ML20217D476
| ML20217D476 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 07/31/1996 |
| From: | Capra R NRC (Affiliation Not Assigned) |
| To: | Mccree V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20217D413 | List: |
| References | |
| FOIA-97-178 NUDOCS 9710030239 | |
| Download: ML20217D476 (120) | |
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- LIMITED OFFICIAL USE ONLY - d)Y July 31, 1996 -
C = 1ssion Briefina Paner NEMORANDUM T0. Victor M. McCree, Chief Regional Operations Staff Office of the Executive Director for Operations --
FROM: Robert A. Capra Director Original signed by Project Directorate III-2 Robert A. Capra Division of Reactor Projects - I!!/IV Office of Nuclear Reactor Regulation
SUBJECT:
COMONWEALTH EDISON COMPANY EXECUTIVES, MR. JAMES O'CONNOR AND MR. MICHAEL WALLACE, VISIT WITH CHAIRMAN JACKSON Mr. James J. Wallace visit with ChairmanJ.
(Senior ViceO'Connor President Nuclear Jackson on August 13, (Chairman and Strategic Services 1996.
haveChief scheduledExecutive a Off s
Enclosed is a background briefing package in preparation for the meeting. The purpose of the visit is to discuss the recent organizational changes at Comed and the company's management focus for the immed< ate future.
The following items are enclosed in the briefing package:
Names and Resumes of the Comed Officials Expected Topics for Discussion by Comed
- Corporate Organization Chart Background of Comed Plant Performance e
Current Issues and Concerns
- Points to be Emphasized Recent Performance Assessments for each Site should you require any adettional information, please contact either me (415-1395) or Mr. George Dick (415-3019).
DISTRIBUTION:
Docket Nos.50-010 STN 50-454 STN 50-455, P0lll-2 r/f RAssa STW 50-456, STN 50-457, 50-237, BClayton, RIII DSkay 50-249, 50-373, 50-374, 50-254, RPulsifer CMoore
- 50-265, 50-295, 50-304 CShiraki J$ tang PHiland, RIII IBlynch Attachments
- As Stated MWebb, 011820 : EDick WAxelson, RI!! RCapra cc: W. Russell LMiller, RIII F. Miraglia JCaldwell, RIII M.Satorius, 07H5 BJorgensen, RIII R. Zisseman A. Thadani J. Roe.
y H. Miller, R-!!! /}
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DATE 07/St/96 07/5//96 " 07/3 //96
)DCUMENT L'?.E: G:\896 COMED.VST OFFICIAL RECORD COPY NSE PARADIS97-178 PDR
- LINITED 0FFICIAL USE ONLY -
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. \] UNITED STATES
- . W E NUCLEAR REGULATORY COMMISSION Q'e- l wAswiwatow, o.c. samaaos
' % ,', ' , # July 31, 1996 Camission Briefina Paper MEMORANDUM TO: Victor M. McCree, Chief Regional Operations Staff Office of the Executive Director for Operations FROM:
Robert A. Capra,!!!-2 Project Directorate Director T w g, ( W Division of Reactor Projects - !!!/IV Office of Nuclear Reactor Regulation
SUBJECT:
COMMONWEALTH EDISON COMPANY EXECUTIVES, MR. JAMES O'CONNOR AND MR. MICHAEL WALLACE, VIslT WITH CHAIRMAN JACKSON Mr. Jaws J. O'Connor (Chairman and Chief Executive Officer) and Mr. Michael J. Wallace (Senior Vice President Nuclear Strategic Services) have scheduled a visit with Chaiman Jackson on August 13, 1995.
Enclosed is a background briefing package in preparation for the meeting. The purpose of the visit is to discuss the recent organizational changes at Comed and the company's management focus for the imediate future.
The following items are enclosed in the briefing package:
Names and Resumes of the Comfd Officials Expected Topics u r Discussion by Comed
- Corporate Organization Chart
- Background of Comed Plant Perfomance Current Issues and Concerns
- Points to be Emphasized Recent Performance Assessments for each Site Should you require any additional information, please contact either me (415-1395) or Mr. George Dick (415-3019)..
Docket Nos.50-010 STN 50-454, STN 50-455, STN 50-456, STN 50-457, 50-237, 50-249, 50-373, 50-374. 50-254, 50-265, 50-295, 50-304 Attachments: As Stated cc: W. Russell F. Miraglia R. Zimmerman A. Thadani J. Roe H. Miller, R-Ill B. McCabe
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JAMES J. O'CONNOR Chairman and Chief Executive Officer EXPERIENCE a
Unicom/ Commonwealth Edison Company Present 1980 Chairman and Chief Executive Oflicer 1980 1978 Member of Board of Directors 1978 - 1977 President 1977 1973 Executive Vice President 1973 1970 Vice President 1970 1967 Assistant Vice President 1967 1966 Division Commercial Manager at Chicago North 1966 - 1963 Staff Assistant to the Chairman of the Board and Chairman of the Executive Committee l
- Un!ted States Air Force 1963 1960 Three years of active duty EDUCATION .
JD Georgetown Law School,1%3 MBA - Harvard University,1960 i
BS Holy Cross College, major in economics,1958 PROFESSIONAL AFFILIATIONS
. Director of Nuclear Energy Institute, Chairman of the Advance Reactor Corporation Director of Edison Electric Institute, past Chairman Board of the Institute of Nuclear Power Operation, past Chairman
.' tember of Board of Directors of American Nuclear Energy Council 9
ATTACHMENT 1
4 MICilAEL J. WA LIACE 4
Senior Vice President Nuclear Strategic Services
}3PERIENCE
- Commonwealth Edison Company ,
Present 1996 Senior Vice President Nuclear Strategic Services 1993 1996 Senior Vice President and Chief Nuclear Officer 1993 1993 Vice President, Chief Nuclear Of0cer i 1993 1992 Vice President, Chief Nuclear Operating Omcer 1992 1990 Vice President, Nuclear PWR Operations 1990 1989 Manager of Engineering and Construction 1989 1987 Manager of Projects and Construction Services 1987 1982 Assistant Manager of Projects, and Braidwood Project Manager 1982 1981 Superintendent, Waukegan Station 1981 1979 Assistant Superintendent, State Line Station 1979 1978 1 toject Coordinator, Byron Project 1978 1977 Field Cost Engineer, LaSalle, Byron, and Braidwood Projects 1977 1974 Quality Assurance Engineer, NSSS Programs
- United States Navy 1974 1969 Line Officer, Nuclear Submarine Force U.S. Navy EDUCATION
- MBA University of Chicago,1978 BS Marquette University in Electrical Engineering,1969 OTIIER OUALIFICATIONS Registered Professional Engineer PROFESSIONAL AFFILIATIONS Advanced Reactor Corporation, Vice President Commonwealth Research Corporation, Vice President and Director
EXPEC1ED TOPICS FOR DISCU$5!0N BY COMED Deregulation and Industry Restructuring Probable Changes in the Industry
+ Organizational
+ financial Role of the Industry's Regulators l
- Decommissioning
(
Current Sufficiency of Funding Regulation of Additional Financial Assurances Use of mixed oxide fuels from excess weapons grade piutonium 4
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i j BACKGROUW INFORMATION ON COMED i
! Commonwealth Edison Company (Comed) underwent a restructuring in June 1994,
! whereby it became a wholly owned subsidiary of Unicos. The purpose of the -
i restructuring was to permit the company to operate in an unregulated
- environment. Comed has 12 operating units at six sites and one unit in
- SAFSTOR.
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! In recent years, the performance of Comed plants has been inconsistent and a 4 concern to the NRC. Comed had traditionally promoted from within and as a i result benefitted little from outside experience. During its ambitious plant .
i construction program during the 1970's and early 1980's, many of the company's l j more talented managers were moved from site to site to complete construction :
- and get the units licensed and started up. LikwHse, corporate attention and 1 resources were focused on the newer units while thry were in the latter stages 3 of construction and licensing. As a result, the older plants generally got i fewer resources and less qualit management attention. Plant material condition and operating standa s and practices declined.
! SECY-92-228, ' Performance of Commonwealth Edison Company Plants," dated
- June 25, 1992, described Coned's major weaknesses. These weaknesses were:
l (1) lack of effective management attention and application of resources' [2)
! weak corporate oversight of nuclear operations; (3) poor problem recognltnon j and failure to ensure lasting corrective actions; (4) lack of adequate i
j engineering experiences atsupport; other Comed and (5)ites s and other utilities.an inability or reluctance to learn fr; a
l In recent years, the cyclical performance of Comed plants has concerned the Commission and NRC staff. Dresden was on the Watch List from June 1987 until 4
i December 1988 and was returned to the Watch List in January 1992. Zion was
! on the Watch List from January 1991 until January 1993; however, the rate of 1 l performance improvement was not sustained. Declining performance at Quad 1 Cities was discussed at the June 1991 and June 1993 SMMs; a Diagnostic l Evaluation Team (DET) assessment was performed there in the fall of 1993.
! Both Quad Cities and LaSalle were issued Trending Letters in January 1994 and again in June 1994. Significant problems were even noted at Dresden, Urtit 1,
! . which was permanently shut down in 1978. In January 1994, a significant i freezing event on Unit 1 identified a number of management oversight weaknesses. In January 1995, Quad Cities received a third Trending Letter and
' LaSalle was removed from the Trending category. Braidwood has been an average performer; however, personnel and equipment problems are staff concerns.
i Byron's performance has been excellent and it was identified as a Good
- Performer at the January 1994, June 1994 and January 1995 SMMs. Presently i Dresden is the only one of the Comed plants on the Watch List. However, the i performance at LaSalle, Quad Cities, Zion, and Braidwood remains a staff l concern.
i Only within the last several years has Comed begun to take significant steps to improve performance. These steps included reorganizing to clearly establish responsibilities for plant operation and oversight; increasing the
} company's engineering capability; improving craft skills; benchmarking their
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performance against other utilities; and management individuals from outside the co(maybe most importantly) mpany. -Among hiring those hired were several corporate vice presidents, site vice presidents p various senior and mid-level plant management individuals.lant managers,-and A number of the managers hired early in this process had no experience in improving the performance of problem plants and were not effective in doing so at Comed.
This resulted in numerous senior management changes at the poorer performing plants.
Comed has continued to make organizational changes. In April 1996. Thomas J.
Maiman was selected to replace Michael J. Wallace as Senior Vice President for oversight responsibilities of Cosmonwealth Edison Company's Nuclear Division and reports directly to the Chairman, Mr. James J. O'Connor. Mr. Wallace was named as the Senior Vice President of Nuclear Strategic Services.
Mr. Wallace now has responsibility for nuclear fuel procurement, the storage of low-level and high-level radioactive waste, developing competencies for the decommissioning of Comed nuclear plants and other nuclear strategic services.
He is also responsible for Comed's strategic nuclear alliance with other corporations and for operations at Cotter Corporation, the company's uranium and mill operation.
Prior to being selected to relieve Mr. Wallace, Mr. Maiman held various senior management positions in the consany's Fossil Division and Commercial Division.
Prior management positions in tie Nuclear Division included Vice President of PWR Operat'ons and Vice President and Manager of Projects for construction of the Byron /Braidwood Stations.
Chief Nuclear Operating Officer, Harold W. Keiser, continues to be responsible '
for the day-to-day operations of all six Comed nuclear stations. Mr. Keiser joined Comed in December 1995 after serving in a similar position as Chief Nuclear Officer and Executive Vice President of Entergy Operations Inc. In March 1996, Mr. Keiser accepted the position of Chief Nuclear Operating Officer thereby eliminating the Senior Vice President for BWR and PWR operation positions. Mr. Steve Perry, formerly the Senior Vice President for BWR operation, is now the full-time Site Vice President at Dresden Station.
Functions that support day-to-day operations (e.g., engineering) report to Mr.
Keiser. Support functions of a planning and strategic nature continue to report to the Senior Vice President of the Nuclear Division, Mr. Maiman.
One of Mr. Keiser's primary areas of focus is in assessing and improving management's effectiveness at each of six nuclear sites and bringing in outside talent where needed. On May 25, 1996 Mr. H. Gene Stanley relieved Mr. Karl Kaus ss Site Vice President for Braidwood Station, and on August 5, 1996 Mr. Josn Mueller will join Comed to assume the position of Site Vice President for Zion Station, replacing Richard Tuetken. Prior to joining Comed, Mr. Stanley was the Vice Pres' dent for Nuclear Operations at the Susquehanna Nuclear Station. Mr. Mueller was Chief Nuclear Officer for Nebraska Public Power District's Cooper Station.
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3 Mr. David A. Sager, previously Vice President for Florida Power and Light's St. Lucie plant joined Comed in June 1996 as Vice President for Generation Support. Mr. Sager oversees functions that directly support plant operations. -
including maintenance support, regulatory assurance, and health physics.
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Current Issues and Concerns
'* Most Recent SAlp Scores ElAg SALP Period 'LP Scores (1)
Braidwood 02/94-09/95 2.2.2.1
- Byron 03/93-08/94 1.1.1 Dresden 08/93-03/95 3,2,3',2 LaSalle 06/93-11/94 2,3,2,3 Quad Cities 12/93-07/95 2,3,2,2 Zion 05/94-12/95 3,2,2,2 NOTES: (1) Operations, Maintenance, Engineering, Plant Support
- Plant Performance l Comed still faces significant operational challenges. During the last i
3 years, the licensee has implemented both corporate and site reorganizations and has brought in considerable management talent from outside Comed. Older stations (Dresden, Quad Cities and Zion) continue to be challenged by longstanding material condition and human performance problems. These problems also exist at LaSalle.
Cuad Cities is making progress in raising standards and accountability, most notably in conduct of operations in the control room. Performance of personnel in other areas warrants continued attention. The most recent refueling outage on each unit significantly improved some major-equipment deficiencies. The Unit 1 outage which started on February 10, 1996, was nearing completion at the time of the May 10, 1996 tornado event. Both units have remained shutdown since then to address numerous s engineering issues identified in response to enforcement action. The maintenance backlog remains high, the work control process has been ineffective, and material condition needs further improvement. Some recent safety equipment performance problems were due to ineffective root cause evaluations (HPCS, RCIC, emergency diesel generator reliability).
Following a January 1994 pipe rupture / freezing event in the unhested Dresden, Unit 1, containment, a special NRC team inspection identified a pattern of declining management oversight at the facility. Escalated Enforcement Action was taken and a $200,000 civil penalty assessed. In response to the event, Comed has taken a number actions including forming a Decommissioning Project Team to manage the plant activities and assure adequate configuration control, providing heating to areas inside containment to ensure that the spent fuel pool would be protected from potential freezing accidents, draining and isolating fluid. systems that entered the containment sphere, conducting an extensive cleanup of the spent fuel pool, and improving the quality of the water in the pool
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by installing a new filtration and domineralization system. In response
, to NRC concerns about the detection of tritium in the underground water 4 at Dresden, Unit 1, from the spent fuel pool, Comed conducted an environmental evaluation of the pool's integrity and exper.ded its well monitoring profiras both onsite and offsite. Comed has infomed the staff that it 'ntends to use dry cask storage for the Dresden Unit 1 q fuel.
! Operation of both units at Dresden has been a struggle over the past six j months. Material condition problems have contributed to both units i being shutdown. In May 1996, a feedwater control valve failed on Dresden, Unit 3, resulting in an automatic plant scram. The NRC conducted an AIT of the event. the licensee discovered a J failed 4160 voit safety related breaker. In June 1996,h Bot units are currently shutdown while the licensee refurbishes all 4160 volt breakers in both i units. Dresden, Unit 2, completed a 10 month refueling outage in April
, 1996 in which many safety related material condition issues were j completed. The conduct of operations in the control room has been good;
'uel load activities durinfi the Unit 2 outage went well. However,
. p rsonnel performance outs'de the control room continues to demonstrate i watk configuration control indicating that performance and expectations
{ ara still not fully understood and implemented by the work force.
- Anadequate control of work activities while performing modifications on j the reactor feedwater level control system led to a manual scram on Nay 31, 1996. Maintenance has struggled and efforts to improve the work
' control process have not been successful. Some improvement in Engineering Support to the station has been noted. Performance in the
! area of Plant Support has been good with respect to security; however, weak performance in radiation protection continues. As a result of a
- decision made during the June 1996 Senior Manager Meeting regarding the licensee's failure to demonstrate a sustained improvement in
, performance, an Independent Safety inspection will be conducted in the l ,
fall of 1996, t
! Comed has tried to address problems at Zion with a management team that j is a mix of long time Comed employees, retirees from the Navy, and from
! other utilities. While performance is now improved from that in the l
1990 time frame (when the NRC perfomed a DET assessment), it has
! stagnated for the last few years. Operational errors and slow progress in correcting a large backlog of material condition problems are the l NRC's most significant perfomance concerns at Zion. The concern
~ regarding personnel errors, ptrticularly among licensed operators and l auxiliary operators resulted in an enforcement conference on July 17,
! 1996 and has led the staff to schedule an Operational Safety Team
! Inspection. In August 1996, John Mueller, formerly the Chief Nuclear i Officer at Nebraska Public Power District's Cooper Nuclear Station (CNS), will replace Richard Tuetken as the Site Vice President of Zion
!. Station. Prior to assuming his responsibilities at CNS, Mr. Mueller was
} the Plant Manager of Nine Mile Point Unit 2 (NMP 2). .
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3 Lasalle has brought in several capable managers from outside Comed and generally there has been slow, but steady improvement in material condition. Inefficient work control processes and weak engineering
- support have contributed to the slow rate of improvement. The recent Unit I refueling outage addressed several significant material condition deftetencies and design weaknesses. Management has been attempting to upgrade operating standards similar to Dresden with some success. The biggest challenges at LaSalle are material condition and personnel performance. Both units were shut down recently for 2 weeks as a result of foreign material in the service water tunnel that caused plugging of the non-essential service water strainers with the potential for inoperability of all essential and non-essential service water. The event was caused by poor work control and poor licensee knowledge of the l
facility. The staff conducted an MT as a result of this event. During the event and subsequent cleanup, the licensee demonstrated poor safety focus resulting in incorrect root cause end operability determinations.
l The NRC had to influence the licensee to take conservative corrective i
actions and subsequently issued two Confirmatory Action Letters to the licensee.
Braidwood, long considered a better than average performer, exhibited performance problems, beginning about 18 months ago due to declining material conditions, problems with poor craft capability, configuration control (control of equipment lineups), engineering, and corrective actions. Since then, the licensee has made several key management changes; specifically the selection of a new Site Vice President with
, previous nuclear utility experience and a slant manager with successful experience at Byron. This new management ins initiated efforts to resolve material condition and configuration control problems. The effectiveness of these efforts is not yet determined, but it appears that the downward trend may have stepped and the station may be on its initial stages of improving conditlens.
Byron is a good performer. Although it has lost several key management individuals to other Comed stations no change in performance has been evident.
RESOUR(ES Recently, the company provided an accelerated 1996 improvement program which provided increased funding (0 & M and Capital) for all six stations. The funding is primarily focused to improve longstanding material condition deficiencies with a large fraction going to Zion and LaSalle to fix poor designs.
- Steam Generators The tubes in the steam generators (Westinghouse Model D-4) at Byron.
Unit 1, and Braidwood, Unit 1, are subject to outside diameter stress corrosion cracking (00SC0) at the tube support plates (TSPs), it is believed that the ODSCC at the TSPs is attributable to the use of carbon
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steel TSPs, the type of crevice between the tube and TSP, and prior secondary side chemistry control. in addition, circumferential crack indications units, were discovered the majority of them ininByron tubes in the1.tubesheet area for both Unit All tubes with such indications were either sleeved or plugged. As a consequence Byron Unit 1, operating with an effective steam generator tube plugging value of 17% is limited to less than 100% power, Byron, Unit 2, and Braidwood, Unit 2 have Westinghouse Model D-5 steam generators which have not shown ev\dence of accelerated tube degradation.
The licensee's long-ters solution is to replace the steam generators; Byron is scheduled to be done in the spring of 1998 and Braidwood in the fall of 1998 In the short ters, the licensee is taking steps to safely maintain as high a power output as possible with the degraded steam generators. At present the Itcensee is required to rcpair or remove from service those tubes that have eddy current voltages greater than 3 volts and all tubes with circumferential crack indications. The staff approved the 3 volt criteria based on the expansion of selected tubes into the TSPs event of a maln steamline break.thus preventing _ a rupture of any degraded tubes in Technical Sotsification Unarades All of the Comed sites,are upgrading their Technical Specifications (TS). Dresden and Quad Cities which had custom TS recently converted to the old version of the Standard TS. Zion is converting to the Improved Standard Technical Specifications (iSTS) with full implementation scheduled for the fall of 1996. Applications from Byron, Braidwood, conversion to iSTS are expected in September 1996. The LaSalle submittal is expected in October 1996.
Emeraency Ooerations Facility (EOF)
In February 1996, the staff approved the use of the corporate EOF in Downers Grove as an interim EOF until the nearsite EOF is activated.
Because the corporate EOF is more than 20 miles from any of the Comed sites, Commission approval was required for the change. The licensee now has a request in front of the staff to approve the consolidation of the nearsite EOFs into one single EOF located at Downers Grove.
Approval of this change, if recommended by the staff, will alst, require Commission approval.
Use of Mixed Oxide Fuel Comed in partnership with Duke Power has responded to DOE's request for expression of interest by indicating an interest in burning excess weapons plutonium as mixed-oxide (M0X) fuel. Comed has pro Byron, Braidwood, r.nd LaSalle as sites for use of the fuel. posed using Comed /Ouke have aligned themselves with France's Cogema to study the burning of plutonium in PWRs and with British Nuclear Fuels to study burning M0X fuel at LaSalle. DOE is expec bd to issue a final Programmatic
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5-4 Environment Impact Statement in the fall of 1996 and a Record of .
Decision regarding its preferred method for disposition of plutonium by the end of 1996. If the decision is made to proceed with the use of -
existing reactors, Comed is expected to participate in a test program i
followed by the use of M0X fuel at its sites. The NRC staff has informed the industry that the use of M0X fuel in a commercial reactor will require staff review and an amendment to the Itcense. In addition to the normal safety analyses, licensees will have to address the sufficiency of the methods used to predict performance of MOX fuel potential for interactions of MOX fuel with low enriched uranium, a,nd methods to identify and respond to anomalous performance of the MOX fuel.
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points to be Emphasized Dresden and Quad Cities Material condition & Human Performance laproyaments Needed ,
While steps have been taken at Dresden and Quad Cities to improve -
. material condition over several years and management changes have been made, Comed has a long way to go on these plants. The Quad Cities management team has made good progress in resolution of major plant deficiencies while the Dresden management team has yet to prove itself.
Significant work remains to fully resolve equi ment, technical s@ port and work control issues. While both stations gave made some progress in improving human performance standards and accountability (e.g., recent steps to improve control room standards sustained management attention i and stability are critical to achieve ne)eded station-wide, lasting change.
- Iion Proaress Slow 1
While equipment and personnel performance at Comed's other older station (Iton) has not recently declined to the level of Dresden and Quad Cities -in some respects progress has been slower. Because of concerns with the slow progress in correcting material condition problems and recent control room operational performance, we are closely evaluating the effectiveness of the new management team.
Maintain Attention on LaSalle
' LaSalle has made slow, but steady improvements over the last year.
However, equipment problems and poor original design issues continue to challenge the operators. In addition, recent incidents resulting from personnel errors may indicate the need for Comed management to arrest any declinin performance,g trend in performance and continue to improve its e Material Condition at Braidwood We are concerned that Comed has allowed material condition to degrade at Braidwood, their newest plant. Weak engineering and corrective actions, high threshold for identifying problems, and lack of questioning attitude by most plant disciplines have led to a gradual decline in overall plant performance. Comed management has begun to address this situation. It is too early to evaluate the effectiveness of their actions; we will continue to closely monitor the licensee's activities.
. Many Manaamment Chances Could Affect Byron Performance Byron has had numerous management and staff personnel changes over the last couple of years. Many of these individuals have taken positions at
- the poorer performing plants. To date, it does not appear to have adversely affected Byron's performance, but we will continue to monitor it.
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- Maintain Focus on Plant Performance
' Comed needs to maintain a managene.it focus on plant perform:t.ca and .
ensure that resources are used to see improvement programs through to the end. Too often, the Itcensee has ' declared victory' too soon and abandoned programs prior to completion or changed the management team
, too quickly n ter improvements were noted (e.g., Zion).
o Na'ntain Strona Manaamment Oversicht in Decentraltration While reducing resources to stay competitive, licensees should carefully evaluate the effect of planned reductions on all aspects of plant operation so that safe operation of the plants is not compromised.
Further, with CosEd's large number of nuclear units and its efforts strong corporate management oversight of the toward decentralization,intain'ng sites is important in ma Comed's authority and responsibility for its nuclear program.
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SEh! ANNUAL PLANT PERFORMANCE A55Es& MENT PRE-DECI510NAL SYRON Assessment Period: AUGUST 1995 TO FEBRUARY 1996 -
SALP Period: AUGUST 21, 1994 Throuth AUGUST 17, 1996 Previous SALP Ratin9: OPERATIONS: 1 -
MAINTENANCE: 1 ENGINEERING: 1 PLANT WPPORT: 1 I. Performance Overview In general the licensee's perfomance during this six month assessment was above avera,ge.
During this period, both units continued to operate quietly with no reactor triss or major ESF failures. Both Units operated at or near full power except tiat Unit I was shutdown for a mid-cycle steam generator inspection outage from October 22 through December 25, 1995. Excellent interdepartmental comunication and teamwork continued. The licensee continued to be self-critical by identifying and resolving performance problems.
Engineering during this period was actively involved in good programmatic problems. Strong efforts and programs to identify and correct engineering performance from plant support groups continued.
Although the licensee's overall performance was considered good, personnel performance errors were noted during the latter part of the assessment period.
Perforn.ance errors were noted in the areas of operations, engineering, and maintenance. Also, a decline in chemistry performance was noted. Maintenance performance during the latter part of the period was considered weak. Some procedural adherence and configuration control errors were identified.
Management attention to human performance errors continues and appears to be
, satisfactory.
II. Functional Area Assessments A. Operations
- 1. Current Performance Performance in Operations continued to be good overall. The licensee demonstrated professional control room operations. Operators demonstrated a strong questioning attitude in the control room. During the previous semi-annual period, personnel errors were controlled and no significant mistakes were noted. There were no notable personnel errers early in this assessment period, however, some minor errors occurred late in the period. Examples of personnel errors are inctJded beloW.
t i .
- 2. Assessment / Issues Operations continued to be self-critical and demonstrated a strong quest:oning attitude. Several subtle issues were identified by operators on shift in the control room: '
lhe licensee has enhar<ced its control room shift briefings by adding unit specific briefs prior to conducting the overall control room brief. Shift tcrnoverk and control room briefings continued to be thorough The two SRO configuration has improved control room effectiveness. The duty SR0 was freed from administrative burdens and was able to more effectively concentrate and oversee plant evolutions.
The questioning af.titude of one operator led to the recognition that the IB Hydrogen Monitor had been inoperable for a long period.
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The licensee identified two inadvertent entries into Technical l
Specification 3.0.3 as a result of an operator questioning leak detection capability requirements.
The operators provided suggestions to the review of precautions and expectations'for shutdown operations with both source range nuclear instruments were out-of-service.
After tube repairs on the Unit 1 A steam generator, air pressurization of the generator was required to test the welds on pulled tubes. An operator identified that a rapid depressurization following the test could-initiate an inadvertent safety injection signal. Procedural precautions and shift briefings were conducted to prevent the problet from occurring.
Recent performance errors indicated a lack of attention to detail with respect to valve lineup practices and procedural adherence. However, no major plant consequences resulted due to operators continued good response to plant events and transients.
~
An operator deenergized an electrical panel during a scheduled maintenance activity which caused a loss of automatic control for the charging header flow control valve (ICV 121).
An operator did not align the Unit 1 Boric Acid Transfer pump properly. The electrical knife switch was left open during pump line up.
I Two operators inadvertently transferred approximately 1000 gallons of RWST water to the spent fuel pool due to an improper RWST purification line up.
2 e
During a Power Range Nuclear Instrument calibration, an operator left rod control in automatic vice placing it in manual !
as required by the procedure. This error resulted in the control j rcds inserting 23 steps before they were stopped. -
The IB Hydrogen Monitor (Trouble Alarm) alarmed intermittently
- i without explanation since initial construction (during performance of routine hydrogen monitor surveillances), indicatin j opportunities by the licensee to correct the anomaly.g many missed
- 3. Actions / Recommendations Continue the routine core inspections for the operations area. The inspectors will concentrate on reviewing valve lineup problems and
- infrequently used procedures.
i B. Maintenance
- 1. Current Performance 4
Performance in the Maintenance area was considered satisfactory. The licensee's coordination of routine surveillance and maintenance i
activities continued to be good, and no safety concerns were noted, Maintenance continued to display good work control, planning, and team effort with other departments. With the exception of the IAF013G valve 4
repair, the maintentr,ce activities during the mid-cycle outage were well performed. Maintenance continued its self-assessment process to improve performance regarding personnel errors, as noted during the previous
! semi-annual period. However, some weaknesses were noted during the latter part of the assessment period. These weaknesses concerned procedural adherence, and configuration (parts) control.
- 2. Assessment / Issues Some examples of weak procedural adherence and personnel errors were noted.
Occasionally, poor foreign material exclusion (FME) practices were identified by the inspectors. For example, an individual was
'. found working inside the spent fuel pool FME cleanliness zone without taking the required FME precautions.
During performance of a cable spreading room fire protection surveillance, a C0 leak occurred. A personnel error resulted in the installation of the temporary vent valve on the CARD 0X system 1
Due to inadequate post maintenance verification during the main feedwater pump 28 lube oil pump and Electro-Hydraulic Control (EHC) fluid leak repairs, the manual trip linkage was found disconnected after the feedwater pump was returned to service.
4 3
i i
The failure to quantify potentially highly radioactive system leakage outside containment was identified by the inspectors.
(Error made by engineering personnel.)
Inadequacies in the contractor's verification process led to seven steam generator tube sleeves (out of a population of over '
2000) being welded twice or welded in the wrong location within the tube. (Error made by engineering personne .)
Some examples of configuration control problems were noted. -
During the IAF013G maintenance the licensee installed the wrong valve stem, which damaged the valve backseat. Several ?ndividuals in the process missed opportunities to further evaluate the stem.
During the restoration of the main feedwater pump 28, the licensee identified that the manual recirculation valve was found mispositioned. The cause was not yet detemined; however, the potential cause may either be an inadequate tagout process-or improper maintenance manipulation of a tagged 005 valve. This event was still under investigation by the licensee.
.0verall, work control and maintenance activities were good.
Additionally, good interdepartmental coordination with operations and engineering was observed.
- The licensee continues to plan and control maintenance work well. The licensee effectively schedules maintenance activities in accordance with their 12 week work windows.
Good maintenance coordination between operations and engineering rapidly identified the failure mechanism for the charging system discharge isolation valve (ICV 8105) motor pinion gear. The gear was made of the wrong material which allowed the teeth to strip off the gear. Several other potentially effected valves were verified to have the correct motor pinion gear material.
Good troubleshooting and repair efforts were demonstrated by both maintenance and engineering in the identification of faulty solder joints in the emergency diesel generator Agastat relays.
Approximately 100 relays were removed, repaired and replaced in a short period of time.
- 3. Actions / Recommendations Continue with the routine core inspections for the maintenance area. A portion of this self-assessment concern should be evaluated during the upcoming IP 40500 inspection (March 11-15, 1996 . Additional attention will be focused on maintenance performances (per)onnel errors, procedure adherence) and configuration control. A portion of this concern should be evaluated during the upcoming Motor Operated Valve inspection (March 4
11-15,1996).
4 C. Engineering
- 1. Current Performance -
Engineering performance was good during the previous semi-annual assessment period and rearins generally good during this assessment
- period. There were good engineering programmatic efforts and s>ecific
- programs to identify and correct engineering problems. Also, tiere was good engineering interface between Byron, the corporate office, and other sites. However, concerns were noted with system engineering walkdowns during this assessment. In particular, the lack of detailed guidance and expectations for conducting system walkdowns were identified by the inspectors. In addition, isolated examples of inadequacies and a lack of thoroughness existed in the area of design calculations.
- 2. Assessment / Issues j Good engineering programatic efforts and specific programs were in place to identify and correct engineering problems.
The level of support and quality of the investigations performed by the engineering group was very good. Examples included the investigation into the IB Hydrogen Monitor inoperability and Agastat relay cold solder joint concerns identified during troubleshooting and repair of the IB diesel generator.
- A system engineer identified a minor feedwater flow venturi discrepancy on Unit 2.
The licensee's trending program on problem identification forms (PIFs), the temporary alteration process, the workaround program, self assessments, and on-site quality verification audits of engineering activities were good.
- Specialized engineering training was good.
Licensee identified two Appendix R violations concerning the electrical design configuration for the protection of safe shutdown equipment.
The licensee continued to exhibit good comunications and team work between engineering and other groups.
- The licensee exhibited good coordination between operations, i maintenance, and engineering in the investigation and repair of the emergency diesel generator Agastat relays.
5
. 4 A large number of peer groups have been formed between sites.
Peer groups have improved and continue to improve site to site communication.
Weaknesses were identified in the system engineering walkdown program. ,
System Cngineering walkdowns failed to identify material '
condition deficiencies which were identified by the NRC. Examples included loose or missing support hangers in the diesel generator Toom.
- The inspectors concluded, based on licensee discussions and on material deficiencies that the inspectors identified, that detailed guidance and expectations were lacking for system engineers on how to conduct system walkdowns and identify equipment deficiencies.
Some engineering work lacked thoroughness in engineering activities such as design calculations.
A number of minor design calculation errors were noted by the inspectors. The licensee's design review process failed to l identify these errors.
Nuclear Fuel Systems (Comed corporate) design activities demonstrated weaknesses in design control and corrective actions for determining correct shutdown margin.
- 3. Actions / Recommendations Continue with routine core and the LEAP engineering inspections, with particular attention an system engineering material condition walkdowns. Also, during routine LEAP visits, review licensee's corrective actions regarding the identified concerns in design calculations.
D. Plant support
- 1. Current Performance Performance in radiation protection (RP continued to be strong.
However, an overall decline in wrforman)ce was noted in the area of chemistry, characterized-by weatnesses in self assessment, procedural adherence, and high radiation sampling system (HRSS) quality control.
Security performance has been very good and consistent. The Emergency Preparedness (EP) program was strong has good management support, and the last exercise performance was ver,y good. The fire protection program was good, the activities were adequately implemented to meet the safety objectives. However, the number of impaired fire doors remained high.
6 saw
4
- 2. Assessment / Issues Radiation Protection: .
Radiation >rotection Station -
personnel save a good (RP) perfonnance continued to be strong. knowledge of RP pri doses ALARA.
- Implementation of the revision to 10 CFR 20 was well done..
1995 collective dose was low. However, the 3 year rolling average placed Byron in the lower half of the 2nd quartile. This drop was due to the additional Unit I steam generator inspections and the most recent mid-cycle outage.
The RP assessment of the December 1995 intakes from steam generator repair evolutions was very comprehensive. The l licensee's corrective actions appeared to address the root cause.
I Chemistry:
Chemistry program implementation has indicated a declining trend.
Although water chemistry was well maintained, management oversight in the routine laboratory programs was weak.
Poor analytical chemistry techniques and radiation protection practices were indicated by chemistry technicians' failure to follow procedures during routine sampling.
Quality control of the HRSS system failed to be maintained from July through October of 1995.
Chemistry self assessments failed to identify HRSS quality control deficiencies. Chemistry staff knew of some problems
' concerning the implementation of the HRSS quality control, but did not identify the problems to chemistry management.
Security:
Security performance has been very good and consistent.
Security monitored trends have generally improved or remained steady, for example security door ajar events.
Self assessment efforts continued to be strong and maintenance support for security equipment was good.
A previous weakness in searching of hand carried items has been resolved.
Hand geometry technology was successfully implemented.
7 J
- Emergency Preparedness
- The licensee's performance in emergency preparedness was excellent.
- An announced, daytime emergency preparedness exercise was conducted on November 15, 1995. The licensee's performance ivas .
very good.
- Performance in the simulator control room was excellent.
- Performance in the TSC was very good, including cosmand and control, event classifications and notifications, and protective action recommendations.
- Perfomance in the OSC was also very good, as evidenced by the assembly, briefing, dispatching, and debriefing of the Emergency Teams.
Fire Protection:
The main program strength was fire prevention, which included control of transient combustibles, and fire brigade responsiveness.
. The fire brigade drill was excellent.
. The number of fires in the plant during the past three years w1s low.
The material condition of fire protection equipment, including the fire suppression and detection equipment was considered satisfactory.
However, there were some material condition and fire barrier impairment concerns.
- Numerous fire protection impairments were not being accurately tracked for closure. Also, a violation was identified for a failure to authorize an impairment for fire doors which were blocked open to support flushing activities.
- Several fire main valves have packing leaks due to the poor quality of the fire main water supply.
. Although the licensee had established a team to assess fire door problems, the number of impaired fire doors remained high.
- 3. Actions / Recommendations Continue with the routine core inspections for the radiation protection and chemistry areas, with increased attention to corrective actions and management oversight within the chemistry department. During the next 6 montt.s, radiation protection / chemistry inspections are scheduled for April 22-26 (Outage) and June 3-7 (Routine 83750 & 84750).
8
Continue core inspections in security and emergency preparedness.
III. Future Insoection Activities Routine Resident Inspections and Lead Engineering Inspector visits Self Assessment IP 40500 inspection (March 11-22,1996) -
Notor Operated Valve inspection (March 11-15,1996)
Rad Protection / Chemistry inspectton - Outage (April 22-26,1996)
Radiation Protection inspection - Routine (June 3-7,1996)
Security - Access Authorization Program (July 8-15,1996)
IV. Attachments AE00 Performance Indicators l
l 4
9
PLANT ISSUES LIST l
l BYRON .
l DATE l ID SY l SALP l DESCRIPTION l CMSE l AEF l 02/19/96 Lic Ops During the purification valve lineup Personnel 95013 -
of the RWST, the operators failed to error and close one valve (FC 053, spent fuel fallere to pool discharge) which inadvertently use transferred 1000 gallons of RWST pescedures water to the spent fuel pool. The 1000 gallons of water raised the spent fuel pool approximately one inch.
01/30/96 Lic Ops Unit 0 Boric Acid Transfer pump was Procedures 95013 not electrically aligned to Unit 1. and personnel The valve Ifneup was correct and the error Unit 0 pump's power cable was plugged into Unit l's switch box, but the .
switch had not been shut. The procedures available at the time made no mention of the electrical lineup.
The valve Ifneup and electrical lineups were done as " skill of the craft.'
01/11/96 Self-ID Maint Mechanical maintenance failed to Personnel 95013 install a gasket on a temporary vont error valve on the CARDOX system leading to a CD, leak and precautionary evacuation of the turbine building 12/95 Lic Eng sc sleeving issues: Personnel 95011 Error seven sleeves improperly welded due to inadequate QC 5 elf-identifying two defective welds on plugs not identified prior to leaking during a leak test.
g . . . .
PLANT ISSUES LIST l BYRON ,
j I am I 1n I saw I *scun= I ca m I ur 1 l
12/95 frRC Ops operator loge for Do improperly Nman perf -
maintained, le governor oil level logged as SAT when Out of Sight High.
12/24/95 Self- Eng Unit 1 Unit Aux Transformer bus Noterial disclosing feeder breaker 1431 failed to Condition shut during startup. Levering-in device thrust bearing not in place, causing breaker to rock hard.
11/08/95 Lic Eng Over 1500 SG tubes with circ Material cracks repaired with a condition combination of sleeves and plugs.
11/95 Lic Eng Three DC Agastat relays had Material failed in a one year period. Condition Aggressive trouble shooting ,*
. identified cold soldered joints. Repaired approx. 50 affected relays.
10/26/95 Self- Ops U1 in Mode 5. 1400 gallons of Numan identifying water displaced from vessel to Performance pzr when N2 used for draining loops escaped into vessel.
Disk pressurization was intentionally not in use for numerous reasons.
O
.. .. i PLANT ISSUES LIST BYRON I mu I mn I su I uscen. I fast Iof 10/25/95 Self- Ops Unit 1 in Mode 5. During de- Human identifying energization of a panel for Performance ~
work, auto control of charging flow (CV121) was lost. Quick operator action prevented major pressure transient. Auto control of cv121 was not indicated on a de-energization procedure and thur not on the OOS prepared. See ICV 8105 above, occurred during this transient.
10/25/95 Self- Eng Unit 1 in Mode 5. 1Cv8105 Naterial identifying (charging header containment Condition isolation) stripped motor pinion gear while operating.
~
10/23/95 Self- Ops Unit 1, both Source Range NIs, Material disclosing N31 and N32, inoperable due to Condition noise, spiking, and age. Both ,,
NIs detectors replaced during i
outage.
16/13/95 Self- Ops During PRNI calibration, rode Ntomen l identifying inserted 23 steps when gain -
Performance l adjust locking device was
! tightened. Procedure should have had rods in manual.
10/10/95 Licensee Eng The NRC identified an Human Perf 95011 additional design configuration problem following the licensee's identification of an inadequate design configuration .
of two divisions of equipment required for safe shutdown (2 App. R. Violations)
\
_ . _ . . . . _ . ~ . _ _ _ _ _ . _ _ _ . . . . . ~ . . _ __._ _- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ __
- .i Pt. ANT ISSUES LIST 'I BYRON DATE l ID BY l l SALP DESCRIPTION l CAUSE l REF l-09/13/95 Lic Ops Unit 1. TS 3.0.3 was entered Human 09/15/95 inadvertently on two occasions Performance due to " misunderstanding" of ,
LCO action requirements for containment leak detection ;
systems.
8/95 NRC Maintenance A maintenance person was noted i
Personnel 95000 to be in a material exclusion error &
(FME) clean 11nese zone who did training not meet-the requirements for !
i control of personal articles.
The maintenance person was not aware of the FME requirements.
8/29/95 Lic Eng A recent procedure revision wee Procedure ,
'i 95006 being used to perform a review and surveillance on the fire paraonnel i suppression system at the River error ,
Screen House (RSM). The new -
revision required two alarias to be actuated, however, for the zone being tested at the RSN i only had one alarm. This error in the procedure caused i
confusion. A second try of the i
test created a potential personnel hazard, possible carbon dioxide asphyxiation.
13
~
1
. a.
' ~~
PLANT ISSUES LIST BYRON l DATE l ID BY l SALP l DESCRIPTION l CAUSE l REF --__
j ]
8/21/95 Lic Eng The IB Hydrogen monitor was Procedures 95008 ,
identified as being inoperable and because the drain lines to the personnel water trap were found error disconnected and capped. The inoperable condition may have existed since construction. A review revealed three occurrences when both monitors were out of service for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Escalated enforcement resulted in a level 3 violation.
e*
=
5
- - - ;m .
m.- - - -
PREDECISIONAL t end 5""***"""",' "
BYRON 1 Refueling R Operation 93-1295-4 Querioriy Date Not Shown using Op. Cycle m Ops Ops. -, -
R R R R E bt b3 kt k3 95 1 E3 ' W D3 I' 33 3 kf ks Ei 95 3 I Year . Quarter Year . Quarter 4 Automatic Screms Whbe Crtucal , Safety System Actuations 3- 3-g 2 < 2-
- 1. 1.
0 ' 0 911 93 3 41 k3 951' 953 i 83 1' kk3 ki- 3 96 1- 953 i Year . Quarter Year . verter 20 Significant Events Safety 3ystem Failures 4
l 1.5 I 3-W 11.0- wg2 gg
"' '~ $ hE to o b 951 953 kt' 43 b51 95 3 3 D3.f 953 b4 64 3 96-1 ts 3 4 Year . Quarter Y . Quarter Equipment Forced Outagost
,og Forced Outage Rate (%) , 1000 Commercial Crttical Hours
< to - -
m 0. g..
6 ,
2 20 e6a A
m g a E O -0 13 f-93 3Year Rf. Quarter k3 96-f 93 f 9%3 kr 54 3 36 f 953 ' w 96 3 3 Year. Quarter Cause Codes
- a. Admin b. Uc Oper c. Oewr Por g CoGeetive Radiation Exposure = = =
g .. .. ..
W 1 ,, ,, ,,
1,50. 00.
. a.. 2. .. _ -
e d. Mart a. Desigr f. Mac 50 - E- * * *
., J ,a A, ,a ,
Year . Quarter
' See Average Radisson Espesure
- g 3 [ .
.g- - - -J" ""
PREDECISIONAL BYRON 1 L e
- staa='s'endia ae. w'en si=ismi Peer Group Westinghouse New 3 and 4-Loop
- 931 to 96-4 Trends and Dewations Deviatens From Plant Peer Group Self Trend Median Short Term , ,
Long Term oneened emereved weree asser OPERATIONS Automatic Scrams While Crftical - o 0.30 feafety System Actustions - o -
0 Significant Events - o -
o Safety System Fallures - 0 -
o Cause Codes (All LERs) a aemmrevieve en pre me - 4.90 -
O e useness operame arvere - l 0.84 -
O
- t. oowr Pereenam sure - 0 -
0.18 [
- s. momerense piene.no - 0 30 R -
] 0.26 e m:-r--- :enweeneseen P, emme - C' 1 + .-
0 95 -
4.09[
- s. - : - 0 -
0 SHUTDOWN -
Safety System Actuations - o -
0 Significant Events - o -
0 Safety System Failuros - o -
o Cause Codes (All LERs) a aamoveevevocam w piennene =
)0.03 -
] 0.19 m useness operamtarvers - 0.45 -
0.37 I s.comr Pereennes smre - ] 0.0a - 0.45 b-et asemmaanse p,eesene - -
0.35
) 0.03 g_,_- - _ _ _ __ _ __ eenasses Preemene - 0 -
0 v.insesammeen - 0 -
0 FORCED OUTAGES Forced Outage Rate * - 0 0.02 Equipment Forced Outages / * - -
g 0 g 0.26 1000 Commercial Critical Hours 12 Oh 00 Ch 1.0 14 C'.5 0.0 Ch im Performance index Performance index
- woi cmeweise ser o,erseener crue
_a
PREDECisloseAL
- t. gene
" " ^ " * " " " ' * " ' " ' ' ,'
BYRON 2 Refueling R Operation m tsaustry Avg.Trond Shutdown ris5sg hot Shown Using Op. CYele m l I I I l l I n l 1 l l 1
B a l B I I E E I I I ta) DS3 ki ks 86 1 36 3 i 331',*333 k1 k2 E1 E3 i Yeer. Quorter . YeeT Quarter 4 Automatic Screms Whte Cetlical , Safety System Actuations 3- 3-g 2- 2-0 sit 93 3 ki Year . rter D61 96 3 '
bi E3 ki Year . rter k1 BM7 20 8%nlAcant Events , sew SWem Fanures l
1.5 3-W s i.0 -.! 6)2 s ,.
03 - 1- g 00 ki ' 0 E E D31 93 3 k3 E1 95 3 D31 93 3 k1 k3 D61* E3 6 Year - Quarter Year . Quarter Equipment Forced Outages 1 100 . Forced Outage Rate (%) .
g 1000 Commercial Crtlical Hoi,*r 80
= to - g4-
- ~ '
2-20 -
w 0 g3,1 %,3,j l gi, g ,,,1, ,,,3 ,
w 0-93 3 kii Es i Year . Quarter Year.NriorDS 1' Cause Codes y Conective Radiation Exposure = = =
I W
=. .. ..
150
= .. .. ..
k200. . - = I o n. . .- - - . L. y.
- d. Maint g, we
- e. O, sign
=
- m. _
g .
.0-l' W
0 k b>1.aDu
$llu t k ,; m e arum to.,; 9, .
sn.Av.r.o.n.41'n'd".u,7 .aeaE:a , n .E ., ..
25 - _ _ _ _ _ _
. PMDECISIONAL l BYRON 2 e smose i sene. won ===
Peer Group Westnghouse New 3 and 4-Loop M W* M 93-1 to 95-4 Trends and Devotons , ..
Devntens From "
Ptsnt Peer Group SeWTrond Medan Short Term , , Long Term OPERATIONS (including startup)
Automatic Scrams While Crttical - o 0.30 Safety System Actuations - o o
i Significant Events - o o
Safety System Failures - o -
o Cause Codes (All LERs) e sea wesen ceaww P, wens -
4.27 [ -
4.05[ b a usene.e opereur smes - 0 -
4.23 [
s os r Peroena i snore - 0 - O s : 1 -- : Pre ===s -
4.06[ -
] 0.15 e oesisM;eacevce anasemeo**sens.o.a prema==s - 4.32 1 -
1 0.40 t amesen a.ees - 0 -
0 SHUTDOWN Safety System Actuations - o -
0.42 Significant Events - o -
o Safety System Failures - o -
0.45 Cause Codes (All LERs)
- a. Aa m.eeen c.=w prom - 0 -
10.a0 m.usea e operiner an re - 0 -
4.Os[
os.,pers enero - 0 -
0.01 a esmassa aee pnen - 0 -
1 0.37 sr . --- sein.s w r.ee pmemme - 0 -
l 0.33 c: -- . 0 -
n FORCED OUTAGES Forced Outage Rate * - 0 -
0.26 Equipment Forced Outages /
- 1000 Commercial Critical Hours 0
lg 0.26
'12 43 0.0 Ch 1.0 1A 43 04 0'S
. 1A Performance Inder Performance index
- het cuevast.e ser operse.nas cyc.
SEMIANNUAL PLANT PERFORMANCE ASSESSMENT PRE-DECISIONAL BRAIDWOOD Assessment Period: August 1995 to March 1996 SALP Period: October 1, 1995 through June 21, 1997 Previous SALP Rating: OPS _1_
MAINT _Z_
ENG _1_
PS _1_
!. Perfermance Overview Management focus on identified problems such as material condition and foreign material exclusion improved. Identification of material condition problems by all departments improved. Although several long standing material condition problems were addressed, quantifiable improvement in the corrective maintenance backlog was not achieved.
Work control, procedure adequacy and adherence, and craft skill capabilities were continuing problems.
The licensee made several management changes in key areas this period (see attachment). The effectiveness of these changes was not yet determined.
Braidwood operated throughout the period with one significant operational transient. Unit 2 lost off-site power in January but the plant did not trip and there were no significant equipment problems, other than the failure of the system auxiliary transformer. Unit 1 j completed a refueling outage in December.
1 II. Functional Area Assessments A. Operations
- 1. Current Performance Performance was good with a slightly improving trend. Response to transients was good. However. reactivity management was weak.
Control room teamwork improved. Problems with procedure adequacy and adherence continued but were on an improving trend. i Identification of material condition problems by operators was weak but on an improving trend. Personnel errors by operators declined. A new problem with configuration control was identified
' by the licensee. Over 50 components (breakers and valves) were found out of position in 1995.
ATTACHMENT 7 1 l
- 2. Assessment / Issues Operator actions in response to transients were good. .
Operator actions taken during an inadvertent actuation of a -
pressurizer power-operated relief valve were good.
Operator actions in response to a loss-of-offsite power were good.
- Reactivity management was weak.
A decision was made at the start of the refueling outage to cooldown Unit I without knowing the shutdown margin.
Positive reactivity additions were restricted by technical specifications with one source range monitor inoperable. However, positive reactivity was inadvertently added upon starting a reactor coolant pump when a positive temperature reactivity co6fficient existed, and upon making up from the refueling water storage tank which had a lower boron concentration than the reactor coolant.
A control room operator did not reverify boric acid flow during a Unit 1 volume control tank auto-makeup l resultir.g in an overboration and a four degree drop in l T-ave. He was distracted while adjusting primary water flow manually to workaround a chronically malfunctioning primary water flow controller.
Control room teamwork improved.
An instance of weak control room teamwork occurred early in the period when a one hour limiting condition for operation was violated for a radiation monitor which was out of service. However, effective corrective actions were subsequently taken. No additional problems with control room teamwork were noted.
Good teamwork was demonstrated during a loss of offsite power event on Unit 2.
Procedure adherence improved but problems still occurred.
Actions specified in annunciator response procedures were not followed for level adjustment cf the Unit 2 pressurizer relief tank and a Unit I safety injection accumulator.
2
A non-licensed operator failed to valve in lube oil cooling water to the Unit I start-up feed water pump. Pump bearing temperature exceeded 200 degrees but the pump did not fail before the problem was found.
Procedure adequacy improved but problems still occurred.
Operator rounds were not updated with new technical specification teminal voltage acceptance criteria to reflect a modification of the station batteries.
Because of an error in a procedure, over 500 gallons of Unit 1 pressurizer inventory were lost during restoration of a local leak rate test valve lineup in October. This error should have been caught by ,
operators during the pre-restoration review of the procedere, but was not.
Operator identification of plant material condition problems improved.
l Action requests written by operations personnel increased.
About 100 workarounds have been identified and are in various stages of prioritization and disposition.
However, operator identification of problems continued to be weak.
- Standing water was found in the Unit 1 blowdown valve isle by NRC inspectors during the material condition inspection.
Operators had known of the water for some time but took no action.
A non-licensed operator noted that the flow conditions and valve positions were different between the two identical Unit 2 hydrogen monitors and no problem identification form was written.
Configuration control was poor.
The licensee identified over 90 problems with configuration control, 50 of those problems were with mispositioned valves or breakers in 1995.
- In October, a breaker for a Unit I diesel generator was not racked-in properly rendering it inoperable and the other diesel was out-of-service for maintenance at a time when at least one operable diesel was required.
3
_a
Components of the wrong Unit 1 diesel generator were taken out-of-service in November due an erroneous tag out. '
In February, an equipment operator adjusted valves on the Unit 2 containment hydrogen monitor system when ,
the function anc correct position of the valves were not known. .
In March, the only operable Unit 2 safety injection pump was partially disabled by starting maintenance on a flow orifice in the system with an incorrect work authorization. The other safety injection pump was also out of service at the time for planned maintenance, and the unit was at full power.
- 3. Actions / Recommendations Continue with the routi;.. ... '7spections for the operations area focusing on reactivity management, procedure adequacy and adherence, and configuration control.
B. Maintenance
- 1. Current Performance Overall performance was satisfactory. Overall material condition did not improve. Althou h some longstanding equipment problems were addressed, a number of deficiencies remained. Improvement was noted in the area of problem identification. Procedure adherence and procedure adequacy weaknesses, craft skill errors I and work planning problems continued with no improvement. Good I critical self-assessment initiatives were discontinued due to a lack of resources. Increased problems with foreign material exclusion controls compared to the previous period are a new concern.
- 2. Assessment / Issues Material condition problems ccnticued. The licensee has focused on material condition issues but has not seen quantifiable improvement.
The action request backlog and corrective work request backlog were increasing.
Only non-outage corrective maintenance that is critical for the completion of the upcoming Spring 1996 Unit 2 refueling outage will be performed during the outage.
4
The licensee began to correct the following longstanding material condithn problems. However, most were still incomplete:
Condensate /condensa,te booster pump refurbishment '
Residual heat removal pump seal replacements Auxiliary building ventilation modification .
1B Essential service water pump seal replacement Process radiation monitor pump upgrades Work Control Prob' ens continued.
During Unit 1 on-line maintenance activities, work control problems delayed restoration of safety injection, containment spray, essential service water, and residual heat removal systems. Specific reasons for the delays were:
Poor identification of valves for out-of-services, Inadequate parts availability prior to beginning work, and Inadequate work package ins' t ructions.
The Spring 1996 Unit 2 refueling outage had to be moved back two weeks due to too many unprepared work packages.
Procedure Adequa'cy and Adherence Problems Continued.
Instrument maintenance technicians failed to follow a surveillance procedure which resulted in a primary power-opergted relief valve (PORV) actuation at tull power.
Due to inadequate work package instructions, endbells on numerous safety-related lube oil coolers were incorrectly oriented.
Due to inadequate work package instructions, IA CV pump seal package access plugs were not installed following maintenance.
Craft Capability Concerns Continued.
During essential service water (SX) lube oil cooler maintenance, a head gasket was incorrectly oriented.
During 2B residual heat removal pump maintenance, the shaft was damaged due to improper impeller removal.
Quality control rejected about 10 percent of mechanical maintenance work packages reviewed in the field.
5
0 A declining trend in FME controls was observed.
During refueling operations, the inspectors identified foreign material inside the Unit I spent fuel pool foreign .
material exclusion zone.
Following maintenance, the 1A centrifugal charging (CV) pump was energized with herculite inside the cubicle cooler fan >
housing.
The licensee identified that the 1A CV pump oil reservoir contained paint chips and a tygon hose.
The licensee failed to prevent roofing materials from blowing off the service building and turbine building roof in the vicinity of the system auxiliary transformers, after l becoming aware of the potential for the material to cause a problem with the transformers.
- 3. Actions / Recommendations l Continue with the routine core inspections for the maintenance area. Concentration should be on material condition, procedure adherence, procedure adequacy, foreign material exclusion, craft capability, and work control.
No deviations occurred from the previously planned inspection activities.
C. Engineering
- 1. Current Performance Performance within the area of engineering was satisfactory.
Some improvement was noted in the area of evaluations and root cause determinations. However, material condition walkdvan, by system engineers and their supervisors were not performed on a routine basis. Recently, engineering supervisory personnel changes have been made, but it is too early to assess the effectiveness of these changes.
- 2. Assessment / Issues Engineering performance correcting identified problems improved.
The licensee developed a modification to correct a design weakness in the solid state protection system in response to Information Notice 95-10.
6 l
1
0
- The engineering evaluation and proposed corrective actions to address refueling water storage tank level oscillations were good.
The identification of problems by engineers improved. ,
- The number of action requests in the field written by system engineers increased.
- A system engineer identified a previously unknown trip function that would prevent operators from opening or modulating closed secondary PORVs (atmospheric dump valves) from the control room.
- While conducting modifications to eliminate Themolag fire barriers, the licensee discovered five areas where they had not been meeting Appendix R requirements for protection of safe shutdown equipment.
However, identification of concerns was not consistently timely.
The inspectors identified inadequate inspection requirements for the 4160V breaker levering-in device and acceptance l criteria in the 4160V breaker racking-in l procedure.
- The material condition inspection found:
- System engineering group leaders and system engineers were not performing system walkdowns on a routine basis.
- Repeat leaks following repack on valve
, ISX178 (essential service water return from IB auxiliary feed pump heat exchanger) were not adequately evaluated / addressed by engineering.
+ Nuclear Fuel Systems (Comed corporate) design activities demonstrated weaknesses in design control and corrective actions for determining correct shutdown margin.
Communications between engineering and maintenance personnel was sometimes weak.
- The material condition inspection found that maintenance craft personnel were sometimes discouraged from contacting engineering personnel, and considered communications between engineering and maintenance to be weak.
7
- 3. Actions / Recommendations Continue with routine core and the LEAP engineering inspections.
Plant Support D.
- 1. Current Performance The licensee's performance in the area of plant support continued to be excellent overall.
- 2. Assessment / Issues Radiation Protection The licensee's performance in the area of radiation protection continued to be excellent.
The licensee's as-low-as-reasonably-achievable (ALARA) planning and dose control for the Unit I refueling outage were excellent. The licensee completed the f.TD bypass elimination job for less than its initial ALARA estimate and established a new industry dose record for a first-time evolution for that job.
l The licensee's contamination control efforts resulted in minimal personnel contamination incidents during the Unit I refueling outage, none of which resulted in any radiologically significant dose.
Security Continued improvement in performance was noted in the area of security. Implementation of the physical security program was good. _ Effective security management was the main contributing factor to the improvement. Weaknesses were noted in the contingency response program. A negative trend was noted in some security equipment failure rates.
Implementation of the physicel security program was good.
A biometrics hand geometry system was successfully set up for unescorted access entry to the protected area.
Security staffing resources were adequate to meet security plan commitments.
Security staff membert demonstrated teamwork, initiative, professionalism, and program ownership.
8
. . _ . _ . . _. _ . _ . _ _ _ - m m ._4_e .._ . ~ - - - m _ - a..m_
e Substantial progress was achieved in the goal of a security computer system replacement scheduled to be installed in December 1995.
Weaknesses were noted in the contingency response program.
Critical vital area target sets, timelines, and deployment strategies have not been determined.
However, tactical response capability was improved through the acquisition'of new contingency weapons.
Hardware failure rates increased for security doors and equipment tamper alarms during the previous 5 months.
Chemistry Licensee performance in the radiochemistry confirmatory measurements program was excellent, with all agreements in 142
' comparisons. The radiochemistry quality assurance program continued to be effective in maintaining laboratory performance.
l The chemistry laboratory quality assurance program was excellent, t
! Emergency Preparedness i During this period performance and overall status of the emergency preparedness program was good and indications of improving trends
- were identified.
Emergency facilities and equipment were in an excellent
- state of operational readiness.
A recent peer review of the emergency program had been initiated by corporate emergency preparedness personnel and has improved licensee program performance.
Licensee emergency response actions during an actual loss of offsite power were good.
Fire Protection l
The licensee's performance in fire protection remains adequate to
! meet safety objectives. There was not sufficient inspection data to facilitate an overall perfenmance assessment in fire protection. The licensee's performance was excellent with respect to its identification and resolution of an isolated fire protection issue involving oil soaked lagging in the turbine building, i
9 i
l l
_____m-- __ _ - - - . - - - - - - . - _ _ _ _ _ _ _ _
~
- 3. Actions / Recommendations Cont;aue with routine core inspections of the plant support areas.
No deviations occurred from previously planned inspection activities.
III. Future Insoection Activities Continue with the routine core inspections for the operations area focusing on reactivity management, procedure adequacy and adherence, and configuration control.
Continue with the routine core inspections for the maintenance area.
Concentration should be on material condition, procedure adherence, i
procedure adequacy, foreign material exclusion, craft capability, and work control.
Continue with routine core and the LEAP engineering inspections.
Continue with routine core inspections of the plant support areas.
IV. Attachments AE00 Performance Indicators 10
. . ,5 PLANT ISSUES LIST BRAIDWOOD ,
DATE l ID BY l SALP l DESCRIPTION l CAUSE l REF l 01/24/96 NRC Both Unit 2 hydrogen monitors -
inoperable due to mispositioned valves.
12/26/95 Lic Power supply to 2A S/G PORV tripped with no control room indication.
12/15/95 Lic While attempting to place the "2B" EDG control switch in the pull-to-lock position, the EDG inadvertently started. The operator inadvertently placed the switch in the start position when the switch did not turn far ~
enough to the left when he pulled it out.
12/13/95 Self- 125V. 112 battery charger failed-identifying 24 hr. LCO.
12/07/95 Lic Failure to start cooling for the '
Unit 1 feedwater pump lube oil cooler during startup.
12/04/95 Lic High noise problem on the N31 source range monitor.
11/25/95 NRC Severe seal leak on 1A cent.
charging pmp.
11/18/95 Lic 1A CCW pump breaker damaged because of broken cubicle shutters.
, 11/06/95 Lic Unit 1- OOS tags hung on wrong diesel generator.
11/03/95 Self- During surveillance of the IB AFW identifying pump, it repeatedly oversped after maintenance.
l
PREDECCIONAL
. te ,eae .
5""'"""""'""','
BRAIDWOOD 1 tefuehnl R Operation 3:::::ll:
incustry Avg frene thistDown c= 3 9).) to 95 4 Quanerty Data hot thee Wng Do. Cycle suggi 0D5 - 005 -
! R ! R ! R ! R W 9 tat ska E3F U Irkt' 93 7 E3 i be v.a1', . ou.y ner~ Et' M..,
v AJ .,n to t'
, Au'omet6c Screms Whee cett6 cal , 3ah M eA m s i 3- 3-J. i .
'5
{,- . . .
r
- , g. s: g l ' ,a ,,3 M c3 .,
vear Quarter
,m . ' E, ,m am i est . Quarter w,> .m - ,
signincent Events , safety system Facures to 11- 3 W w
- s 1.0. gg i.
05.
- 1. g g g
,, ~ t31~ $53 M b.-3 96 t' Dm I
, a a a kkv thi M D6 t' EP
@'6 I Year . Quarter Year . wrter -
Equipment Forced outagest Forced Outage Rate (%) g M Commercial CW hrs 100 i.J u g,
}j
.d 4=
h g a- . 8 ,.
J U aa a E a
} "*~ '.,. e iP.>>" v.ar "iAner 1 a
a vs 1.,,.% r .
Cause Codes
#""" b Lic Oper s.oeher Pee p., Conective Radiation Esposure , ,
. e. ..
I Y thOe .. ..
- jg tco- .-
b.., -a..h , , .
dw ..o. + tm g h
!g ":,,l,l i,,, *yJ i h ,i _ m se. Aver.p. R 43.*aE p U7 MM; n,, ,J , m .
.o PREDICISIONAL BRAIDWOOD 1 te ene swesse.i s e e. n .
.s Peet Group beteng%use Now 3 and 4 Loep Wecium giam
$3-1 to 9fr.4 ' '
Trones and Denations Deostions From ^
Plant Peer Group Self Trend . Medan Short Term 1.ong Term o e, 4 tyer e .. Wme ese ,
OPERATIONS (including startup) g Automatic Scrams While Critical - 0 46 -
0 Safety System Actuations - 0 0
Significant Events - o -
o Safety System Failures - o -
.o 10 l
Cause Codes (All LERs) e a .m.m. c w P . -
1.03 -
] 0.1, s L..w oper=w ann - 4 as I -
O s oww Pw =nes an=re - l 4.64 -
O s m.namaanse Pr.n=ans - M4.57 -
] 0.26 e tweherw..*w.wewes.een Pv.we.e - ) 0.00 -
]0.20 t enu.a -
0.30 l -
4a$ g SHUTDOWN Safety System Actuations - 0 -
-0.21 Significant Events - o -
0 Safety System Fellures - 0 04 -
0 39 Cause Codes (AllLERs) aa rie*c.=wP > .- l 0.12 -
4.01 a us.a e o ,== = an.re - 0.30 -
4 Os [
t ce* Pw.m.d aan - 0 -
4.21 [
t memesa = Paw . -
.] 0.09 -
4 23 [
c ;-- n - m .ensen-P en . - l0.03 - 4.3e tamenman.== - 0 -
0 FORCED OUTAGES Forced Outage Rate *
- 0.32 -
0.01 Equipment Forced Outagesl* -
1000 Commercial Critical Hours 0.40 -
0.14 18 4'3 0.0 0'3 18 1.0 4'S 0.0 0'S 1.0 t ,
Performance Inden Performance inden l
,o '
PRfDECISIONAL teeeno .
BRAIDWOOD 2
" " " " " ' ' ' " " ' ' ,l $=*a ' '
Rtfu*khg R Opere$on m 931 to D'A Quarterly Data
' E Not Snown Using 09. Cvete gang ,
008 - Ops 7,
n I e a l a SS 1 i nf t>3 kf k ~~ Ef es > > SS , ss.f e3.s ki kJ Ds.f es.3 .
Yes' Querier Year . Quarter
, Autonaue Screms While Cathcal Safety Syelem Actueuens 4
f3 3 y 2 3
,~ . . .
3~ i e F C "'
F E R
O 0- --
tai h3 kf k3 Et' by ' D3 0 SL3 kt kJ Et' D67 Year. Quorter Year . Quarter 20 SignlAcant Events Safety System Failures 4
1.5 - 3 l w '
w i
i 1.o . '
g, 3 03"
- 1*
h g hr D3 3 ki k2 Ef Dks I 33 0 thy kr kJ 50 Is.3 8
Year . Querier year . Quarter Equipment Forced Outagest g Forced Outage Rate (%) g im Commercial CMm* Houm 7 .. .l k
a so .
f**
~
2 20 . lu , , ,
go 0 "' L-t DSU DSP kf k7 Bs f E7 8 w h 1' SkJ f %3 Ef 947 8 Year Quarter ear . Quarter Cause Codes
,gg Collective Radiation Exposure m = -=
I
~
- s. .. ..
. ""'"-*,.:..- R- - - - - -
dioo. ,
- d. MsW e.Dee pn t.h6s4 el b * - - -
g .
, e ,-- , 5 B .1 ,a B , .atk,s.efe,",. .
.3.f 3 kr .. ..
Year . Quarter a la J
'See Averspe ReeeeenExposure om. e-B J .."'.* . .
p .
e PCE DECISION AL BRAIDWOOD 2 b O.no sas..c.is.r *.,= a,e Peer Group Westng%voe New 3 and 4. Loop Wesium m 9k1 to 9W Trends and Denatons Dewations From .
Plant Peer Group Self Trend Median Shoit Term Long Term OPERATIONS Automatic Scrams While Critical - o -
o Safety System Actuetions - o -
o Significant Events - o -
.o,90 Safety System Failures - o -
o Cause Codes (Ail LERs) a4 ore e c.aev eve . -
4A9 [ -
1OJs e useasse openew saw, - 0 -
O t omer Pnen J saws - 1 0.39 -
M 4.$4 a mimosanee >menene -
] 0.00 -
4.11 [
e os Sc. m o o + eene.- e ws. er eae - 4.32 I -
] 0.20 t ei.= a aene. - 0 - 0.90 1 Cafety System Actuations - 0 -
0.24 Significant Events - o -
o 5afety System Fallures . , o go -
,o og Cause Codes (All LERs) e Aame-sees.ec.aew Pr. eases - M461 -
4.es E 4 usenese operaent Saws - 0.90 1 -
4A7 E a omac Pnemies sness - 0 - 0.90 a asemesanase reses e -M.1.C3 -
] 0.27 a .-r - n.r eensemaseresamen Preesome - I -
0 to - 0 01 8 etenemonesias -
4.30 [ -
M 4.54 FORCED OUTAGES Forced Outar,e Rate *
- 0.33 -
0.11
~
Equipment Forced Outagent
- 1000 Commercial Critical Hours 0M -
6
.t A C's Om O's 1.0 .t a 4'.s o O's 1A Perfom.ance indes performance index
. e c.ieweise w o,nosas er.
PRE-DECI510NAL DRESDEN IRICLEAR POWER STATION
$ ALP Period: March Ig, 1995 through October 26, 19H Previous SALP Ratings: Operations J _
Maintenance JL
- Engineering J _
Plant Support JL
- 1. PERFORNANCE OVERVIEW Dresden was first placed on the NRC Watch List as a Category 2 plant in June llet. Subsequent licensee management initiatives were successful in improving perfomance, and the site was removed from the Watch List in December 1988.
In January 1992, Dresden was again placed on the NRC Watch List because of problems in maintenance, operations, management control, and hardware reliability concerns. Little progress was seen from 1992 through 1994 in improving overall performance. Corporate management attention increased-for BWR during operations,the who last has 6 months ofprincipal been the 1995 and the senior change Vice-President agent within Comed emp(VP) hasizing a conservative operations philosophy, assumed direct control at the site (relieving the site-VP . Reaction to events and accountability improved. A priority was placed on) operations with positive results observ',d in the control room.
Since the January SM, the conduct of plant operations by licensed control room oper.tc,rs has continued to be good. In contrast, the performance of operations personnel outside of the control room has not demonstrated the same degree of adherence to-management expectations and standards. Implementation of performance standards by other station work groups (e.g. mechanical and electrical maintenance) continues to be a concern. To improve work force skills, fundamental and supplemental training was implemented. During the training initiative, the workforce was backfilled with contractors. A period of sustained dual unit operation will be necessary to fully assess the licensee's effectiveness in elevating performance standards throughout the organization.
Facility material condition has continued to show improvements. The ooerating history on larle rotating machinery has been good following several major outages on bota units. Recently, System Engineering has been effective at making material condition improvements in several systems. Work planning and scheduling weaknesses impede the rate of material condition im>rovement.
There are larpe backlogs of engineering and maintenance work ttat have been generally eva usted by the licensee. liowever, corrective actions for known
-structural steel deficiencies were significantly delayed due to perceived higher priority work. Subsequent licensee reviews of all engineering backlogs resulted in some minor changes in work priorities.
The management " team" at Dresden has continued to experience change. Most notably, the VP for BWR Operations will no longer have responsibility for other Comed BWRs and will concentrate solcly on Dresden as the permanent Site VP. Key management changes over the last 6 months include the Engineering Manager, Regulatory Assurance Manager, Outage and Work Control
1 1 .
i
)
,DRESDEN PRE-DECl$!0NAL
, Manager, site Quality Vertftcation Director, Support Services Director, and 4 Maintenance Superintendent.
Overall, an improving trend in station perfonsance has continued, but progress 1 in many areas has been slow. The effectiveness of actions taken to improve i material condition, outage management, work control, and implementation of performance standards will be assessed during dual unit operation and the
- upcoming U-3 refueling outage scheduled for fall 1996.
II. FUNCTIONAL AREA ASSES $NENTS l Doerations i
A. Assessment l Performance in the operations area has been good over the last 6 months.
! Control room demeanor and attentiveness have remained _ steady. However,
! weaknesses were identified with operations performance outside the control j room.
Operations personnel have exhibited a conservative operating philosophy in the i control room during several major plant evolutions. Operators have
! demonstrated a questioning attitude which allowed prompt identification of j potential problems. In addition, the control roora operators are less willing i to tolerate degraded plant equi m nt. Operations management fully supports i the operators when stopping worc to ensure conservative control of all evolutions.
! Outside of the control room, several operator errors have occurred over the i last 6 months which indicates that the rigor and attention to detail seen in i the control room has not been consistently implemented in the fleid. In some l cases, Field Supervisors have been ineffective in assuring performance
! expectations were followed. In addition, configuration control problems (e.g.
j . control of equipment lineups) continued to be a concern, a
l B. Basis l Operations personnel have exhibited a questioning attitude and a conservative j operating philosophy in the control room, t
- Operations conservatively placed an administrative limit on resctor i power (2470 Wtch vs. the license limit of 2527 Wth) following performance of a new reactor feed pump feed flow calibration procedure.
! The administrative limit was removed (several weeks later) after a
! thorough evaluation of the calibration data. (2/96)
I
- During a loss of ventilation cooling to the recirculation motor
- generator (MG) and subsequent unsuccessful attempts to restart the fans, P
reactor power was rapidly reduced to prevent overheating the MG sets.
After cooling was restored, full power operation was resumed only after
- an engineering evaluation and repairs were appropriately scheduled.
! (2/95)
. t I
i ,
i j
! DRESDDI PRE-DECISIONAL
- Good uestioning attitude was exhibited by a unit supervisor, who inoui ed about contlegency actions associated with maintenance work on a leaking valve. Whee the unit supervisor detemined that no actions had been developed, the work was put on hold until the contingent,v actions were in place. (3/96)
I
.
- The performance of Ft pre-startup testing (" fast-cruise') had a
} positive impact on the startup schedule.' Many items that would have ,
- caused problems during startup were identified and repaired. Problems '
j found included a fmiwater regulatine valve (FRV that would not operate
- locally, damage to a recirculation M4 set ventila) tion dan>er, and I transformer cooling fans that were not working. (Note
- tte ' fast-cruise' identified some 50 problems and tested 60 systems.) (3/96&
4/96)
!
- The deliberate and slow approach to the U-2 startup gave operators i sufficient time to guestion system operations and initiate repairs.
j This was evidenced by the startup being halted at 50 psig while a irregular FRV operations were discussed with the system engineer.
(4/96)
Poor procedural compliance and poor self-checking contributed to recent errors i by operators outside the control room.
- Numerous problems with the out-of-service (005) program resulted in operations managenest ' locking-out" operations personnel from the electronic 005 system. (2/96)
- An ' equipment attendant" (non-licensed operator) left the U-2 drywell-access locked high radiat4en door unlocked. (2/96)
= .a. licented senior operator in the work execution center authorized a work activity which required a valve to be in the opposite position as the in-place 00$ tag. An on-coming control room operator identified the error during turnover. (t/96)
- The NRC identified that operators were not following the station's valve and electrical lineep checklist procedure or the locked valve program.
Both of these examples of poor configuration control, coupled wit l) the 005 problems, were being considered for possible enforcement. (3/96)
C. Plans Site Focus Group to contiene routine core inspections peogram with special attention on performance of operators outside the control room, the 00$
program, and configuration control. The resident staff will be supplemented by a RIII operator license examiner specialist to evaluate operator's performance. Additionally, a special 'pra-implementation" inspection of the Technical Specification grade Program is planned for June 1996. Continue assessment of the licensee s 1996 Management Plan improvement efforts by the Site Focus Group.
3
DRE90EM PRE-DECISIONAL Maintenance A. Assessment Performance in the maintenance area has been adequate. Significant weaknesses with work con'.rol, scheduling, rework, and skill of the craft remain evident.
A new Maintenance Superintendent was hired from outside the Comed system and the 'unitired" maintenance s,anager positions were eliminated.
While the Lutai haaber of non-outage work requests has decreased, the licensee has continued to strupple with a large work backlog and with scheduling work activities. The estar ishment of a new work centrol process including a work control center, an outage control center, and a work execution center has been slow in achieving positive results. The control room deficiency correction team, fomed earl group numberand work-it-now of outstanding (WIN)ial deficiencies. y in 1995, have reduced the mater Unit I outage work was restarted in January 1996, and perfomance of outage work improved. Recall that the outage was stop and reschedule the remaining work activities.For pedthe in November first time, a1995 to rescope formal forced outage schedule has been developed for the operating unit and was being updated as equipment concerns emerge.
B. Basis 4
Poor quality work packages or poor implementation of the packages continued over the last 6 months.
- poor implementation of foreign material esclusten (FME) controls during modification work resulted in two examples of rags clogging the suction to containment cooling service water (CC5N) pumps. Th's item was an uu.,,la si & failure to implement effective corrective action for similar FME problems in the same system. (1/96&4/96)
- A missing procedure from a work package for the calibration of a containment hydrogen and oxygen analyzer sample pump resulted in personnel incorrectly attempting to "meggering" the pump from the power supply breaker vice the control panel. This not only slowed completion
. of the work but had the potential for personnel injury. (3/96)
- An uncontrolled modification used to hold removable inspection panels was identified by NRC inspectors during the U-2 drywell closeout.
(3/96)
- Failure to perform post modification testing on a steam jet air ejector required delays in plant startup while shifting to the standby air
. ejector. (4/96)
Several examples of maintenance items requiring rework were identified.
- A mechanic damaged the U-2 reactor head vent flange while attempting to remove what he believed was a gasket in the flange. The gasket had been removed earlier. (t/96) 4
4 DREsotu PRE-DECIL!0NAL Wrong size motor installed on drywell sump pumps. Additional expuure
' of 9 Rom was required to repair. (4/96)
A U-2 reactor water cleanup pump flange that was overhauled during the refueling outage leaked and required retorquing. (4/96)
The *28' condensate / condensate booster p' ump, which were worked on during the outage, was taken out of service due to pump seal high temperatures.
(4/96)
Continuing examples of poor craft skills were identified by the NRC durleg the last 6 months.
Bolts missing from a standby gas treatment inlet valve flange - no effect on function (attention to detail issue).
- Recirculation flow line flanges for shutdown cooling p9mps 'tA" and '28' sissing 2 bolts each - no effect on function (attention to detail issue).
Electrical terminal junction box plugs not fully installed in a safety related motor-operated valve torque switch housing.
Numerous examples of fundamental weaknesses in craft knowledge were evident.
Inconsistent use of flat and lock washers.
Screws missing from junction cable pull box covers.
Use of soft flat washers under torqued bolts.
Misaligned flanges and bolts too small for flange holes.
C. P1 .:
Site Focus Group to continue routine core inspections program, with assistance from specialist inspectors, giving special attention to the quality and implementation of work packages, the effectiveness of the new work control process, rework, and skill of the craft. Additionally, a special pre-outage Maintenance Inspection. -'amented by region based specialists, is planned for August 1996, prior to tia and of the current SAlp period. Continue assessment of the licensee's 1996 knagement Plan improvement efforts by the Site Focus Group.
Enaineerina .
A. Assessment Improvement in Engineering support to the station has been noted, particularly the efforts of system engineering. However, the engineering organizaties is still in a state of transition. Although some improvement is evident, several fundamental performance areas remain problems, i
5
. DREsDEN -
ptE-DECISIONAL l The engineering backlos is a major challenge, diverting focus and attention from current issues. Engineering's ability to taprove and maintain equipment '
material condition continues to 'aprove. Despite these improvements, ;
. significant ground remains to be covered with regard to improving material '
condition.
Engineering frequently has not emphasized Final safety Analysis Report fFSAR) l or other l' censing document comeltments. A. specific weakness was ident4fied
% the last 6 months where Engineering allowed ' Operability Evaluations,' done in accordance with Generic Letter 91-18 to remain the basis for continued l Plant operations through more than one r,efueling outage.
l
! 3. Basis .
The Engineering organization is still in a state of transition.
- Onsite contract architects / engineers were integrated into the Design Engineering organization at the end of 1995.
- A new engineering manager has hired from outside the Comed organization.
(2/96) >
- Numerous responsibilities are being permanently transferred to other :
organizations (e.g. vendor manuals and operability evaluations).
- The Inhouse Transition plan (increasing engineering done by Comed engineers) accomplishe d-in 1996. remains in process with several major actions to.be i
- Engineering is developing an improved system trending program and just started development of a self-assessment program. (4/96)
Engineering backlog is major impediment to resolving current issues.
- A prioritization and elimination process for modifications (currently 400) and engineering requests (currently 1300) is ongoing. (4/96)
- Throughout 1996, additional engineering personnel are being loaned from corporate and other Comed plants to work on configuration management backlogs (i.e. vendor manuals, master equipment list upgrade design basisreconstitution,equipmentqualificationbinders,fuselist,etc.).
Engineering's support to improve and maintain equipment material condition has improved.
e significant modifications and overhauls addressing material condition issues were completed in the most recent outages on both units (i.e.
feedwatermodifications,pumpoverhauls,etc.). (4/96) s
- Indicators such as 'to
~
temporary alterations,p technical issues,' operator workarounds,and ou trending downward. (4/96)
-,-yy . - -
,.v-,,n.,-n...n...,,.nn., , . - - - + , ,,,-,e,.,-,-,-,,,,m.-,--,~.>-,..w,,_-, , . ~ - , ,,,,-,.,w..n,,,,--. <,_,c,- ,-,e,w,.-s,.-,-,-,w-,,-n-, n,,
O DRESDDI PRE-DECISIONAL
- Latent system reviews are continuing to identify numerous material contlition issues. In general, the items beinfi identified do not impact system function. However, long term reliabil' ty may be enhanced by addressing the items identified. Twenty-seven systems were reviewed in -
the initial phase of this program. This review effort is only a
' surface' look at the ' corporate knowledge' of individual systems and was not intended to be an in-depth technical design basis review. The prioritization and scheduling to correct the deficiencies was still ur. der review. (4/96)
- The identification of several older design and process deficiencies is positive.
Control rod drive single failure (CRD)ility. scram vulnerab 10/95) discharge volume instrumentation
- CRD scram discharge volume galle(ry steel not meeting FSAR allowables. 11/95) l -
Motor control boundaries Primary containment (center with38-3 breaker no previous local incorrect tap setting.s testing. (1/96)
Reactor recirculation pump seal purge line missing containment isolation valves. (3/96)
Significant progress remains, to be achieved with regard to material condition.
- While U-3 has operated continuously since November 6,1995, some material condition problems continued.
- Main steamline drain valve packing leak. (t/96)
Fursinite in,jections on a feodwater regulating valve.
(1/96 & 2/96)
Oil leak on a recirculation motor causing repeated alams. (2/96)
Leak in drain line of U-3 high pressure coolant in,jection system steam supply. (2/96)
A significant packing leak on the *3D' CCSW pump. (4/96)
- Several material condition problems were identified during U-2 ' fast cruise" and startup. (3/96 & 4/96)
- A FRV that would not operate locally.
Damage to a recirculation MG set ventilation damper.
- Transformer cooling fans that were not workinfl.
- Body-to-bonnet lea t on feedwater system conta' nment isolation valve.
- Electrical issues continue to be a concern. An overloaded non-safety bus caused a loss of fuel pool cooling on both units. Initial licensee calculations showed other non-safety buses were effected. (1/96)
- Several failures of 4 KV circuit breaker highlight problems with control of breakers and breaker material condition. (1/96&2/96) 7 :
.DRESDEN PRE-DECISIONAL -
. Untimely actions to address a nonconforming condition with the ECCS cemr recer' structural steel not meeting FSAR allowables. Originally identified as a site issue in early 1994. Corrective actions were ,
implemented on U-2 only after significant NRC involvement. Unit 3 will be worked in September 1996. This item was the subject of an enforcement conference in May.
C. Plans Site Focus Group, which includes a dedicated lead engineer and assistance from RIII specialists as needed, to continue routine core inspections program with special attention on the effectiveness of the 'new' engineering organization, the engineering backlog, engineering's support to improve material condition, and engineering's emphasis on the FSAR and other design basis comitments. An Engineering and Technical Support inspection is scheduled for May and June 1996. An inservice inspection program inspection is planned during the upcoming U-3 refueling outage beginning in September 1996. A motor operated valve close out inspection is planned for October 1996. Continue assessment of the licensee's 1996 Management Plan improvement efforts by the Site Focus Group.
E]_ ant Support l
A. Assessment Performance in the Plant Support functional area has been good in the areas of Security and Fire Protection. Slight improvement has been recently noted in the Radiation Protection (RP) area. However, continued significant management attention is needed to address previously identified programatic weaknesses and to instill station-wide ' buy-in' to the RP pro The overall operational status of the Emergency Preparedness (gram.EP) program was good. The EP program wn eure %ed when a Notice of Unusual Event (NOVE) was declared in December 1995 and it Aarch 1995. In both cases the entry and exit into the emergency plan was :propriate.
B. Basis Radiation Protection The RP department has undergone extensive management and supervisory changes.
Most of the changes have been effective in the initial establishment of improved expectations and quality standards, particularly with the RP technician level and above. It is too soon to assess the long term effectiveness of these changes and the impact these changes will have on station radworkers perfomance.
Significant radiological control problems were identified during an NRC tour of the radioactive waste areas, including a resin spill that had gone uncorrected for over a year. Some of the concerns were previously known by radiation protection technicians and supervisors; however, no action was being taken to resolve the problems. This illustrated that continued eifort is needed to ensure that station management's expectations are accepted down to the staff level. (2/96) 8
O DRESDEN PRE 4EC18101EL
- Exposure control was adequate for the original outage work sco w of the 11-7 nubca However, emergent wori and re-work continu(which stated ally hampered in June the station from 1995).
meeting exposure estimate goals. Outage work was suspended in November 1995 and restarted in -
January 1996. Dose perfonnance improved and the ALARA organization was aggressive in presenting exposure control concerns durir.g work planning and scheduling meetings. Again, emergent work on the ECCS corner room steel and other rework items increased the planned exposure. (4/96)
Security -
Security program performance during the last 6 months was good.
Licensee and contractor self assessment efforts were well documented and considered a program strength. (2/96)
- Initial training was well defined in scope and was implemented in an effective manner. (2/96)
- No unauthorized access and no failures in security barriers. (2/96)
Some minor performance weaknesses were identified.
- Inadequate compensatory measure occurred due to personnel error. (2/96)
- Overall maintenance of security equipment. (2/96)
- Security computer operations involving inventory control of card keys and timely submittal of fingerprint cards. (2/96) '
Fire Protection ,
The overall. fire protection program was assessed as good and improving.
- Good control of combustibles' including the control of transient combustibles in the plant. . (2/96)
- Few impairments. requiring fire watches. (2/9'6)
- The fire protection staff was experienced, knowledgeable, and' proactive in dealing with plant problems. (2/96) , ,
some deficiencies were identified with the control of caergency lighting.
Inadequate discharge tests on emergency lighting in'1994 and again in, 1995. . Corrective actions appeared adequate to prevent recurrence.
(2/96) ,-
9 4
DRESOfN PRE-DECISIONAL
- Multiple minor examples of continued p'roblems were identified by the NRC. (2/96) .
Backup eme 1pency light that was not operable. -
Lamps that were dirty or had paint over-spray.
- Several emerTency lighting lamps that were not properly aimed.
A 400C was declared in December 1995 for hydrogen buildup in the Radwaste building ad in March 1996 for a potentially contaminated injured man.
- The classification and notifications were made properly and in a timely manner. (12/95 & 3/95)
- The documentation package for the events was detailed and complete.
(12/95 & 3/96)
The overall operational status of the emergency preparedness program was good.
- Response Mlfit'ies and equipment were adequately maintained and in an operational state of readiness. (4/96)
- Audits and surveillance of the program satisfied the requirements of 10 CFR 50.54(t). (4/96)
- Nanagement support for the program was good and key emergency response personnel possessed a good knowledge of emergency responsibilities and procedures. (4/96) -
C. Plans site Focus Group, with assistance from RIII specialists as needed, to continue routine core inspections program and to continue assessment of the licensee's 1996 Management Plan improvement efforts. Radiplogical Protection inspections to focus on station-wide ' buy-in' of management's performance expectations and standards. Continue with core inspections in the fire protection, emergency p'reparedness, and security areas and followup on previously identified weaknesses.
III. FUTURE ACTIVITIES Since the last Sitt, the inspection oversight of Dresden was further enhanced by assigning a full-time Branch Chief and Project Engineer. The additional resources strengthened the existing Site Focus Grous which consists of a N+1-resident staff, dedicated senior project manager (NtR), dedicated lead engineer, specialist inspectors from RIII (e.g. HP, Sec licensed examiner),
, and augmented site coverage by both regional and NRC specialists. In addition, a dedicated SES manager continues ta provide Focus Group oversight.
The Site Focus Group will continue to implement the routine core inspection program and assess the licensee's improvement progress, 10
==
DPIfDEN PP.E-DECISIONAL Senior NRC managers plan to continue frequent site visits to independently ate.es the station's paterial condition and overall perfontance. Public meetings at the site, R!!!g and headquarters will continue to ensure the NRC's assessment of the licensee progress is clearly comununicated. .
INSPECT 10NS:
Engineering and Technical Support - May/ June 1996 Technical Specification Upgrade Program - June 1996 Radiation Protection - June, August, September, & October 1996 Security - June & August 1996 Licensed Operator Examinations - July 1996 Pre-outage Maintenance Inspection - August 1996 5 ALP-14 completed September 28, 19M Inservice Inspection Program - September / October 19M Motor Operated Valve Closeout - October 1996 51GNIFICANT MEETINGS /V! SITS:
Comed Brief the Chairman on Dresden's Performance - May 1996 Milhoan/ Russell Site Visit - May 1996 Unit 3 Refueling Outage - September 1996 9
8 9
4 9
9 11
DRESDEN PRE-DECI510NAL DATA suf5LARY
\
I. PRA -'
A. PBA Insishts i Unlike most SWRs, Dresden does not show station blackout (500) to be the '
s dominant contributor to core damage frequency. The passive isolation j condenser reduces the risk from Sto. In order to further reduce the 500 j risk contribution, the licensee has completed the installation of a 4.4 We $80 diesel generater at Unit 2. The Unit 3 sto diesel is expected to be completed in September 1996. ;
Loss of DC power is significant at Dresden because it impacts the two systems used for decay beat removal during an 500, the isolation condenser and the high pressure core injection (HPCI) system, and impacts one train of suppression pool cooling. Units 2 and 3 share two 125 Vdc and two 250 Vdc battery systems. Comed has installed an additional 125 Vdc back-up battery system on each unit. A non-safety 250V battery was aise lastalled in each unit where non-safety loads on the safety busses were transferred. These additional batteries were not modeled in the Dresdee IPE submittal. Both of these modifications will i reduce the loss of DC power contribution to risk.
B. PRA. Profile In response to Generic Letter 88-20, the Itcensee submitted an IPE for Dresden on January 28,1993. The IPE submittal contains a full- scope Level 1 and Level 2 PRA. The IPE estimates a core damage frequency of '
1.85E-3 pr year for laternal events. Internal flooding was included in the analysis and the licensee concluded that the impact of internal flooding on overall CE was insignificant.
The staff IPE Level I review has been completed and the detemination made that the submittal did not meet the intent of the generic letter.
The staff could not conclude that: a thorough examination for plant-specific initiators was performed, the use of low beta factors for common cause failure analysis was appropriate, diagnostic human error and human error dependsscies were appropriately treated, plant-specific factors and experfence were adequately factored into estimating human error probabilities, and pre-initiator human errors (and especially were adequately examined and evaluated. The NRC miscalibration errors)l of the IPE by August-15,1996.
expects the resemitta The IPEEE is scheduled to be submitted in December of 1997.
It
t
' +
DRE5 DEN PRE-DECISIONAL The IPE CDF profile is listed below by initiating events:
Initiatina twent cataeorv CDFilyr) E of Total TRANSIDif & Sto (885)
Loss of DC Power 1.1tE-5 60.25 General Transient 2.64E-7 1.45 Single Unit LOOP 3.69E-6 19.M .
Dua Unit LOOP 1.24E-6 6.95 LOCASEQUENCES(95)
- Medium LOCA 1.38E-6 7.55 Larpe LOCA 3.66E-8 0.25 Saa 1 LOCA 6.23E-9 <0.15 Inadvertent Relief Valve Opening 1.79E-7 1.05 ATWs SEQUENCE (35) 5.34E-7 2.95 ISLOCA(<0.15) 4.34E-10 sL.11 TOTAL 1.85E-5 1005
! The dominant accident sequence, which represents 44.2 5 of the C0F, is loss of DC power and subsequent loss of suppression pool cooling.
Containment failure is associated with 895 of the sequences leading to core damage.
Two procedural enhancements resulted from the IPE The first involves alignment of low pressure coolant injection (LPCI) or core spray (CS) pump suction to the CST when suppression pool cooling cannot be estabilshed. ..The second procedure modification was to manually open the circuit breakers to the isolation condenser's MOVs prior to depletion of the 125 Vdc batteries. The IPE states that by incorporating these changes the total Dresden CDF would be reduced to 3.7E-6/ year.
C. Core Damano Precursor Event 1 On the basis of the precursors identified by ORNL for 1994 (NUREG/CR-4674, Vols il and 22 and the preliminary precursors for 1995 and 1996, the staff did not identify any precursor events for the site that have a conditional core damage probability of IE-5 or greater. In addition,' no recent events have been classified as "Significant Events' in the Performance Indicator Program.
13
DRESDDI PRE-DECISIONAL, i 1
II. DFORCENDif NISTORY < '
6/94 - CIVf PENALTY (Suno1' nt I. Reactor Onorationst EA 94-044): The action was pased on three v'o'ations of the order ap roving the ;
- decommissioning plan for Dresden 1 involving the fai ure to maintain *
- HVAC and the failure to drain or proptrly lay up fluid systems in Unit !
l 1. When a rupture occurred in the service water system that froze due i
to sub-zero temperatures, 55,000 gallons, of water drained into the .
- centainment on January 25, 1994. These violations represented a lack of '
attention and carelessness toward licensed responsibilities and, in the aggregate, constituted a Severity Level III problem. A civil penalty was issued to emphasize the need for increased management attention to
- licensed activities and strict adherence to the Unit 1 Decommissioning Plan. Escalation of 2005 was warranted for each of the factors involving licensee's poor past performance, prior opportunity to identify, and duration. ($200,000) ;
4 11/94 - SEVEpITY LEVEL IV VIOLATION ISunnlement 1. Reactor Onera11gan t
- A 94-148): The staff considered escalated enforcement action for the l licensee's failure from January 1992 until April 1994 to take prompt and t adequate action to correct inadequate design calculations that could have resulted in a degraded condition of the High' Pressure Coolant Injection (HPCI) ventilation system. Upon evaluation, the staff concluded that this was a severity Level IV violation; however it noted that it further demonstrated problems associated with the Itcensee's corrective action program as cited in EA 94-048.
3/95 - CIVIL PENALTY fSuontement I. Reactor Onerations EA 95-030): The action was based on several violations associated with violations of the technical specifications, inadequate procedures, and the failure of i licensee workers and operators to follow procedures that occurred during_
January - February, 1995. The violations were grouped into one Severity Level !!! yroblem. The base civil penalty was mitigated 505 each for l
corrective actions and identification. The base civil penalty'was escalated 100% each for poor past performance and prior opportunity to identify the problem. ($100,000) 3 12/95 - CIVIL PENALTY (Sunclement V. Trantnortatient EA 95-2145: The action was based on a radioactive waste shipment that was recetved at an offsite vendor facility with an external radiation level in excess of the Department of Transportation (00T) limit. A base civil penalty was issued to emphasize the need for strict compliance with D0T limits, and to recognize the licensee's previous escalated enforcement history.
Because this was not the first escalated action within 2 years, the NRC considered whether credit was warranted for identification and corrective ection. Credit was not warranted for identification because the vendor identified the issue upon receipt of the shipment. Credit was warranted for corrective action. ($50,000)
, PENDING (EA 96-115): The staff held a predecisional enforcement conference on May 1, 1996, and is considering escalated enforcement action for corner room structural steel in a condition potentially
! outside the FSAR.
i 14
. _ _ . _ _ _ _ _ _ _ _ _ . _ ~ . _ _ _ _ _ _ _ _ _ _ _ _ , _ _ . _ - - _ . - . - . _ _ . _ . _ _ _ , . _ -
_~
PREDECISIONAL L*9*nd DRESDEN 2 Refueung R Operacon m Industry Avg. Trond ShutDe E!E3 93-1 to 9%4 Quarterly Dets Not snomi using 09. Cycse . . - .
Ops. . -- Ops. . --
R R R E
- m y;, . e., .,. m . - .- .m y;,.e .,-, m -
Automsoc Screms While Cret6 cal Safety system Actuations
, 4 3- 3-g 2- 2-
- 1. 1.
.a .w ya,, g,, e m . 'a .w y ; g ,,,, e m i sign =.ni Event. .
tv y. tem r u, _
1.5 - 3-W w
'510- ,
gg 2 0.5 -
- 1. El 0~0 n1- sm k1 k) E1' es.3M d
I
$ BM o.i t
E Eki-Wks' ts.1; E 4' tu i Year . Quarter Year. Quarter Equipment Forced Outagest Fc, teed Outage Rate (%) 1000 Commercial Catecal Hours 100 6 30 U
I a: so. p 4.
I 2 E
20 -
o "o a5s m .h. , o: &w~'.^. $ Y k1 ts.1 43 kii k)
Year . Quarter E1' b3
- 7 DM kii Year. Quarter 96 1' 53 3 Cause Codes
- *' N' Cosective Radiation Exposure =
200
- e. .. ..
y W 190.
E 100. j
. ."=E* e P ..
, - e. ~ .
q . .
1,,. J.m I.,.iA.dh,-- 1 -
0 m,.
k3 m m . ..
4 gi I
- sn.Awr.pR.4.*n N *'
PREDECISIONAL DRESDEN 2 e s==w son 4- w9n --
Peer Group General EW Pro-TMI "'8'W* M 831 to 954 Trends and Devotons Devet>ons From Plant Peer Group Self-Trond Medan Short Term Long Term o.ee 4 s,ie m .d ww.e bener OPERATIONS i
Automatic Scrams While Critical - 0 0.30 Safety System Actustions - 0 -
-0.72 Significant Events - 0 -
0 Safety System Failures - 0 -
1.20 Cause Codes (All LERs) e Aa. e en courv p.m -
]031 -
4.90 e poene.e opereer ames - 1.59 . 4 -
4.80
- e. oom pw.amw amre -M +7.20 -
4.90 s enennenanme Priesame - 2.19 / W 7- , * *iA3
,, -,,,,,,,,p,,e-
-M *1.29 0.90 *
- CTA '
tam ma - 0 --
0.90 i SHUTDOWN Safety System Actuations - o -
0 Significant Events - o -
o Safety System Failures - o.1 g -
o.34 Cause Codes (All LERs) sA weenc.aevp an - 0 - lOA9 6us aopwennsm - 0 - 7 033 e, con ev s amri - 0 - 0.73 M a en== a.ev.emme -
p, 0 - 0.72 M
.an -
] 0.00 -
- 0.50 l
t sammen==sem - 0 - 0 l
FORCED OUTAGES Forced Outage Rate * - 0,10 = ,
0.51 Equipment Forced Outages /* , c 1000 Commercial Critical Hours 0 26 1A C'S DA Ch 1A 1A 4h 04 Ch 1.0 Performance indet Per*ormance incex
- pass comnaene ser operseenes cyme l
l l
.x___ - ____________________________ _ __________ _ _ _ _ - _ _
PREDECl& TONAL i
t.g.no inum- .pnrox. n an ,, ==me, cm DRESDEN 3 . n, , o,,r.oon Mustry Avg.frend th N M 33-1 to 95 4 Quartetty Del' tot sewn using op. Cycle m
. .- _ ,. _ o.a. .. __ . _ .
R a E
Dt It>3 gi , ,151' Ar i ISt 143 g,151~ AP '
Automs6c Suom MBe Crecal Sawy Sydnen Amaeons
, 4 3- 3 i
J 3 g2
' $1 b gb M' ~ hti B53 ,g M $3 I 8%n nt ems , SaWWom %ms ,.
2.0 ,
3 f 1.6.
0 w" y 2 .-
's 1 D .
^
03- 1 4 d
,- : MLt a E'88
,, - .m y,,,, g,,,,- m . m .m g , g,- m .
Equipmed Forced Outagest Forced Outage Rate (%) , i m Co h lC h % n 100
- ~
.. 1 f-I. aa a
. . , _84 . m$ = ..
_ . _= r_ m
- d.s W Oper s.OswtPer Cotective Radiation Exposure .
200 '
.. I' Wi I
W jg 4
m* b ""a'a e a
**5" ,
f*
so.
- J ,! @ dh = = -
- m y, , . g,- .m . .. j
. .d, n.
- -a- n. ne . ,- , ,
y
PREDECISIONAL DRESDEN 3 *ne s=== i smaa- wien ===== -
Peer Group General Doctne Pro-TWI '#"* E 931 to 95-4 Twnds and Densbons Deviehons From .
Plant Peer Group Self-Trend Medan Short Term Long Term OPERAT10NS Automatic Scrams WWie Crttical - 0.28 0.77 Safety System Actuations - o 0
Significant Events - 0 0
Safety Systen Fallures - 0.86 -
1.20 Cause Codes (All LERs) 6Asaw.stownamowPow=me- 0.53 E -
4.48 E s.u n eso. mew en n = ]O.14 -
M, 0.87 e.cowPweenas snwe - 1.29 -2 .ea - 4 34 I l a emm e -
a an ve o.4e -
% 4.se
. - ,- 0.2,
.senuma .s .
s sa a - I 4.00 -
0 SHUYDOWN Safety System Actuations - 0 -
0 Significant Events - o -
o Safety System Failuree - o 35 -
o,34 Cause Codes @ll LERs) sA merw.e wPiwn -
ens ( - 4 22 susa ee,ww.canwe- 0 - 025 I
- e. ce= Pwe.a m erna -
& es mas a e Prem.me -
J030 -
M 4.5a 0 - O a o.a.e - sese.un Prem.me - 4.15 [ -
0.50 tsh a e- O - 0 FORCED OUTAGES Forced Odage Rate ' - o,49 .o,4g #
Equipment Forced Outegest * -
g -
1000 Commercial Critical Hours 428 g[j -
-o,14 1D 4's ton O's 12 1D 0's CD o's 1D e,,,,msnse m . , ,,e,,,,m.n o ce,
- 9e.t Cowvested 8.c opereennel cree.
~
. : l 1
PRE-DECISIONAL QUAD CITIES WCLEAR POWER 8TATION SALP Period: July 23, 1995 through December 28, 1996 '
Previous SALP Ratings: Operations JL
. Maintenance JL Engineering JL .'
Plant Support JL
! June 1993. Following both SMs in 1994 and the January 1995 SM the NRC j expressed concern over the continuing decline in overall performa,nce. Major 4
problems were poor material condition, ineffective self assessment and
! failure to accomplish improvement plans. During the first half of 1995, overall performance improved. The new senior management team estabitshed a i
clear course of action and increased account 6bility to improve performance.
- Following the June 1995 SM , NRC senior managers concluded that the declining i
trends had been arrested. Since June 1995, continued propress was seen in the i areas of Operations ALARA e) planning and execution, and in improvemen(As low As Reasonably Achievab ts to the station's material condition. Slower j progress was seen in the itcensee's taprovement initiatives for Engineering 3' and Maintenance, particularly in the work control process.
i Since the last SM, station performance improved slightly. Many of the 1995 i Management Plan objectives were accomplished including: reductions in operator i errors, maintenance backlog, and overall dose; improved unit performance; and i
i leadership improvement initiatives. However, enforcement of expectations, accountability, and communications standards have not been consistently I implemented down to the first line supervisor level. Ineffective work control i
and inconsistent problem identification and root cause evaluations have i continued to contribute to the plant's poor material condition. Poor
- maintenance supervisory and craft skills and rework were also contributing
! factors, "
i i operations performance has remained good, but pro i weaknesses in planning (including risk planning),gress communications, was hindered by
' understanding of Technical Specifications conditions for operation, and by somennel perso(TS),
errors. Unit tracking 1 (U-1of liatting) started l a planned 78 dt.y refueling outage in February and U-2 continued to operate.
some success ha: resulted from engineering focus on improving root cause
! evaluations and engineering involvement in correcting material condition i problems, on weaknesses in training and mentorings en enforcing expectations, '
i and on reducing backlogs. Poor corrective actiors on some problems remained i an issue. Radiation Protection improvements included source term reduction, 4
ALARA planning and implementation, and station leadership initiatives.
, Radiation worker practices, while improving, were still problemat.c. Station i dose for 1996 will be quite high due to material condition improvement 4
efforts.
! 4
.,,,-.,,,-~.y . m--,-r,--4-, - - - - . , ~ ,.p,.mr ..,-,-,---.4
, - - , , , , . , , - - . - - - - , - . . , u-,_,,c-,,_,,_.,,.mm.,w-.. --,--.,..--w.m-- --
m .w c-r
QUAD CITIES PRE-DECI510NAL Nanaflement changes at Quad Cities ever the last 6 months included: Site Qual'ty Verification Director, System Engineering Supervisor, Lonfi Range Planning Superintendent, aad Executive Assistant to the Vice Pres dent. .
II. FLMCTIONAL AREA ASSES $NDITS Goarations .
A. Assessment Over the last 6 months, Operations perfonnance remained good, with some notable weaknesses. Improvement initiatives in self checking, panel monitoring, and communications were successful, particularly in the control l
room. Some personnel errors resulted in reportable events. Operations s
understanding'he were weak. licensee's ability to manafie and complete priority work wasof desig hindered by poor inter-departmental communtcations and programmatic weaknesses and in the 'out-of-service" in planning program. (including Based risk management) on field observations,- implementation of perfomance(005) expectations by operators outside the control room is below the perfonnance i
level of control room operators.
- 8. Ba,is Control room improvements have led to fewer operator errors and related transients.
- Unit 1 operating record of 263 days was a Comed SWR record.
A notable reduction in licensee event reports caused by personnel errors occurred in 1995.
Operations knowledge and understanding of TS requirements was weak.
- The inspectors found that operator knowledge of intentional entry into TS 3.0.A (3.0.3) was weak. Operations management a entry into T.S. 3.0.A for local leak rate testing (pproved a voluntary L.RT) which breached containmentintegrity.(2/96) .
._ Internal communication, scheduling, and planning weaknesses hindered station performance. .
- Failure to periodically clean and monitor the performance of the intake structure trash rack led to the initiation of a forced dual unit shutdown. Debris had clogged the trash rack, which resulted in the loss of required suction head for the station's fire pumps and jeopardized the performance of safety related pumps. (1/96)
- Communications between Operations and Engineering were poor when residual heat removal service water (RHRSW) vault seals failed leak tests (2/96).
2
U guAD CITIES PRE-OEC!stmAL Ex5mples of weak understanding of risk management and a poor risk assessment program continued.
As noted above, intentional entry into TS 3.0.A was directed in order to perfore routine LLRT surveillance. (2/96)
During the U-l outage, the U-l standby diesel generator (SBDG) work was not treated as a risk priority and work activities were only scheduled for day shift. As a result of the length of time the U-l $80s was inoperable and an unrelated failure of the ' swing' $80G equipment failure), the shutdoun risk for U-l increased.(due to (2/96) l The material condition problems identified by the NRC indicated some poor operator walkdowns.
Poor housekeeping and lighting conditions in emergency core cooling systems (ECCS swing bus were) noted on several occasions. (4/96) rooms and near low pre Corrective action implementation weaknesses persisted.
The NRC identified poor root cause analysis in the failure to pursue proper corrective action for operator-identified problems in the U-2 SBDG, which led to 3 consecutive months of diesel start failures during surveillance testing. (11/95)
The inspectors found that plant operators were not periodically checking the U-l reactor core isolation cooling RCIC trip throttle valve. That check was part of corrective actions rec (ommen)ded by engineering following a RCIC failure to start in May 1995. (12/96)
Operations failed to initiate timely corrective actions when informed by Engineering that RHR$W vault seals failed leak tests. (3/96)
Structural steel deficiencies in ECCS corner rooms were not addressed in-a timely manner. (4/96) .
Out-of-service (005) errors, continued.
Over-current protection fuses were removed from the ' swing" SBDG in accordance with an 005. The intent was to disable the U-1 control circuit. However, the tagout aise disabled the U-2 control circuit, making that.SBDG inoperable. (3/96) ,
Human perfomance and 00$ program deficiencies while hanging tags led to an inadvertent primary containment isolation. (3/96)
C. Plans Site Focus Group to continue routine core inspections program with special attention on: risk management; operations personnel knowledge and understanding of TS requirements; performance by operators outside the control 3
quad CITIES PRE-DECISIONAL room; and improvements in the work control process including tagouti restoring equipment to service, and prioritization of work. TheresIdent staff will be supplemented by RIII license examiner specialist to evaluate the '
licensee's performance. Additionally. a special '
inspection of the technical specification upgrade'programpost implementation" (TSUP) is planned for November 1996. Continue assessment of tTe licensee's 1996 Management Plan improvea*nt efforts by the Site Focus Group. - , , ,
Maintenanca <
A. Assessment .
While the overall maintenance process remained poor, some improvements in the work control process have been made. Craft and supervisory training weakosses were evident, and improvement plans are slowly being imp emented.
- poor maintenance practices resulted in-excessive equipment-down time and l- damage to equipment. The licensee continued to have problems with human l and a cumbersome wotk process.
performanceissues,equipmentparformance\ncreasedequipmentoutagetimes,and These problems resulted in plant events, led to unnecessary rework. Additional resources have been devoted to increase maintenance training in ar. effort to improve the skill of the craft. Since the last $5, a reduction in high priority maintenance items, such as operator workarounds and control room corrective work requests, has been noted.
However, non-outage corrective nuclear work request tasks were high (2534 for both units) and trended up during U-1 outage.
Personnel changes made since the last SM in an attempt to improve Maintenance Department performance included:
- Mechanical Master was replaced with the Electrical Master. The Electrical Master position was filled by the Electrical General Foreman.
- Addition of maintenance staff and senior reactor operators into work control positions.
Added resources strengthened the Fix It Now (FIN) team concept.
B. Basis Poor maintenance practices resulted in excessive equipment down time. >
+
poor communications during motor operated valve (MOV) V0TES testing led to a , jumper being inadvertently.lef,t in RCIC valve, causing repeated cycling. (2/96)
Poor.005 planning by Instrument Maintenance resulted in removing the
, wrong reactor protection system ' shorting" links. (4/96)
Deficiencies in Electrical Maintenance training for soldering and tubing connections led to rework on Control Rod Drive (CRD) and Standby Liquid Control (SBLC) systems. (4/96) 4 J
4
- QUAD CITIES PRf.-dEC1510NAL
- Wit 1 meter head was initially misaligned when reinstalled.
, (4/96)
Efforts were made to reduce the higher priority work backlog over the last 6 months.
- The licensee implemented another 13-week rolling work schedule. The lupact of the rolling schedule is still minor, as outage work uses'the me.jority of shop resources. (2/96)
- Control room work requests were reduced to about 70 items. (4/96)
- Operator workarounds were reduced to about 40 items. (4/96)-
l Outage preparations for U-1 were improved, but some difficulties remained.
- The long range plan for the outage was improved over previous outages.
l Personnel and dates were assigned for implementation of tasks. Most l preparatory tasks were completed by the date due. (2/96)
- Work package properation schedule curves were developed as a tool to detenmine U-1 outage planning effectiveness. Four of ten were not completed prior tc the start of the outage as scheduled. (2/96)
C. Plans Site Focus Group to continue routine core inspections with special attention on the effectiveness of the work control process including work planning, maintenance practices, and craft skill. Continue assessmer.t of the licensee's 1996 Management Plan improvement efforts by the site Focus Group. Engineering and Technscal Support inspection (planned for July 1996) to provide some es a s w nt in these areas.
Enaineerina A. Assessment overall engineering performance over the last 6 months has been adequate with some visible improvements. Expectations in system engineering have not been fully realized for root cause assessments, prioritization and execution of work (including system walkdowns), and recurrence of backlogs. As a result of inadequate root cause asst.ssments and previously existing design and maintenance problems, poor plant material condition continues to hinder plant performance. Corrective actions for known design deficiencies have been delayed.
Progress was made on improving material condition during the 1995 U-2 refueling outage. Work during the 1996 U-1 outage was similar and should result in corresponding in) roved system performance. However, numerous longstanding equipment pro)1 ems still exist and considerable room for material condition improvements remains.
5
QbADCITIES PRE-DECISIONAL
! of design change documentation has been problent. tic Th :n;in::rie h: Ele; inaccurate data base of setpoints for instruments such endhasresultIHfinan I as drywell and residual heat removal CRHR) pressure switches. Other backlogs ,
continued in Nuclear Tracking System 4tems, Nuclear Work requests on engineering hold, and overdue problem identification forms (PIFs).
Engineering had not consistently included a review of Final Safety Analysis Report or other licensing document connitaents during routine engineering work
, activities. A significant weakness was identified in the last 6 months; ,
engineering allowed an ' Operability Evaluation,' done in accordance with l Generic Letter 91-18, to remain the basis for continued plant operations i through more tk n one refueling outage. After NRC involvement, a structural steel modifir n va: added to the 1996 U-1 outage to restore design basis margins.
B. Basis Material condition problems recurred due to poor root cause assessments.
l
. Units 1 and 2 high pressure coolant injection (HPCI) systems wars declared inoperable several times due to valve stroke problems, failure l to go on turning gear, and gland seal and auxiliary oil probl6ms.
(11/95-2/96) l
- Repetitive HPCI and feedwater check valve failures were indicative of ineffective root cause evaluations and corrective actions. (4/96)
Problems identified by the NRC over the last 6 months were indicative of weak walkdowns by some system engineers.
. improperly aligned scram valve limit switches. (11/96)
. Solenoids on the hydraulic control unit directional control valve interfere with scram inlet valve stroke. (11/96)
. Improperly mounted solenoid for U-1 HPCI air-operated valve. (12/96)
Backlogs in engineering were high but improving.
. Design change documentation backlog 'nas been problematic and resulted in ,
inaccurate instrument setpoints in a controlled data base. (4/96)
. Overdue Nuclear Tracking System items were reduced to about 32.
. Several hundred overdue station PIFs w'e re open in December 1995. This number has been reduced significantly in 1996, but still remained high
.(170). (3/96)
Some engineering improvements were observed.
. Increased connunication between sites.
6
-r-u, , .,. . . , - - - - . -.-,y- ,,my . - , - ,,---- -,,m-- w%,-.-~mw--,.-%m.mm%-.- , , , - . , - - - - , - . . , . , . - . , - - ._-..,-,y--. r-..-,-ee,- --e .--,. -
EiAD CITIES PRE-DECISIONAL s Er.-ir.r.crir.g roics, responsibilities, and expectations are clearly '
defined. .
- Increased syst3m engineering presence in the field.
- System engineering notebooks upgraded. .
- System readiness review board procwa developed for system status presentation to senior management.
- Reduction and prioritization of the modification backlog. 5
- Addition of senior personnel from outside the Comed system to act as $
role models and to improve engineering. ~
i Problem identification was good with an active Integrated Reporting System generating over 3100 PIFs in 1995.
Corrective actions for known design deficiencies have been delayed.
- Inservice testing weaknesses were evident in failure to test a U-1 HPCI valve and a U-2 SBDG fuel line check valve. (12/95 & 1/96)
Structural supports for RilR corner room steel and RHRSW pump modifications to prevent runout conditions were not brought to resolution. The lack of prompt corrective action for the RHR corner room steel was the subject of an escalated enfcrcement conference.
(5/96)
Equipment failures caused the loss of availability of numerous pieces of saf ety equipment, plant transients, and challenges to operators.
auxiliary oli pump cycling, gland seal exhauster fan breaker tripping, cnd slow air-operated valve stroke times (11/95-3/96)
Loss of main bank cooling fans on U-l'eain transfomer due to a single fan failure (1/96) .
' Swing" S80G inope.able due to lube oil huter failures (2/96).
- Numerous cracks identified on U-l recirculation piping and reactor vessel internals (3/96).
Failure of a Turbine Control Valve servo required taking the U-2 turbine off-line (3/96.)
The LPCI swing bus feed breaker coil caught fire (3/N;,
Unit 1 SBLC 'Squibb* valve failed to fire during test (4/96).
7
4 quad CITIES PRE-DECISIONAL C. *1en? .
Site Focus Group,' which includes a dedicated lead engineer, to continue .
routine core inspections with special attention on the effectiveness of engineering involvement in improving the plant's overall material condition, in root causes assessments and corrective actions, in reducing backlogs, and in Engineering's emphasis en maintaining the plant's design basis. .
Continue assesswnt of the licensee's 1996 Management Plan improvement efforts by the Site Focus Group. An Engineering and Technical Support (E&TS inspection is scheduled for July 1996, to provide some assessment of) work control processes. An MOV closeout inspection is planned for November 1996.
. Plant Suonert A. Assessment -
Perforsance in the areas of Plant Support was. good. Radiation protection performance was good with continuing efforts to improve ALARA planning and reduce the source ters. However, radworker performance problems continued.
Security program performance was good with strong management oversight.
Security force performance was good despite it. creased job stress caused by downsizing. There were few personnel error evants. Maintenance of security
- equipment was adequate. Based on resident staff observations, performance l remained constant in the areas of Emergency Preparedness and Fire Protection.
B. Basis Radiation Protection Effo:La Lo iw ove ALARA planning and reduce radiological source term continued.
Station dose continued to decline and was about 740 ren in 1995 (about equal to station revised goal).
. An ALARA manager is named for each task and detailed plans with contingencies are developed.
. Several ALARA initiativer have been taken, including moving a high dose rate line from the reactor yder cleanup (RWCU) access control area and increased use of lead shielain: and cameras. Good use of industry and U-2 outage " lessons learned" for turbine and RWCU work, t
Source tern reduction efforts conti'nued.
. Examples included hydrolazing, installing low cobalt replacements for the RHR pump suction valves and several CRD blades, removing the CRD sink drain line, chemical decontamination of the RWCU and reactor recirculation systems, and installing permanent shielding in the RWCU heat exchanger room. These efforts were expected to save about 650 rom.
8 l
QUAD CITIES PRE-DECISIONAL The lice"ee recently implemented a program to minimize cycling of the hydrogen water chemistry (WC) system. However, effects from previous -
WC cycling appears to have resulted in a significant increase in dose rates for the U- 1 turbine internals and may also have increased plant source ters. (2/96)
Some problems were noted with raoworker perfomance.
- Probleas with control of locked and high radiation areas continued causing the licensee to assemble a task force to determine root caus6 and develop corrective actions. (11/95)
- Several examples of radiation workers failing to follow station radiological policies and procedures were identified by NRC. (3/96).
Security Security performance was good based on the following examMes:
Several eouipment upgrades to improve performance, including the installation of har.d geometry and protected area land vehicle protectivo systems. The licensee was also designing a new security computer system.
Security force performance was good with few personnsi error events despite increased job stress caused by downsizing. -
Emergency Preparedness On three separate occasions (two were county wide and one .sas for an individual <.ity), emergency sirens, were found out of service. Two of these instances were weather related failures. (3/96) -
Fire Protection p Some material condition problems were noted with the shared diesel fire pumps.
- The "B" pump failed its annual flow test. (1/96)
- The 'A' pump's diesel tripped on overspeed. (1/96)
Fire loading in a computer room in excess of design allowables. (1/96)
C. Plans Continue the routine core inspection program and continue assessment of the licensee's 1996 Hanagement Plan improvement efforts by the Site Focus Group.
Radiation Protection inspections to focus on ALARA program, efforts to reduce the source term, and radworker performance. Conduct additional inspection to monitor security personnel performance, assess perimeter alarm system effectiveness, and evaluate maintenance support activities. The 1996 9 1
.. __J
j QUAD CITIES PRE-DECISIONAL F=rgancy Phaniac evercise is scheduled for August 1996. A follow-up fire protection inspection is scheduled for May 1996 to review corrective actions for previously identified weaknesses.
III. FUTURE ACTIVITICS INSPECTIONS: * -
Fire Protection - May 1996 Engineering and Technical Support - July 1996 Emergency Preparedness Exercise Evaluation - August 1996 Licensed Operator Examinationt - October 1996 SALP-13 completed Octeoer 26, 1996 MOV Closecut - November 1996 Technical Specification Upgrade Program (TSUP) ' post implementation' inspection planned - November 1996.
10
IPJAD CITIES PRE-DECI$10NAL DATA SWOLARY ,
I. PRA .
A. PRA Insights The Quad Cities IPE results show loss of offsite power as the major contributor (725) to CDF. To mitigate a loss of offsite power, Quad Cities has only three EDGs for two units (a dedicated EDG for each unit and one swing). Quad Cities has the ability to cross-tie emergency power between the units by closing two normally open breakers. Several changes have been made at the station to improve the ability to cope with a loss of offsite power. The most significant of these improvements were making the Unit 2 Station Blackout diesel generator and the 4kV Division I cross-tie operable and implementing a procedure to manually operate RCIC after battery power has been lost during an extended SB0 event. In addition the licensee plans to make the Unit 1 580 diesel operable by the miodle of 1996.
In addition to HPCI and RCIC, Quad Cities is equipped with a shared, safe shutdown (Appendix R) makeup pump which can be used following vessel isolation and. loss of feedwater. This pump, in addition to HPCI 4 and RCIC, can prcvide sufficient makeup to event of a single stuck-open reltJf valve. prevent core damage in the B. PRA Profile In response to Generic Letter 88-20, the licensee submitted their IPE on December 13, 1993, consisting of a Level 1 and Level 2 analysir,. The Q a d Cities IFC cut-off date for changes in plant design or operation was July 1991. Plant specific data was collected for the period from 1985 to 1991. The C0F for internal events was found to be 1.2E-6/yr.
Although internal flooding was included in the analysis, the licensee '
concluded that the impact of internal flooding on the overall CDF was insignificant.
The RES Level 1 IPE review has been completed and the determination made that the submittal did not meet the intent of the Generic Letter 88-20.
The staff could not conclude that: a thorough examination for plant-specific initiators was performed, the use of low beta factors for common cause failure analysis was appropriate, diagnostic human error and human error dependencies were appropriately treated, plant-specific factors and experience were adequately factored inte estimating human error probabilities, and pre-initiator human errors (and especially miscalibration errors) were adequately examined and evaluated. _ The SER was issued on November 9,1995 and the licensee plans to re-submit a revised IPE by no later than August 30, 1996.
O 11
O QUAD' CITIES PRE-DECISIONAL The IPE risk ' profile is listed below:
Initiatina Event Cateoorv CDF/vr E of Total CDF Dual Unit LOOP 6.74E-07 56.2%
Single Unit LOOP 1.92E-07 16.1%
Medium LOCA 1.72E-07 14.3%
ATVS .
7.61E-08 6.4%
General Transient 4.69E-08 -
3.9% >
Large LOCA 2.48E-08 2.0%
Small LOCA 1.14E-08 1.0%
Inadvertent Open Relief Valve 8.71E-10 0.1%
ISLOCA 6.30E-10 0.1%
The most significant hardware contributors toward total CDF were found to be EDG failures. The most significant operator related contribution resulted from failure to depressurize the reactor when required. Also, nearly 75% of the CDF involved the loss of the high pressure makeup ability. The dominant accident sequence.was found to be Dual Unit loss ,
t of offsite power, EDG failures resulting in station blackout, and failure to recover offsite power prior to battery depletion. This-sequence frequency was calculated to be 5.3E-7/yr, and contributed 44%
to the total C0F.
i Contairment failure is associated with 79% of the total CDF as follows:
Rapid high temp./ pressure structural failure . . . . . . . . . 22%
Late high temp./ pressure structural failure . . . . . . . . . . 53%
i Vented but structurally intact .. . . . . . . . . . . . . . . . . 4%
l Intact containment . . . . . . . . . . . . . . . . . . . . . .
21%
hbmission of 15 IPEEE is scheduled for December,1996.
C. Core Dnmaae Precursor Events -
On the basis of the precursors identified by Oak Ridge National Laboratory (ORNL) for 1994 (NUREG/CR-4674, vols. 21 and 22) and the preliminary precursors for 1995 and for 1996, the staff identified no precursor events for the site that has a conditional core damage probability (CCDP) of IE-5 or greater. In addition, no recent events have been classified as "Significant Events' for the Performance Indicator Program.
II. DiFORCEMENT HISTORY 10/94 - CIVIL PENALTY (Suoolement IV. Health Physics: EA 94-186): The action was based on a violation involving the apparent deliberate actions on the part of worker of external radiation exposure (s).
that resulted Specifically, in a significant a strontium-90 beta source source was deliberately removed from its mounted plant location and placed in the pocket of a female radiation worker on August 8,1994.
12
9 quad CITIES PRE-4ECISIONAL This Yicl2tien was classified ,as 'A Severity level II Violation. A civil penalty was issued to emphasize the importance of maintaining control over radioactive material and the unacceptability of deliberate violations in this area. Mitigation of 25% and 505 were warranted for the identification of the self-disclosing event and the licensee's prompt and comprehensive corrective actions; the penalty was escalated 100% for past poor performance. ($100,000) 10/94 - CIVIL PENALTY fSunclement VII. Miscellaneous Matters: EA 94-Inti: The action was based on the failure to promptly suspend a manager's unescorted access and test his for cause following reports by two employees that the individual appeared to be under the ' nfluence of alcohol on April 23, 1994. A civil penalty was issued to emphasize the importance of establishing and maintaining a Fitness-For-Duty program that provides reasonable assurance that plant personnel will perform-their tasks in a reliable and trustworthy manner and are not under the influence of any substance that could adversely affect their ability to safely perform duties. The violation was categorized at Severity Level 11 and no civil penalty adjustment was made. (580,000) l 11/94 - CIVIL PENALTY (Suoolement I. Reactor Doerations: EA 94-220):
The act;on was based on two issues associated with a breakdown from May 1993 and September 1994 in control of licensee activities regarding the control rod drive system that, in the aggregate, constituted a Severity Level III problem. The first issue consisted of four violations related to the licensee's maintenar.ce practices. The second consisted of one violation related to cor-ective action regarding degraded diaphrages in the rod scram solenoid pilot valve. The root causes of the violations included failure to follow procedures and an overemphasis on production.
Procedures tore used that did not reflect current work practices and there wo an inadequate response to industry information. The violations were significant because they indicated a lack of sensitivity to the importance of reactivity management and, more broadly, to the need to aggressively pursue problems which can impact on the operability of safety equipment. The civil penalty was mitigated 505 for comprehensive corrective actions and escalated 50% and 100%-for identification and poor past performance, which included five escalated enforcement actions in the 2 years preceding this action. ($100,000) 1/96 - CIVIL PEMALTY (Sucolement 1. Reactor Ooerations: EA 95-241): The action was based on the licensee's failure from June 1994 until October 4,1995, to promptly correct the potential for safety-related motor control centers to trip on current overload. A base civil penalty was issued to emphasize the need for increased management involvement and oversight of its corrective action program, and more engineering rigor and involvement when reviewing potential plant deficiencies. Because this was not the first escalated action within 2 years, the NRC considered whether credit was warranted for identification and corrective action. Credit for identification was not warranted because the NRC identified the corrective action problem. Credit was warranted for corrective action. ($50,000) 13
CITIM PRE-DECI5!0NAL PD!DIt!C fEA 06114): The staff held a predecisional enforcement conference on May 1,1996, and is considering escalated enforcement action for corner room structural steel in a condition potectially .
outside the FSAR.
1 4
4 4
14
PREDECISIONAL
- t.g.nd:
QUAD ClTIES 1 Refuenng , R Operation m tidustry Avg.Trond ShN M
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PRE;)ECCIONAL QUAD CITIES 1 Lasead s===i s w* a== won Peer Group.Genersi Elecmc Pro TM1 931 to 95 4 Trends and Devistons Devistons From '
Plant Peer Group Set-Trend Median Short Term Long Term cosmies ememed wwee esser
,0*ER ATIONS .
Automatic Screms While Crftieel - o o ,
Safety System Actuations - o 0
SignlAcant Evu .s - o 0.00 Safety System Failures - 0,34 -
0.50 Cause Codes (All LERs) t- . __ c e pi.emme - o -
] o.is 6 ta===e o eme ories - 0 -
cAS E t omer sweenne ari ru - lc39 -
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s amanne p e==. -
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-0.24 Cause Codes (All LERs) tan ===ess c===preemme - -
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o FORCED OUTAGES Forood Outage Rate * - .o,4g - 0.40 Equipment Forced OutagesI* -
0 0.26 1000 Commercial Crftical Hours tm o's om ch im -tm ch o'o. ch im performance index Performance index sem emessee e., o,.se am cre.
. PREDECISIONAL t ena- t Shutsown < approt 72 hf1 g Startup C QUAD C.ITIES 2 , n, , o,.e, n ,
industry Avg.Yrond shutdown E55559 S3-1 to 54 Quarterty Det' Not Shown Usint 09. CYC6' EERB ,
ops.
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PREDECZONAL QUAD CITIES 2 Leeena staa* S
- a= non ===
Peer Group Generaf Doctric Pre-TMl "* M 931 to 9M Trends and Devotons Deviations From Plant Pear Group .-
Self-Trend Medan Short Term Long Term OPERATIONS (including stattup)
Automatic Scrams While Critical - 0.22 -
l -0.51 Safety System Actuations - o -
o Significant Events - o -
o !
Safety System Failures - 0.26 - '
-0.90 Cause Codes (All LERs) a Ann-areen ceaew prome== - 0J1 I -
032 ' -
t usenses opwaar arrers - 0 -
1 0.45 s osw Pwasans amre - 0 -
O s.timmenamase Presume - I 0.51 -
0.37 E e.Demowurieseen Promisme - 0.51 o .-: , e -
0.49 e is -
0 -
0.30 i SHUTDOWN Safety System Actuations - o -
-0.21
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o Safety System Fa!!ures - o -
o,73 Cause Codes (All LERs) s Am.mmenen emera prownm - - 0.90 : *
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0J5 I a.opw rwe=== amre - 0 -
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0 FORCED OUTAGES Forced Outage Rate * - T'9 .o.go -
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Equipment Forced Outages / * - s 1000 Commercial Critical Hours -0'4 8) W- -0'83 1D 0A CD os 1D 1D ds 00 CE 1.0 Perfcrmance eder Performance index um coun.e ser operenes cre.
s>"2
e t
l , PRE-DECISIONAL LASALLE COUNTY STATION
~
SALP Period: November 27, 1994 through August 3, 1996 Previous SALP Ratings: Operations 1 haint3 nance 1 Engineering 1 Plant Support 1 -
I. PERFORMANCE OVERVIDI LaSalle has been discussed at Spels since the January, 1994, meeting, following which it was issued a trending letter because of poor radiological work practices, declining material cor.dition, and declining personnel performanco.
The NRC was concerned with the ' licensee's ability to pursue and resolve the root causes for these issues. A followup trending letter was issued.in June, 1994. By January 1995, NRC concluded that the declining trends at LaSalle had been arrested in most areas. However, material condition continued to be a major concern, as exhibited by deterionted hardware and design deficiencies, engineering ineffectiveness at resolving problems, ineffective work planning and control processes, and operator recognition and acceptance of equipment workarounds. During the hot summer, weaknesses in ventilation system design and performance challenged both worker safety and plant equipment. Throughout 1995, the licensee continued to make changes to the LaSalle management team.
By January 1996, reasonable progress had been made in identifying material condition deficiencies, and slow but acceptable progress was being made in correcting them. Engineering effectiveness was somewhat improved but work planning and control processes were still not being implemented effectively.
During the last 6 months, material condition sss slowly improved but continued to be the largest prchlem facing LaSalle. Improvements have been noted in conservative decision making and operations approach to problems. Engineering effectiveness in identifying material condition problems and prioritizing corrective actions has improved. Implementation of material condition improvements remain slow due to the necessity of complex engineering designs, and problems with scheduling, planning, and correctly performing ma'ntenance work. Specifically, emergent work and rework limit LaSa11e's ability to accomplish werk in accordance with a pre-planned schedule. The corrective maintenance backlog slightly decreased and some progress has been made in
-reducing operator workarounds. Performance in radiation protection continues
-to improve and was considered good. Attempts to upgrade operations standards have been somewhat successful, particularly in the control room. However, human performance impro'vement efforts have not been widely effective. Human -
perfomance has been an increasing concern recently due to the numerous personnel errors throughout the organization during the Spring 1996 Unit I refueling outage.
The only sanagement changes since the last S691 were consolidation of system engineering under site engineering and the new System Engineering Supervisor.
)
LASALLE PRE-DECISIONAL II. FUNCTIONAL AREA ASSESSMENTS Doerations '
A. Assessment A slow improvement in performance was noted in the area of operations. The operations manager continued to emphasize leadership and to raise standards and expectations. These efforts appeared somewhat effective, particularly 'in the control room. Conservative dec;sion making was improving, and operations took a more prominent leadership role and asked the other organizations to support this initiative. The operators' response to transients was a strength; however, poor material condition continued to pose unrscessary challenges. Both the number of automatic scrans and the number of scrans with subsequent equipment problems was greatly reduced. A recent issue is the increased number of personnel errors occurring during the Unit I refueling outage. Most of the errors appeared to be related to attention to detail.
B. Basis Equipment problems due to poor material condition and/or design vulnerabilities continue to unnecessarily present challenges to the operating crews. However, conservative to:lsions and responses to these equipment problems have resulted in manual scrans without additional equipment complications. ,
A faulty connector on an IRM caused a spike which resulted in a Unit I reactor scram during refueling (only one control rod was withdrawn at the time). (3/96)
- Leaking drain tank check valves caused a steam leak in the Unit 2 heater bay when placing 2nd stage reheat in service. (2/96)
- - Loss of cooling to Unit 2 main power transformer required a manual reactor scram. Subsequent unit startup was delayed approximately 3 days by an EHC leak in the Unit 2 heater bay (loose fitting); CRD flow escillations (due to a previously identified air leak); and a failed turbine control valve (would not open due to a failed servo valve).
(2/96)
During the controlled power decrease to begin the Unit I refueling outage, dirty control switch contacts caused the A reactor recirculation pump to fail to downshift properly and it coasted down to zero speed.
(1/96) . .
A Unit 2 turbine control valve drifted closed (a turbine bypass valve opened to compensate) due to a wire becoming disconnected at the local control cabinet. (1/96) 2
LASALLE PRE-DECI$10K4L
- A failed temperature element caused an automatic reactor water cleanup uoiation on Unit 1. Operations responded well. (12/95)
- Failure of condensate polisher laterals on Unit 2 caused a chemistry excursion. Response by the operations department was good. An innediate root cause investigation was begun, showing improved ownership t,y cperations. (1/96) .
78 hente* drain pung tripped due to motor winding short. The short was l caused by a fault in the winding (manufacturing defect) and premature I aging of the insulation due to high temperatures in the room. (12/95)
. Failure of a control power relay led to a loss of the IB RPS Mil set.
This led to a loss of reactor building ventilation which requires the operators to bypass safety systems to prevent a reactor scram. This is a significant operator work-around that LaSalle is actively addressing.
Note that this was partially corrected on Unit I during the Spring 1996 refueling outage. (11/95)
Operations has improved in the area of conservative decision making. There have been times, however, when the threshold for action was not at the desired level. .
. During startup following the Unit I rerueling outage, the licensee conservatively shut down the reactor to troubleshoot EHC problems, rather than closing the HSIVs with the reactor critical. (4/96)
- A root cause investigation was begun immediately following the failure of the 2B heater drain pump discussed above. This indicated improved ownershio by operations. (12/95)
. Operations did not take timely action to respond to a failed ADS pemissive pressure switch. The delay resulted in exceeding the associated 24-hour LCO and necessitated entry into a 7-day LCO. Timely call-out of a maintenance crew euld have prevented the additional LCO entry.
(12/95)
Human performance errors are still occurring and appear to be related to attention to detail. The number of errors increased during the Unit I refueling outage.
- An R0 unthinkingly res)ved the key from the mode switch after placing it in run, making the m2 switch inoperable. This would have prevented or delayed using the mode switch as an innediate action in response to an ATWS event. The SRO did not raise this issue to higher management.
(4/96) 3
. LASALLE PRE-DECISIONAL
- An improper return to service followig a weekly surveillance resulted in running an Amertap pump 3ea4 headed for a day, causing seal damage.
Repair of this seal will delay other material condition improvements. *
(4/96)
- A non-tech spec surveillance activity (lifting lead to prevent control rod movement) was missed prior to fuel offload. A poorly human factored procedure was a contributing cause (instructions to perform the action were in the prerequisites and precautions of the procedure.) (1/96)
. A small spill of non-contaminated water occurred ir returning a condensate booster pump to service when the operator did not reposition a vent valve. The valve was not on the line-up sheet but was listed under special instructions. (1/96)
C. Plans The current N+2 inspector staffing should be maintained to monitor performance regarding personnel errors, conservative decision making, and operations' overall leadership of the station. Emphasis will be placed on the effectiveness of licensee efforts to raise standards throught it the plant, and not just in the control room.
Maintenance A. Assessment Material condition continued to present the biggest challenge to LaSalle. The limiting factor in improving materisi condition has changed from identification and prioritization of problems to scheduling and fixing the identified problems. The corrective maintenance backlog has slightly decreased. Problems with rework and emergent work prevented LaSalle from effectively reducing the backlog. Skill of the craft appeared weak,
- considering the necessary rework. The number of maintenance personnel errors was a growing concern during the Unit I refueling outage.
- 8. Basis -
The work control process at LaSalle was not an effective mechanism for improving the material condition at LaSalle. Work was not being effectively planned and scheduled. On-time job starts and completions were typically less than 60 percent.
. Poor communications and coordination resulted in some parts of a TS surveillance (response time test) not being completed within the 1.25 time limit. (4/96)
- Main power disconnects would not properly close when attempting to restart Unit 2. Lack of preventive maintenance was determined to be the cause. (2/96) 4
LASALLE PRE-DECISIONAL W ae wrk en Unit 2 due to material condition problems (fuel leak, main power transformer (MPT) cooling, MPT manual disconnects, and turbine control valves) caused a 4-day delay in the Unit I refueling outage. (1/96)
Poor personnel performance, including errors and skill of the craft problems, caused events and impacted LaSa11e's ability to improve material condition.
A painter bumped open an RPS switch (EPMA breaker) and, after realizing he had done so, he re-closed it. Opening the switch caused the loss of an RPS bus, isolations, and a half scram. One isolation was reactor building ventilation, necessitating bypassing main steam isolation signals on both units. (Note a -similar equipment challenge to operations (11/95) on page 3.) (4/96)
. A diesel start, HPCS actuation and injection into the reactor vessel were caused by a pressure spike while instrument mechanics were valving l in AVLIS. (4/96) An identical event occurred on 5/95.
Maintenance workers were observed performing hot work without taking proper precautions for combustible materials in the area. (4/96)
A pressure spike caused by testing of the excess flow check valve caused an ESF Division II actuation, starting a diesel generator and two RHR pumps. (No injection occurred.) (4/96)
. A foreign material exclusion (FME) plug was left in the stator water cooling system when it was closed up following work during the refueling outage. It was found during return-to-service testing. (4/96)
Welders went on break with a welding stinger energized and an acetylene bottle valve open to a cutting torch, resulting in a fire in the Unit I heater bay. (3/96)
Work perfomed on the wrong side of an out-of-service boundary resulted in releasing the freon from an auxiliary building air conditioning unit.
(3/96)
. Several FME events on the refuel floor led to a stop work there for 2-1/2 days. (3/96)
- Human performance errors during preventive maintenance caused the security power supply to be de-energized. (3/96) 5
LA1ALLE PRL-DECISIONAL C. Plans 1 The site faces team will continue to assess the licensee's prgress in improving material condition includig evaluating the material condition -
improvements planned for the Unit 2 refueling outage (Fall 1996). A material condition team inspection is scheduled for April 29 - May 17,1996. The residents will monitor corrective actions for the recent personnel errors.
Enaineerina
~
A. Assessment Engineering performance was mixed during this period although a slight improving trend continued. Engineering managers have increased standards and expectations on the quality of work as well as early engineering involvement in problem resolution. While resolution of routine issues is sometimes slow, engineering continues to do a good job at addressing most problems once they are raised to a significant attention level. Exceptions were two license amendment requests which did not provide adequate bases. Engineering continues to face significant challenges in improving plant material condition issues. There have been no focused engineering inspections since the last SMM. This assessment is based on input from the resident inspectors and the lead engineering inspector from the region (DRS),
B. Basis -
Persistent material condition problems continue to exist and contribute to operator workarounds. Substantial engineering effort has gone into fixing these problems; however, final resolution of some of these problems has been slow.
- Operatars had to use jumpers to bypass main steam leak detection isolation when reactor building ventilation was lost. An engineering soluttom was partially implemented on Unit 1-during the refueling outage. Completion of this solution is scheduled for 1997. (4/96)
A Unit I scram signal (no rod motion) was generated during the refueling outage due to a bad connector on an intermediate range neutron monitor.
Replacement of the connectors is scheduled for the next refueling outages. (3/96)
Overall implementation and progress on generic engineering issues was good.
LaSalle's efforts on the ECCS suction strainer plugging issue were proactive. Testing and suppression pool cleanir.3 were performed during the Unit I refueling outage. (2/96) 3
LA5ALLE PRE-DEC15!0NAL
- Generic Letter 89-10, " Motor-0perated-Valve Program" was completed and tha N u was closed by the NRC. The MOV program was considered one of -
the best in Region III at that time although the program had gotten off to a slow start. (11/95) '
Sose engineering designs and modification submittals were inadequate and post modification testing was not always adequately specified.
3ignificant additional infomation was required to support licensing submittals for a main steamline isolation modification and for a leakage control system modification. Both licensing actions were needed for Unit I refueling outage modifications. (1-3/96)
- The Unit 1 HPCS pump was made inoperable because the modification test procedure for testing its d wsel generator following replacement of the reverse power trip relay did not identify all expected control room alams. (12/95) 1 C. Plans A material condition team inspection is scheduled for April 29 - May 17,1996.
The residents and the assigned lead engineering inspector will assess the effects of the installed portions of the modifications on the plant ventilation systems during the summer of 1996. The site focus team will evaluate the impact of the 1996 refueling outages on material condition and operator work around issues. Extra attention will be given to core physics testing following Fall Unit 2 outage due to installation of a different vendor's fuel (Siemens) and changing to 24-month cycles.
flant Suonort A. Assessment Plant support perTormaace was good. In radiation protection, improvement was noted with ALARA planning and source tem reduction. Daily dose remained high due to material condition improvements, but ALARA planning was effective in keeping the dose expended reasonable for these efforts. Weaknesses in being able to effectively schedule, control and perform work increased overall dose and stressed ALARA planning resources during tb recent refueling outage.
There were also some continuing radiological performance problems indicating that improvement efforts were still needed to address these deficiencies. No significant problems were observed in the Security program; however, the resident inspectors recently identified some human perfomance issues which require followup by regional specialists. Recent inspections of the Emergency Planning and Fire Protection programs concluded they were good.
7 9
j ,
LASALLE PRE-DECISIONAL
, B. Basis-Radiation Protection l Continued improvement was noted in ALARA planning and source ters reduction.
1 Although there is still room for improvement, the 1995 dose (520 rem) was the lowest in recent history and the' associated three year rolling i average has declined since.1993. Currently, LaSalle is in the second l j quartile for ir.dustry BWRs.
Unit I drywell dose rates (20-100 ares /hr) remained constant owing to zine injection. Source ters reduction initiatives for the Unit 1
- refueling outage included chemical decontaminations of the reactor
! recirculation (RR) and residual heat removal (RHR) systems and j hydrolazing of high source tern piping. (3/96)
Good ALARA planning and initiatives (cameras, shielding, etc) for Unit 1 '
refueling outage. Use of Limerick station " lessons learned" in radwaste j modification work. (1/96)
- Weaknesses were noted with work planning and coordination.
I
- Continued problems with schedule adherence, work scope control and rework contributed to ' additional dose during the unit I refueling i outage. In particular, about 11 rem was accrued from rework activities alone. (4/96) l
- Weaknesses in communication and clearing of out-of-services (005) by 1 operations delayed work and impacted RP coverage of inservice inspection (ISI), refuel floor and source term reduction activities (3/96).
- Several RP re'quirements were identified in operations procedures that RP was not aware of, impacting RP oversight of plant activities. (2/96)
- Poor interdepartmental communication (shielding installation and tool availability / ownership) delayed several jobs in (and prior to) the Unit I refueling outage. These problems also occurred during last year's Unit 2 refueling outage. (1/96)
Problems were noted with radiological performance.
- ?oor communications with radiokgical protection staff and lack of thorough understanding of RP procedures resulted in several engineering managers and INP0 evaluators accessing the refuel floor, a posted high radiation area, without being signed onto the appropriate RWP. A
, subsequent licensee investigation identified at least two additional
- similar events. (4/96) 8 s
i k
LA5ALLE PRE-DECISIONAL
- Poor radiological job coverage by an RPT resulted in inadequate survey of valve stem during RCIC valve work (2/96)
- Recent findings included protective clothing found across a contaminated area boundary near the heater drain pump rooms; unofficial, handwritten dose rates were posted RP on ainstructions panel in thatconcerning area; an action highrequest (45-75tag ares /hr) hanging adjacent to.a posted hot spot; and a corporate engineer working in the RPA who had not read his RWP. (2/96)
Material condition concerns ispected outage and non-outage dose.
- The large amount of corrective work contributed about 75 rem to the Spring 1996 Unit I refueling outage dose. (4/96)
Although declining, non-outage and individual worker doses remain high owing to increased material condition improvement efforts. In addition to the 75 rem during the Unit I refueling outage, an estimated 80 rem was expected from planned material condition improvement initiatives for 1996 (4/96).
- A valve leak in a condensate pump room resulted in contaminated water on floor. (1/96)
Concerns with radwaste tank rooms included corrosion on the floor drain collector tank supports, past leakage on radwaste discharge tank piping, and visible indication of corrosion and past leakage from the 'A' waste concentrator tank. (1/96)
Security The se!Hty program remained fundamentally strong with adequate resources.
Cutbacks in armed guards have essentially ended, although more staff reductions may be made (through attrition) if the licensee considers them prudent. There have been some performance problems noted that appear to have different root causes and generally not programmatic. A recent audit did find consistently poor performance in some of the licensee's searcaing drills; we are currently evaluating. Maintenance support has been excellent and some needed, but modest equipment upgrades are being made. Material condition of equipment and weapons is good. Their performance in last summer's OSRE was adequate.
- Security missed several opportunities to identify that an individual had failed to card out properly. (4/96)
Compensatory measures for significant equipeent degradation were implemented promptly when the security power supply .was de-energized due to a maintenance arror. (3/96) 9
LASAL!.E PRE-0E015!00MLL The licensee identified potential misconduct by a contractor security e marviene **
Th'e licensee'peding s initialhis duties was followup as secondary slow. alarm station operator.
(2-3/96)
Emergency Preparedness A recent program inspection found the overall status of the EP prog- m improved and very good. Response facilities were in an excellent state.of readiness. The licensee's 1995 annual audit and surveillances of the program were effective in identifying issues. Procedures and training were current, and communications systems were in a state of readiness. One deviation from the UFSAR was identified regarding accuracy of a meteorological monitoring instrument. Licensee performance will be monitored during the June 12 graded EP exercise.
Fire Protection The licensee has made improvements and overall fire protection program performance was good. Most problems in this area were licensee identified and appropriate corrective actions were taken or planne.1. The licensee continued to develop the Fire Protection Improvement Plan. There were few impairments that required fire watches. Fire protection equipment was well maintained.
Except for hot work, cos'bustibles were well controlled. There were some problems, mostly related to personnel performance.
Inspectors observed two instances of hot work (cutting, grinding, welding) being conducted with combustibles in the area. (4/96)
Welders went on break with a welding stinger energized and an acetylene bottle valve open to a cutting torch, resulting in a fire .in the Unit I heater bay. (3/96)
The licensee missed TS required firewatches on two occasions.
- (3/96 and 1/96) ,
+
A TS surveillance on fire protection valves was not performed before the required date. (2/96)
C. Plans Continue monitoring licensee improvement efforts via core and regional initiative' inspections. TI 2515/127, Access Authorization, is scheduled for the week of April 29, 1996. The LaSalle annual EP Exercise is scheduled for June 12, 1994, and will be evaluated by a regional team. Resident and regional inspectors will continue to assess perforisance related to fire protection while performing inspections in other areas.
10
@ t
s LASALLE -
PP.E-DEC!sIONAL III. Future Activities Material Condition Inipection - April, May 96 Routine Radiological Protection Inspections - May, July, and October 96 Operator Requalification Program Inspection - May 96 11 2515/127, Access Authorization Inspection - May 96 Security Program Core Inspection - May 96 Emergency Preparedness Exercise Evaluation - June 96 -
SALP Board - July 3 SALP Conference - August 13 Unit 2 Refuel Outage - September 7 ' November 15 ISI Inspection - September 96 Core Physics Test Inspection Coverage to Focus on New Fuel Type - After Unit 2 refuel outage Maintenance Rule Inspection - December '96 I
4 4
e e
O t
11
LA$ALLE PRE-DECISIONAL DATA
SUMMARY
I. PRA A. FRA Insights The LaSalle units are BWR-5 designs with Mars 11 containments. Because BWRs are equipped with diverse and redundant systems to mitigate LOCAs, station blackout (590 sequences tend to be the dominant contributor to core dange frequency)in BWR PRAs. At LaSalle, each unit has only one immediate source of offsif.s power via the Station Auxiliary Transformer (SAT). Each unit's SAT is powered by a ring bus supplied by four independent 345 kV transatssion lines. The SATs have a cross-tie to supply power to the opposite unit's emergency buses. This manual action can be accomplished in approximately ons hour. Therefore, the SATs serve as redundant offsite sources of emergency power to the respective opposite unit. This capability provides the additional protection against a S80 that makes the LaSalle units comparable to units with two separate sources of offsite power. Removable links in the main generator leads allow the station to backfeed through the main transformers to the Unit Auxiliary Transformers (UA"s) to provide offsite power when the main generator is tripped. However, this capability takes many hours. To mitigate a ioss of offsite power (LOOP), LaSalle has five EDGs for two units (two dedicated EDGs per unit and one swing).
B. PRA Profile The first LaSalle PRA was performed for the NRC by Sandia National Laboratories (SNL) and completed in 1992. The PRA included a full-scope Level. I analysis, the Risk Methods Integration and Evaluation Program (FAICT), and a Level II and III analysis, the Phenomenology and Risk Uncertainty Evaluation Program (PRUEP). These analyses are documented in NUREG/CR-4832 and NUREG/CR-5305, respectively.
In response to Generic Letter 88-20, the licensee submitted an IPE/IPEEE Report on April 28, 1994 which basically is a review of the previous NRC-sponsored PRA study described above (NUREG/CR-4832 and NUREG/CR-5305). The staff completed the review of the IPE portion of the submittal, and concluded that it met the intent of Generic Letter 88-20 in a letter to the licensee dated March 14, 1996. The IPEEE portion is under review by the staff.
The total core damage frequency (CDF) at LaSalle from internal and external events was reported to have a mean value of 1.01E-4/yr. Fire contributes to 49% of the total CDF, flood contributes to 5%, and internal events contribute to 46% of the total CDF, which corresponds to 4.41E-5/yr. For comparison with other plants, the internal events risk profile by initiating event is given below.
12
V
. N
. p$
l
} LASALLE PRE-DECISIONAL j Initiatinfi Event % of Internal Event CDF Loss of 0"fsite Power 74.3%
Loss of Division 1 4160 VAC bus 8.1% .
Transient with turbine bypass 5.5 a
" i Loss of Division 1125 VDC bus 5.5 Transient with total loss of feedwater 2.9% .
Some of the events found to be most important to risk redution were:
the frequency of LOOP, the frequency of control room fires, the I
i 1 probability that operators will not successfully recover the plant free l' the remote shutdown panel, the non-recovery of offsite pouer within one 1, j hour, and the EDG cooling water pump common mode failure. :l k d .
The Level 11 results in the PRUEP study are tabulated below. , l ii Containment Failure location Containment Failure Times l f
. p Drywell 22% Early 13% i i Wetwell 17% Early Vest 5% jf Vent 49% Intermediate 17% l Bypass 0% Late 9% f I[
Intact 12% Late Vent 44%
Bypass
- 0% ; !
Intact '
12% j
[1 The licensee is also performing an independent update to the analysis l (i performed by Shl. The updated Level 1 analysis was submitted to the NRC on April 18, 1996. 1he Level 2 analysis is in progress and is expected l' to be completed in the second quarter of 1996. The licensee noted that l they modified the Human Reliability Analysis and the common cause treatment for this updated IPE. The updated IPE determined the CDF to : i be IE-5/yr from internal events. For comparison purposes with the '
original IPE subelttal, the updated IPE risk profile is given below.
i -
)]
Initiatina Event 5 of Internal Event CDF
[L Loss of Instrument Air / Service Air 33% $
LOSP Loss of AC or DC' busses 29%
11%
a f'
Turbine Trip with Bypass 5 i [:
Turbine Trip without Bypass 7% ! ?
Stuck Open SRV 4% l b l
MSIV Closure . 4% ; j Loss of Feedwater 2% !l Reactor Butiding flood 15 9
. LOCA 1% [
L 13 j 4
l
e
, LASALLE PRE'DECI510NAL on the basis of the precursors identified by Oak Ridge National Liberateries for'1994 (NUREG/CR-4674, vols. 21 and 22) and the preliminary precursors for 1995 and for 1996, the staff did not identify any precursor events for the site that have a conditional core damage -
probability (CCDP) of IE-5 or greater, in addition, no recent events have been classified as a 'Sigcaficant Event" in the Performance Indicator Program.
- 11. ENFORCEMENT HISTORY 2/96 - EXERCISE OF ENFORCOMENT DISCRETION (EA 96-024): This action was based on an Office of Investigations (01) report regarding the deliberate misconduct of two non-licensed operators on July 24, 1995 e involving security badge control procedures. The NRC exercised discretion in accordance with Section Vll.B.1 of the Enforcement Policy and refrained from issuing a Notice of Violation because: (1) the violation was identified by the licensee, (2) an uncontrolled badge, absent any consideration of wi11 fulness, would normally be categorized at Severity Level IV, (3) the violation could not reasonably be expected to have been prevented by corrective action for a previous violation or previous licensee finding, (4) comprehensive corrective actions were taken, including a 10 and 5-day operator suspensions, (5) the actions involved the acts of two non-supervisory employees, and (6) the violation appeared to have occurred as a result of isolated actions by the two employees without the involvement of minagement, and did not appear to have been caused by a lack of management oversight.
9 6
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. -. oss. . _ _ .
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comed oa.e == m . Sea - rwCe _w-=
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?
1 PREDECitl0NAL ,
LA'SALLE1 Leseae s==% a,n Peer Group General Electne Poet TMI needlurr. m 831 m 96 8 Trends and Devistons Deviations From Plant Peer Group Se#-Trond Median Short Term Long Term pesarme impmov weres numer OPERATIONS ,
Automatic Scrams While Crttical - o 0.26 Safety System Actuatsons - 0 0.45 Significant Events - o -
o Safety System Failures - o -
.c,25 Cause Codes (All LERs) a as M cenew *m== . - ]0.07 -
.c.16 [
a ummess asement anare - 0 -
o a sour Peresuma anses - 0.51 l -
l036 a masennease eveemme - ]0.12 -
.C.26 au numswcensevemenmmessaareenseems pressene - 0 -
4.00 [
t emmenema=== - 0 - 0 SHUTDOWN Safety System Actuations - NA -
0 Significant Events - NA -
-0.36 Safety System Failures - NA -
0 Cause Codes (AN LERs) a seemsessa canew resen - m -
0.04 [
k unemenecommeraners - M -
0.55 I
- e. seer Asemme snan - m -
] 0.24
- a. mammansv r = - m -
] 0.06 4 -
- u ,e - m - # t,24 t u y usw. - m -
0 FORCED OUTAGES
~
Forced Outage Rate * - o,5o -
.o,03 Equipment Forced Outages / * ~ -
1000 Commercial Crttical Hours 0.11 -0.48
{ _
.tm .cl om O's im tm .c3 cm 03 sm performance index Performance index
- test comuassed ser Operseensa opene k
I
~,
. 1 PREDECIS10NAL
- t. gena LASALLE 2
'""$ * **'*" * ,' ** cm refuseng R oper: Don
~
931 to 96 4 Quwtorty Dets het Snomi Using op. Cycle m vsm. Ops.
l l l
! R ! R R R I l ; I E Ef DJ l WP i hf BM I ,
36 1' WP i g 361 Automs6c Scrams mile Crtucal ,
Safety 3#em Actuations j3 3 2- 2
}'- 0=
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j" 0- ,3,1
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SigntScant Events ,
Safety system Fanures 7,
$ 3 I 1.5.
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. ~m a 33 1- BM 1 963 Ef E3 8 g 96-t 36-3 i Equipment Forced outagest Forced Outage Itate (%) g M Commed Cecal He 1,
80 -
co - f 40 - 2-
}o 20- 5dE b 0
"- 0 D3.f sw e4.t ks DS t 96 3 6 w B3-f 33 3 D*.f k2 06 f BM '
Year - Qumrser Year. Quarter Cause Codes Conective Radiatien Exposure = = e
- l .. .. ..
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4
LASALLE 2 Leand. s=** s*=ne. we ===
Peer Group Generst Decine Post-TMI "'#"* "
93-1 to 95-4 Trends and Devwtions Deviations From Plant Peer Group Ser.Trond Median Short Term Long Term D se, 4 biipemd wwie Soter OPERATIONS (including startup) ,
Automatic Scrams While Crttical - 0 0
Safety System Actuations - 0 0.18 Significant Events - 0
-0.90
$sfety System Failures - 0.21
-045 i Cause Codes (All t.ERs) t Aen.n.sreen c arW preenses - 0.90 M - 0 E usea.ms opereen smra - 1033 -
l 0.45 e.cei.e p.e a snare - 1 4.64 -
0.18 [
aen n nseev em - 0.70 M -
4 45 [
r .- ~ w fn na nnsen ev.w -
ri 0.35 -
0.17 E
.--- . 0 -
4.45 I_
SHUTDOWN Safety System Actuations - 0 -
-0.42 Significant Events - 0 0
Safety System Failures - 0 0.45 Cause Codes (All LERs) s a inserw c.new presens - } 0.03
]0.14 k usen eopw.sseano. - 0 - 4.29 I
- c. omer pw.ennes arve , -
] 0.23 -
4.11[
s.seemannanse pressene -
)0.06 -
] 0.24 r .- reen.na n Pr.enne - ]0.12 - 1034 t-
-- 0 - 0 FORCED OUTAGES -
Forced Outage Rate * - 0.05 0.04 Equipment Forced Outages / --
4 07 1000 Commercial Critical Hours 1D 02 On Os 1D 1D .C's on CE 1D performance moex Performance meer
- men camnaese ser everessans eram
_ . _ . _ _ _ . . _ _ _ _ _ . _ ~ . _ _
f l ,
l PRE-DECI$10NAL ,
! ZION NUCLEAR PLAlfT l
SALP Period: . December 24, 1995 through July 19, 1997 -
Previous SALF Ratings: Operations 1 Maintenance 1
( Engineering 1 -
l Plant Suppert 1 i I. PERFORMANCE OVERVIEW -
Zion was on the NRC Watch List as a Category 2 facility from January 1991 to January 1993. The plant was removed from the Watch List based on improved performance and this improving trend continued through August 1993, Zion Station was last discussed during the January 1996 Spel. Zion's performance has remained stagnant from August 1993, with intervals of slight improvement and decline, but no clear trend. However, material condition has continued to slowly improve in key targeted areas, such as diesel generators and auxiliary building pump rooms. Zion's latest SALP rating in Operations declined due to persistent operational mistakes in the latter half of 1995.
Zion's performance since the'last SM4 continued to be mixed. Conservative plant operating decisions were made on several occasions to address equipment problems. However, inconsistent operational performance and slow progress to correct a large backlog of material condition problems were significant concerns. Operators were challenged by a variety of workarounds and material condition deficiencies. Personnel errors occurred frequently. These errors were variously caused by lack of procedural adherence, inattention to detail, and configuration control mistakes. In particular, several occurrences of unplanned limiting condition for operation entries and improper operating mode ch:ng:s .:cre made in February and March. In contrast, recent plant startups have been conducted well, when management attention and presence was evident.
Some improvements were seen in corrective maintenance planning and scheduling, using a new scheduling system. However, correction of longstanding material condition deficiencies has been slow. The backlog of pending work remains above average. These persistent problems are due, in part, to weaknesses in :
work quality, craft capability, and personael familiarity with the electronic work control processes. Some performance improvements were seen in engineering, and to a lesser degree, in maintenance. However, root cause assessments and corrective actions for specific problems continued to be limited. Consequently, these followup efforts did not contribute significantly to lasting improvements la material condition. Performance in security and radiation protection program implementation declined.
l l
ZION ptE-DECISIONAL I II. FUNCTIONAL AREA ASSES $NDiTs Doerations ,
A. Assessment Operations performance was inconsistent and characterized by frequent personnel errors. Although a conservative operating philosophy was observed, personnel errors and lapses in configuration control continued. An above average number of workarounds, and below average material condition, provided significantly more challenges to operators than typically seen, due to the added distractions and compensatory actions required. The recurrence of Zion specific problems, and the self-revealing nature of events which occurred indicated corrective actions for them lacked effectiveness.
B. Basis Personnel errors continued to result from a lack of attention to detail, lack of a questioning attitude and insufficient self-checking. Management efforts to improve the performance in this area were not effective.
- The 2A steam generator was overfilled while at I percent power, causing an unexpected mode change, due to poor crew teanwork and test briefings.
(1/96)
- Several engineered safety features pump rooms and other auxiliary
- building areas were contaminated when a operator did not properly c=plete a valve lineup. The incomplete valve lineup caused the condensate storage tank to drain back through floor drains. (1/96)
- The three operable charcoal booster fans were unintentionally made inoperable by placing their control switches in the'0ff position, vice the normal Auto position, defeating automatic start of the fans on a high radiation signal. (2/96)
- An equipment operator started the 1A charging pump auxiliary lube oil l pump instead of the 1A turbine driven feedwater pump auxiliary lube oil pump, by mistake. (1/96) :
Weak controls on plant configuration and lineup resulted in several personnel l errors.
- An engineering supervisor inadvertently started a residual heat removal
~
pump during troubleshooting activities.while, Unit I was at full power.
(1/96) 2 i
- i. ,
i ZION PRE-DECISIONAL i
- Several unplanned limiting conditions for operations entries occurred ;
- wMla ,narfoming routine maintenance and surveillance activities.
- Examples were
- ,
! - Inadvertent removal of two Unit I service water pumps from service. (2/96)
- Inadvertent disabling of both saftty injection load sequencers for i one diesel generator (DG) on Unit 2. (2/96) '
l Failure to perform post-maintenance testing of a safety injection j conLeineent isolation valve prior to a Unit I mode change. (2/96)
- Changing plant modes on without containment integrity. (3/96) l
- Making two containment penetration pressurization zones on Unit 2 inoperable at the same time. (2/96) l Workarounds and plant material condition continued to challenge operators.
l
- Leakage past the residual heat removal / safety injection system suction l cross-connect valve in conjunction with an inoperable HVAC damper led
- operators to find a Unit 1 frozen safety injection recirculation lir,e.
l (3/96) l
- A Unit I reactor trip occurrad from full power when two flow indicators
( spuriously indicated low primary coolant flow in one loop. The spurious l condition resulted from air in the instrument sensing lines. (3/96) i . A Unit I reactor trip occurred when operators were unable to control a l sluggish feedwater regulating valve. Contributing causes were poor j simulation of the valve response in the simulator, as well as poor tuning of the valve's response. (3/96)
- Operators had to respond to numerous erroneous control Unit I rod pw.itiw.a dwir.g routine shutdowns, startups, and power changes.
i Indications of individual rods out of position were common. (3/96) i
- Leakage past the main feedwater regulating and regulating bypass valves
, contributed to an inadvertent power increase and mode change on Unit 2.
l (1/96) l In contrast, the overall operating philosophy was conservative.
l = Reactor startups in February and March followed procedures closely, were well supervised, and demonstrated excellent teamwork and communications.
l (3/96)
I
- Unit I was taken off line to search for suspected foreign material in the IB steam generator; none was found. The shutdown was extended to
- plug anosalous indications in previously installed steam generator sleeves. (2/96) 3 i
. . - - - ---t-
ZION PRE-DECISIONAL
- Unit 2 was taken off line once, and frequently reduced power to 50 p e nnt.tn fix recurring condenser tube leakt. Since June of 1995, nine power reductions and one shutdown were taken. (3/96)
C. Plans ,
The existing enhanced staffing level (n+2)ficient shouldareas:
be maintained to monitor the licensee's performance in the following de personnel errors; .
procedural adherence; and attention to detail. The enhanced resider.t ~
inspector staff consists of four inspectors. Emphasis should be placed on licensee root-cause and corrective actions to identified problems and self-assessments. Additionally, a stiecial focus inspection on plant operations i standards will be developed in response to the persistence of personnel errors, including configuration control errors. Finally the Zion team will assess the licensee's readiness to implement the improved technical specifications, considering training, and implementation procedures.
No deviations occurred from the previously planned inspection activities.
Maintenance A. -Assessment ;
Performance in the maintenance area was satisfactory. The licensee exhibited good decision-making in the resolution of emergent issues. The quality of work was gcod on high visibility jobs. Initiation of the twelve week rolling schedule in January,1996, caused work to be scheduled several weeks prior to its performance; previously, work was usually scheduled-a few days prior to its performance. The new system has resulted in over half of the pre-scheduled work being completed'on schedule. However, weaknesses were still eeuled in the quality of routine work activities. Weaknesses in the work control process continued to impact the ability to reduce the large .
maintenance backlog and improve significantly the overall material condition of the plant. Also, material conditions not identified in the work control system continued to be revealed by. events (see Operations, above).
l B. Basis ,
! The licensee made sound maintenance'. decisions and demonstrated good safety
' focus. . -
. During the initial implementation of a twelve week rolling. work' schedule, significant increases occurred in the amount of scheduled work i relative to unscheduled work. (1/96) '
l
. A Unit 1 outage was extended to plug steam generator sleeves which had anomalous indications, before the required resolution of these anomalies had been worked out with the NRC. (3/96)-
. , 4 G
' , - - , , _ , , , , . - , - , - - - , , ,- .-w.n, . _ , _ - ,-v--- .n,, -,-,-e ---,w,, ,- e e ,- ,--- m v
C l -
L ZION PRE-DECISIONAL
- Unit 2 power was repeatedly reduced to 50 percent to fix condenser tube lade wMth continued to occur. (3/96)
!
- Safety focus was maintained in the performance of on-line maintenance -
! through the use of the operational safety predictor program; a i '
probabilistic risk assessment database was used to prov'de risk-related information about the selected plant configuration.
! In March, funds were ande available for correction of same longstanding
! material condition issues within two years. Meanwhile, these degraded l conditions, and others, continued.
!
- Debris was found in the 1A $1 pump recirculation orifice, a recurrent l 1ssue. Corrective actions to prevent Unit I safety injection pump l recirculation line orifice plugging were funded. (1/96)
- Rod posit %n. indication malfunctions, when changing power, continued to i burden the operators and instrumentation maintenance mechanics. A system replacement was funded. (3/96 & 4/96)
[
- Station radiation monitors continued to experience a high rate of
! equipment failures. An action plan to improve the reliability of the l radiation monitors is being implemented slowly.
!
- Leaks ir *he Unit i. Refueling Water Storag's Tank are scheduled 16 be
! repaire Fall 1997s l
- Auxiliary .mwater pump IB tripped on a surveillance start due to shaft p driven oil pump failure Prom excessive wear. (3/96) t
- The 2A DG and the 28 DG both failed surveillance starts due to independent air system component failures. (3/96 & 2/96)
- Weaknesses were noted in the quality of routine work, and the effectiveness of
- j. the maintenance training program. -
!
- Electricians incorrectly installed a torque switch even though clear
! guidance was provided on correct torque switch installation. '(1/96)
- Instrument technicians inadvertently removed a containment pressure ;
l channel from service, violating the Technical Specifications. (1/96) !
l 1
- Personnel skill deficienc'ies were not being consistently identified and
! remediated by the training program. These weaknesses in licensee 1 l training assessment may partially explain the recurrence of maintenance '
l personnel errors. (3/96) i; i .
i 5 f
i .
_ _ _ _ _ _ _ ___ _ _ ______ _ ___ ~ - - ~
0 4
, ZION PK-Otti;10NAL Weaknesses in the work control processes increased the corrective work backlog ano oeiayed improvement in the miow average material caedition of the plant. .
. Although implementation of the 12-week rolling schedule has improved .
schedule adherence, its implementation has not yet begun to reduce the backlog of corrective maintenance activities.
- Quarterly surveillances on two boric acid transfer pum>s were missed for two quarters due to unfamiliarity of personnel witt the proper. use of the electronic work control system. (2/96) ,
C. Plans The one week two person training inspection in March prwided support and explanation for the previous anecdotal evidence that maintenance skill level was inconsistent. Continue with the routine core inspections for the maintenance area. No deviations occurred from the previously planned inspection activities.
Enaineerina A. Assessment Overall performance was satisfactory and appeared to be improving; however, some weaknesses in engineering perfomance, and one sipificant engineering personnel error occurred that detracted from generally good performance.
These examples included a few instances of continuing unak root cause analysis and corrective actions (a longer term performance issue at Zion) were oburved.
B. Basis Performance by engineering was generally satisfactory.
. Test engineers displayed good safety focus, and attention to detail in performing assigned surveillances during approaches to criticality.
. A system engineer identified declining individual cell performance on battery 211 by a review of quarterly surveillanca data. (1/96)
. The engineering effort to locate and identify a suspected loose part in the primary side of the IB steam generator has been extensive, although unsuccessful, as of April,1996.
Some weaknesses in engineering performance occurred. For example:
. A safety injection pump cosmon recirculation line froze due to a poor
. design, the limitations of which were not appreciated until after the
. line frcze. (3/96) 6
ZION PRE-DECISIONAL
- Engineering work associated with an inoperable pipe support was not t 4:1y, :nd the corrective action lacked focus and rigor, until NRC inspectors intervened. (12/95)
!
- Engineering work associated with the repair of a leak on the pressurizer l stray manual isolation valve was not thorough and complete, until NRC l
inspectors intervened. (1/96) .
- System Engineering and Maintenance Engineering personnel did not consistently l observe established limitations on the work that they are allowed to perfom.
l For example:
- Without informing the control room, an engineerin supervisor i inadvertently started the IB residual heat remova pump while rotating a
! safety in.jection timer can shaft. This was similar to earlier unauthorized work by engineers. (1/96) l C. Plans Continue core inspection efforts to assess effectiveness of engineering support to operations. This effort will be coordinated by the lead engineering assessment inspector (currently, also acting temporarily as the senior resident inspector). Augment this with an Engineering and Technical Support insp2ction with emphasis on engineering root cause analysis and ,
i corrective action (8/96). This effort should include an evaluation of whether l previous weaknesses in root cause analysis and effectiveness of corrective action have begun to be corrected.
No deviations occurred from the previously planned inspection activities.
Plant Suonort i
- A. Assessment i
Overall, performance in radiation protection was good. Although the ALARA
, program was strong, the NRC and licensee identified weaknesses in the control and identification of radiological hazards. Additionally, the poor material j condition of plant radiation monitors continued to negatively impact plant '
operations. Fire protection was adequate, however significant weaknesses in the emergency lighting program were found by the (4RC. These problems indicated a fundamental lack of rigor by a few electrical maintenance personnel in carrying out their surveillance responsibilities. Tha emergency ,
l preparedness program was good, with good management support and an experienced coordinator. Although the performance of the security program declined, it was still satisfactory.
7
4 Z!6N PRE-DEC15IONAL
- 8. Basis-Radiation Protection: .
Radiation protection program implementation has declined, as reflected by .
weaknesses in radiation worker practices (first observed in inte.1995, and continuing to occur), radiation protection technician performance, and work planning. As noted at the previous Senior Martagement Meeting, the licensee ,
continues to make some progress in source term reduction. However, numerous hot spots ano sources of high general area radiation levels make it likely that Zion will continue to have one of the highest total personnel radiation exposures among PWRs.
. A i.ighly radioactive steam generator gasket was left unattended in March on a steam generator platform for a day. The gasket was over 200 ren/hr on contact. (3/96) ,
- Leaks in the residual heat removal pump rooms led to several area recentaminations. 3
. The NRC found an unposted radiation area (7-8 ares /hr). (3/96)
. The licensee continued to strengthen the ALARA program and departmental dose ownership.
Although the 1995 collective dose was high (about 800 res), the licensee demonstrated good ALARA controls.
Steam generator.nockups were used to ensure the staff working on the steam generators performed their , jobs ALARA.
Each department set dose goals which they were achieving.
. Radiai. ion annit.ur operability was poor. The licensee has been slow in implementing plans and setting goals.
Dur.ing.1995, about 6 - 20 radiation monitors (averaging about 10) were out-of-service each month.
The monitor problem was first noted by the NRC in 1991; however, the licensee had not established a formal plan with mjlestones until late 1995.
Security Overall perfomance in security was adequate, but a decline from past performance was observed.
.' Minimum staffing leve11 requirements were met through the extended use of overtime. Reductions were noted in oraite response team exercises and the amount of tactical firearms training..
8 e
i
ZION PRE-DECISIONAL
- The procedure to respond to certain security threat scenarios proposed in table ton del 11s did not meet regulatory requirements. This problem .
was identified in 1989. In 1993, the licensee discontinued corrective actions for the 1989 problem. -
Emergency Preparedne'ss ,
Overall performance in emergency preparedness was excellent. Strengths included the overall operattonal status of the program, facility ma' ntenance, and the s, table and experienced staff, .
Fire Protection Fire protection equipment was well maintained, and most transient combustibles were well controlled. The performance of the fire brigade drill was good, with very few problems.
. Significant weaknesses in emergency lighting were identified by the NRC.
- Procedural adherence by a few electrical maintenance personnel was weak. These personnel demonstrated a lack of rigor in their approach towards completing emergency lighting surveillances. In addition, the emergency .ighting surveillance procedure was inadequate.
- Corrective actions to prior findings involving the er,ergency lighting were inadequate to prevent recurrences of problems in this area.
C. Plans Continue with the routine core inspections for the radiation prtO ction and chemistry areas. Radiation protection inspection will focus on trainin source term reduction implementation, and licensee correctivt actions (g, for radiation monitors and radworker performance).
Continue with core inspections and conduct a follow-up fire protection inspection later this year. Continue the security and emergency preparedness core programs. An OSRE inspection is scheduled for August.
No deviations occurred from the previously planned inspection activities. ,
9 e
9
ZION PRE-DECIS10luu.
III. FLTURE ACTIVITIES A. Inspec ions
~
Routine core program using n+2 inspectors.'
OSRE Inspection (8/96).
Operations Standards Inspection.(5/96).
Engineering and Technical Support Inspection (7-8/96). .
B. Octage activities Next Refueling Outage: 9-11/96 (Unit 2). Major licensee outage activities will include:
- 1. 2A emergency diesel generator, generator replacement
- 2. Condenser repairs
- 3. Refueling water storage tank leak repair
- 4. Steam generator repairs C. Improved Technical Specification Implementation: 7/96 1
l 4
'One inspector is a qualified reactor engineer on rot-tion for one year.
10 l
f .
I ZION PRE-DECISIONAL DATA SUIOERY I. PRA A. PRA Insights Zion units 1 and 2 are Westinghouse four*- loop PWRs with large dry containments. The Component Cooling Water (CCW) system at Zion is shared between the two units. A single break in the consson header could o disable the entire system. This would result in an RCP seal LOCA and a loss of the charging and SI pumps to both units. NUREG-Il50, as well as previous Zion PRAs, showed that this particular vulnerability was the largest estimated contributor to plant CDF. Zion addressed this issue in April 1989 by providing 'an auxiliary water supply to each charging pump's cil coolers via the fire protection system. Hoses, fittings, and tesis are now locally availchle at each unit's charging pump oil cooler for immediate hookup if required. A formal procedure change providing instructions for the hookup was also completed in April of 1989.
Accounting for this alternate cooling to the charging pumps reduces the CDF in NUREG-ll50 by approximately 80%.
B. PRA Profile The first Zion PRA was required by NRC and perfomed by PL&G in 1984.
The second PRA (NUREG/CR-4550, Vol. 7, a rebaselining of the first PRA) was performed for the NRC in 1990 as a part of the NUREG-1150 study. In response to GL 38-20, the licensee submitted its IFE in April,1992 an(
the RES completed the review of the submittal and issued a Staff Evaluation Report (SER) on November 22, 1994. The SER stated that
<hough the IPE submittal, in general, responded to GL 88-20, the process used in the IPE could mask potential vulnerabilities and lead to a false sense of security with respect to the likelihood of a severe accident. In particular, the SER concluded that the human reliability analysis (HRA), success criteria, initiating frequencies, and common cause failure analysis in the IPE were the examples of those shortcomings. The staff couldn't conclude that the IPE submittal met the intent of GL 88-20.
In September of 1995, the licensee submitted the modified IPE that addressed the staff concerns and comments raised in the base Zion IPE.
RES is currently reviewing the modified IFE. The preliminary, cursory review by the staff indicated that the modified IPE, though it made a significant improvements, was not fully responsive to the concerns and shortcomings raised previously.
11
PRE-DEC1510NAL
, ZION The dominant contributors to CDF by accident type in unit I were ider.tifisc in the NUREG-1150 as follows: ,
Accident L as CDF f/vri LGIE ,
CCV-iduced Sea? LOCA 1.5E-N 43.1 W-induced Seal LOCA 1.5L-N 42.9 LOCA 2.5E-05 -
7.! .
Transients 8.5E-06 f.2 A1WS 7.1E-06 1.1 Station Blackout 6.5E-06 1.9 Sypass 1.7E-06 0.5 The base and modified 1PE risk profile by initiating event is listed below:
Initiatina Event NF J/vr) GF f/vri ILQE
- 8ASE) 5,$p{)
[sASE ;M00!FIED) ;i@lFIED)
Large LOCA 1.3E-06 33 1.0E-06 37 SGTk 1.tE 06 29 1.0E-06 21 Dual Unit LOOP 9.0E-07 26 2.'9E-07 6 Medium LOCA 3.9E-07 10 1.0E-06 21 Small LOCA 1.6E-07 4 7.5E-08 2 Gen 9ral Transient 4.8E-08 1.2 4.5E 9 Si..gle Unit LOOP 2.0E-08 0.5 1.1E-07 0.2 ISLOCA 4.0E-09 0.1 5.7E-07 0.1 Loss of SW 5.1E-11 <0.01 7.8E-08 1.6 Loss of CCW 4.7E-13 gLg1 1.2E-07 ' Li Total' 4.0E-06 100 4.8E-06 100 The modified IPE reported the total COF to be 4.8E-06/yr, a 205 increase from the base IPE result of 4.0E-06/yr. The change, according to the licensee, was due to the efforts made by Comed to address the shortcomings and concerns identified in the SER, and implementation of a RWST refill enhancement described melow.
The modified IPE CDF is lowered by about 2 orders of magnitude when compared to the NUREG-1150 estimate of 3.4E-4/yr. Loss of CCW and loss of SW, as initiating events, contributed to approximately 45 of the total CDF in the modified IPE whereas in NUREG-1150, these 'm events initiated the majority of core damage sequences. The lic e u stated that, with the' plant modification of alternate emergency cooling to the charging pumps, the CDF is reduce' d from 3.4E-4/yr to 6.tE-5/yr. This modification was implemented as a result cf the NUREG-1150 findings.
The licensee. claims that the remainder of reduction in CDF can be attributed to more realistic modeling of expected plant and operator responses to accidents, credit for symptom-based E0Ps, and more realistic asodeling of common cause failures, 12 -
i
~
e . .
9 ZION PRE-DEcl$10NAL The licensee stated in the modified IPE .that the CDF would have been 9 26F-06/yr, compared with 4.8E-06 were not marie.' This enhanctmentwered lo/yr,the if the CDFRWST refill of LOCA enhancement sequences trith .
loss.of recirculation and 54TR sequences. ,
C. Core heree Precursor tygtg , ,
On the 'buis of the precursors identified b'y ORNL for 1994 (NUREG/CR-4674, Vols. 21 through 22) and the preliminary precursors for 1995 and 1996, the staff identified the following precursor event for the site that had a conditional core damage probability (CCDP) of IE-5 or greater: -
On March 7,1994, durin'g a refueling ~ outage, :.lth Unit 2 in het shutdown, operators were performing a surveillance test on the turbine-driven auxiliary feedwater pump (TDAFW) and an endurance test on the 28 EDG. During the tests, the TDAFW pump tripped on overspeed and the EDG experienced frequency swings and was manually tripped. An operator also observed an temperature increase in its lube oil and jacket
- water coolers. The cause of the TDAFW pump trip could not be determined. The EDG frequency swings were caused by a blown fuse, and the elevated lube oil and jacketwater cooler temperatures were caused by zebra mussel shells in the lube oil and jacket water coolers for 2B EDG. CCDP: 2.3E-5.
In addition, the following event was identified as an ' interesting event" by ORNL:
On May 23, 1994, during the reactor startup following a 6-month refueling outage , containment pressure indications did not change during ; containment vent. Investigation revealed that the sensing lines on all of the safety-related containment pressure transmitters were capped inside containment. This event was not modeled as an accident sequence precursor due to the.short time period during which response to accidents would have born impacted ano the availability of alternate actuation signals for safety injection. This event is an example of a common-mode failure that resulted in the disabling of all the instrumentation for a safety-related process variable.
13 i
s L .
ZION PRE-DECISIONAL II. ENFORCEMENT HISTORY 8/94 - CIVIL PENALTY (Suoclement L Reactor Doerations: EA 94-079): The- -
action was based on Severity Levet III violations in March 1994 that were indicative of a weakness in the knowledge and control of safety-related equipment configuration. required to ensure the plant is maintained in compliance with the license and procedures. The violations included inoperability of auxiliary feedwater pumps, inadvertent capping of containment pressure sensinfi lines, and the failure to reinstall lifted leads on safety inject' on valves. A civil j penalty was issued to emphasize the need for attention to detail of
- licensed activities and the importance of configuration control of
- safety-related equipment. The civil penalty was sitigated 255 for
! licensee identification and 505 for corrective actions. ($12,500) i
. Reactor Doeratis t: EA
- 1/95 - SEVERITY LEVEL III PROBLEM (Suoclement 90-L18): The action was based on multiple vio' ations that involved the faiDJre to: (1) comply with technical specification surveillance requirements for several engineered safety features includinfi auxiliary feedwater, safety injection, containment spray, containment ' solation, and steamline isolation systems for periods before April 1995; (2 ,
obtain Commission approval prior to revising an emergency diesel ) I esting procedure in February of 1994; and (3)- assure that a l generator condition at.dverse to quality concerning steam generater tube cracking l was promptly identified and corrected during the 1993/lp94 outage. The i violations collectively represented a sigaificant regulatory concern.and l were therefore categorized as a Severity Level !!! problem. Full credit was warranted for the licensee's identification and prompt and compreh'ensive corrective actions, thereby fully attigating the civil penalty.
I 11/95 - CIVIL PENALTY fSunelasent VII. Miscellannous! EA 95-1441: The
' action was based on discrimination by a first 'ine supervisor against an employee, in that the employee was not rehired during the 1994-1995 outage because he had raised safety concerns about respirators during the 1993-199* outage. A base civil penalty was issued to emphasize the i importance of maintaining a work environment in which employees are free l
.to engage in protected activities without fear of retaliation. Because i this was a willful violation, the NRC considered whether credit was I warranted for identification and corrective action. Credit was not warranted for identification, but was warranted for corrective action.
($50,0000) i 14 l
l
w ZION PRE-DEC1510KAL If96 - civil PENALTY (Sueolement 1. Reactor Operations: EA 95-283): The action was teased on multiple examples of a violation from October 1994 through November 1995, associated with the station's emergency lighting system. A base civil was issued to emphasize the need for increased -
management involvement and oversight of the emergency lighting program, the importance cf identifying, evaluating, and correcting plant hardware problems, and the need to fully implement commitments made in response in NRC violat'ons. Because this was not* the first escalated action within 2 years, the NRC considered whether credit was warranted for identification and corrective action. Credit was not warranted for identification, since the NRC identified the violation. Credit was warranted for corrective actions. ($50,000)
PENDING (EA 96-150): The staff is considering escalated enforcement action related to a frozen high pressure safety injection (HPSI) recirculation line during plant shutdown that could have resulted in both trains of HPSI being inoperable if the plant was in operation.
0
/
15
~
PREDECISIONAL, I t
yg .l Shutcown < approx.72 hrs Startup t--]
Refueling R Operation m htNetry Avg. Trond Shutdown E55553 NotShoe usenf Op. Cycle m ,
UD6. , Ops. ,
a l l l l 1 i l g l g l R I g i I I I E E1' B3 3 k1 kJ 06 1 B6 3 i E thi BS3 43 96 1' E3 3 Year . Quarter k1' . Que,rter Year
, Automatic Scrams Whbe Crtuca! ,
Satury System Actua# ens h3- 3-a g 2- 2-
~W 1 Eli E3 -
'- b1' 313 g hi t E3 3 Signif cant Events , Safety Syriem FaRures 2.0 i
15- 3 W 6 1 1.0- '
gg 2 J $N
- j os- pi- s 4 g
I 0.0 0 N M E M tk1 BM De 1 k3 95 1' 95 3 4 L' Y BS3 I41' 143 06 1' B6 3 8 Yeer. Quarter Year. Quarter Equipment Forced Outagest 3gn Forced Outage Rate {%)
4 1000 Commercial Crttical Hours
?
~ B0 -
S O 4-
= .0 ,
3g h-w- i l
O! ,.
J
. E h M Md, 0
,3,,; ,M ,?g%,y ,,,, ,
- 0-
,D,1 g g17g-',,,1, ,,,, ,
Yosr. Quartet Year - Quarter I Cause Codes
' "' ' "' *' h '
Collective Radia6on Exposure = -. .
200
- m. .. ..
i W e 150- e, s. e.
jp , i R -
3J1o0-
! .. m ! .
- ' tm e. o.* t. w.c g , , ,
I -_Ea&3BaMian^
es.t m3 3 av es.i. De,3 i
~
i ..
. ;:: w c p3 , ..ba . . s a,
en PREDECitiCWAL ZION 1 tend. m -w-e+ wen -
Peer Group Westnghouse Older 4-Loop " "" M 931 to 96-4 Trends and Devebons Deviations From Plant Peer Group SeN-Trond Median Short Term Long Term Destned impreted Weres Deeer
=
OPE 8tATIONS (including startupj Automatic Scrams While Critical - o
- p ,
Safety System Actuations - o o
significant Events - o o
Safety System Failures - o,21 -
o Cause Codes (All LERs) e As=mmeson cearw P=wame - ~1 -
1.29 -
0.90 et useases comenw eners - l 4A0 -
] 0.23 e oew Persenner eners - 0 - 0.90 c - P,een - -
.t04 - 0.50 . .
. one e-eene esa Prenemme - ]c.19 -
]0.10 tansaamenese - 0 - 0 SHUTDOWN Safety System Actuations - -0.15 -
-0.10 significant Events - o -
o safety eystem Failures - o -
0.45 Cause Codes (All LERs) a maneusesen ceaew Prene -
] CDs 4.06[
eu uneases oserener aner - 0 - 0
'~
e.com Peresanes eners - J 030 - 0.08 I e asemeinense Pretensis - ] CDs
- O sr cn - -- eenseeen Preasons - ) 0.03 - 0.19 tesmenneneses - 0 - 0 FORCED OUTAGES Forced Outage Rate * - o -
.o,10 v -
( Equipment Forced Outagest ' , ,
g 1000 Commercial Critical Hours _
1m -03 cm 03 tm 1m -0h 02 0h to Performance inces Performance indeu
. semics:weere sw operseens cy =
I
Appointment Schedule Edward McGaffigan 12/03/96 - 12/03/96 November December January S MT W .T F S S M T W T F S S M T W T F S 1 2 1 2 3 4 5 6 7 1 2 3 4 3 4 5 6 7- 8 9 8 9 10 11 12 13 14 5 6 7 8 9 10 11 10 11 12 13 14 15 16 15 16 17 18 19 20 21 12 13 14 15 16 17 18 17-18 19 20 21 22 23 22 23 24 25 26 27 28 19 20 21 22 23 24 25 24 25-26 27 28 29 30 29 30 31 26 27 28 29 30 31
'Tunsday 12/03/96 7: 30AM 7:31AM CONF: Joe training 9:00AM 10:00AM CONF: (Tech Assts meeting on materials) 10:00AM 10:01AM CONF: .(Note: Fire Drill scheduled.(not on 18th floor])
10:00AM-11:00AM CONF: John Cook, Sr. VP, Wilfred Conne] , VP , & Paul Telthorst, Director of Licensing of ILLINOIS POWER CO.
(Jackie 217-935-5623) 10:00AM 11:00AM CONF: (USEC briefing on status of DOE Waste to NMSS staff in Rm T-9-A1, Tech Assts invited) 11:30AM 12:30PM CONF: Mike Wallace, Sr. VP, & Jim O'Connor, CEO, COMMONWEALTH EDISON, re current CE issues (Mary, Winston & Strawn, 202 371-5751) 12:30PM 1:30PM CONF: Periodic meeting w/ Chairman 2:00PM 4:00PM CONF: Reception for OWFN employees (18th floor Exec. Rm/
Dining Rm)
NOTES: (GJD-Travel) C F -9 ,
- I DU Or) Q[$jk
'MOL W
May 28, 1997 PAGE 1
._ _ _ - - _ _ -