ML17202L299
| ML17202L299 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/29/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202L297 | List: |
| References | |
| 50-237-90-01, 50-237-90-1, 50-249-90-01, 50-249-90-1, NUDOCS 9007100209 | |
| Download: ML17202L299 (34) | |
See also: IR 05000237/1990001
Text
I
-
SALP 9
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
.REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-237/90001; 50-249/90001
Commonwealth Edison Company
Dresden Station
February 1, 1989 through Apri 1 30, 1990
'p
1 .***
I
.
- ..,.
TABLE OF CONTENTS
Page No.
LIST OF ACRONYMS
I.
INTRODUCTION ............................. ~. . . . . . . . . . . . .
1
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
A.*
Overview ....... * ...................... * ....... *.......
2
B.
Other Are~s of Interest ....................... *. ...
2
I I I. C.RlTERIA ; ..... * ........ , ...... .' ..... * . . :.. . . . . . . . . . . . . . . . . . .
3
IV.
PERFORMANCE ANALYSIS .... *...............................
5
A.
Plant Operations ............... *...................
5
B.
Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8
C.
Mai ntenance/Surveil 1 ance . . . . . . . . . . . . . . . . . . . . . . . . . .
10
D;
Emergency Preparedness ......... : ...... ....... ;....
14
E.
Security .......................... *................
15
F.
Enginee~ing/Technical Support ...........
L **** ;~...
17
G.
Safety Assessment/Quality Verification ............
20
V.
SUPPORTING DATA AND SUMMARIES ................ : . . . . . . . . . .
26
A.
Licensee .Activities .................... ~..........
26
B.
Inspection Activities .......... *...................
28
C.
Escalated Enforcement Actions .....................
29
D.
Confirmatory ActionLe.tters (CALs) ..... : ..... :....
29
E.
Review of Licensee Event Reports ........... :; ..*.. *
30
i
)
- ..
- -
ACAD/CAM
A LARA
ANSI
CECO
CFR
DCRDR
DRSS
DSIP
EDP
I GS CC
IN
kV
LER
MIP
NRC
atmospheric containment atmosphere dilution/containment atmosphere
monitor
Office for Analysis and Evaluation of Operational Data
Augmented Inspection Team
as-low-as-reasonably-achievable
American National Standards Institute
balance-of-plant
boiling water reactor
closed circuit television
Confirmatory Action Letter
Commonwealth Edison Company
Code of Federal Regulations
Detailed Control Room Design Review
Division of Reactor Projects
Division of Reactor Safety.
Division of Radiation Safety and Safeguards
Dresden Station Imp_rovement Program
emergency core cooling system*
electrical protection assembly
emergency operating procedure -
Emergency Plan Implementing Procedures
Electric Power Research Institute
environmental qualification
Emergency Re~porise Organization
eng1neered safety feature
Final Safety Analysis Report
health physics
high pressure coolant injection
hydrogen water chemistry
isolation condenser
interg~anular stress corrosion cracking
Information Notice
ins&rvice inspection
inservice testing
Kil ovo ltage
licensee event report
local leak rate test
low pressure coolant injection
maintenance improvement program
Nuclear Regulatory Commission
ii
.. *** ....
..
NSO
RER
SA/QV
SMAD
TS
voe
Office of N~clear Reactor Regulation
nuclear station operator
preventive maintenance
quality assurance
quality control
roentgen equivalent man
Radiological Environmental Monitoring Program
Regulatory Effectiv~ness Review
reactor operator
.
reactor protection system*
Systematic Assessment of Licensee Performance
Safety Assessment/Quality Verification
Station Blackout
System Materials Analysis Department
senior reactor operator
Technical Specifications
Volts~Direct C~rrent
iii
i;.
I.
INTRODUCTION
- The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee ~erformance on the basis
of this information.
The program is supplemental to normal regulatory
processes used to ensure compliance with NRC
rul~s and regulations .. It
is intended to be iufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC' s assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of- the staff members listed below, met on*
June 13, 1990, to review the observations and data on performance, and to
assess licensee performance in accordance with the guidance in NRC Manual
Chapter 0516, "Systematic Assessment of Licensee Performance."
The
guidance and evaluation criteria are summarized in Se~tion III of this .
report.
The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at Dresden.Station for the period February 1, 1989, ~hrough April 30, 1990.
The SALP Board for Dresden Station SALP 9 was composed of the following
individuals:
Board Chairman
-,
C. E. Norelius, Director, Division of_ Radiation Sa.fety -and.Safeguards (DRSS)
Board Members
E. G. Greenman, Director~ Division of Reactor Projects (DRP)
T. 0. Martin, Deputy Director, Division of Reactor Safety (DRS)
R.
F~ Dudley, Acting Project Director, Project Directorate III-2,
Office of Nuclear Reactor Regulation (NRR)
-
W. D. Shafer, Chief, Branch 1, Division of Rea~tor Projetts
a. L. Siegel, Project Manager, Project Directorate III-2, NRR
S. G. DuPont, Senior Resident Inspector
Other Attendees at the SALP Board Meeting
L; R. Greger, Chief, Reactor Programs Branch, DRSS
M. P. Phillips, Chief, Operational Programs- Seciion, DRS
W. G. Snell, Chief, Radiological Controls and Emergency Preparedness
Section, DRSS
-
J. M.
Hinds~ Chief, Projects Section 18, DRP
J. R. Creed, Chief, Safeguards S~~tion, DRSS _
D. Hills, Resident Inspector, DRP
D. Jones, Reactor Engineer, DRP
D. aarss, Emergency Preparedness Analyst, DRSS
T.- Madeda, Physical Security Inspector, DRSS
F. *Maura, Reactor In specter, DRS
II.
SUMMARY OF RESULTS
A.
Overview
This assessment period is from February 1, 1989 through
April 30, 1990 (15 months versus 12 months for the previous
assessment period).
Management involvement was generally evident
and resulted in improved overall performance.
Good performance
i.n the areas of Operations, Emergency Preparedness and* Security
demonstrated management effecti~eness. The licensee's
responsiveness to NRC initiatives and cohcerns was adequate with
some weaknesses regarding the quality and timeliness of corporate
licensing activities.
I
Resolution of technical issues was good.
Enforcement history
generally improved with no escalat~d enforcement actions taken.
Training and qualifications wa*s very good overall with the exception
of Engineering/Technical Support.
Staffing was adequate overall
with the exception of Engineering/Technical Support. *
The performance ratings during the previous assessment period and
this assessment period according to functional areas are given below:
Functional Area
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical Support
.. Safety Assessment/Quality
Verification
B. *
Other Areas of Interest
None.
2
Rating Last
Period .
1
2
2
- 1
2 Improving
2
2 Improving
Rating This
Period
l.
2
2
1
1 .
2
2
Trend
Improving.*
" .
I I I. CRITERIA
Licensee performance is assessed in selected functional areas.
Functional
- areas normally represent areas significant to nuclear safety and the
environment.
Some functional areas may not be assessed because of little
or no
licen~ee activities or lack of meaningful observations.
Special
a~eas may be add~d to highlight significant observations.
The following evaluation criteria were used to assess each functional
area:
1.
Assurance of quality, including management involvement and control;
2.
Approach to the identification and resolution of technical issues
from a safety standpoint;
3.
- Responsiveness to NRC initiatives;
4.
Enforcement hi story;
5.
Operational events (including response to, analyses of, reporting
of, and corrective actions for);
6.
Staffing (including management); and
7.
Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have
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 performanc~ categories are as follows:
Category 1:
Licensee management attention *and involvement are readily
evident and place emphasis on superior performance of nuclear safety or
safeguards activities, with the resulting performance substantially
exceeding regulatory requirements.
Licensee resources are ample and
effectively used so that a high level of plant and personnel performance
is b~ing 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 that good plant and personnel performance is' being
achjeved.
NRC attention may be maintained at normal levels.
Category 3:
Licensee management attentibn to and involvement in the
performance of nuclear safety or safeguards activities* .are not
s~fficient. The lic~nsee's perform~nce does not s~gnificantly exceed
that needed to meet minimal regulatory re~ui r.~ments~ *_Licensee resources
appear to be* strained or not e(fectively ~ied.
NRC ~tt~ntion should be
increased above normal levels.
-
-- ------
--
--~---
3
.. -
The SALP Report may include an appraisal of the performance trend in a
functional area for use as a predictive indicator.
Licensee performance
during the assessment period should be examined to determine whether a
trend exists.
Normally, this performance trerid should only be used if
a definite.trend is discernable.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving during
the assessment period.
Declining:
Licensee performance was determined to be declining during
the assessment period, and the licensee had not taken meaningful steps to
address this pattern.
4
IV.
Performance Analysis
A.
Plant Operations
1.
Analysis
Evaluation of this functional area was based on the results of
routine inspections by *the resident inspectors, one Augmented
Inspection Team (AIT) inspection, and one rciutine fire
protection inspection.
Enforcement history in this functional area improved since the
last SALP rating with only t~o violations (1 Severity Level IV;
1 Severity Level V).
One of the violations pertained to a
failure to follow procedures during a ground checking evolution
which resulted. in a reactor scram.
This violation occurred
early in the assessment period and effective corrective actions
prevented recurrence.
The second violation pertained to an
iMadequate operational procedure.
Although this violation was
issued during this period, the event occurred during the
previous assessment and does not reflect performance in this*
peri~d.
The corrective actions were effective in preventing
recurrence.
The licensee requested and received one waiver of
complianc~ pertaining to the testing of the reactor protection
system (RPS) electrical protection assemblies on Unit 3.
The
request was well prepared~ accurate and timely.
The licensee
also submitted a request to revise the Technical Specifications
to eliminate any further requests .for discretionary action on
this issue.
Licensee events attributed to personnel errors continu~d to
d~crease. One reportable event associated with pla~t
operatio~s involved personnel error.
This event involved a*
reactor scram as discussed previously, and occurred during
the first m6nth of the assessment period~ The corrective
actions were effective in preventing recurrence of both
personnel ~rrors and scra~s associated with plant operations.
The Dresden plant showed an improved trend in its operating
p~rformance during this period.
Although eight scrams occurred
early in the assessment period, both units were operated for
long continuotis periods.
Unit 3 exceeded its previous record
for continuous days on line.
Seven of these scrams were a
result of equipment failures and surveillance activities and
are discussed in Section IV.C.
Engineered safety features
(ESF) actuations we~e low with improvement in ESF actuations
attributable to outage testing.
During the previous assessment,
the 12 ESF actuations that occurred during outage testing.were
identified as a weakness .. During the recent Unit 3 outage
only three ESF actuations occurred.
One safety injection also
occurred as the result of a false signal being generated by a
leaking test isolation valve.
. .
The operating-department demonstrat~d ~ood superv1s1on and
coritrol of plant activities and excellent response to off-normal
5
events.
Examples included two loss-of-offsite-power events,
a feedwater transient, and reactor scrams.
The operator
actions durjng the feedwater transient rapidly mitigated the
transient and ptevented a reactor scram.
During these events,
the operators' actions were effective in mitigating the plant
upset conditions and demonstrated both effective training and
a conservative approach to safety .. The operating crews
displayed a high degree of attentiveness, were knowledgeable
of plant status and regulatory requirements, and projected a
positive safety attitude.
Control rotim conduct was professional
and businesslike.
Operating personnel demonstrated good
procedure discipline and effective use of plant drawings and
task briefings.
Aggressive management and supervision
immediately detected and 2orrected pos~ibilities for errors
during implementation before they became actual problems.
Examples of these possible errors included procedure adherence;
and removing equipment and 1nstruments out of service.
The
corrective actions addressing these cases were prompt and
effective, resulting in improved attentiveness.
The operati~g staff interface with NRC was open and candid.
This was evident in their communication of problem identification.
and resolution, by the operating staff's responsiveness to NRC
observatio~s,.and with NRC management during site visits.
The overall appearance of the control room improved significantly
ctimpared to the previous assessments.
These improvements were
due to modifications made as a result of detailed control room
design review (DCRDR) requirements, but also are attributable
to continuing hardware and environmental changes proposed by
the operations staff:
Housekeeping conditions within the plant were very good
throughout the assessment period, including refueling outages:
Management was aggressively involved in the assurance of
quality in plant operations and demonstrated support of*
improvement initiatives. Oil and water leaks were identified
and repaired.
The number of existing leaks was previously
identified as a weakness.
Other improvement initiatives
included the ~ystem labeling, valve tagging and breaker cubicle
identification programs.
These programs were effective in
preventing identification errors and inadvertent manipulation
of components on the wrong unit.
Continued improvements in
the effective cooperation between management and the operating
staff were also noted.
For example, management performed
frequent in-plant self-assessments aod. held aggressive onsite
root cause determi~atiorr critiques involving all plant
departments.* These critiques were effective in determining
subsequent corrective actions.
The previous SALP assessment identified that teamwork between
the various departments had improved at Dresden in regard to
addressing some of the more significant pr,oblems.
The
implementation and expansion of this conce~t continued.
Examples included the assistance from the operations department
6
..
in identifying problems with 4-kV breakers; cooperation with
the instrumentation department in dev~loping and obtaining
improved reactor process instrumentation in the control room;
combined efforts of all departments during the preventive
replacement of a main transformer and the reactive replacement
of the failed reserve auxiliary transformer; and the assistance
of operations in the development of good target analysis and
planning in preparation for the NRC Regulatory Effectiveness
Review.
Other demonstrations of effective teamwork were the
good housekeeping conditions during outages and the revision
of the emergency operating procedures (EOPs).
The EOPs,
previously. identified as a weakness, were found to be above
average.
The control and overview of outage-related activities by the
operating staff resulted in reduction of ESF actuations,
reduction of system lineup and verification errors~ and the
overall good housekeeping conditions during the outage.
Previous SALP assessments identified outage contror as a
~eakness* because of the high occurrence of ESF actuations.
Although the cu.rr.ent licensed staff performed we 11 during
events, because of effective training, the recent initial
senior reactor operator (~RO) and reactor operator (RO)
examinations indicated weaknesses in. training as discussed
in Section IV.F.
One of three (33%) senior reactor operators
and two of *five (40%) reactor.operators failed the examination
- for a total failure rate of 37.5 percent.
Staffing for plant operations was very good and the licensee
effectively* trended and controlled operator overtime.
The
operations staffing includes four senior reactor operator and
four reactor operator licensed individuals per shift for six
shifts. Additionally, a complete extra shift of four SROs is
maintained to assist in shift manning and improvement initiatives.
The initiation of the fourth reactor operator in th~ control
room wa~ effective in providing an additional trai~ed operator
to assist in mitigating off normal conditions and during high
activity periods.
Additionally, improvements in the fire
protection program resulted with the addition of an~ssistant
fire marshal.
2.
Performance Rating
The licensee's performance is rated Category 1 i.n this area.
The licensee's performance was rated Category 1 in the previous
assessment period.
3.
Recommendations
None.
7
B.
Radfological Controls
1.
Analysis
Evaluation of this functional area was based on the results of
seven inspections conducted by regional inspectors and observations
made by the resident inspectors.*
Enforcement history during this assessment period was good with
one Severity Level IV violation issued.
Staffing, traihing and qualifications were adequate during the
assessment period, with chemistry stronger than radiation
protection.
The as-low~as-reasonably achievable (ALARA) staff
was weak and had significant turnover during the middle of the
period, but was re-staffed with individuals with extensive and
appropriate nuclear power plant experience.
Two degreed .individuals
were added to.the radiation protection staff as replacements;
however, neither had nuclear power experience.
In chemistry,*
prof~ssional staff experience levels ha~e improved and are
generally good .. The permanent assignment of technicians, all
American National Standards Institute (ANSI) qualified, to
chemistry has substantially improved laboratory capabilities and
- technician proficiency.
Management involvement in ensuring quality was adequate .
Management attention was not sufficient*to ensure that c_orrective
actions for problems identified and documented in radiological
occurrence reports (e.g., contamination and high radiation area
controls) are sufficient to prevent recurrence.
In addition,
problems involving inadvertent disposal of a batch waste release
tank composite sample, incorrect verifications of liquid effluent
monitor setpoints, untimely correction of airborne radioactivity
releases from the hydrogen addition system, and inadvertent
release of contaminated scaffolding from the site highlight the
need for greater management involvement.
The water chemistry
program conformed to the Electric Power Research Institute
(EPRI) boiling water reactor (BWR) owners Chemistry Guidelines
and was under good control, as demonstrated by parameter trend
charts.
Hydrogen water chemistry on Unit. 2 to reduce intergranular
stress corrosion ~racking (IGSCC) has improved the overall water
chemistry, however, a new electrochemical potential monitor
install~d to optimize hydrogen *addition (and therefore not
unnecessarily inc~eas~ radiation levels) is not yet operational.
Laboratory facilities were greatly improved and analytical
instrumentation was extensively upgraded:
Respon~iveness to identified concerns was generally good.
The
licensee has been receptive to the confirmatory measurements
programs and has improved both the radiological and nonradiological
laboratory quality assurance/quality control p_rograms.
Detailed
discussions were held regarding the status:of several highly
~
.
-
-
8
- -
contaminated radwaste rooms and the licen~ee initiated corrective
action to decontaminate these rooms.
However, the licensee has
a number of unattended exits from the radiologically controlled
area which increases the potential for contamination control
degradation. *Also, the amount of contaminated dirt, shielding,.
and other material ~tared onsite remains hig~.
The licensee 1 s approach to identifying and resolving technical
issues was adequate.
Implementation of.radiological controls
was good during and after the release of radioactive isotopes
contained in water vapor from the Unit 2 isolation condenser
(IC) on March 25,
1989~ The licensee has since developed a .
method o( feeding clean ~ater to the shell side of !Cs when
offsite power is lost; this develo~ment corrects a long-standing
radiological problem that occurred when offsite power was lost
during power operations.
The total station dose .for 1989 ~as
1139 man-rem.
This total is understandable given the
contribuiion from two refueling outages. and a major project to
upgrade radwaste facilities. *In 1988, the total station dose
was 1407 man-rem.
The licensee also significantly reduced the
number of personal contamination events, from 534 in.1988 to 215
in 1989, which is indicative of improving performance .. This
reduction has been achieved through in~reased worker training,
plant material condition improvements, and greater management*
review of contamination e~ents. However,
s~ve~al recent
whole-body exposures in excess of administrative limits and. a
. 7 rem extremity exposur,e that was significantly higher than
projected, indicate a continuing weak~ess in pre-job dose
evaluations.
No unplanned liquid or transportation incidents
were reported during the assessment period.
Gaseous-activity
r:.eleased was very low.
Liquid activity released and volume of
solid radwaste w~re average.
The results of the nonradiological confirmatory measurements
program were good.
With 26 of 30 initial analyses in agreement
.and two qualified agreements, the quality of measurement improved
from that in the previous period.
The results of the radiological*
confirmatory measurements were adequate with five disagreements
in 30 comparisons m~de on six routinely used samples on.three
detection systems.
The Radiological Environmental Monitoring
. Program operated satisfacto~ily.
2,
Performance Rating
The licensee 1s performance is rated Category 2 in this area.
The licenseeis performance was rated Category 2 in the previou.s
~ssessmeMt period.
3.
Recommendations
None.
9.
-*
- - ,-- " ---
-
C.
Maintenance/Surveillance
1.
Analysis
Evaluation of this functional area was based on routine and
special inspections, and a maintenance team followup inspection,
by the resident and regional inspectors, including two AITs.
The enforcement history in thi's functional area showed improvement
with three Severity Level IV and one Severity Level V violations
compared to five Severity Level IV and one Severity Level V
violations during the previous assessment period.
Two of these
violations concerned maintenance activities while the other
related to surveillance activities.
One involved inadequate
maintenance and post-maintenance testing regarding control rod
charging water check valves prior to )986 and the other concerned
a failure to pl ace an emergency core cooling system ( ECCS)
initiation level switch in the proper tripped condition during
maintenance.
The third violation involved_placing the service
air system containment isolation valves in a test condition
without use of a procedure during an integrated leak rate test
(ILRT).
There was no improvement in the total number of component
failures reported in li~ensee event reports (LERs) and reactor
scram events during this period. Thirty-five of the 50 LERs were
attributable to the Maintenance/Surveillance functional area
co~pared with 21 of the 41 LERs d~ri~g the previous period. *
Twenty of these LERs were attributable to component/equipment
failures as opposed to other root causes.
There were two LERs
associated with personnel errors, indicating good personnel
performance practices.
Seven of ~he eight reactor scrams were
attributable to component failur~s-compared to the previous
period when one scram occurred.
However, four cif these scra~s
were the result of initiators that were either spurious or from
offsite equipment failures.
These included the March 25, 1989
loss of off site. power from a failed 345 kV switchyard circuit*
breaker; the March 30, 1989 spurious reactor protection system
(RPS) electrical protection assembly (EPA) breaker trip durtng
surveillance testing; the July 12, 1989 spurious main steam
isolation during surveillance testing; and the January 16, 1990
failure of a condensate pump motor from an undetectable internal
fault.
Two of the scrams resulted from noise occurring during
RPS surveillance testing at power.
One of the licensee's
proposed corrective actions is to perform this surveillance
during shutdown conditions.
This proposal is currently unde~
NRC review.
None of the scrams were directly related to an
ongoing maintenance activity and only one of the scrams was
directly related to the actual methodology of a surveillance
activity conducted at the time of the scrams.
The January 5, 1990
scram during the main steam line high .flow surveillance was
attributable to an inadequate venting proced~re.
10
Management's involvement to ensure q~ality in maintenance and
surveillance activities was effective as demonstrated by prior
planning and assignment of priorities, policies being well
stated and disseminated, decision making usually at a level that
ensured adequate management review, corpor~te management involvement
th~t was effective in assuring iompletion of improvement goal.s
and root cause analyses that usually resulted in. improvements.
The licensee was effective in assuring that scheduled surveillances
were completed.
No surveillances were missed during this
assessment.
Supervisory tours of the plant increased and
communications improved between maintenance and* supporting
groups.
Implementation of a very extensive Maintenance Improvement
Program (MIP) continued from the previous period.
This program
r~sulted in cont~nued good performance of the diesel generators
and high pressure coolant injection (HPCI), and in the improved
a~ailability of the low pressure injection systems.
The
effectiveness of the motor operated valve improvement program
resulted in significant reduction of valve f~ilures from 12 in
1987 to 8 in 1988 and 2 in 1989.
Managemeht 1 s fnvolvement in
the security preventive maintenance program resulted in significant
reduction in corrective work activities.
Management overview .
also resulted in the completion of the recent Unit 3 refueling.
outage on schedule with minimal problems.
A detailed planning
program was incorporated that effectively set the prior{ties *
and scheduling of these tasks to ensure use of a 1,1 resources.
The licensee also implemented a program to effectively prepare
for maintenance activities during unexpected outages.
The
operating staff in cooperation with the maintenance staff
maintained prepared corrective work requests to b~ performed
~uring short outages.
Thes~*preparations allowed the licensee
to effectively resolve most of the degraded equipment that would
normally only be ~ddressed during the scheduled outages.
Departmental effectiveness was enhanced through improved
.
. communications, meetings between all departments, and detailed
coordination of activities.
Conversely, because the Maintenance Improvement Program for**
balance of plant equipment (BOP)_ is not scheduled for completion
unti.l 1992, not all of the goals were achieved.
Many of the BOP
equipment programs were not fully implemented and, as.such, were
not y;.1.t effective.
This was evidenced by the January 16, 1990
scram and loss of offsite power event.
Although the reliability
of safety-related equipment has improved, th.e reliability of BOP
equipment did not improve as evidenced by_the number of component
failures.
The preventive maintenance (PM) program continued to improve in
certain respects but some specific weaknesses were still evident
with procedures, and problem analysis data sheet control.
Also,
there was an indication of a lack of PM on a shutdown cooling
pump outlet valve that failed due to a sheare.d shaft key .. In
the first half of the assessment period,.the scope of the PM
11
'program was incomplete and PM was ineffective as evidenced by
the lack of scheduled maintenance on 250 VDC HPCI motor control
centers, safety-related and BOP 4.16 kV breakers and the larger
- number of potentially significant ~vents in the first quarter of
1989.
However, aggressive management involvement resulted in
considerable improvement in the latter half of the period
specifically in the electrical area, the check valve inspection
program, control room instrumentation, and the BOP motor 6perated
valve overhaul program.
The improvements were also attributed
to attention to detail and pride of workmanship by maintenance
and support personnel.
Increased emphasis on predictive maintenance
techniques was demonstrated by the pre-failure replacement of
the Unit 3 main transformer.
Additional predictive techniques
of equipment failure were being developed by the licensee such
as a thermography program.
Detection of intergranular stress
corrosion cracking (IGSCC) of piping was improved with surface
enhancement of the inspected welds. The licensee plans to
prepare all IGSCC susceptible welds for future inspections.
The, licensee's approach to resolving technical issues from *a
safety standpoint was sound and thoro~gh. A clear understanding
of these issues was demonstrated by management through discussions
with NRC.
Conservatism was generally exhibited when the potential
for safety significance existed.
The licensee's in-service
testing program was considered effective as demonstrated by the
high availability of ~otor operated valves.
Conser~atism with
respect to safety was exhibited by declaring pumps and valves
inoperable when discovered rather than at the conclu~ion of
testing.
Licensee augmented inspections were implemented to
assure that degradation of safety-related components was monitored
arid contro 11 ed.
Conversely, the frequency *of a chi evi ng an
11blackboard
11 status declined during the first half
of this assessment period; however, improvements were made late .
in the assessment period with assistance -0f the operations
department to return annunciator status to similar conditions of
_the previous period.
Corrective actions described in LERs were generally ad~quate,
but not all of the corrective actions were completed in a timel~
manner.
Some of these corrective actions did not prevent
.
recurrence:
Although they met the regulatory requirements, the
licensee could have done more to reduce the leakage rate from
cont~inment isolation valves during the Unit 3 refueling outage.
The failure to vent the service air system during the Unit 3
ILRT also indicated an inadequate licensee evaluation of this
activity. This problem was attributable to weaknesses in staff
kn owl edge.
..
Licensee management was responsive to NRC initiatives, as
evidenced by their prompt actions to Information Notice (IN) 90-02,
11 Potential Degradation of Secondary Containment 11 by
-comp 1 et i ng a tho:roughwa 1 kdown and maintenance review. of the
--
- - ----
12
ventilation and standby gas treatment systems.
The licensee's
maintenance activities related to this IN, and application of
"lessons learned" in IN 90-11, Maintenance Deficiency Associated
With Solenoid Operated Valves, and Bulletin 89-02, Stress
Corrosion Cracking of High-Hardness Type 410 Stainless Steel
Internal Preloaded Bolting in Anchor Darling Model S350W Swing
Check Valves or Valves of Similar Design, were very prompt and
effective.
In the case of IN 90-11, although the type of
solenoid mentioned in the notice was not used at Dresden, the
licensee applied the guidance to the specific solenoids that
were utilized ~t Dresden.
Responses and actions were adequate
to assure the potential maintenance related discrepancies
addressed by Generic Letters were inspected, evaluated and
corrective action taken when required;
Additionally, the
licensee was prompt in correcting deficiencies associated with 4
kV breaker preventive maintenance.
When the NRC raised concerns
relating to maintenance or surveillance activities, the licensee
usually responded in a timely and effective manner.
Communications
between the licensee and the NRC were generally good.
Staffing in the maintenance/surveillanc~ area was adequate.
Additional personnel were added to the Maintenance Improvement
Program during this asse~sment period to aid in implementation
of the programs and the. upgrade of the maintenance procedures.
The corrective maintenance backlog was not excessive with
about 850 work requests (corporate goal is 900) for the available
resources.
Staffing was augmented by contractor's for specific
activitie~ s~ch as. non-destructive examinations (NOE).
The
licensee also used the servi~es of CECo System Materials Analysis
O~~artment (SMAD) for consultation on NOE verification and
corporate staff to augment limited plant staff expeftise regarding
leak rate testing.
Maintenance department personnel training and qualification
programs were acceptable and improving.
Personnei received the
required training under the accredited program for performance
of their assigned duties.
- *
Personnel involved in the supervision of assigned ta~ks appeared
to be well trained and knowledgeable of task objectives as
~vident in the reduction of maintenance related errors during
outages.
This was identified as a.weakness during the previous
assessment.
Training and qualification of inservice testing
personnel and of NOE inspection contractors was adequate.
2.
Performance Rat~ng
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous
assessment period.
13
3.
Recommendations
None.
D.
1.
Analysis
Evaluation of this functional area was based on one routine
- inspection, two annual e~ergency preparedness (EP) exercise*
inspections, one special inspection of corporate support activities
of EP, and a special Augmented Inspection Team (AIT) inspection.
Enforcement history_ has remained good.
No violations were
identified during this or the previoui assessment period~
Management involvement in assuring quality continues to be good.
Fouf quality assurance (QA) audits were completed during this
assessment period.
Two assessed onsite activities, one focused *
on offsite matters and one concerned corporate emergency
preparedness issues.
Several QA surveillances of EP activities.
were also conducted.
Where necessary corrective actions have
been initiated or completed to address items found through these
self a~sessments.
The licensee'~ response.to operaiional eventi was good.
Seven
emergency p1an activations occurred in this assessment period.
Each event was correctly classified in a timely manner.* Six
events were classified as Notifications of an Unusual Event and
one as an Alert. Appropriate notifications to the State, counties
and the NRC were made ~ithin th~ required time limits for each
event.
The li2ensee effectively utilized the emergency response
facilities, procedures and organization to evaluate plant c
conditions and anticipated actions to successfully mitigate the
consequences of an event which occurred jn*March 1989 which did
not procedurally requir~ that l~vel of response.
Responsiveness.to identified concerns was good.
An exercise
weakness for failure to provide adequate contamination and
exposure control was identified during the evaluat.ion of the
April 1990 annual exercise.
In response to the exercise weakness,
licensee management promptly scheduled * drill to.demonstrate
contamiriation and exposure control.* Additionally, recommendations
for improvement have been appropriately evaluated and considered
by licensee personnel .
The licensee's identification and resolution of technical issues
has been excellent.
During this assessment period the entire
vol~me of Emergency Pl~n Implementing Procedures (EPIPs)-were
reviewed and revised.
Many EPIPs were shortened and provided
with checklist aids to improve ease of~use. In response to the
em~rgency plan activations the licensee tond~cted post-activation
14
reviews for each event to identify areas which could be improved
upon.
Items identified through these reviews of real events
,
have been incorporated into the licensee's Nuclear Tracking
System and appropriately resolved.
Staffing l~vels for the Emergency Response Organization (ERO)
remain good.
Semiannual off-hours drills have been conducted
to demonstrate the capability to augment onshift personnel in a
- timely manner.
The EP staff has increased during this assessment
period to include a Lead EP Coordinator and an EP Coordinator.
There is also a training staff member assigned responsibility
- for.EP training.
The Lead EP Coordinator reports directly to
the Technical Superintendent, who in turn reports to the Station
Manager, ensuring EP concerns receive ready access to upper
management.
The licensee's EP training program was ex~ellent. In addition
to the required annual retraining, all members of the ERO were
provided additional training on the revised EPIPs.
Training
records were meticulously maintained and an appropriate training
matrix established and implemented.
A new training module was
developed to strengthen a weakness that had been identified with
Operational Support Center personnel's knowledge of emergency
response activities.
The training program's effectiveness is
evidenced by the licensee's generally good response during.
emergency exercises.
The scenario's prepared for the exercises
were sufficiently challenging to test the licensee's emergency
response capabilities.
During the exercises the licensee made
extensive efforts to use mock-ups to provide realistic conditions
.for the emergency responders.* The complexity of the responses
necessary to suppor*t the use of mock-ups in the exercises po.sed
new challenges to the licensee's exercise control organization.
2.
Performance Rating
The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated Category 1 during the
previous assessment period.
3:.
Recommendations
None.
E.
Security
1.
Analysis
Evaluation of this functional area was based on the results of
three routine inspections conducted by regional inspectors and
observations made by resident inspectors.
Additionally, a
Regulatory Effectiveness Review (RER) was. conducted.
15
Enforcement related performance has essentially remained the
same~ Three violatio~s (2 Severity Level IVs; 1 Severity Level
V) were identified during this period compared to two during the.
previous assessment period.
Reportabl~ security events were properly identified and analyzed.
The licensee had two reportable security events during "the
~ssessment period, neither resulted in violations.
During the
- latter part of this assessment period, a significant increase in
the number of loggable security events was noted.
This increase
- was largely a result of expanded and revised corporate guidelines
which were developed in response to NRC concerns noted during
the previous SALP assessment period. *The scope of the licensee's
procedures for loggable items now more closely follows regulatory
guidance.
The majority of loggable events identified particular*
problems with environmental effects related to the closed
circuit television system and perimeter alarm system.
Because
these expanded data became avaiJable only near* the end of the
assessment period, the NRC staff .is still analyzing them.
Management involvement in assuring quality was good and is a*
program strength.
This was evidenced by the licensee's planning
and ~mple~entation of a restoration project w~ich has significantly
increased th~ effectiveness of the protected area b~rrier and
.associated alarm system.
The license~ also develo~ed and
implemented an equipment upgrade. that. significantly incr:-eased
their aisessment capability of the protected area perimeter.
In
addition, the licensee has expanded its use of contract security
personnel to conduct audits/survei l lan*ces of the security .
- .
- prog_ram.
The licensee's approach to the identification and resolution of
technical security issues was *excellent and ~s a program strength.
This was evidenced by the licensee's continuing implementation -
of its performance indicator prog~am and mana~ement's involvement
in root cause analysis of identified concerns.
Also management
has taken an aggressive approach.to resolve issues that are
identified through event logs.
Initial rev.iew showed effective.
licensee planning to identify causes and actions needed to
r~solve the problems.
Responsiveness to identified problems is good and corrective
actions are comprehensive and completed in a timely manner.
However, on one occasion during this assessment period, corporate
security arid licensing failed to adequately monitor licensee .
commitments to the NRC which resulted in the licensee's failure
to implement corrective action in'a timely manner.
This failure
to mbnitor ~nd implement corrective action commitments resulted
in Dresden receiving a violation for the same type of event that
was previously identified at ano~he~ Commonwealth Edison site~
Communications with regional safeguards:personnel continues to
be frequent and effective and is a streng~h of the program:
16
- ,
2.
.
.
.
.
Staffing has been expanded during this assessment.perio.d and is
ample.
The licensee has increased their utilization of the
contract se6urity organization.
The contractor's staff has been
given increased responsibility by the licensee in the collection,
analyzing and dissemination of security data to the licensee *
relating to the effectiveness of security equipment and performance
of security force personnel.
To accomplish this task the senior.
management level. of the contract security force has been increased
in size.
This expansion has enhanced the proactiveness of the
security program through the early identification and correction
of potential problems.
The licensee's security force was adequately supervised and
- trained.
Generally, the licensee's procedural guidance for the
security force was sufficiently detai]ed to ensure that personnel
are knowledgeable of their responsibilities and conduct their
duties in an effective manner.
The training and qualification
program utilized by the licensee and implementation by the
security contractor was considered acceptab 1 e and meets, commitments.
However, the tactical contingency training program recently '
developed and implemented by the licensee/security contractor
exceeds commitme~ts and is a program strength.
The RER concluded that the licensee's security program had many
strengths and it. was evident that the ~licensee had commi.tted
expanded resources to improve its security program.
The RER
identifi~d no major problems but did identify° several areas in
.the licensee's program that could.be strengthened or improved.
The licensee has acted in a positive and aggressive manner to
implement improvements.
Performance Rating
The.licensee's performance is rated Category 1 in this area.
- The licensee's performance was rated Category 2 improving during
the previous assessment period.
3.
Recommendations
None .
. F.
Engineering/Technical Support
1.
Analysis
Evaluation of this functional area was based on the results of
three routine, one special, and two team inspections by regional
inspectors; inspections by the resident -inspector; and interactions
with the licensee and review of licensee submittals by the
Office of Nuclear Reactor Regulation {NRR) staff.
17.
One Severity Level IV violation was issued during this assessment
period.
The violation invol~ed the licensee's failure td
control the design of a fire penetration in a 3-hour fire rated
wall. While this violation had no major safety significance,
when taken in combination with other events in which maintenance
personnel failed to recognize a fire barrier, it reflects a
weakness in the licensee's implementation of its fire protection
program ..
Ten licensee event reports (LERs) were attributed to this area.
Six were the result of design problems of which only one (caused
by a loose wire connection to a thermal overload due to an
incorrect tightening criteria) was attributed to activiti.es
performed during this assessment period.
The other design
problems w~re related to design activiti~s performed during
previous assessment periods or original plant design deficiencies.
Three were related to inadequate procedures; and one ~as due to *
personnel error (improper inspection of a fire penetration
device).
None of the events appeared to be indicative of
programmatic weaknesses.
Management involvement to assure quality continued to be mixed.
On the positive side, the licensee has improved its performance
in the a~ea of design changes, especially on post-modification
. testing.
Identification and tracking of the Top Technical
Issues ensured man~gement and engineering attention toward
specific and difficult :to rectify technical issue*s such as the
main
~team line temperature switch drifting and reactor/turbine
building ventiiatio~ problems.
Management involvement in
ensuring comprehensive corrective actions for deviation reports
was evident.
Management also ensured that offsite engineering
resources were effectively utilized.
Safety evaluations continued
to have a sound engineering basis, and t~mporary modifications
were few in number and well controlled.
In fire protection, the
licensee has shown a willingness *to test equipment, develop
preventive maintenance for fire prot~ction equipment, and
develop fire plans for areas not covered by the Fire Hazards
An~lysis report, such as the hydrogen storage areas.
On the
negative side, at the beginning of the assessment period, a
walkdown and physical inspection of ,equipment required to be
- environmentally qualified (EQ) was performed which found several
terminat boxes and one terminal block' which failed to meet EQ
requirements; subsequent to the end of the assessment period,*
additional problems in the identification and qualification
of EQ equipment were identified.
Another area not receiving
adequate management attention has been the performance of the
condensate/condensate booster pumps.
While not safety-related,
these pumps have continued to cause loss of reactor feedwater
transients and resultarit reactor scrams despite several
modifications performed since 1987 to the auto-start logic.
In
addition, several initial licensing*submi~tals were incomplete
18
by not providing all of the technical information used by the
engineering evaluations, necessitating additional request~
for information to complete the reviews.
Other weaknesses identified late i~ the assessment period
included the numerous deficiencies in the material supplied for
the initial licensed operator examiriations.
The facility
pre-examination review did not appear to resolve examination
inaccuracies as evidenced by the number of post examination
comments.
In addition, the examination results showed a weakening
in the effectiveness of the licensed operator training program
for new operators with regard to administrative procedures,
familiarity with routine shift administrative duties, EDP
implementation, and lack of proficiency in the use of the
Generating Stations Emergency Plan.
The EDP followup inspection
found that the revised EOPs were significantly improved over the
earlier versions with regard to clarity and ease of use.
Two
weaknesses were identified however, one that related to the lack
of a basis document that could provide justification for differences
between the plant specific technical guidelines and the EDP flow
charts and another regarding the lack*of documentation that
provided justification for the programmatic changes to the EDPs.
The licensee's approach to the identification and resolution of
technical issues was good.
In the temporary modification*
program, there was clear understanding of the us~ of temporary
- measures to resolve technical problems.
were few in number, had definite scop~s, thorough evaluations~
and defined permanent resolutions.
The licensee self-identified
past design problems such as the low pressure coolant injection
(LPCI) swing bus, s_tandby gas treatment system (SGTS), and
atmospheric containment atmosphere dilution/cont~inment atmosphere
monitor power supply design discrepancies, single recirculation
loop stress analysis deficiencies, an_d design basis accident
analysis discrepancies in regard to consideration of swing bus
transfer time.
This commitment to self-identification was also
evident through a system engiheer who identified a*self-made
error that had caused a missed Dresden administrative technical
requirement.
The engineering and safety evaluations *prepared
for modifications were thorough And technic*lly sound.
Although
processing delays of problem analysis data sheets existed, those
that were processed were adequate.* Although also at ti.mes
delayed, responses to deviation reports were thorough and
reflected a conservative approach to safety.
Most engineering
work for modifications was completed well in advance of the
planned implementation.
The staffing of the onsite engineering and technical support
groups was insufficient with respect to the work load during
this assessment period.
This was demonstrated by delays in
problem analysis data sheet and deviation report preparation.
Competition of various activities for tec*hnical staff engineer
19
availability was eveTI more pronounced during the Unit 3 refueling
outage.
The licensee recognized this problem and addressed it
with staffing increases throughout the assessment period and
planned additional staffing increases to further address the
problem.
The system engineer staff included positions and responsibilities
that were clearly defined.
The licensee was in a transition
phase; so that while expertise was generally available, it was
not always with the person who had the assigned responsibility.
Th~ LPCI injection val~e stem to plunger separation event
indicated inadequate involvement of technical staff engineers in
immediate problem analysis.
In addition, inadequate system
engineer knowledge in regard to analysis of motor operated valve
test data was evident.
The licensee recognized these weaknesses.
and was attempting to rectify them by providing additional motor
operated valve tr~ining. The licensee also implemented expanded
general systems training for systems enginee~s.
In general, training of non-licensed operators appeared adequate.
Initructors were knowledgeable of their subject area, and
considerable positive feedback was obtained from participants .
. 2.
Performance Rating
The 1icensee*s:performance is rated Category 2 *in this area.
The licensee 1 s performance was rated Category 2 dudng the
previous as~essment period:
3.
Recommendations
None.
G.
Safety Assessment/Quality Verification
1.. *Analysis
Evaluation of this functional area was based on the results of
routine and special inspections, including two AITs, by the
resident and regi~na1 inspectors.
In addition, NRC staff review
of licensee submittals and requests.for amendments to the
operating license was considered.
Enforcement history in this functional area was good with only
one Severity Level V violation.
This violation involved a*
failure to perform an adequate i ndepe_ndent verification.
The
licensee took prompt and effective corrective actions as evidenced
by lack of recurrence .
20
Management's involvement in ensuring quality. was generally good.
Management exhibited good performance in regard to the quality
verification self assessments, as demonstrated by the reduction
in the number of LERs attributed to personnel errors, good plant
housekeeping, and improvement in the station's performance
during non-routine activities such as outages and the return to
service following outages.
Several major audits were conducted
.of the radiation protection area.
The audits were in-depth with
a good mix of programmatic and performance-based review of
activities.
In addition, radiation protection management
participated in audits at other nuclear power plants.
Implementation of the Dresden Station Improvement Plan (DSIP)
continued from the. previous assessment period including changes
near the end of the p~riod to ihift overall responsibility for.
the program to a more in-line function.
These changes were ~ade
as a natural -evolution of the program to place more reliance on
an organizational culture committed to safety and quality
improvements .. A number of beneficial programs evolved from*
or were affected by the DSIP, such as the MIP, Scram/ESF Actuation
Reduction Program and the Top Technical Issues.
The Top Technical
Issues program is a management tool to track and plan resolution
of various eng~neering issues such as improved performance of
systems, components, and overall plant performance.
Various
issues, such .as; drywell cooling, feedwater regulating valve
modifi~ations, and feedwater heat~r leakage were tracked through
~esolution with the Top Technical Issues Report.
The report
maintains a current history of the issue, engineering evaluations,
and ma~agement analysis.
The status of corrective action
- completion is described and maintained current.
Additionally,
- .the daily unit operating performance report, a 1 so prepared by
the technical staff, is used by management to monitor the plant
performance through parameters for various safety and balance of
plant systems, including drywell temperature, recirculation pump
seal temperature and pressure, and feedwater heater drain
temperaturas.
Although still in the implementation phase, the
MIP was utilized in addressing numerous internal and external
mainten~nce ~ffectiveness concerns as described in the
Maintenance/Surveillance section of this report:
The Scram/ESF
Actuation Reduction Program was regarded as an excellent program
to determine root cause and to implement corrective actions
to reduce adverse events.
Most notable was the inclusion of
near misses (half scrams and half isolations) for Scram/ESF
actuation investigation thresholds. The increase in the number
of scrams in this assessment period compared to the previous
period did not r.eflect licensee initiatives in this area, in
that, the licensee extensively addressed each to prevent
recurrence.
Corporate management was frequently and effectively involved in.
site activities as evidenced by critical self:-*assessments
performed by corporate personnel, the BWR General Manager's
21
attendance at the Unit 3 post-refueling outage startup onsite
review meeting, and the rec~nt assignment of a plant specific
cognizant individual from the Vice President-BWR Operations
staff to ensure.corp6rate management awareness of plant activities
- and status.
Management involvement and concern for Technical
Specification compliance was exhibited by *conservative Technical
Specification shutdown decisions involving a failed recirculation
pump seal, a drywell personnel interlock local lea~ rate test
( LLRT) failure, and .HPCI structura 1 support damage.
Management remained well informed and aware of internal plant
activities and* applicable activities at other plants.
Frequent
plant tours by manage.ment encouraged improved cleanliness/
housek~eping conditions ~nd the identification and tracking of
water and oil leaks for repair .. An example of these findings
included the identification of a degraded fire barrier by the
- plant manager.
The monthly status reports evolved into an
excellent management tool for re_maining cognizant and identifying
trends in various departmental indicators.
A riotable exception,
however, was the absence of indic~tors to easily monitor the
effectiveness of the MIP.
-
-
Monthly performance review meetings encouraged non-supervisory"
.
representative participation such ~s to elevate concerhs* to a
higher management level.
These meetings also usually included a
repr~sentative from the Quad Cities plant to extend the ~haring
of experiences._ This .same goal was also addressed by.discussion
of. other CECo plant events during the daily morning meetings.
The.QA-superinte~dents meeting held at Dresden encouraged the
effective transfer of information and included a tour of the
facility and subsequent discussion of observations.
Specific_*
examples of in.corporation of experiences observed at other.
plants included the discovery of pathways not addressed in the
LLRT pro~ram, design basis accident analysis deficiencies, area -
combustible material loading deficiencies, and LPCI swing bus
transfer design deficiencies.
Additional -improved communicati_ons
with plant workers was encouraged during weekly tailgate meetings
which plant management frequently attended.- As such, policies
were well stated, diss~minated and understandable.
The lic~nsee's approach to the identification and resolution of
technical issue_s was excellent.
This was achieved by being
aggressive in creating an environment conducive to problem
identification, a willingness to expend resources to resolve
these i~sues and in most case~ a conservative approach in
regards to safety and compliance.
This approach permeated.the_
working levels as shown by the ~ignificant reduction* in the
number of LERs attributable to personnel *rrors. Of the LERs
i*ssued, .20 percent (8 of 41) were attributed to personnel error
during the previous period compared with 10 percent (5 of 50)
-during this period.
This trend showed improvement over four
"con s*ecut i ve periods. _The 1 i cen see' s cortect fve actions were, in
general~ encompassin~ and ~ffective: However, in one caie~
involving degradation of a fire barri~r, corrective actions were
- fn retrospect too narrow in scope *to prevent a similar occurrence.
22
..
.
- .
.The licensee identified past design problems as described in
section IV.F -0f this report and as indicated by the HPCI drain
pot piping thermal and seismic design discrepancies identified
by a licensee safety system functional inspection.
The licensee
was aggressive in finding, evaluating and conservatively rectifying
difficult equipment proble~s such as the LPCI outboard injection
-valve stem to plunger separationi the HPCI system feedwater
backleakage, and the recirculation pump innef seal cooler.
leakage events.
The licensee applied a low threshold for
issuance and resolution of deviation reports which aid~d in the
identification of and directed management attention toward
specific plant problems~
Th~ licensee's root cause analysis was aggressive and thorbugh
in arriving at the correct conclusions as exemplified by the
licensee's response to the January *16, 1990 loss of off site
power event.
In a few cases, the licensee's r6ot cause analy~is
was initially incorrect, such as th~ main generator reverse
power relay. failures, RPS motor generator (MG) set thermal
overload tiips, and main steam *line radiation monitor locku~s.
These events occurred more than once before the correct root
cause ~as -identified.
These cases were difficult to analyze and
- it was only through the diligence of the 1 icensee that' correct
root causes were eventually determined.
Special investigation~
coordinated by the licensee's regulatory assurance organization
for issues such as the grease discovered on the torus to reactor
- ,building* v~cuum breaker check valve seats were tho~ough and
comprehensive.
Management Is ability to. recognize and address adve.rse trends was
exemplified by the licensee's February 25, 1990 Unit 3 50
percent power plateau ~pecial review after the post-refueling
outage start up and. the licensee 1 s efforts to i ncreas.e the size
of the plant technical staff .. QA audits .were scheduled, based
on audit and assessment experience fo the prev.i ous year, to
effectively target problem are~s.
S~veral proposals to meet
requirements presented in initial lic~nsirig submittals were not
conservative with regards to safety.
These included station
blackout (SBO), wetwell venting, and post-accident hydrogen
control.
The initial response to the SBO rule did not significantly
improve the reljability of onsite or offsite power systems.
S~bsequent submittals and discussions r~sulted in the addition
of a diesel generator to improve the reliability of onsite
power.
This resolution wh~ch is under staff review, appears to
meet the SBO Rule.
The licensee's responsiveness to NRC initiatives was good.*
Respqnse to generic letters, bulletins and info.rmation notices
were timely.
On occasion, time extensions for responding to
regui'atory actions were requested and made.
These requests
resulted in a more comprehensive response.
A quality assurance
surveil 1 a rice conducted as a res1Jl t of NRC ,.conc_erns about an
.
.
23.
upward trend in outstanding control room work requests resulted
in specific actions to address and resolve the problem.
Another
exampl~ consisted of actions taken, including increased QA
~igilance and QC involvement, due to NRC concerns regarding
contractor control in the.previous assessment.
This resulted in
the on-schedule completion of the Unit 3 refueling outage with
few problems.
This was also aided by an increased emphasis on.
planning and staging of activities during the outage.
On a few
occasions, responsiveness to followup actions was not good.
Th~se included licensing resporise to the Salem ATWS Item 4.5.3,
the masonry walls, and the post-accident hydrogen generation
issues. The licensee's responsiveness was good with respect to*
allegations regarding unsealed fire openings inside conduit
- penetrations in fire walls and pyrocrete covering polyurethane
in fire walls.
The licensee, in general, expedited thorough
responses to various inquiries originating with the NRC regional
and NRR staffs.
Licensee management at several levels aggressively
pursued continued good communicati~ns with the NRC resident
inspectors and NRR staff with the intent of sharing and resolving
concerns.
The licensee's Nuclear Tracking System ensured that
NRC findings and commitm~nts were a~propriately*proce~sed.*
Staffing as well
a~ the effectiveness of the training and
qualification ~rogram was excellent.
The licensee's site*QA and
QC organizations were staffed to ensure experience in a wide
range of disciplines .. The QA organization was c6mmitted to the
evaluatiori of ope~ational activities by having QA engineers.with
SRO licenses.
In addition, the QA supervisor was :experienced in.
radiatio~ prote~tion. The QA org~riization was especially
effective through.the performance of in-depth audits and
.surveillances ~f emergency preparedness, radiation protection,
and securiti activities.
On a routine and as needed basis, QA
also conducted reactive surveillances .. The seep~ and quality of
the audi*ts/surveillances were good in assessing technical
performance, compliance with NRC requirements, and training of
security personnel.
Licensee responses to QA security findings*
were timely and technically sound.
The auditors involved in
security were qualified and competent to perform their audit
responsibilities.
The licensee secur1ty organization also
established an internal audit function to supplement QA review
activities.
Both audit organization~ ~ere positi~e contributing
factors to the security organization's per.formance.
However,
the QA audits in the main~enance are~ were found not to be*
performance based during the first half of the period.
The
audits improved, in general, during the last half of the period
by incorporating a performance based m.ethodology.
The onsite
review committee was appropriately staffed with qualified
individuals ~esulting in generally comprehensive and thorough
reviews.
The Nuclear Safety Gr~up exceeded.Technical Specification
requirements by including an onsite as well as the required
offsite contingent.
The Nuclear Safety Group conducted quarterly
24
(
meetings with plant management to discuss recurring events,
corrective action evaluation and the results of various other
Nuclear Safety Group reviews.
This group was effective in
identifying adverse trends such as the timeliness of deviation
report processing.
Corporate assessments were conducted by
knowledgeable individuals. Management attention was directed
toward improvement in the QC group as exemplified by a staffing
increase and additional job s~ecific trainin~. The increased
competence of this group was shown by the ability of the QA
organization to release certain oversight functions back to the
QC group such as radwaste shipment reviews and receipt inspections.
Additionally, the QC organizational improvements resulted in
effective oversight of outage activities and an overall reduction
of *errors.
2.
Performance Rating
The licensee's performance is rated Category 2 improving in this
area.
The licensee's performance was rated Category 2 improving
in the previous assessment period.
3.
Recommendations
None.
~------
25
..
.. -*
v.
Supporting Data and Summaries
.A.
Licensee Activities
1.
Unit 2
Dresden Unit 2 began the SALP assessment period in a scheduled
maintenance outage, whi~h began on October 30, 1988.
Unit ~ was
returned to service from this outage on February 21, _ 1989, after*
which, the unit operated routinely at varied power levels
throughout the majority of the SALP assessment period including
reduced power loads and several short outages for maintenance,
surveillance and equipment repairs.
Unit 2 ended the SALP
operating routinely at full power.
Dresden Unit 2 experienced 12 ESF actuations (~ncluding two .
safety injection signals) and four automatic reactor scrams.
Three scrams occurred as the result 6f equipment failures, and
one was the result of a personnel error. * *
...
Significant outages and events ,which occurred during the SALP
assessment period are summarized below.
Significant Outages and Events
a.
- During October 30, 1988 through February 21, 1989, Unit.2
was shutdown for i~s el~venth refueling outage.
.
.
- b.
On March 4, 1989, Unit 2 scrammed due to the 1 oss of
reactor feedwater pump oil pressure control circuitry
duririg the 125 VDC battery ground checking. * Adjustments
and repairs were made, and the unit was returned to
service on Mar~h 6,
1989~
c.
d.
e:
During March 16~11, 1989, Unit 2 was shutdown *to perfori
. ov_erspeed trip setpofnt tests.
On July 12, 1989, Unit 2 scrammed due to a main steam line
(MSL) radiation moni~or spurious signal .. *The
11A
11 MSL
radiation monitor was replaced, and ~he unit was returned
to service on July 14, 1989.
On December 10, 1989, *un.it 2 shutdown for a planned maintenance
outage and restarted on December 20, '1989;
The major
activities inclu~ed facility testing of batteri~s.
On December 22, 1989, Unit 2 was separated from the grid
due to seal oil backing up into the generator casing.
It
was determined that a clogged seal oil fl oat trap caused
oil to overflow the hydrogen seal oil drain enlargement,
resulting in tiil backing up int6 the generator casing.
The unft was back on line December15; 1989.
26
..
g.
On January 5, 1990, Unit 2 experienced an automatic reactor scram as the result of procedural deficiencies
during a surveillance test such that inadequate controls
were provided to prevent a potential pressure transient .
.The unit was back on line January 10, 1990.
h.
. On January 16, 1990, Unit 2 experienced an automatic
_
reactor scram and a loss of offsite power as the result of
~ condensate ~ump failure and 'subsequent low vessel level.
The unit was returned to service on Ja*nuary 23, 1990.
2.
Unit 3
Dresden Unit 3 began the SALP assessment period operating at
approximately 97% power.
On December 3, 1989, refueling
activities began~ following a continuous operating run of 185
days.
Unit 3 was returned to service on February 10, 1990, and*
operated routinely through the remainder of the assessment *
period.
- Dresden. Unit 3 experienced three ESF actuations (including one
safety injection signal) and four autcimatic reactor scrams~
- All of the scrams occurred as either the result of equipment
.failures or spurious sign~ls during testing.
Significant outaQes and events that occurred during the SALP
assessment period are summ.arized below.
Significant Outages and Events
a.
On March 25, 198~, Unit 3 ~crammed and experienced a loss
of offsite power as the result of a 345-kV breaker
failure .. The unit was return~d to service on March 27,
1989.
- b.
On March 30, 1989; Unit 3 experienced an automatic scram
due to a MSL radiation monitor spurious signal dur~ng RPS
EPA testing.
'Th~ unit was returned to service on April 1,
1989;*
c.
d.
e ..
On Aprii 15,* 1989, Unit 3 scrammed during turbi~e testing
a_s a result of a defective master-slave relay contact on
the No. 2 turbine stop valve.
The relay was replaced and.
the unit was returned to servfce on April 17, 1989.
During May 5-31, 1989, Unit 3 was shutdown for a scheduled
maintenanc~ outage to replace the degrading unit mai~
transformer.
During December 3, 1989, through Febn1ary 11, 1990, Unit 3
was shutdown for a scheduled refueling o~tage. The unit
completed a 185 continuous operatirig"run prior to the
outage.
27
....
f.
On February 11, 1990, Unit 3 was shutdown as a precaution
due to seal leakage on the B reactor recirculation pump.
The seal was verified to be operational and the unit was
returned to service on February_ 23, 1990.
g.
On March 10, 1990, Unit 3 scrammed as* a result of a MSIV
pilot air line failure.
The direct line was replaced and
other air lines were inspected .. The unit was returned to
service on March 11, 1990.
B.
Inspection Activities
Thirty~five inspection report5 are discussed in this SALP Report -
(February l, 1989 through April 30, 1990) and are listed in
Paragraph 1 of this section, Inspection Data.
Table 1 lists the
violations by fonctional areas and severity levels.
Significant
inspection activities are listed in Paragraph 2 of this section,
Special Inspection Summary.
1.
Inspection Data
Facility: Dresden Nuclear Power Station
Unit 2 Docket No.:
050-00237
Inspection Reports No.:
89005 through 89008, 89010 through
89026, and 90002 through 90012
Unit 3 Docket No.:
050-00249
Inspection Reports No.:
89005 thr6ugh B9026, and 90002 through
9001.1
-
TABLE 1
Number of Violations in Each Severity Level
Unit 2
Unit 3
Common
Functional Areas
III
IV
v III
IV
v
III
IV
v
-
a.
Plant Operations
1
1
b.
Radiological Controls
-
.1
c.
Maintenance/Surveillance -
1
2
1
d.
-
e.
Security
2
1
f.
Engineering/Technical
Support
1
g.
Safety Assessment/
Quality Verification
1
Unit 2
Unit 3
- .Common
- . '.*.' . ~--*' .
TOTALS
III
IV
v-
III
IV
v
III
IV
v
2
2
.;..
6
2
28
....
2.
Special Inspection Summary
Significant inspections conducted during the Dresden SALP 9
assessment period ar~ listed below:
a.
b.
c.
d.
e.
On March 25~26, 1989, a team inspection was ccnducted as a
result of the Unit 3 scram and loss of off site power on
March 25, 1989 (Inspection Report Nos. 237/89005;
249/89005).
.
During April 17-21, 1989, a team inspecti~n**of the EQ
program was conducted (Inspection Report Nos. 237/89010;
249/89009).
.
.
During April 24-25, 1989, a special inspection of the
emergency ~reparedness program was conducted (Inspection
R~port Nos. 237/89014; 249/89013) ..
During July 31 - August 4, 1989, a team Regulatory
Effectiveness Review was c~nducted (Inspection Report
Nos. 237/89024; 249/89023).
During Octobe~ 31 - November 3; 1989, a team inspection of
the emergency preparedness exercise was conducted
(Inspection Report Nos. 237/89021; 249/89020) .. '*
. f.
DuriAg November 1-4, 1989, an-augmented inspectton team
inspec.tion_of the Units 2 and 3 HPCI waterhammer:events was
conducted (Inspection ~epor~*Nos. 237/89023; 249/89022).
g.
h.
i .
During January 9-24, 1990, an inspection of the emergency
preparedness program was .conducted (Inspection Report *
Nos. 237/90002; 249/90002).
During January 17-20, 1990, an augmented team inspection
of the Unit 2 January 16, 1990 loss of offsite power event
was conducted (Inspection Report No. 237/90004)
During April 10-13, 1990, a team. inspection Qf the
emergency preparedness exerciie was ~onducted (Inspec~ion
Report Nos. 237/90007; 249/90008). *
C.
Escalated Enforcement Actions
None.
D.
.Confirmatory Action Letters (CAL)
A CAL was issued on January 17, 1990, (CAL RIII-90-001) addressing
the root cause determination and corrective actions associated with
the Unit 2 reactor ~cram and loss of offsite p~wer ..
29
E.
Review of Licensee Event Reeorts (LERs}
Collectively, 50 LERs were issued during this SALP assessment
period, in accordance with NUREG-1022 guidelines.
Unit 2
LER Nos.:
89001 through 89032, and
90001 through 90003.
Unit 3
LER Nos.:
89001 through 89011, and
90001 through 90004.
Table 2 below, shows cause area counts by unit:
- Table 2
Number of LERs by Cause
- Cause Areas
Unit 2
Unit 3
Personnel Errors
2
3
Design Deficiencies
8
2
External
1
1
Procedure Inadequacies
10
4
Equipment/Component ..
13
5
Other/Unknown
0
1
TOTALS
34
16
Table 3 below shows a cause code comparison of SALP 8 and SALP 9:
Table 3
SALP 8
SALP .9
(12 Mo.)
.( 15 Mo.)
Cause Areas
No.
Percent
No.
Percent
Personnel Errors
8
19.5
5
10.0
Design Deficiencies
3
7.3
10
20.0
External
0
0.0
2
4.0
Procedure Inadequacies
11
26.8.
12
24.0
Equipment/Component
17
41. 5
20
40.0
Other/Unknown
2
4.9
1
2.0
--
TOTALS
41
100%
50
100%
Frequency LERs/Mo
3.4
3.3
NOTE:
- The above LER information was derived from the:~evi~w of LERs
performed by the NRC staff, and may' not coincide with the licensee's
cause code assignments per NUREG-1022 guidelines.
30