsite engineering a~d technical support staffs were
instrumental in helping the licensee provide prompt responses td
technical, safety, and licens~ng concerns.
The engineering and
technical support staffs also demonstrated good responsiveness
dufing the failure of the main steam isol~tion valves (MSIVs)
to close and*the high.drywell temperature event.
The staffing of the onsite engineering and technical support
groups is consider-e.d to be adequate.
In response to problems
identified in the previous periods, the licensee has increased
the engineeririg and technical staffs.
In addition, the
technical staff was reorganized and a system engineering
co~cept was implemented as previously discu~sed. Onsite
engineering personnel have increased their involvement either
by performing more evaluations, such as that of the failure of
the MSIVs to close, or by performing parallel evaluations, suc.h
as that of the high drywell temperature event.
Although this *
indicates an improvement over the practices noted during previous
20
as~essments, the licensee continues to rely almost exclusively
on outside engineering consultants w~thout positive oversight
control for many of the complex ~ngineering evaluations;
including all aspects of design and analysis of plant
modifications.
This r~liance on contracto~s without technical
Oversight appears to have coritributed to the 4-month deJay in-
recognizing modification deficiencies ~n the flued head anchor
- structures.
Th~re appeared to be a lack of technical involvement
between the licensee's BWR engineering- staff and consultants
performing the design and analysis work.
The effectiveness of the training and qualification of personnel
in this functional area was adequate.
Observations of
modification installation and testing and discussiohs with
technical personnel showed that an adequate level of knowledge
to perform their assigned tasks had been attained.
When
complex engineering activities were undertaken, licensee
engineering personnel often referr~d the~e activities to
outside contr~ctors.
2.
Performance Rating
The 1icensee's performance is rated Category 2 in this area.
The licensee's performancewas rated Category 2 during the
previous assessment period.
3.
Recommendations
None.
G.
Safety Assessment/Quality Verification
1.
Analysis
This is a new functional area and inco~porates many of the
activities reported under the functional a~eas of quality
programs and.administrative controls affecting quality and
licensing activities in previous repo~ts. Evaluation bf this
functional area was based on the result~ of routine inspections
conducted by the resident and regional inspectors, an emergency
bperating procedures (£0~) inspection, and a maintenance team
inspection.
In addition, NRC staff revie~ of licensee submittals
and requests for amendments to the operating license.were
considered.
Enforcement hfstory in this functio~al area was good with only
one Severity Level IV violation. *This is an improvement compared
with a Severity Level III and Severity Level Vin the similar
functional area during the previous assessment period.
The
v~olatioh no~ed during thi~ assessment period was associated
with inadequate auditing *Of the EOPs.
During the NRC EOP
21
inspection, the team found that the results of the initial
quality assurance revfew of the ~OPs were not incorporat~d
into the final EOP product and that subsequent audits were
not performed.
This .was the only violation associated with
the EOP~, .and it was promptly corrected.
Manigement has taken significant actibns to improve quality and
safety.
In respohse tb problems identified in the previous
assessment period, the 1.icensee iniiiated the Dresden Station.
lmpr6vement Plan (DSIP) during this assessment period.
The
DSIP was instrumental in providing viable goals and actions.
The DSIP consolidated management efforts ~nto a singular
.
direction for station improvements by delineating responsibilities,
accountability, actions, and progr~ss trending.
M~ny of the
improvements, such as reduced reactor scrams and ESF actuations,
~ffective inservice testing (!ST) programs; time serie~ analyses
of system performanc~, motor operator overhaul program, and
facility improvements, were directly affected by the DSIP.
The DSIP also was instrumental in improvihg performance such
as safety system failures, forced..:outage rates due to component
failures, and entry into limiting conditions for operation.
These actions a~d improvements have met the licensee's commitments
in response to the NRC DET findings to improve quality and
safety.
The licensee's response to the NRC initiatives
associated with the EOPs was also considered to be good
as evidenced by its prompt correction of the identified
short- and long-term concerns during this assessment.
Management's high level of attention and com~itment in the
area of training *and qualification has resulted in significant
improvements and changes in the lic~nsee's program.
These-
included increased simulator training, increasing the
plant~specific knowledge of classroom and simulator instructo~s.*
and use of the tea~ concept during simulator training.
Most
noticeabl~ was ~he licensee's approach to realism during simulator
training by requiring notification prior to the SE's respon~e.
The licensee also has increasingly emphasized training by
requir1ng 100% attendance and implementing required makeup
. training for any training that was missed.
The simulator al~o
has been extensively upgraded to ensur~ that it. reflects the
"as-built" condition of the plant.
The licensee's responsiveness to NRC initiatives was prompt and
timely for bulletins, generic lette~s. special inspecti6ns~ and
non-:obligatory surveys and studies. *The corporate office and
- station made their most knowledgeable people available to assist
the NRC and its contractors.
Only a few longstanding* regulatory
issues remain that can be attri.butable to the licens~e. The
licensee has greitly reduced the number of these issues during
~his assessment period.
An example of this is the resolution of
approximately 380 inspection findings within ~he last 2 years
22
and the reduction of the outstandin[ findings to a manageable
100 items.
Although the licensee has, on occasion, requested
time extensions for responding to regulatoty actions, it has
ge~erally been to allow for the opportunity to produce~ better.
prod~ct than allowed by the ori~inal schedule.
During the assessment period, the licensee anticipated several
regulatory initiatives and maintained an awareness of operational.
experience in the industry.
This was indicated by the licensee's
prompt evaluation of a 10 CFR Part 21 associated with Power
Converiion Company battery chargers used at the Commanche Peak
facility and the rapid issuance of an operating directive based
on the industry study of neutron flux oscillations: Additionally,
the *licensee was prompt in addres~in~ NRC initiatives at other
facilities, such as the Vermont Yankee neutron flux os~illation
- and the Pilgrim reactor neutron building vacuum breakefs.
Another example was the r~cent concern with the torus to reactor
- building vac~um breakers at the Pilgrim facility .. The licensee
actively responded to information relating to the instrument air
problems associated with.the v~cuum breakers by forming a task
force.
Because of this, ~he l~censee was abl~ to rapidly
address the concerns of the NRC before a bulletin was issued.
The licensee has also used experience gained by various site
visits to other facilities.
Based upon these experiences, the
licensee initiated several i~provements such as, a recorded
morning status repott to minimize inquiries into the control
room, an area status map used within the plant to _indicate the
location of import~nt equipment and radiological conditions,
and the application of a floor sealant that has reduced
decontamination efforts.
There are still some weaknesses in
incorporating experiences outside the Dresden Station.
One
example is the failure to perform effective preventi~e
maintenance on 4.16kv breaker~ in light of recent problems
identified at Quad Cities by the NRC and the licensee.
The licensee has performed a significant number of self-
ass~ssments (16) during this assessment period .. The li~e~see
also participated in several Institute for Nuclear Power
Operatiori (INPO) assisted evaluations and initiated a self SALP
type concept conducted by an outside independent tonsultant.
The licensee also conducted a sec6nd safety system functional.
inspeciion (SSFI) of the Unit 2 high pressure coolant injection
(HPCI) system which increased reliability of the HPCI system.
Anothe~ self-assessment r~sulted in imp~6ved reliability and
safety of the station emergency diesel generators.
During this assessment period, the offsite nuclear safety
organization met with Dresden management every quarter arid
reviewed the ~ffectiveriess of corrective actions associated
with nonrouti~e e~ents. These reviews have been effective in
evaluating the licensee~s cor~e~tive actions.
Onsite safety
reviews have alSo resulted in correcting many long:--term .
deficiencie's at the facility by directing the control room and
- . .-: -
panel modifications, reducing the occurrence of reactor scrams
23
a~ a result of past problems, ah~ providing a preventive
maintenance program for security equipment and components.
These reviews have also in addressed and resolved many of the
deficiencies that had been identified at other facilities.
Th~ licensee ~emonstrated an active ?pproach tb identifyihg and
~esol~ing technical issues. from a ~af~ty standpoint.
Exam~les
of this were the rapid development of an investigation team
during the Unit 2 MSIVs failures and the timely r~solution
of the problem.
During this event, the licensee sought and
received assistance from their onsite and offsite engineering
including the manufacturers of the components involved or
suspected to be
involv~d with the event.
The
lit~nsee provided
prompt notification to other facilities of the failure and *
cause of the failure of the MSIV eve~t thrbugh the INPO
notification reportin~.systems.
During this assessment period, NRR issued seveh Technical
Spetification (TS) amendments for both Unit 2 and Unit 3.
Additionally, six safety evaluations were issued on vario.us
safety-significant ~ssues. The most important of these lic~nsing
- issu~~ and TS amendments included those peftaining to
Appendix R exempt~on retjuests~ rel6ad submittals; IST reliefs;
emergency core cooling system (ECCS) o*perability requirements;
Regulatory Guide. i.97; and diesel generator testing.
The
licensee a~d its contractors demonstrated a clear undirstanding
of the compl~x technical and safety issues associated with these
- licensing and regulato~y actions .. Although the technical
.. approaches were generally sound and comprehensive, management's
att~ntion to the resolution rif th~se issues has not resulted in*
consistent performance in accordance with regul~tions.
On the
_positive side, most notably the fire protection (Appendix R)
exemption and the reload submittals, a high level of management
attention resulted in strong performance .. The licensee did
an excellent job of discussing issues in a clear and complete
manner in its reload submittals and of acknowl~dging previous
safety evaluation report (SER) topi~s. The Appendix R revi~w
involved complex issues of protection for safe shutdown
components and systems that were located in many separate
areas of several buildings throughout the plant. The licensee
promptly responded to NRC requests for additional iriformation
or clarif1cation by providing answers that were complete and
demonstrated good attention to the issues.
The good technical
support for these exemption requests and the smooth interaction
with the*NRC was evidence that manage~ent was continuously
i.nvolved at a high level~ During the*previous ~ssessment
period, this was noted as a weakness in management inv6l~em~nt.
By contrast, for other reviews such as the anticipated transient
without* scram (ATWS) rule, alternate safe shutdown, flued heads,
24
and. monitorin~ of de voltage systems; the initial submittals
did not contain a clear and compl~te discussion of the issues.
These submittals required additional information.
Sevetal of
these issues ~ave taken more than a reasonable time to resolve,
which indicates tha~ additional management involvement is still
needed to provide consistent licensing performance for _all
issues.
.
.
Management's support of quality assurance (QA) activities was
evident.
The licensee's site QA organization is professionally
organized and staffed.
As was noted in the pr~vious a~sessment
period, the licensee'.s QA organization is committed to the
evaluation of operational activities by having QA engineers
maintaining senior reactor operator (SRO) licenses_ This, in
addition to station management's involv~ment, has tesulted in
an overall improvement in plant performance.
QA engineers
provided extensive surveillance coverage (including off~shifts
and weekends) during both refueling outages, the dual-unit
outage for maintenance on the service water system, startup,
and plant operating periods.
Specifically noteworthy were QA
ve0ification activities in plant improvement programs, including
corrective actions associated with the findings of the NRC
diagnostic evaluation team, implementation of the DSIP, and
the IST program.
The site QA organization is functibnall~
inde~endent, asseitive, and effective in the identification and
r~solution of quality concerns such as those associated with a
~o~tractor, used at both the Quad Cities and Dresden facilities,
and a shipping concern associated with the transport of a sealed
source between the Zion and Dresd~n faciliti~s. In both of these
events, the site QA organization was instrumental in identifying,
resolving, and providing prompt notification of the concerns to
the NRC resident staff,
QA personnel were actively involved in
the licensee's process for id~ntifying and resolving problems.
Audits and surveillances were performance based.
Management and QA personnel were very active in reducing operational
events.
During the previous assessment period, the licensee
issued 58 licensee event reports (LERs) at a rate of 4.5 per
month.
During this assessme~t pe~iod, it issued 41 LERs at a
rate of 3.4 per month, an improvement of 1.1 LER per month
since the previous assessment period.
Significant improvement
in the reduction of the number of LERs attrtbut~ble to personnel
errors continued during this assessment period.
Of the LERs
issued, 24% (14 of 58) were attributed to personnel errof *
during the previous assessment period compared with 20% (8
of 41) during this.assessment period.
This trend has shown
continued improvement in personnel errors ov~r three ~onsecutive
periods.
The licensee was effective in determining the root cause of
several major events, including the failure of the Unit 2 MSIVs
25
and the high drywell temperature conditions.
However, the
licensee, as indicated in the Maintenance/Surveillance functional
area, has not been fully effective in all its analyses of
individual compon~nt failures.
Open, effective, and frequent communications existed between
the_li~ensee and the NRC.
Conference .calls and meetings to
discuss technical and administrative issues occurred ~n a
proactive environment.
The licensing staff continued to
maintain a high level of experience and competence:
The licensee also had a very effective me~hod of tracking the
DSIP and station performance ~hrough its monthly plant ~erformance
report.
The report trended over 100 performance indicators
within 13 site-specific functional areas.
The majority of these
trended NRC initiatives or station. performance improvement
programs.
The5e indicators were determined to be an effective
management tool in trending both the completion and effectiveness
of station goals and programs.
The licensee also effectively
communicated the goals of the DSIP, station performance trend~,
and industry ev~nts to station personnel tro~gh daily and
monthly update letters.
The daily update lett~r provided
summaries of industry-related events a~d notific~tions that
enabled plant personnel to provide feedbatk to management.
Additionally, plant personnel participated in the DSIP by
providing feedback on the progress of the correcti~e actions.
2.
Performance Rating
The licensee's performante is rated Category 2 with an
improving trend in this area.
Because this is a new area,
no rating is avail~ble for the previous assessment period.
3.
Recommendations
None.
26
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities.
1. .**Unit 2
Dresden Unit 2 began.the assessment peri6d operating at.full*
power and set a licensee record of 205 dais for continuous
dual unit operation.
The unit experi~nced a few short outages
and power reductions for maintenance and testing activities,
equipment repairs, and load dispatcher request~. Unit 2 completed
its eleventh refueling outage, and ended the assessment period*
in routine power operation.
Unit 2 experienced five ESF ~ctuations and one reacto~ scram ..
The reactor scram occurred without rod motion and was caused by
- persohnel. error.
The ~nit has not experiehc~d a reactor scram
from power for 460 days.
Significant outages and events that occurred during the
assessment period are sum~arized b~low.
Significant Outages and Events
a.
As ot March 12, 1988, Dresde~ Units 2 and*3 oper~ted
continuously for 156 days exceeding the previous licensee's
records for continuous dual unit operation of 141 day~ set
by Zion, and 132 days set by Quad-C1ties for.BWRs.
b.
On May 15, 1988, (after 205 days of continuous operation)
Unit 2 was sh~tdown for a scheduled. 10-day maintenante
outage.
An unexpected reactor scram occurred with no rod
movemerit~ and an unusual event (UE) was d~clared ai a
result of a loss of secondary containment.
The licensee
remained shutdown to conduct special tests on the MSIVs.
c.
During October 29, 1988; through February 19, .1989, Unit 2
was shutdown for a scheduled 15-week refueiing outage.
Major activities included torvs recoat; mechanical stress
- improvement program reviews, recirculation piping
decontamination activities, cleaning of low press~~e
coolant injection (LPCI) heat excha~gers, and control rod
drive blade cleaning.
In addition, 42 modificatibns were
accomplished, including control room human factor modifications.
2.
Unit 3
- Dresden Uriit 3 begari the assessment period oper~ting at maximum
flow and reduced loads as directed by the load dispatcher.
The
unit began its tenth refueling outage in March 1988 ~nd recom~enced
-Operating at slightly reduced power levels and adjusted power
27
... -_ .....
. ~
rates in late June 1988 .. Unit 3 e~perienced no significant
outage~ until November 27, 1988, when it was shutdown for
equipment repairs.
The unit ended the assessment period
operating at normal power levels.
Unit 3 experienced seven ES~ actuations and one reactor. scram.
This reactor scram oc~urred above 15% power and was spuii~us and
unavoidable .. This reactor scram also ended a c6ntinuous 403 day
period without any scrams from pow~r from either unit, setting
a wo~ld record for du~l unit BWRs.
Significant outages and events that occurred during the assessment
period are summarized below.
Significant Outages and Events
~-
As 6f March 12, 1988, Dresden Un~ts 2 and 3 continuously
operated for 156 days, exceediog th~ previous litensee's
records for continuous dual unit operation of 141 days set
by Zion, and 132 days set by Quad-Cities for BWRs.
b .. During March 26 through June 24, 1988, Unit 3 ~perated
continuously for 172 days, until. it comm~nced an orderly
shutdown fo~ its planned tenth cycle refueling outage;
Major activities d~ring the refuelin~ outage included
feedwater regulator valve modifications, LPRM replacements,
SRM/IR dry tube replac~ments, and standby liquid control
system (ATWS) modificatibns.
c.
During November .27 through December 10, 1988, Unit 3 was.*
shutdown.fat a dual outage.
Major activities included
service water system maintenance of both units and the
installation of a temporary piping system for shutdown
cooling.
d.
On January 2, 1989, Unit 3 was shutdown because of a false
failure indication on two of the main. steam line radiation
monitor channels.
Repairs were performed and the unit was
returned to service .after approxi~ately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />,
R.
Inspection Activities
Thirty-five inspecti6n reports are discussed in this SALP report
(February 1, i988, through January 31, 1989) and are listed in
Paragraph 1 of this section, Inspecti6n Data.
Table 1 lists the
violations per functional area and severity levels.
Significant*
inspection activities are listed in Paragraph 2 of this section,
Special Inspection Summary.
28
'*.:
1.
Inspection Data
a.
Unit 2
Docket No.:
50~237
Inspection R~ports No.: 8704G, 88002 through 88019,
88021 thro~gh 88030, and 88002 through 89004. *
.b.
Unit 3
Docket No.: 50-249
Inspection Reports No.: 87039, 88002 through 88020,
88022 through 88031, 88200~ and 89002 through 89004.
- Table 1
Number of Violations in Each Seve~ity Level
Functional Areas
Unit 2
III
IV
V
A.
Plant Operations
1 -
B.
Radiological Controls
c~
Maintenance/Surveillance -
1 1
D.
E.
Security
F.
Engineering/Technical
Support
G.
Safety Assessment/ .
Quality Verificition
TOTALS
Unit 2
III
IV
V
2
1 *
2.
Special Inspection Summary
Un,i t 3
III IV
V
1 -
1 -
Unit 3
III. IV
V
2 -
COMMON
.III
IV
V
-
. 1
1
1
2
... 2
1
Both
III
IV
V
8 -
a.
During February 16 through March 16, 1988, a followup
SSOMI was performed (Inspection Report No. 249/88006).
b.
Periodically from April 18 th~ough December 13, 1988,
a special ffre protection inspection was conducted
(Inspection Report Nos. 237/88010, 249/88012). *
29
c.
During May 31 through June 8, 1988, a ~pecial team inspection
of emergency operating ~rocedures was performed (Inspettion
Report Nos. 237/88012, 249/88014).
d.
During May 17-24, 1988, an AIT inspection of MSIV failures
was perf6rmed to ~evi~w the circumstances surrou~djng the
failure of all eight Unit 2 MSIVs. (Inspection Report
No. 237/88013).
e.
During February 22 through March 11, 1988, a SSOMI team
followup
inspectio~ was tonducted (Inspectibn Report
No. 249/88200).
f.
During December 5, 1988, through January 6, 1989, a biannual
inspection of activities associated with the NRC DET was
conducted (Inspection Report Nos. 237/88023, 249/88024).
g.
During January 23 through February 10, 1989, a MTI was
- conducted (Inspection Report Nos. 237/88029, 249/88030).
C.
Escalated Enforcement Actions
1.
A notice of violation and proposed imposition of civil penalty
in the amount of $50,000 was issued to the licensee on.
February 11, 1988.
This action was based on two events in which
the licensee exceeded the speciffed time limits for two Te.chnical
Specifications associated with containment deinerting for
Unit 2.
Although escalation and mitigation factors of the
enforcement policy were considered, no adjustment to the base
civil penalty was deemed appropriate.
The licensee p~id the
$50,000 civil penalty.
T~is notice of violati6n was addressed
in a previous assessment per1od. (Enforcement Not1ce No. EN-88-007,
Enforcement Case No.
EA-87-207~ Inspection Report No. 237/87005).
2.
A pr6posed imposition of civil penalty in the amount of $150,000
was issued -0n April.28, 1988.
This action was based on violations
6f equipment qualificatio~ (EQ) requirements of 10 CFR 50.49.
The NRC
~taff submitted this action for the Commission'~ review
as part of SECY,:88-104, via memorandum dated April 27, 1988,
is still under review.
D.
Confirmatory Action Letters
A confirmatory action letter (CAL-RIII-88-012) was issued to the
licensee on May 18; 1988, regarding the failure of the MSIVs~ The
licensee was requested to take the necessary actions needed to ensure.**
that complete documentary evidence of the *~s f6und 1 condition of
30
- *, ';,!
( ..
equipment being inspected is maintained, to ~rovide a st~p-by-step
troubleshooting program, and to*establish root-cause.
In addition,
the licensee was asked not to disturb any .components that offer
potential for being the root-cause, and to submit a formal report of
their findings, conclusions, ~nd causes within 30 days of the letter.
E.
License Amendments Issued
- Amendment No.
98/93
94
99/95
100/96
101/97
102/98
103/99
104
De?cr1 pt ion
Date
Dfesel Testing
2/19/88
Unit 3 Cycle 11 reload
7/12/88
Security Plan
7/22/88
APRM/IRM Downscale Scram 8/24/88
ECCS Operability
. 10/26/88
R.G. 1.97 Changes
11/3/88 * *
Oxygen Conc~ntration
11/8/88
Unit 2 Cycle 12 reload
1/6/89
F.
Review of Licensee Events Reports Submitted by the Licensee
1.
Uhit 2 LER Nos.: 88001 through 88023
2.
Unit 3 LER Nos.: 88001 through 88018
Table 3
.
.
.
Collectively, 41 LERs wer~ issued in accordance with NUREG-1022
guidelines duriri~ this assessment, and are addressed in this
report.
There wer~_23 LERs reviewed for Unit 2, and 18 LERs*
reviewed for Unit 3, for this assessment per.iod.
Table 2
compares the cause codes associated with the LERs issued for
each unit.
Table 2
Cause Areas
Unit 2
Unit 3
Personnel Errors
6
2
Design Defici~ncies
1
2
External
0
0
Procedure Inadequacies
6
5
Equipment/Component
9
8
Other/Unknown
1
1
Totals
23
18
shows a cause code comparison of SALP i versus SALP 8. LERs ..
31
\\
- i,
-!;
Cause Are.as
Personnel Errors
Design Problems
External Causes
Procedure Inadequacies
Equipment/Component
Other/Unknown
TOTALS
FREQUENCY (LERs/MO)
Table 3
. Dresden 2/3
(12-MO)
(13-MO) .
7
8 .
14 (24.1%)
8 (19. 5%)
9 (15. 5%)
3 ( 7.3%)
o ( o. o~~)
0 ( 0.0%)
6 (10. 3%)
11 ( 26. 8%) .
22 (38.0%)
17 ( 41. 5%)
_l {12.1%2
2 { 4.9%2
58 (100)
41 (100)
4.5
3.4
NOTE:
The above LER information wa~ derived frbm a review of
LERs performed by the NRC staff ~nd may not completely
- coincide with the licensee's cause code assignments.
32