ML20217D539

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Partially Withheld, Commission Briefing Paper for 960513 Commission Meeting W/Commonwealth Edison Co
ML20217D539
Person / Time
Site: Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  
Issue date: 05/02/1996
From:
NRC
To:
Shared Package
ML20217D413 List:
References
FOIA-97-178 NUDOCS 9710030272
Download: ML20217D539 (83)


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TABLE OF CONTENTS A

May 2,1996, Chairman Jackson Briefing Information (Slides)

B May 2, 1996. Chairman Jackson Briefing Information (Suppor'.ing Background Material)

C Primary Comed Spokesperson Resumes D

Corporate and Dresden Station Organization Charts E

Dresden's Semiannual Plant Performance Assessment -

F Plant Issues List 4

G Performance Indicators Assessment and Data (AE00)-

H Human Performance Information (NRR HHFB) 1 Letter from J. S. Perry (Comed), to the U.S. NRC, "Dresden Station Improvement Plans and Progress," dated January 30, 1996.

J Letter from J. M. Taylor (NRC), to J. O'Connor (Comed), Concerning SMM Findings, dated June 20, 1995.

K Letter from J. M. Taylor (NRC), to J. O'Connor (Comed', Concerning SMM Findings, dated January 29, 1996.

L S!iM Summary Matrix Licensing Issues M

Dresden Significant Enforcement History N

0 Letter from Chairman Jackson (NRC) to J. O'Connor (Comed), dated March 22,1996.

Licensees Progress Made in Resolving Issues Raised in the P

March 22, 1996, Letter.

Q-Suggested Questions to be Asked of the Comed Management R

Background Information on Comed S

Current Issues and Concerns i

COMMISSIONER'S BRIEFING FOR COMED MEETING CONCERNING DRESDEN'S PERFORMANCE PRE-BRIEF OF CHAl01 MAN JACKSON 05/02/96 4

S-1

DRESDEN Brief History and Context

  • 1994 Initiatives 1995 TS Violations and Outage Performance Principal Focus on Operators
  • Conservative Operating Philosophy 9 Control Room Conduct and Standards
  • Operator Workarounds Results in Control Room Positive -- In Field Results Are Mixed
  • Successful Plant Operations (Startups/ Shutdowns)
  • Valve Lineups "OOS" Problems Material Condition - Improving
  • Impact of Outages Since 1992
  • Impact on " Big Ticket" Items
  • Unit 3 Operation Maintenance Backlog Still Lar0e
  • Significance
  • "Out of the Way" Areas Maintenance Process
  • Very Slow Progress on Work Control / Planning Weaknesses
  • Skill of Craft Still Weak -- Training and Results Current Efforts to identify " Hidden" Material Condition Deficiencies Latent " Problem" System Review
  • Unit 2 " Fast Cruise" Engineering Performance - Stillin Transition improved Capability and involvement e
  • Large Backlog - Priorities Key issue (structural steel problem)
  • Design Control /UFSAR lssues Self Assessment
  • Problem identification - Improved
  • Trending - Improving Response to issues at Lower Management Levels - Mixed (e.g. valve lineup problem)

S-2 I

March 22,1996 Letter to Mr. O'Connor PROGRESS AGAINST PLANS AND MILESTONES Dresden Station Improvement Plan Progress Toward April 30 Short-Term Milestones WORKFORCE IMPLEMENTATION OF STANDARDS MATERIAL CONDITION IMPROVEMENT EFFORTS PLANT SYSTEM ASSESSMENT RESOURCES AND MANAGEMENT ATTENTION SYSTEM WIDE S-3

COMMON THEMES More Conservative Operating Philosophy -- Improved Response to issues e impact of Outside Hires

  • Slowly Filtering Downward Mixed Picture on Personnel Errors and Operation Improved Control Room Performance a: BWRs
  • Problems With Field Ops Continue (e.g. OOSNaive Lineup)

Material Condition

  • Large Material Condition Backlog at Older Plants

- Uncertainty of impact (e.g. Zion SI Recirc)

  • Very Slow Progress on Work Control / Planning Weaknesses
  • LaSalle - MS isolation Workaround Turbine Building Ventilation
  • Dresden - Offgas System Engineering Improving but Still in Transition
  • Increased Capability
  • Root Cause Evaluation inconsistent
  • Large Backlog 4

,4 S4

QUAD CfDES Conduct of Operations improved Control Room Communication and Panel Monitoring improved Improvements Lagging for Out of Service, Planning, and Inter-department Communications Material Condition Poor - Improvement Slow Numerous Cracks in Recirc Piping, Core Spray Piping and Core Internals Numerous Improvements During Recent Outages (e.g., MOVs upgraded, RWCU piping replaced, feedwater in 3 element

":ontrol)

Large Backlog Remains Safety System Performance (HPCl/RCIC) Still Poor Work Control Process ineffective Scheduling and Coordination Problems Not Yet Overcome Impacts Ability to Improve Material Condition Personnel Performance issues Personnel Errors Still Problematic Primary Conta:nment Breached - Misunderstood TS Skill of Craft Problems - High Rework Root Cause Evaluations of inconsistent Quality (Contributed to Recent Unavailability of Emergency Diesel Generator)

Radiological Controls ALARA Planning and Practices improved High Outage Dose Due in Part to Emergent Work and Higher than Expected Radiation / Contamination Levels Good Source Term Reduction Initiative S-5

LASALLE Material Condition Degraded Improvement Slow Remains Biggest Concern e

Both Design and Degradation issues Recent Unit 1 Outage Addressed Severalissues (MSIV Workaround, Turbine Building Ventilation)

Rate of Improvement Slow Work Control Process inefficient Slightly Improved Contributes to Slow Rate of Material Condition improvement Engineering Support Weak but Improving t

Personnel Performance issues Senior Management Team Reacts Well to Most Challenges and Events Recent Attempts to Upgrade Operations Standards Somewhat Successful Human Performance Error Rate Remains High

- Improvement Efforts Not Very Effective

- Personnel Errors Occur Independent of Job Complexity S6

BBAIDWOOQ.

Equipment Alignment Errors Problematic

)

Numerous Valve Lineup (out-of service) Errors Safety injection System Degraded By On Line Maintenance Hydrogen Monitor E ystem Disabled L!censee Slow to Flx This Recognized Problem Maintenance Effectiveness inconsistent Work Control Mistakes Shared with Operations Skill of Craft Sometimes insufficiant Material Condition Degraded but Recently improved

  • Leaks / drips Being Fixed
  • Deficiencies Being Tagged
  • Inoperable Control Room Ventilation Not Recognized i

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S-7

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BYRON i

Teamwork and Communications between Departments Strong 4

i System Engineering Solid i

Unit 1 Steam Generators Degraded IGA /lGSCC Tube Support Plates Previously Circ Cracking at Top of Tubesheet Currently Electronic Work Control System Working Better i

i Management Changes i

Personnel Errors intermittent Dralned 1000 gallons from RWST to Spent Fuel Pool On Line 1

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S-8

ZION Operations Performance Inconsistent e Personnel Errors Continue e Conservative Plant Operating Decisions Material Condition Progress Slow e Chronic lasues e Hidden Backlog and Workarounds e Maintenance Personnel Skills / Training e Recent Work ControlImprovements-Engineering Support Better but Still Inconsistent e

Weak Root Cause and Corrective Action e

Good on Focused Special Efforts Radiation Protection Program Declining S9 i

_________.m__

L BACKGROUND - DRESDEN M7.TERIAL CONDITION MAJOR IMPROVEMENT 4 1992 - 1996 Reactor Recirc Pump Seals (Better Motor Alignment)

Unit 2 Reactor Water Cleanup Piping and Heat Exchanger Replaced (Unit 3 scheduled-IGSCC ISSUE)

Reactor Level Instrument Mods (replaced Yarway on Unit 2. Unit 3 scheduled)

Feedwater Pump Seals (installed new seal design)

Feedwater Control System Mods on both units (3-element control)

Condensate / Condensate Booster Pump (Piping, Seals, Bearings and Motors)

Containment Cooling Service Water (CCSW) Pump (Thrust bearing, Seal Cooling, Valve Alignment)

Control Rod Drive Mechanisms (essentially all overhauled since '92)

Recovery of Unit 3 *A* ttain SJAE and recombiner.

Retubed Unit 2 TBCCW heat exchangers Control Rod Drive Scram Solenoids (all. replaced)

Station Air Compressors and Receivers (Compressors 2A, 28, 3A and 3B overhauled and all five receivers and associated piping replaced)

Major Motors overhauled (Reactor Recirc/ Core Spray / Feedwater/LPCI)

Motor Operated Valve Program (89-10 complete)

HPCI Systems Pump overhauls cod drain pots modified Fire Protection improvements (new nump on Unit I and Unit 2/3)

Unit 1 Fuel Pool and Transfer Canal cleaned and Transfer Tube capped.

New Refueling Bridges installed for both units.

Core Shroud Repair completed on unit 2 (Unit 3 scheduled).

Main Turbine overhaul (Unit 2 & 3 LP blades [ic containment air'95)

Installed NCAD and eliminated ACAD [atmospher dilution]

Unit 2 reactor bottom head drain cleared (Unit 3 scheduled)

Zine Injection Skid added to Unit 2 (Unit 3 scheduled)

Removed abandoned equipnent (Unit 2 caustic acid system and Unit I tanks) 250 Volt non-safety battery added to both units (reduced safety bus load)

ECCS corner room steel reinforcement on Unit 2 (Unit 3 scheduled)

Station Blackout Modification installed and tested Unit 2, Unit 3 installed New site-wide galvanic corrosion protection system installed New floors installed in both units Contaminated Water Storage Tanks Installation of new Reactor Building Chilled water units (HVAC)

Iso Condenser Diesel-driven Makeup Pumps added PLUS:

HQj 1/95 BACILQQ 4/30 BACKLOG

  1. worked Control Room Deficiencies:

120 29

[445)

Operator Work Arounds:

70 30 L65)

Non Outage Temporary Mods:

56 4

L52]

B1

BACKGROUND - DRESDEN MATERIAL CONDITION 1995/96 IMPROVEMENTS 1995 UNIT 3 FORCED OUTAGE Forced outage started on May 28, 1995, due to a failed turbine blade.

The outage was extended to 16 weeks and the work scope increased to about 350 work requests which included:

Inspected the 30 reactor water cleanup demineralizer bed for blockage Inspected and replaced all last row Unit 3 low pressure turbine blades Repaired the 3A feedwater regulating valve system Replaced the 3B recirculation pump seal Replaced 68 control rod drive scram solenoid pilot vahes Repaired a ground in the drywell floor drain circuitry Modified the traversing incore probe logic to prevent reopening on a containment isolation signal Medified seismic mounting of safety related electrical buses 38 & 39 Performed minor maintenance on the high pressure coolant injection system and three of four containment cooling service water subsystems Modification of three core spray and low pressure coolant injection system injection valves in response to pre ture locking concerns Identified and repaired minor leaks in the drywell pneumatics system.

1995/96 Utill.2 REFUEL OUTAGE Refuel outage started June 2, 1995. Outage work was stopped in November 1995 and restarted in January 1996. Outage was completed in late April 1996 and included the following material condition improvements.

Overhaul of a low pressure coolant injection and a core spray motors Overhaul of the high pressure coolant injection main pump, auxiliary pump, and booster pump Modifications to the feedwater system to run in 3-element-control with the ability for automatic control of the feedwater regulating valves Replacement of all scram pilot solenoid valve assemblies Inspection and repair of Unit 2 LP turbine blading Reactor level instrumentation (Yarway) replacement Reactor water cleanup, heat exchanger and pipe replacement (IGSCC)

Material condition improvements to the safety-related 125 Volt direct current system Repair / replacement of 46 hydraulic control unit manual isolation valves Testing and/or repair to about 80 safety-related motor operated valves required by Generic letter 89-10 Reduction of the number of control room work requests for both units from about 120 to 30 or less Reduction of the number of operator work arounds from 65 for both units at the beginning of the Unit 2 outage to about 30 Fifteen of the " Top 25" technical issues were targeted for resolution or for start of work during the Unit 2 refuel outage Cleared blockage from the reactor vessel bottom head drain line Completed Unit 2 Station Blackout Modification ECCS corner room steel reinforcement B2

BACKGROUND - DRESDEN MATERIAL CONDITION IRIiBJER 1996 UNIT 3 REFUEL OUTAGE The licensee plans to address the following material condition issues during the Fall 1996 Unit 3 refuel outage:

Upgrade 3 MSIVs, and perform A)pendix J valve improvements Core shroud repair and bottom head drain cleaning Low pressure coolant injection motor replacement Complete Unit 3 Station Blackout Modification Reactor water cleanup, heat exchanger and pipe replacement Installation of zine injection skid Feedwater valve and 3 element level control upgrade 24/48 VDC battery replacement Replacement and cleaning of drywell coolers Reactor level instrumentation (Yarway) replacement ECCS corner room steel reinforcement B3 i

BACKGROUND INFORMATION DRESDEN 91ERAL OVERVIEW Over the past six months, Dresden Unit 3 has continued to operate with few problems since it's return to service last November.

The Unit 2 refueling outage, which was put on hold last November, was restarted in January and that unit returned to service in April.

The conduct of plant operations has been very good with a conservative approach to the day-to-day running of the station; fuel lohd activities on Unit 2 went well.

Efforts to improve the work control process have not been successful. Some improvement in the Engineering support to the station has been noted, but the engineering organization is still in a state of transition.

Performance in the area of Plant Support has been good with respect to security and fire protection; however, weak performance in radiation protection continued with only slight improvement noted.

Problems with implementation of the licensee's out-of-service (005) progr"n have not been resolved.

In addition, implementation problems were found in the use of system lineup checklists and the station's locked valve program.

Recent NRC inspections of the engineering backlog identified a significant delay in restoring design margin to ECCS corner room structural steel and other UFSAR deviations that were not being addressed (e.g. IEEE standard and open items from 1992 UFSAR rebaseline effort).

MATERIAL CONDITION - (IMPROVING)

Since 1992 slow improvements in plant material condition have been made.

Both units have had multiple maintenance and refueling outages that addressed major equipment. problems and bulk work.

Unit 2 operated well following the fall 1994 duel unit shutdowns until the start of its refueling outage in June 1995.

Unit 3 has operated well since it was returned to service in November 1995 after a forced outage (turbine blade).

WHAT'S BEEN DONE Equipment problems seen several years ago are not recurring.

More recently, the Unit 2 refueling outage was completed in April with essentially all planned work being accomplished (similar work is planned for the 1996 Unit 3 refueling outage). Safety improvements made during the Unit 2 outage included:

Overhaul of HPCI, LPCI, and Core Spray motors Feedwater modificationr to allow 3-element control Replaced all Scram Solenoid Pilot valve assemblies Reactor Water Cleanup Heat Exchanger and piping replacement Cleared Reactor Vessel Bottom Head Drain Implemented Core Shroud repair Reduced operator work-arounds and control room deficiencies tiadified structural steel in LPCI heat exchanger corner rooms B4

CURRENT EFFORTS Material Condition improvement is the licensee's primary focus in 1996.

Current efforts to improve material condition of the station include specific equipment u) grades on Unit 3 during the fall outage and reducing station bacciogs.

Short term (4/30) goals included the following issues:

Reduce work arounds (<30) and control room deficiencies (<30)

Reduce non-outage temporary alterations (<10)

Complete selected perfon..ance centered maintenance reviews (5+14)

Complete selected " Latent System Reviews" (26)

Reduce corrective maintenance backlog (<950)

WHAT REMAINS Non-outage work request backlog short-term (4/30) milestone was not met, but a large amount of emergent work was done in the 1st quart 9r of '96 Scope of additional work based on the Latent System Review is unknown 1

Hidden engineering problems such as scram discharge volume instrument logic, scram discharge volume support steel, and LPCI corner room steel WORK PLANNING. SCHEDULING AND EXECUTION - (REMAINS A CHALLENGE)

OUTAGE kORK CONTROL Replaced in-house outage work group with contractors (8/95)

Stopped the Unit 2 outage to "rebaseline" (11/95)

Unit 2 outage restarted January 22 Plant restarted April 15 Essentially all Unit 2 planned work was completed (4/96)

New outage work control center viewed as a positive Large amount of work accomplished following the Unit 2 outage restart with fewer resources Utilized " FAST CRUISE" plan to identify deficiencies (3/96)

I NON-0UTAGE WORK CONTROL Work control is still,. bottleneck Positive use of "fix-it-now" (FIN) team for routine tasks Replaced work control superintendent (1/36)

High backlog of non-outage work requests (1,000)

High amount of rework (10%)

4 Results of Latent System Review not included in backlog (?)

Rolling maint schedule started with limited success (2/96)

HUMAN PERFORMANCE - (GETTING BETTER IN SOME AREAS)

Control room operators Lasting performar.ce improvement initiatives (18 mos.)

Few errors (no safety significant errors)

Operators outside control room c

Implementation errors with out-of-service continue Implemtntation errors with valve and electrical lineups System engineers Improved support to operations visible B5

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Test controls need improvement (emergency diesel not tested in accordance with procedure)

Maintenance Workers 11C performance remains good j

Electrical and Mechanical craft still need improvement Radworkers Changes in first line RP supervisors having positive influence A known resin spill that went uncorrected for over a year Station is cleaner and amount of contaminated areas is reduced Radworker performance expectations are slowly being accepted LNGINEERING - (IMPR0 VIN 61 Still in transition 1

New engineering manager, Mr. Raj Kundalkar (Turkey Point)

Onsite contract A/Es were integrated into the Design Engineering organization at the end of 1995.

Numerous functions are still being transferred between organizations (i.e. vendor manuals and operability evaluations).

The inhouse Transition Plan (increasing engineering done by Comed engineers) remains in process with several major actions to be accomplished in 1996.

Engineering is in the process of developing an improved system trending program and just started development of a self-assessment program.

Engineering backlogs is major impediment, diverting focus and attention from current issues.

Outstanding modifications (400) and engineering requests (1300) are being prioritized or eliminated Additional engineering personnel are being loaned in 1996 from 4

corporate and other Comed plants to work on configuration management backlogs (i.e. vendor manuals, master equipment list upgrade, design basis reconstitution, equipment qualification binders, fuse list, etc.)

UFSAR deviations found (e.g. corner room steel, open items from rebaselint, IEEE standard, locked valves)

Engineering's ro!e in improving and maintaining equipment material condition continues to improve.

Modifications and overhauls addressing material condition issues were completed in the most recent outages on both units (i.e.

feedwater modifications, pump overhauls, etc.)

Indicators such as the " top technical issues," operator work arounds, temporary alterations, and outstanding control room work requests are trending downward.

Latent system reviews are continuing to identify numerous important material condition issues.

Material condition problems still remain.

B6

Main steamline drain valve packinn Icaks, multiple Furminite injectionsonafeedwaterregulatingvalve,andanoilleakona recirculation motor causing repeated alarms (Unit 3).

Numerous issues identified in the latent system reviews have not been addressed.

Electrical issues continue. An overloaded non-safety bus caused a loss of fuel pool cooling on both units in January.

Several 4 KV breaker difficulties encountered in January / February.

Engineering development efforts Expectations disseminated through plant engin3ering handbook, _

design engineering chief's meetings, system review boards, and weekly tests on recent performance improvement forms (PIFs).

Training program underway with fundamentals training completed in December 1995 and systems training planned for April 1996.

Some engineering personnel are especially effective at addressing equipment problems, serving as examples for others (e.g.

instrument air and feedwater improvements.)

SELF ASSESSMENT - (GETTING BETTER IN SOME AREAS)

Performance Improvement Forms (Plfs)

Used extensively at site (5300 in 1995)

Trend Analysis Report (since 6/95) provides focused insights Sighi Quality Verification (SQV) effectiveness Poor corrective action followup (locked valve, checklist)

SQV finding issues; but, not aggressive in elevating findings (e.g.

U2 Orywell closecut)

New Director SQV, Dennis Winchester (Quad Cities)

B7

Operating & Maintenance Expenditures (In Million 5 for Both Units) liig g

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1996(Budaet)*

Braidwood 90.0

!!3.0 101.8 106.4 Byron 111.5 100.9 97.2 114.8 Zion 128.6 111.4 133.3 104.7 Dresden 147.5 139.3 162.1 148.0 LaSalle 102.0 117.7 110.2 127.2 Quad Cities' 130.6 153.6 130.1 114.7

  • An additional ll7H$ is being provided for the 1996 Accelerated improvement Program, with the largest shares to LaSalle and Zion.

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Comed Dost INFO 1996 Dose Data 1995 Dose Data.

1994 Dose,3.311 Goal Actual Goal Actual Goal Actual Braidwood:

200 184 260 237 390 299 Byron:

518 41 332 305 299 277 Zion:

'241 52 724 801 310 306 Dresden:

680 190 867 875 937 833 6

LaSalle:

650 380 520 512 750 725 6

Quad:

700 638 720 736 1250 1128 Notes:

Units are in person rem and includes both units 1994 Industry Averages Avg PWR dose / unit is 194 person rem Avg BWR dose / unit is 330 person rem

  • 1995 Industry Averages Avg PWR dose / unit is 157 person rem Avg BWR dose / unit is 281 person rem NOTES:

' Zion's dose total will be revised to reflect emergent work and an expanded scope for the upcoming unit 2 refueling outage.

5hese goals will be revised to reflect cutage emergent work and possible additional scope from material condition improvements.

'The 1995 industry average data lias not yet been calculated.

These are estimated values based on plant goals as of 5/95.

B9

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JAMES J. O'CONNOR Chairman and Ch'ef Executive Officer EXPERIENCE Unicom/ Commonwealth Edison Company Present - 1980 Chairman and Chief Executive Officer 1980 - 1978 Member of Board of Directors 1978 1977 President 1977 1973 Executive Vice President 1973 1970 Vice President 1970 - 1 % 7 Assistant Vice President 1 % 7 - 1966 Division Commercial Manager at Chicago North 1966 - 1963 Staff Assistant to the Chairman of the Board and Chairman of the Executive Committee United States Air Force 1 % 3 - 1960 Three years of active duty EDUCATION JD - Georgetown Law School,1963 MBA - Harvard University,1960 BS - Holy Cross College, major in economics,1958 PROFESSIONAL AFFIIIATIONS Director of Nuclear Energy Institute, Chairman of the Advence Reactor Corporation Director of Edison E'ectric Institute, past Chairman Board of the Institute of Nuclear Power Operation, past Chairman Member of Board of Directo s of American Nuclear Energy Council k: resume 1.wpf/3

TIIOMAS J. MAIMAN Senior Vice Pruident i

EXPERIENCE e

Commonwealth Edison Company Present - 1996 Sr. Vice President, Nuclear Division 1996 - 1994 Sr. Vice President, Fossil Division 1994 - 1992 Sr. Vice President, Commercial Division 1992 - 1990 Vice President, Corporate Engineering 1990 1987 Vice President, Nuclear PWR Operr'aons 1987 - 1984 Vice President and General Manager, Nuclear Construction 1984 - 1982 Division Vice President and General Manager, Fossil 1982 1980 Asst. Vice President, Engineering 1980 - 1978 Station Mechanical Engineering Manager 1978 - 1976 Distribution Engineering Manager 1976 - 1974 Division Operating Manager, Chicago North 1974 - 1973 Area Manapr, Glenbard Area 1973 - 1972 Area Manager, Des Plaines Valley Area 1972 - 1971 Asst. Division Operating Manager, Northern Division 1971 - 1969 Division engineer, Northern Divisirsn 1969 - 1965 Various functional and Superviso.y Engineering Positions EDUCATION MS - Business Adminisaation, IAyola University, Chicago, Illinois,1972 BS - Electrical Engirecring, University of Illinois, Urbana, Illi.iois,1%2 PROFFMIONAL AFFILIATIONS Member of the Institute of Electrical Bectroni:s Engineers (IEEE)

Edison Electric Institute (EEI)

Western Society of Engineers k: resume 1.vpf/9

Michael J. Wallace Senior Vice President Chief Nuclear Officer EXPERENCE Commonwealth Edison Company Present - 1996 Senior Vice President 1993 - 1996 Senior Vice President and Chief Nuclear Officer 1993 1993 Vice President, Chief Nuclear Officer 1993 - 1992 Vice President, Chief Nuclear Operating Officer 1992 - 1990 Vice President, Nuclear PWR Operations 1990 - 1989 Manager of Engineering and Construction 1989 - 1987 Manager of Project; 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 Project Coordina'or, Byron Project 1978 - 1977 Field Cost Engineer, LaSalle, Byron, and Braidwood Projects 1977 - 1974 Quality Assurarac Engineer, NSSS Programs United States Navy 1974 - 1969 Line Officer, Nuclear Submarinc. orce U.S. Navy EDUCATION MBA Unisersity of Chicago,1978 BS - Marquette University in Electrical Engineering,1969

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OTIER QUALIFICATIONS Registered Professional Engineer PROFESSIONAL AFFTLIATIONS k: resume 1.wpf/1

Advanced Reactor Corpomtion, Vice President Commonwealth Research Corporation, Vice President and Ditector NPOC Ad Hoc Committee for New Nuclear Power Plant Deployment Nuclear Strategic Issues Advisory Committee Nuclear Strategic Issues Steering Group Utility Management Board for the Advanced Light Water Reactor First of a Kind Engineering Program American Nuclear Society ktresumel.wpf/2 2

IIAROLD W. (llARRY) KEISER Chief Nuclear Operating Officer EXPERIENCE e

Commonwealth Edison Company Present 1996 Chief Nuclear Operating Officer 1996 - 1995 Vice President PWR Operations e

Entergy Operations, Inc.

1995 - 1993 lixecutive Vice President and Chief Operating Officer 1993 - 1988 Senior Vice President - Gulf States Utilities Nuclear Pennsylvania Power and Light e

1988 -1988 Senior Vice President 1988 - 1985 Vice President Nuclear Operations, Susquehanna Steam Electric Station 1985 - 1980 Plant Manager, Suso=hanna Steam Bectric Station e

Consumers Power 1980 - 1978 Operations and Maintenance Manager, Palisades Nuclear Station 1977 - 1977 Operations Manager, Palisades Nucicar Station 1976 - 1976 Project Engineer, Palisades Nuclear Station 1975 - 1973 Various Engineering Roles, Palisades Nuclear Station Military Experience e

1968 -l % 1 United States Navy EDUCATION k: resume 1.wpf/7

MS Nuclear Engineering, University of Illinois, Urbana, Illinois,1973 BS - Metallutgical Engineering, University of Illinois, Urbana, Illinois,1972 ERQEESSIONAL AFFILIATIONS i

Certified Senior Reactor Operator License, 976 i

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J. STEPHEN PERRY Senior Vice President EXPERIENCE Commonwealth Edison Company e

Present Site Vice President, Dresden Station 1994 - 19M Vice President BWR Operations Illinois Power Company e

W94 - 1992 Senior Vice President 1 9 2 - 1989 Vice President Nuclear Operations F89 - 1988 Assistant Vice President, Clinton Power Station 1988 - 1984 Manager of Nuclear Power Coordination United States Navy e

Served as Cmmanding Ofticer of nuclear-powered submarine and as Commanding Ofnce.r of a submarine repair ship. Additionally, Mr. Perry served as senior member of the Nuclear Power Examining Board with responsibility for conductmg inspections of all Pacific Fleet nuclear-powered ships for proper and safe reactor plant operation.

EDUCATION MS - Naval Post Graduate in computer Management,1971 BS - U.S. Naval Academy,1961 k: resume 1.wpf/6

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I C0rW10lN#EALTH EDISON COMPANY ORE 5 DEN UNITS 1/2/3 SITE VIEE PRESIDENT J. Stephen Perry 9/95 Ext. 3600 EXEEUTIVE REGULAT04f ASSISTANT A55URANCE SUPV.

Dale Ambler 6/93 Frar.k Spanenberg 2/96 Ext. 3602 Ext. 2718 STATION STATION SITE ENGINEERING SUPPORT SERVICES SITE QUALITY VERIFICATION MANAGER Unit I rtANAGER Unit 2/3 MANAGER DIRECTOR DIRECTOR Tee Nauman 7/94

$;vhn (Mine) Heffley 9/95 Raj Kundalkar 2/%

Peter Tsomes 2/96 Dennis Winchester 2/96 Ext.2441 l

Eut. 2212 Ext. 2580 Ext. 2677 Ext. 2216

$HIFT OPERATIONS DESIGN ENGIEERING TRAINING MANAGER MANAGER SUPERINTENDENT MANAGER

~

Do.glas Strebel 5/94 Tim O'Connor 3/95 Ed Connell 11/94 Joe retowstl 8/95 Ext. 2572 Ext. 2213 Ext. 3425 Ext. 2258 MAINTENAMEE MAINTENAMEE PLANT ENGINEERING SECURITY SUPER!NIERDENT

$UPERINIERDENT SUPERINTENDENT SUPV.

Dean sharper 3/95 Preston $wafford 1/%

Russell Freeman 5/95 Phillig G. Braghini 9/94 Ext. 2418 Ext. 2450 Ext. 2243 Ext. 2264 TEEHNICAL SITE OUTAGC AND WORK SERVICES SUPT.

CONTRCt rANAGER Rick Ralph Jack Che N:? sine 8/95 Ext. 2610 (Contractor)

PLANNING RAD PRCTECTI0ll DIRECTOR MANAGER Coleman McDonough 5/95 Steve Barrett 9/94 Ext. 2945 Ext. 2517 e..

,u..s.

ani c c o.to>n

PRE-DECISIONAL SEMIANNUAL PLANT PERFORMANCE ASSESSMENT DRESDEN UNITS 1,2, and 3 Assessment Period: September 1995 to March 1996 SALP Period: March 19,1995 through September 28,1996 Previous SALP Rating:

Ops

_3_

Maint _2_

Eng

.3_

PS

_2_

l.

Performance Overview Over the past 6 months, Dresden Unit 3 was returned to service and Unit 2 has remained in an extended refueling outage. The conduct of plant operations has been good; fuel load activities on Unit 2 were completed and went very well.

Maintenance has struggled and efforts to improve the work control process have not been successful.

Some improvement in the Engineering support to the stdion has been noted, but the engineering organization is still in a state of transition.

Performance in the area of Plant Support has been good with respect to security and fire protection; however, weak performance in radiation protection continued with only slight improvement noted.

Problems with implementation of the licensee's out-of-service (005) program have not been resolved.

NRC inspections continued to find implementation errors that eventually culminated in a " stand-down" of SR0s responsible for 005 review and approval. One notable insight (licensee identified) was that 80% of the program errors in the 00S effort were being made by three individuals.

A repeated theme from our inspections is that problems not readily visible are not being aggressively identified and entered into the licensee's corrective action system.

NRC identified examples included a number of equipment deficiencies in the Shutdown Cooling and Fuel Pool Cooling rooms and the recent identification that a significant resin spill had gone uncorrec.ted for over a year.

Over the last 6 months, the management " team" at Dresden has been significantly changed.

The most notable changes were in the Engineering and site Quality Verification areas.

Management changes included:

Engineering Manager

- Raj Kundalkar replaced Frank Spangenberg i

Reg Assurance Manager

- Frank Spangenberg assumed new position SQV Director

- Dennis Winchester replaced Rita Stohls Support Services Dir.

- Pete Tsomes replaced Rita Radtke Maintenance Supt.

- Preston Swafford replaced U2 & U3 Supts.

Work Control Supt.

- Robert Fisher replaced Dave Wallick

Dresden PPR 9/95 - 3/96 Pre-Decisional 11.

Functional Area Assessminis A.

Operations 1.

Current Performance Over the last 6 months performance of facility operations has been good. Control room demeanor and attentiveness have remained steady, however, weaknesses were identified with operations work outside the control room.

2.

Assessment / Issues In the control room, operations personnel have exhibited conservative performance during several major plant evolutions.

Operators have demonstrated questioning attitudes, allowing prompt identification of potential problems.

In addition, the control room operators no longer accept degraded plant equipment.

Operations management fully supports the operators when stopping work ensuring conservative control of all evolutions. Examples of conservative decision making include the following:

On September 5, a Group V isolation was received while operators were returning the Unit 3 Isolation Condenser to standby. The licensee terminated startup activities until the root cause of the isolation was identified and corrected.

On September 9, an operator questioned an increasing temperature trend on the 3D ERV tailpipe. Operations stopped the startup until the trend was analyzed by management and engineering. Operations also developed contingency actions in the event the trend continued.

On September 12, HPCI failed its low pressure surveillance.

Operations ceased che startup and shutdown Unit 3 until HPCI was repaired which was more conservative than engineering's recommendation.

On SepteKer 28, operations correctly responded to a load-reject scram due to loss of generator excitation.

On October 29, fish caused a high differential pressure across the Unit 3 traveling screens. With one circ water pump already out of service for maintenance, operators conservatively shut down Unit 3 on an anticipated loss of circulating water.

2

Pre-Decisional Dresden PPR 9/95 - 3/96 Operations management placed a hold on the September startup when an operator questioned the main steam line drain valve lineup.

On November 12, operations successfully responded to an off-gas fire despite inadequate procedures.

Outside of the control room, several operator errors have occurred over the last 6 months which indicates the rigor and attention to detail seen in the control room has not been' picked up yet in the field.

Field Supervisors have been ineffective in assuring performance expectations are followed.

Recent operator errors due to poor procedural compliance and poor self-checking included the following:

In February, numernus problems with out-of-service (00S) program resulted in operations management " locking-out" operations personnel from the electronic OOS system.

On February 1, an " equipment attendant" left the Unit 2 drywell-access locked-high-radiation door unlocked.

On February 6, a licensed operator (SR0) in the work

=

execution center released work which placed a valve in the opposite position of an in-place 005. An on-coming control room operator identified the error during turnover.

On February 10, a non-licensed "high voltage operator" caused a local-start of the Unit 3 emergency diesel generator while attempting to do a routine lamp check.

On February 24, multiple self-check errors occurred resulting in a scram solenoid pilot valve 00S error.

Additionally, the NRC identified that the active status of operator licenses could not be readily verified by operations management and weak administrative controls existed to prevent an s

operator whose license was inactive from performing licensed duties.

3.

Actions / Recommendations Continue with the routine core inspection for the operations area utilizing resident team inspection strategies.

Provide shift coverage of Unit 2 startup utilizing integrated team members.

Perform a TSUP pre-implementation inspection.

3

Dresden PPR 9/95 - 3/96 Pre-Decisional B.

Maintenance 1.

Current Performance Performance in the maintenance area was adequate, with a good operating history on large rotating machinery over the last 6 months. However, weaknesses with work control, scheduling, rework and skill of the craft remain evident. A new Maintenance Supt. (Preston Swafford) was hired from outside the Comed system and the " unitized" maintenance program was combined.

2.

Assessment / Issues While the total number of non-outage work requests have decreased, the licensee has continued to struggle with an unidentified backlog and the scheduling of work activities.

The establishment of a new work control process including a work control center, outage control center, and work execution center has been slow in achieving positive results. The control room deficiency correction group and work-it-now (WIN) team, formed early in 1995, have reduced the number of outstanding material deficiencies.

Strong management action was taken to improve the control of outage maintenance when the Unit 2 outage was stopped in November to provide time for the work control center to rescope and reschedule the outage, Unit 2 outage work restarted in January and performance of outage work s

has improved.

For the operating unit (Unit 3), a formal forced outage schedule has been developed and is being updated as equipment concerns emerge.

Several weaknesses were identified in work package development, completion, and control, especially in the adequacy and performance of post maintenance testing.

Examples over the last 6 months where problems have occurred due to poor work package quality or poor implementation include:

Failure to perform a motor rotation check (post maintenance test) on a shutdown cooling motor operated valve resulted in valve operator damage on October 7.

An inadequate post maintenance test performed on control rod drive f

D-5 in October resulted in neutral leads, reversed during installation, not being corrected until the next scheduled surveillance.

A diesel generator output breaker failed to close twice due to

=

inadequate breaker testing following maintenance on January 11 and January 13.

A rework tracking and investigation program was established providing better identification, tracking, and monitoring. A significant amount 4

s

Dresden PPR 9/95 - 3/96 Pre-Decisional of rework has continued to occur.

Rework is due to a failure by maintenance workers to follow procedures, weakness in craft skills, and poor intra-departmental communications.

Examples of maintenance items requ'. ring rework include the following:

Inadequate comunication of precautions concerning a level float in the containment cooling service water suction bay on October 10 resulted in maintenance personnel removing the float during maintenance.

Failure to follow procedures resulted in:

damage to the Unit 3 main generator exciter breaker's secondary contacts on October 1.

installation of the wrong type washer (critical) during breaker maintenance on October 13.

The wrong size impeller was installed on a LPCI pump on November 1.

During work on the 2/3 diesel fire pump on December 22, the stuffing box was not installed during pump assembly and the wrong oil was added to the gearbox.

The Unit 2 reactor head vent flange was damaged when a mechanic used a punch to remove what he believed to be a gasket in the flange on February 11.

Pipe hangers for two 18 in. Unit 2 offgas lines were not made, but the related work packages were closed.

Examples of old maintenance problems identified by the NRC during the last 6 months included:

four bolts were missing from the Unit 3 standby gas treatment inlet valve flange the recirculation flow line flanges for shutdcwn cooling pumps 2A and 2B were missing 2 bolts undersized bolts were installed on both Unit 2 core spray recirculation flow line flanges Efforts have been initiated to improve housekeeping and cleanliness with varied success. While areas specifically targeted for upgrade have good results, other areas have received little attention.

A comprehensive outdoor housekeeping improvement initiative was completed with numerous RPAs resolved or consolidated and the i

number of sea vans used for storage of outside materials reduced.

Tours of several locked high radiation areas revealed tools remaining after work completed, scaffolding not removed, leaks on components, poor post-maintenance cleanliness standards, and material condition problems.

5

-u-


r--------

Dresden PPR 9/95 - 3/96 Pre-Decisional 3.

Actions / Recommendations Continue with routine core inspections by the resident inspectors with assistance from specialist inspectors.

Perform Maintenance Inspection in August 1996, prior to the end of the current SALP period.

C.

Engineering 1.

Current Performance i

Engineering remains in a state of significant transition.

Although some improvement is evident, several fundamental performance areas remain problems.

Licensee management is well aware of these problems and continue to take actions.

2.

Assessment / Issues The engineering organization remains in transition.

A new engineering manager, Mr. Raj Kund'alkar (Turkey Point), has just arrived on site and is in the process of assuming his duties.

Onsite contract A/Es were integrated into the Design Engineering organization at the end ol' 1995.

Numerous functions are still being transferred between organizations (i.e. vendor manuals and operability evaluations).

The Inhous2 Transititn Plan (increasing engineering done by Comed engineer =; remains in process with several major actions to be accomplished in 1996.

Engineering is in the process of developing an improved system trending program r.nd just started development of a self-assessment program.

The licensee recogr.izes their engineering backlogs as a major impediment, diverting focus and attention from current issues.

A prioricization and elimination proces:, for modifications (currertly 400) and engineering requests (currently 1300) is ongoing.

Additiinal engineering personnel are being loaned in 1996-from corporate and other Comed plants to work on configuration management backlogs (i.e. vendor manuals, master equipment list upgrade, design basis reconstitution, equipment qualification binders, fuse list, etc.)

6

Dresden PPR 9/95 - 3/96 Pre-Decisional Engineering's ability to improve and maintain equipment material condition continues to improve.

Significant modifications and overhauls addressing material condition issues were completed in the most recent outages on both units (i.e. feedwater modifications, pump overhauls, etc.)

Licensee indicators such as top technical issues, operator work arounds, temporary alterations, and outstanding control room work requests are trending downward.

Latent system reviews are continuing to identify numerous important. material condition issues. Five systems were completed in the pilot program with 22 additional planned by April 1996.

An improving trend regarding primary containment isolation valve local leak rate test failures may be an early example of a routine process becoming more effective versus relying solely on these other special focus efforts.

Engineering decisions regarding material condition reflects good safety focus (e.g. CRD HCU scram pilot valve solenoid Viton diaphrages in October, and scram discharge volume header access gallery steel design deficiencies in November.)

Despite these improvements, significant ground remains to be covered with regard to material condition.

There were two shutdowns on Unit 2 (includir.g the refuel outage which so far has lasted over nine months) and four shutdowns on Unit 3 in 1995.

Some involved multiple problems during the shutdown or subsequent startup.

Unit 3 recently achieved 120 continuous dcys on-line-but not without some problems (e.g. significant main steamline drain valve packing leak, multiple Furminite injections on a feedwater regulating valve, and oil leak on a recirculation motor causing repeated alarms.)

The licensee has not yet begun addressing the numerous issues identified in the latent system reviews, and resources are questionable.-

Electrical issues continue to be of concern. An overloaded non-safety bus caused a loss of fuel pool cooling on both units on January 7.

Initial licensee calculations show other non-safety buses to also be a concern.

Several 4 KV breaker.. difficulties encountered during the Unit 2 undervoltage testing in January highlight problems with control of breakers and breaker material condition.

7

Dresden PPR 9/95 - 3/96 Pre-Decisional The licensee is continuing efforts to emphasize engineering work quality expect'ations and skill level improvements.

Initiatives to emphasize expectations include a plant engineering handbook, design engineering chief's meetings system review boards, and weekly tests on recent performar improvement forms.

A more stringent training program is underway with fundamentals

=

training completed in December 1995 and systems training planned for April 1996.

Some engineering personnel are especially effective at addressing equipment problems, serving as examples for others (e.g.

instrument air and feedwater improvements.)

Substantial variations in engineering personnel work quality and abilities remain.

The identification of several older design and process deficiencies is positive (i.e. CR0 scram discharge volume instrumentation single failure vulnerability in October, CRD scram discharge volume gallery steel not meeting FSAR allowables in November, MCC 38-3 breaker incorrect tap setting in November, and primary containment boundaries with no previous LLRT in January.)

Numerous minor material condition problems exist that were not identified during plant engineer walkdowns (i.e. NRC resident inspector findings on fuel pool cooling and shutdown cooling material condition.) A training program was recently initiated to address this.

Initial engineering response to routine deficiencies tended in

=

some cases to be a more cursory review, resulting in ii. effective or delayed solutions, or the need to readdress problems when they recurred (i.e. HPCI exhaust pot high level alarms on October 12, CRD system vibration damage on October 24, fuel pool cooling pump trips on November 27 and November 29, and generator hydrogen line leak on December 17.)

System manager (system engil.aer) knowledge and planning involvement to ensure completion of necessary maintenance work is in some cases deficient with large maintenance work backlogs remaining on most systems.

[

Several recent NRC identified issues question whether sufficient emphasis is placed on FSAR or other licensing document commitments. One specific weakness was identified where the licenree allowed " Operability Evaluations," done in accordance with GL 91-1B, to remain the basis for continued plant operations through more than one refueling outage.

Untimely actions tu address a r.onconforming condition with the LPCI corner rooms' structural stcel not meeting FSAR allowables.

8

I l

Pre-Decisional Dresden PPR 9/95 - 3/96 Originally identified as a site (U2&3) issue in early 1994.

Corrective actions (field work) are just being implemented on Unit 2 after a significant amount of NRC involvement. Unit 3 will be worked in Sept. 1996.

Discrepancies between various licensing docurents with respect to Unit I ventilation system practices and the hot-shop on the Unit I turbine deck.

A failure to analyze PVC piping installations with respect to Fire Hazards Analysis comitments to minimize PVC use in the plant due to toxic gas release.

3.

Actions / Recommendations Continue with routine core inspections by the resident inspectors and LEAP with assistance from specialist inspectors when required.

Engineering and Technical Support Inspection currently scheduled for May/ June 1996.

Need to schedule Safety Assessment / Quality Verification Core Inspection prior to the end of this SALP period.

D.

Plant Support 1.

Current assessment Performance in the Plant Support functional area has been good in the area of Security and Fire Protection.

Slight improvement has been recently noted in the Radiation Protection ar ", however, continued significant licensee management attention is needed to address previously identified programmatic weaknesses and instill station-wide

" buy-in" to the RP program. The Emergency Preparedness program was exercised in December when a NOUE was declared for Hydrogen buildup in the Radwaste building.

2.

Assessment / Issues The current issues and specific assessments for each of the Plant Support areas is itemized below:

a.

Radiation Protection The Radiation Protection department has undergone extensive management and supervisory changes. Most of the changes have been effective in the initial establishment of different expectations and quality standards. However, it is too early to accurately I

assess the long term effectiveness of these changes.

]

9

Dresden PPR 9/95 - 3/96 Pre-Decisional 1

A programmatic weakness was highlighted in the occurrence of a transportation event which resulted in Escalated Enforcement action by the NRC.

Fn11owing this event the station took extensive action to establish clear responsibilities for radiation protection staff for various program elements.

Outage performance which started out well ended with the suspension of work activities in November 1995.

Emergent work and re-work continually hampered the station from meeting exposure estimate goals.

The Unit 2 outage work was re-started in January 1996, dose performance has improved and the ALARA organization has been aggressive in presenting exposure control concerns during work planning and scheduling meetings.

Problems with radioactive material control continue to plague the station. Radiologically Protection Area (RPA) lock-downs have baen implemented by Radiation Protection P.anagement.

During a recently conducted NRC tour of the radioactive waste areas, significant radiological control problems were identified.

Some of the concerns were known by radiation protection technicians and supervisors; however, no action was being taken to resolve the problems. This illustrated that continued effort is warranted in getting management's expectations down to the staff

level, b.

Security Security program performance was good and showed an improving trend.

The assessment of current issues in the security area are listed below:

The licensee and contractor self assessment efforts were well documented and is a program strength.

Initial security training was well defined in scops and was implemented in an effective manner.

Security force performance was good and was not effected by an increase in overtime and turnover. No adverse performance trend by the security force was noted.

i Seven issues were brought te the attention of Region III in October which involved maintaining adequate staffing levels, excessive overtime, visitor control issues, and management overview issues relating to monitoring performance.

One issue resulted in a failure to meet a security plan commitment.

Weaknesses were noted in security computer operations involving inventory control of card keys and timely submittal of fingerprint cards.

10 I

Dresden PPR 9/95 - 3/96 Pre-Decisional Reduction in the number of armed personnel, increased stringent performance standards, downsizing and prospects of future perronnel reductions have significantly increased job stress and resulted in a decline in employee attitudes.

However, security force performance remains good, c.

Fire Protection The overall fire protection program was assessed as good and improving.

There were numerous efforts to improve the program.

A review of emergency lighting 8-hour discharge surveillance i

performed in 1994 indicated that 26 emergency lights had not been adequately tested. This same problem was identified for 21 i

emergency lights for the 1995 surveillance.

The majority of the corrective actions have been completed. Additional emergency lighting proolems identified during plant tours included a backup emergency light that was not operable; a blocked emergency light; lamps that were dirty or had paint overspray; several emergency lighting lamps that were not properly aimed.

Good control of combustibles, including the control of transient combustibles in the plant was evident, few impairments required fire watches.

l Proactive management approach to the maintenance and improvement of fire protection equipment.

i Staff is experienced, knowledgeable, and proactive in dealing with plant problems, including Corporate Sopport with a training or tailgate session with the Electrical Maintenance staff for emergency lighting issues.

PVC use in the plant is not well controlled.

A thorough assessment was not performed for PVC use on CRD modifications as required for USFAR/ Fire Hazards Analysis commitment to minimize use of PVCS.

3.

Actions / Recommendations i

Continue with routine inspections in the fire protection, chemistry, i

emergency preparedness, and security area:;.

Inspection oversight in the radiological controls area has been increased to monitor performance improvements and should continue at an enhanced level.

ill.

Future Inspection Activities Engineering and Technical Support Inspection currently scheduled for i

May/ June 1996.

I 11

Dresden PPR 9/95 - 3/96 Pre-Decisional IV.

Attachments 1.

Plant Issues List 12

Updated 4/18/96 - PLH PLANT ISSUES UST DRESDEN lSALP l

DESCRIPTION l

CAUSE l

REF DATE l

l 10 BY 4/15/96 U-2 restarted (critical) 4/4/96 Lic.

ggg.

U-2 recirculation loops cross tie valve Per.

IR 96004 found about 10% open. License requires Error OPEN that valve is shut. Found during Startup l

system checklist re-vertftcation walkdowns. Evaluating significance and cause.

4/3/96 Stif Maint.

28 cond/cond booster pump 005 due to high Equip.

OPEN seal temperatures. Rework Item.

Problem 4/3/96 Lic.

Ops Operator entered locked high rad area Per.

IR 96004 without electronic dostmetery.

Error OPEN 3/31/96 Self Maint.

The 28 drywell equipment drain sump pump Equip.

RI obsv breaker tripped.' Found 5 Hp motors vice 3 Problem OPEN Hp. New motors installed D2R14.

3/31/96 Lic.

Ops & Pint. Radwaste supervisor tested positive for Failed ENS Call Support alcohol during "for cause" fitness-for-FFD test OPEN duty test. Individual dented onescorted access pending review.

3/Z7/96 Self Ops.

Operator inserted manual full scram on U-2 Per.

EMS Call when 1/2 scram alarm was received during Error OPEN I/C surveillance testing. U-2 still in refueling outage; all rods were already fully inserted.

SPf1 SCREENING NEETING 3/26/96 1

... -=

T 1

Updated 4/18/96 - PLH PLANT ISSUES UST DRESDEN j

l DATE l

10 SY l

SALp l

DESCRIPTION l

CAMSE l

REF l

3/25/96 Lic.

Maint.

One De personnel received notake 6uring Per.

OPENT work on U-2 drywell sump pump motor. De Error personnel not wait for RPs to take air sample.

3/18/96 Self Maint.

U-2/3 diesel fire pump inoperable due to Equip.

RI obsv i

engine coolant leak identified during Probles weekly maintenance run. (Operable 3/21) 3/15/95 MRC Maint. &

Discrepancies were identified in the U-2 Skill of IP. 96002 Ops.

Drywell during "clcse-out" walkdown.

Craft low UP.I Examples included missing screws fons EQ electrical boxes, MOV covers not secured, miscellaneous debris, and "Rockwoo1*

f fiberous insulation.

3/12/96 MRC Epg.

Unit 2 refuel outage was extended again to Mnget.

IR 95015 j

implament structural steel modifications Error.

URI to LPCI corner rooms. The licensee Apparent initially identified the failure to meet Y1olation i

Code rew irements in early 1994, but, did IR 96002 not plan on doing work untti NRC 1

questioned timeliness of corrective actions.

3/7/96 Self Eng. &

U-2/3 diesel fire pump inoperabic due to Mod.

IR 96002 Ops.

cold weather. When low area temperature Error Open alarm anner.ciates, temperature already i

below operable setpoint. Modtfication earlier in year changed area temperature f

required far operability. Alans setpoint not changed.

3/5/96 Lic.

Maint.

U-3 HPCI inoperable. Eng. determined that Equip.

EMS call i

during HPCI startup, the main stems line Problem i

drain valve leak had potential to become i

worse. Leak was associated with 2/27/96 t

HPCI leak. Restored next day.

5 2

1

o..

Updated 4/18/96 - PLH PLANT ISSUES LIST DRESDEN l

l 10 BY l

SALP DESCRIPTION l

CMf5E l

l OATE REF l

3/4/%

Lic.

Ops.

ACAD compressor inoperable. Identified at Per.

IR 96002 day 9 of a 7 day administrative (DATR)

Error Open LCO. Not TS or 10 CFR 50.44.

3/4/96 Self Maint.

2A CCSW pump packing leak.

Equip.

IR 96002 Problem Opec 3/4/96 Lic.

4s.

Oil found in U-2 EDG air box after 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Proced.

IR 96002 endurance run (expected). No procedure Problem Open requirement to drain air box.

Additional

)

questions of how much oil can accumulat?

in air box and is extended EDG run w/o some local operator action possible.

3/4/96 NRC Maint.

Multiple minor material deficiencies Skill of RI Obsv.

I identified after U-2 EDG maintenance.

Craft 3/3/96 MRC Ops.

Discrepancies between locked valve program Program IR 96002 DATE7 and UFSAR. Several U-2 containment Breakdown URI isolation valves not in prcgram.

Esc. Enf.

3/3/96 NRC Ops.

Multiple problems found on " completed" U-2 Program IR 96002 DATE7 startup checklists. Some valves out of Breakdown URI position. Licensee's initial review and Esc. Enf.

corrective actions ineffective. Second review had broader scope.

3/3/96 Self Ops. &

2C condensate and booster pump 4Kv breaker Per.

IR 96002 Maint.

not close. Breaker not properly " racked Error &

Open in."

Equip.

Problem 3/3/96 Self Maint.

Foreign material (rag) found in 2A CCS*J FME IR 96002 pump. Divers inspected intake bay; no Program Lv IV for other FME concerns. Diesel fire pump App 8 engine maintenance last week. Maintenance Crit XVI in vicinity of floor grating for CCSW intake bay. No CCSW suction screens.

i Updated 4/18/96 - PLH PLANT ISSUES LIST 1

DRESDEN 1

I Dur I

==

l sAtP I

usCun=

I C==

l ar i

3/3/96 Lic.

Ops.

Licensed operator signed a routine APRM Per.

RI Obsv survet11ance as complete and satisfactory Error Open when 6 of 8 channels were above limits.

2/29/96 Lic.

Eng.

Non-environmentally qualifted connectors. Proc IR 96002 on U-2 post-accident radiation monitor in Open drywell. Checking U-3 & Quad Cities.

i 1

2/29/96 Lic.

Maint.

Both trains of control room ventilation Equip.

IR 96002 i

degraded. A-train fan motor; B-train does Problems Open l

not have backup cooling water supply.

2/29/96 Lic.

Ops.

Incorrect cation resin added to tank in Per.

RI Obsv i

radwaste system. Wrong resin was Error I

delivered.

S 2/28/96 Lic.

Maint.

Problem with U-3 reactor recirculation MG Equip.

IR 96002 i

set ventilation dampers. The resulting Problem Open high temperature required about 355 rapid load drop.

2/27/96 Lic.

Ops.

New work request added to existing out-of-Per.

RI obsv service tegout. Isolation boundaries were Error inadequate for new work.

2/27/96 Lic.

Maint.

Pin-hole size leak in U-3 HPCI drain line Equip.

RI obsv to condenser. Found der 1rg rounds.

Problem 2/27/96 Self Maint.

U-2 RWCU system ieak (about 100 gal /hr)

Equip.

RI obsv into reactor building drain tank. Leak Problem was past an isolation valve.

2/27/96 Self Eng.

U-2.DC system tripped. Apparently due to Eqwfp.

IR 96002 spuricu:: high temperature signal from a Problem Open reactor recirculation loop therno-couple (T/C).

i Y

4

?'

E

t l

l t

l Updated 4/18/96 - PLH PLANT ISSUES t.IST l

DRESDEN t

l l

l l

DESCRIPTION l,CAUSE l

l ID BY SALP BATE REF 2/26/96 Lic.

Plant Inadequate compensatory actions after Per.

ENS Call

[

I Support recurity intrusion detection system becaee Error IR 96002 t

inoperable due to weather. Supervisor's Open j

error.

l 2/25/96 Lic.

Ops. &

Configuration control problems (tagging)

Per.

RI Obsv Eng.

during integrated leak rate testing (ILRT) Error 2/25/96 Lic.

Ops. &

Latch on fire door found taped over.

Per.

RI obsv Maint.

Error 2/24/96 Lic.

Ops.

Multiple self-check errors found in Per.

IR 96002 performance of Unit 3 CRD accumulator 005. Error Open 4

2/24/96 Self Eng.

U-2 SDC system tripped. Apparently due to Equip.

IR 96002 spurious high temperature signal from a Problem Open reactor recirculation loop T/C.

2/23/96 Self Eng.

3D CCSU pump discharge check valve leaking Equip.

IR 96002 back by resulting !n failure of keep fill Problem Ocen j

system. Foreign material (wood) in valve.

Discharge valve shut, pump 005, and T/S 30 day LCO entered.

2/23/96 Self Maint.

Unit 3 down power to fix material Equip.

IR 96002 i

condition problems, 3A FRV re-injection, Problem Open i

Lic.

3B Recirc pump low cli level, Replace 8 CRD SSPVs.

2/21/96 Lic.

Eng.

Discovery of control room HVAC toxic gas Design IR 96002 i

analyzer loss of power would prevent HVAC

Ope, operation in pressurization mode.

2/15/96 Lic.

Eng.

Possible EQ concern with heat shrink on Design Open drywell rad monitors. connectors in drywell penetration. U-2 connectors replaced and U-3 considered operable.

j 5

i

6 i

Updated 4/18/96 - PLH PLANT ISSUES LIST l,

DRESDEN I

I an 1

Sur I

uscurr 0.

I C sc I

i art ur 2/13/96 NRC Plant Resin spill in radwaste buildina that was Per.

IR 95015 Support approximately 1 year old identified by Error URI RIII HP inspector. Licensee had identified spill on survey map about 1 1

i year earlier.

2/13/96 Self Eng.

U-2 SDC system tripped. Apparently due to Equip.

IR 95015

)

spurious high temperature signal from a Rx Problem recirc loop T/C.

2/13/96 Self Ops.

Numerous Out of Service problems discussed Per.

IR 95015 at exit meeting.

Error re0V 2/11/96 Lic.

Maint.

Mechanic used a hardened steel center Per.

RI Obsv.

punch to remove a gasket from the Unit 2 Error reactor vessel flange. Gasket had already been removed, one inch gouge put in flange. QC inspector was present.

l 2/10/96 Self Ops.

Auxillary operator inadvertently started Per.

IR 95015 U-3 EDG during routine local control panel Error 1 amp check.

2/8/96 Lic.

Maint.

Safety bus fuse configuration out of Per.

RI Obsv.

service problem.

Error 2/5/96 NRC Ops.

Work control SRO approved a maintenance Per.

IR 35015 task (to open LPCI full flow test valve)

Error Nov that was not on the 005 clearance.

2/5/96 Self Maint.

U-2 experienced an unexpected 100 ostg Under IR 95015 discharge of all the HCU accumulators.

Invest.

IFI 2/5/96 Self Ops.

Well water system freezing problems due to Design RI obsv.

[

extreme cold weather. Plant operations t

were effected due to low CST level and inability to make more water.

]

Updated 4/18/96 - PLH PLANT ISSUES LIST DRESDEN l

l DATE l

FD BY l

l DESCRIPTION l

CAUSE l

REF l

SALP 2/3/96 Self

.Neint.

U-2 Groups II & III (RWCU & SDC)

Equip.

IR 95015 Isolations and SBGT initiation during Problem testing, not reportable. ABT failed to return power source due to failed contact.

2/2/96 Self Ops.

U-2 EDG tripped on engine high temperature Per.

IR 95015 due to slow response by non-licensed Error operator. Output breaker not close during test; diesel running unloaded without j

cooling water.

2/2/96 Self Maint.

Loss of ventilation on U-3 recirculation Equip.

IR 95015 motor generator (NG) sets when both Problem operating fans tripped. Power was rapidly reduced to about 60 percent. Damper Ifnka9e failure 7777 2/1/96 Lic.

Ops.

Non-Itcensed equfpment attendant left the Per.

IR 95015 U-2 drywell access deer unlocked. Drywell Error NOV is a locked high radiation area.

2/1/96 Self Eng.

Uninteruptible power supply (UPS) battery Design RI Obsv.

Iow temperature due to low Rx building ambient temperatures. Tencerature control problems with UPS room ar? longstanding.

1/30/96 Self Maint.

Contacts in instrument bus ABT shorted Per.

IR 95015 during maintenance causes loss of bus.

Error group II & III isolations and S3GT initiation.

1/27/96 Lic.

Ops.

Fuel bundle mis-oriented 90 deg. during Per.

IR 95015 D2R14. 3 people on bridge alssed it.

Error NCY Next crew identified error.

7

Updated 4/18/96 - PLH PLANT ISSUES LIST DRESDEN iO n I

sa, I

I 0m I

nscRien0N I

c.sc I

I 1/24/96 NRC Ops. &

Multiple examples of problems with 4Ky Per.

IR 95015 Maint.

breaker storage: breakers racked out &

Error NOV Lic.

not " chocked," no FME covers, non-EQ breaker put into safety related cubicle.

Licensee begins Level It investigation.

1/24/96 NRC Ops.

005

  • test cards" not placed on control Failure to IR 95015 switches of 2F and 2G drywell coolers.

Follow NOV Procedures 1/22/96 U-2 refueling outage activities Mang.

IR 95015 recommenced.

Decision 1/20/96 NRC Ops.

Failure to follow procedures when changing Failure to IR 95015 005 card and checklist for circuit Follow NOV breaker.

Procedures 1/18/96 NRC Ops.

2/3 emergercy diesel generator secondary Equip.

IR 9501:5 containment airlock door not suto close.

Problem Multiple examples identified over past several months by NRC.

1/17/a6 NRC Maint.

Unauthorized modification identified in Per.

IR 95015 Unit 3 torus catwalk area. Ventilation Error NCV ducting supported by csble, permanent supports disconnected.

1/16/96 Lic.

Ops.

Unit 3 matn generator exciter brushes Equip.

IR 95015 found discolored by operator, brushes Problem replaced on-line.

1/16/96 Self Maint.

U-2/3 diesel fire pump cracked discharge Equip.

RI Obsv.

flange identified during modification Problem testing.

1/16/96 Self Maint.

U-2 loss of pressure & flow indication of Equip.

RI Obsv.

2D CCSW purp during testing. Root cause Problem never identified.

8

s l

Updated 4/18/96 - PLH PLANT ISSUES LIST DRESDEN I

rE I

a.1 l-I nScRirrIO.

I c = Sc l

nr i

SaEP I

I/15/96 Self Maint.

Arcing on insulators of 138 Ky lines to Equip.

ENS call 11ft pump house (cooling lake). Licensee Problem de-entrgized line due to eminent loss of power.

1/13/96 Self Maint.

U-2 EDG failed to close during testieg.

Equip.

IR 96002 During cross-tie breaker repairs, an aux Problem LER 96001 contact was broken. Numerous additional URI i

4kV. problems identified during the undervoltage testing.

1/11/96 Self Maint.

U-2 EDG failed to close during testing.

Equip.

IR 96002 Cause was failed position indication Prom en URI l

Interlock from a cross-tie breaker. The U-2 EDG breaker would not have auto closed.

i 1/13/96 Self Maint.

Inadequate 005 boundary for maintenance Failure to IR 95015 activities and instrument air system.

Follow NOV Procd.

1/8/96 Self Maint.

Relay cover holddoun clip broken, cover Equip.

IR 95015 fell shorting contacts and caused a U-3 Problem half scram. A second relay cover was found with the bottom latch unattached.

Poor maintenance restoration practices.

1/7/96 Self Eng.

Feeder breaker (27-4) to non-safety Design IR 96002 related MCC for spent fuel pool cooling IFI demineralizers tripped due to bus overloading.

1/7/96 Self Maint.

U-3A feedwater regulator valve leaking. As Equip.

RI obsv.

of 2/27/96 multiple injections of sealant Problee F/U in used to repair leak.

IR 96002 1/5/96 Self Maint.

3A Service Water pump motor failed, cause Equip.

RI Obsv.

age-related and lack of cleaning.

Problem 9

Updated 4/18/96 - PlH PLANT ISSUES LIST f

DRESDEN l

I. RTE I

=n I

SatP I

l l

  • SCRi m 0M 1

C.Sc I

ur 12/27/95 NRC Maint.

U-3 58GT supply line to Rx building vent.

Per.

IR 95014 f

flange (behind 3A MG set) was afssing 4 Error bolts.

j 12/26/95 Self Maint.

U-2 rectre pump discharge isolation MOVs Equip.

RI obsv.

I (5A & B) funnd overheated.

Prables 12/22/95 Lic.

Feint.

U-2/3 d!esel fire pump stuffing box not Per.

RI Obsv.

installed. Shortly thereafter wrong oil Error i

used in gearbox.

I 12/21/95 NRC Maint.

U-l SFP. Poor housekeeping. ' Electrical Per.

IR 95014 extension cord & tools approx. 1 foot from Error edge of pool.

12/17/95 Self Eng.

Unusual Event declared due to hydrogen Equip.

IR 95014 l

1eak into Radwaste building. M2 from tank Problem farm to U-2 main generator.

12/15/95 Self Maint.

U-2 torus strainer plugging identified as Equip.

RI Obsv.

t part of post outage torus cleaning process Probles after LPCI run.

l 12/15/95 Lic.

Maint.

Undersized bolts on both U-2 Core Spray Ps.

RI obsv.

recirc. flow itne flanges.

Error 12/14/95 NRC Ops.

U-2 protected pathway tacorrectly posted Per.

IR 95104 as 2A SDC vice correct 28 SDC.

Error 12/14/95 NRC Maint.

U-2 FPC room - unauthorized temp. alt.

Per.

IR 95014 (ptpe supp3rts).

Error 12/14/95 NRC Maint.

Emergency lighting survetilance not done.

Per.

IR 95104 Error 12/14/95 MRC Maint.

U-2 (2A & 28) SDC pump flanges missing Equip.

IR 95014 bolts. Numerous other deficiencies Problem identified on RWCU, SDC, & SFP systems.

j 10

~.

Updated 4/18/96 - PLH PLANT ISSUE'3 LIST DRESDEN l

l 10 SY l

SALP l

DESCRIPTION l

CAUSE l

l DATE REF 12/11/95 Self Maint.

U-3 RWCU pressure control valve falied Equip.

IR 95014 open when shifting control to manual.

Problem RWCU relief valve opened. 5 in. Rx vessel level decrease. RWCU sys. auto isolated.

12/11,'E Self Plant 5 fire hydrants found frozen.

Equip.

RI Obsv.

Support Problem 11/29/95 Self Maint.

Both U-3 SFP pumps tripped. Root cause Equip.

IR 95014 was high pressure in demin-filter. Cause Problem URI of high pressure was valve leakage from U-2 SFP cooling system.

j 11/27/95 Lic.

Maint.

Licensee identified MCC 38-3 breaker trip Per.

IR 95014 l

setting not properly ::et.

Error 11/27/95 Self Maint.

Both U-2 SFP pumps tripped. Root cat.se Equip.

IR 95014 not determined. Poor initial Problem investigation.

11/17/95 Self Maint.

U-2 LPCI suction strainers in torus Equip.

RI obsv.

partially clogged after successful 8-hour Problem Bult. 95-02 test. Appeared to be corrosion particles.

Torus cleaned and LPCI re-tested satisfactorily.

11/17/95 Lic.

Eng.

CRD Scram Dischanje Volume gallery Design IR 95015 platforms did not meet UFSAR allowable LER 95022 stresses.

11/12/95 Self Msint.

While attempting to use the 8 train of Equip.

IR 95014 Offgas for the first time in 8 years, H2 Problem fire ignitee do to accumulation of resin fines upstream of recombiner.

Proc.

U-2 refueling outage activities stopped by 11/10/95

=;;;;

station sanagement to refocus the outage management effort.

11

I Updated 4/18/96 - PLH PLANT ISSUES UST DRESDEN i

I mu I=n I

sur I

ocsCR1rn.

I C.Sc l

l Rrr 11/9/95 NRC Maint.

Pipe hangers for two 18 in. offgas ifnes Per.

RI Obsv.

In U-2 low pressure heater bay not made Error up.

I1/6/95 U-3 startup.

11/2/95 Lic.

Ops.

Diver authorized in U-2 cire water pit Per.

RI Obsv.

with no 00S tags hung. No entry made.

Error 11/1/95 Lic.

Maint.

Wrong size impeller insts11ed on 2A LPCI Per.

RI Obsv.

l pump.

Error 10/31/95 Lic.

Eng.

Motor Control Center (NCC) feed breaker Per.

IR 95012 found with incorrect current trip Error IR 95014 setpoint.

LER 95020 URI & NCY ENS call 10/29/95 Self Maint.

U-3 manual trip due to loss of cfrculatfng Equip.

IR 95012 water (CW) system due to fish clogging Problem LER 95019 Intake screens for one CW pump and one traveling screen failure. At the time another CW pump was out of service and the plant was relying on the remaining two.

10/24/95 NRC "aint.

High vibrations on CRD system.

Equip.

IR 95012 Problem 10/20/95 Lic.

Eng.

U-2 scram discharge instrument volume Design IR 95012 found susceptible to single failure.

LER 95019 Appeared to be the result of error made in NCY modification change in mid 1980's. U-3 URI not affected.

ENS call 10/13/95 Lic.

Maint.

N.,n-like-for-like washer installed in 4kV Per.

IR 95012 breaker not documented in work package.

Error

.~

~

Updated 4/18/96 - PLH Pt.ANTISSUES UST DRESDEN i

I

=n I

S*P 1

.EsCum=

I c=st I

art I

=Er 10/12/95 Self Maint.

U-3 HPCI fnoperable Joe to exhaust pot Proc.

IR 95012 high level alam. Caused by procedure not LER 95018 requiring dralning cf drain pot prior to slow start testing.

10/10/95 Lic.

Maint.

Foor communication resulted in CC5W Per.

IR 95012 section bay level flo-t beleg removed.

Error 10/10/95

Lic, Maint.

Inadequate PMT on CRD D-5 resulted in non-Per.

IR 95012 cited violation. Neutral leads were Error NCY swapped and not Identiffed untii next surveillance test.

10/7/9.5 Self Maint.

Failure to perfom post-maintenance test Per.

IR 95312 (motor rotation check) on shutdown cooling Error NOV MOV resulted in valve operator damage.

10/7/95 U-3 plant startuo.

10/1/95 Seir Maint.

U-3 generator exciter breaker secondary Per.

IR Obsv.

contacts damaged during breaker Error installation. Cause was failure to follow ma1at? nance procedures.

9/31/95

- : =:

Steve Perry Comed YP-BWR, assumed dettes

-

as Dresden 51te YP. Tom Joyce started a 6 month rotation with IMPO.

9/28/95 Self Maint.

U-3 plant trip due to loss of generator Equip.

IR 95010 excitation. The cause was a failed Problem LER 95017 resister in excitation circuit.

EMS cal!

9/20/95 Lfe.

Maint.

Wrong valve stroked by VOTES test Per.

RI obsv.

personnel at local control station.

Error Fallure to vertfy through self-check proper valve label prior to operation.

9/16/95

===:

U-3 startup.

=:=

13

Updated 4/18/96 - PLM PLANT ISSUES UST DRESDEN I

I I

I OcsCRmi.

I C sc 1 I

1. n art sa.

nr 9/15/95 Lic.

Maint.

A sys. eng. opewd a breaker for a U-2 Per.

"I Obsv.

l transformer and protective relaying Error circuit without operations knowledge or approval.

9/12/95 Self Maint.

Operations initiated U-3 shutdown due to Equip.

IR 95010 HPCI drain problems.

Problem 9/11/95 Self Maint.

U-2 HPCI Inoperable. Exhavst drain pot Equip.

IR 95010 failed to properly drain fr m previous Problee LER 95016 survelliance. Cause identitled as relay / switch failure.

9/9/95 Self Maint.

Increasing temperature trend ca 3D ERY Equip.

IR 95010 talipipe.

Prsbien 9/7/95 Self Maint.

U-3 startup. 3A RWCU pump degraded - low Equip.

IR 95010 pressure flow.

Problem 9/5/95 Self Ops.

Group V isolation received while restering Per.

IR 95010 a U-3 Iseletion Condenser to standoy due Error LER 9'GIs to inadequately filling condenser.

hCV 8/95 Lic.

Plant Shipped contaminated material (RWCU Per.

le 95011 Support piping) offsite above DOT limits.

Error IR S5010 Contaminated circuit breaker shipped offstte to non-licensed facility.

i 14

a l

PREDECISIONAL PLANT:

Dresden, Units 2 and 3, March 1996 i

AE00 CONCLUSIONS:

l A review of information relating to plant operation since January 1995 revealed some indications of overall improvement in safety perfomance, which i

is rupported by a reduction in the number of reportable events. However, some of the same characteristic problems the licensee experienced for the last several years continue to occur. More than half of the reported events resulted from the recent discovery of past deficiencies, some of which occurred as early as initial operation. The licensee response to these and other recent events was usually thorough, although a small number of events still received narrowly focused corrective actions. There is some evidence that events caused by equipment failures and weak administrative control problems still exist, although the numbers of these events has decreased.

Recent NRC inspection reports state that licensee performance is adequate and l

improving. Then reports particularly emphasize continued improvement in j

operator attentiveness and control of plant evolutions.

i

$ome Indication of Improvement j

During this review period, the number of LERs submitted by the Dresden site dropped to approximately the industry average, LER quality improved, and the LERs issued were primarily the result cf past problems. With one exception, the LCRg indicate thorough investigation and correction of resorted events.

AE00's review did not identify sufficient data to determine wiether prob 1was in the areas of maintenance, procedure compliance,-and Technical Specification (TS) interpretation addressed in previous reviews have been corrected.

Recent NRC inspection reports generally have had favorable findin plant activities, and especially control room operations. gs in the area of L

i The licensee continues to identify problems from past deficient l.

practices which require current LER reports. During the second half of 1995, less than one third of reported events involved current plant i

L activities, either at power or shutdown.

(LERs237/95-16,249/9514,15,17,19)

In the areas of operations, maintenance, and engineering, one inspection report assesseent evaluated licensee performance as ' adequate and improving.' A subsequent inspection report classified operations as

" good,' stating that management made conservative operational decisions and that professionalism in the control room was improving.

(IR9509;IR9510)

An inspection report that covered the period when various Unit 3 startup 4

attempts were conducted, summarized licensee perfomance as ' good' with continued improvements in operator attentiveness and the control of plant evolutions.

(IR9510) j

y ee.is.-*

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+-

PREDECISIONAL PR09LEMS:

Equipment Failures continue The licensee continued to experience diverse equipment failures.

Examples ares j

While performing an instrument surveillance, the licensee identified a Yarway reactor water level switch failura. This failure is a continuing indication of an unfavorable trend histcry on these switches. The licensee has documented numerous similar events and the continued out-of tolerance events have been the subject of significant station attention.

Extensive plant action to resolve the rituation is already in progress.

(LER249/9521)

The licensee conservatively reduced power and initiated a manual scram 1

when the circulating water traveling screens became sufficiently plugged with debris to cause damage to the screens and jeopardize operation of circulation water pumps. Many equipment problems were identified during the scram, including the failure of the extraction bypas: valves to open on a turbine trip, a reactor water cleanup (RWCU) system seal leak, failure of a RWCU motor ourated valve to close, failure of the reactor recirculation pumps to fuily run back, a control rod drive system leak, and two tri)s of one shutdtwn cooling pump while being placed in service.

('ER249/9519) i The licensee experienced an automatic reactor scram due to a generator trip caused by a failed resistor in the voltage regulator.

During plant l

recovery actions, a containment isolation occurred from reactor low l

water level because a relief valve in the RWCU system lifted causing an unexpected loss of inventory. The licensee determines that the relief t

valve setpoint was incorrectly calculated.

(LER249/95-17) i The high pressure coolant injection (HPCI) system failed a startup surveillance test due to a high level alarm on the exhaust drain pot which would not clear. The Itcensee did not complete the surveillance within the TS required time and subsequently shut down the plant to investigate. A day later the alars unexpectedl The licensee 1

suspected alarm relay switch failure; however, y cleared.

extensive troubleshooting efforts failed to repeat the failures.

(LER249/9516)

Administrative Control Problems j

The licensee still has problems caused by weak administrative control, although the incidence of reported events was reduced during recent months.

Some of these conditions existed from initial operation, j

The licensee initiated a manual HPCI turbine trip during a monthly 2-

PREDECISIONAL surveillance test due to high level in the exhaust drain pot. Water, built up in the drain pot from previous turbine operation, was allowed to remain without draining it prier to HPCI operation.

This water, in addition to the water accumulated during turbine wannup for testing, resulted in a valid drain pot high level condition. The procedure did not adequately prepare the HPCI system for testing.

(LER249/9518)

All torus to drywell vacuum breakers unexpectedly opened as designed while operators were relieving negative pressure in the torus. The operators did not know the actual opening setpoint of the vacuum breakers, and the operating procedure lacked a warning that the vacuum breakers could open while relieving negative torus pressure.

(LER 249/9514)-

Two spurious isolation condenser (!C) isolations were caused by a high flow signal during lineup of the FC system. The licensee did not have sufficient procedural controls la place to ensure proper filling and venting of the siping configuration. The licensee determined that the root cause of tiis event was that corrective actions from previous similar events did tot ensure that the piping was completely vented.

(LER249/9515)

While in the refueling mode, licensed operations personnel discovered that the reactor recirculation pop speed mismatch vartfication was riot being performed as required by T5. Operations procedures failed to reqLire this verification while in the shutdown or refueling modes.

The licensee determined that this TS requirement had never been performed while in shutdown or refueling undes at either Unit 2 or Unit 3.

(LER 249/9513)

A technician inadvertently caused a channel 'B" containment isolation signal during reactor protection system maintenance which resulted in a full isolation.

Channel 'A' was already deenergized for maintenance.

No formal process existed to document plant conditions assumed during maintenance planning. The licensee stated that recent improvements in management methods were not effective in controlling the authorization and performance of maintenance activities. The licensee subsequently changed the work approval process.

(LER237/95-16)

The licensee stopped work on the Unit 2 refueling outage in November 1995 in order to improve planning allocation and management of resources. Work restarted in January 1996, and is currently in progress.

(Mrs 3 95 0169, 0173)-

past problem Identification More than half of'the reported events resulted from past deficiencies, some from as early as initial plant operation. Most of these problems were discovered during the cour'3 of routine operations and maintenance. There is 3

.m.,_,__,_,_______.

PREDECISIONAL no evidence of an overall plant initiative to identify and resolve these deficiencies.

Examples are:

4 The Itcensee determined that the core thermal power calculation at both units did not correctly account for recirculation pump seal purge flow.

A 1974 modification added the seal purge flow, and the safety eviluation performed at that time was deficient.

(LER 237/95 21)

Technicians perforring a surveillance on the Unit 2 scram discharge levs! st eers identified a discrepancy between the volume (SDV)dthepn. stat computer nomenclature. The plant subsequently procedure an determined that a 16:;3 spesign modification contained an error which prevented the SDV logic from meeting single failure criteria.

(LER 237/9519)

While evaluating a proposed shielding modification, Unit 3 personnel determined the SDV galleries did not meet design allowable stresses. An error in the design occurred during initial construction, and a modification in tl1e early 1980s failed to identify or consider the discrepancy.

(LER249/95-22) e 4

RfCION 111 ptANTS WITH AT LEAST TWICE THE NATIONAL AVERAGE OF L Q1 2

I Dresden 3 - 17 LERs l

l The major groups of personnel involved in these events were engineering personnel 41%

355. Major contributin(g fa)ctors were inadequate training (415) l an planning (415). Task behaviors were primari y know No single work type appears dominant in <the LER errors. Cognitive errors contributing to the events included misinterpretation of infomation (5g5) and i

falseassumptionaboutconditions(41%). Action errors were primarily those of wrong action (71%).

LaSalle 2 - 15 LERs i

No single group of personnel appeared dominant in these events. Major contributing factors were procedures not followed (475), procedures inadequate (40%),andmanagementandplanning(33%). Task behaviors were primarily rule-based (66%). Work types were primarily operations (33%) and testing Cognitive errors contributing to the events included false assumption (33%).

about conditions (4 M) and attention deficit (33%). Action errors were primarily those of wrong action (66%) and omission (4M).

i l

Zion 1 - 22 LERs The major groups of personnel involved in these events were engineering personnel (45%) and mechanical maintenance personnel (23%). Najor contributing factors were management and planning (5M) and inadequate procedures (36%). Task behaviors were primarily knowledge-based (775). Work types were primarily testing and engineering Cognitive errors l

contributing to the events inc(32%)d false assumption (23%).

lude about conditions those of omission (55%) and wrong action )36%). Action and misinterpretation of infomation (32%

ily I

(

Zion 2 - 18 LERs The major group of personnel involved in these events was engineering personnel (5M). Major contributing factors were management and planning knowledge-based (66%) procedures (28%).No single work type appeared domin (56%) and inadequate Task behaviors were primarily l

Cognitive errors contributing to the events were primarily false assumption l

about conditlons (5M). Actson errors were primarily those of omission (615).

l

)

l l

1-

LER DATA ENTRY SHEET Phu amme: (u marked se LER and talected from sureuses medon M ick hat)

P Docka number:(u marted so LIR)

Contribudes henors:

hafonnsdom unavailable Event due:(u anarked am LER) imedeguese tralalag I'6'f8Per tralaing 12R mm6er:(as marked se LDt) ao retning procedere not followed Event tiene:

procedire landequam back of procedure haue dem:Osave blank) procedere wrong human system lanrhee Poeur kveh work environmem

, ark 3 h

)(icro Sche:Geave klad) wrjassa.-nm.deadan work schedule Syssaminvolved:Geave blank) work lead management and planning Persommel category:

ablAsamover Ecemed operser notrlicemed operawr Plam ident15ed root came:

instrument and control (as marked on IIR by coder) electncal mechanical Ahernadve root samme: (coder must spec!fy here.)

engmeer radiological prosecnon chemistry security saber Week type:

Corrective Actions:

operuang (es marbd by coder) sestmg cahbration Type of event:

trout 4eshootmg Oesw M )

sumennaco engineenng Cognitin erron procedure h:',

amenian esteit asfuebas r.4 informadan '

modincanon Istgesing other hise assumpoon Poorjudgennent Tant bebevlor:

boredoes andB elhar rule

&mowledge PericameleNect ende:

Oceve blank)

Action erron ansvannide Reponabihry codes:

untunely action (as marted on LER) omission out of sequence Penoonel nedviry codes:

wrong acoca Geave blank)

AppenexE E 10 HF1s User Manual

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.h January 30,1996 4

JSP 1 tr. #96 0006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Dresden Station Units 1,2 and 3 Dresden Station Improvement Plans and Progress NRC Docket Nos. 50 010,50 237, and 50 249

Reference:

J.S. Perry letter to USNRC dated November 14,1995 on Dresden Station Improvement Plans and Progress T.P. Joyce letter to USNRC dated August 1,1995 on Dresden Station Improvement Plans and Progress During 1995, Comed continued implementation of the Dresden Plan and initiated several additional efforts to improve the performance of Dresden Station. Dese efforts were coordinated through the 1995 Focus Area plans, which covered Management and Leadership, Human Performance, Material Condition, Work Management, Performance Monitoring, and Radiation Protection. In each of these aren, specific performance targets to be achieved by the end of 1995 were established.

Overall, Dresden Statiori achieved approximately 75% of these 1995 targets, but some significant targets were not achieved. In particular, there was only a minor reduction in the backlog of non outage corrective maintenance, ne outage of both units during the summer and fall months precluded the er.ercising of the new work management systems. Thus the site's ability to successfully execute an adequate number of work requests on a weekly basis remains a problem.

. On the other hana, the Operations Staff has dramatically improved performance. nat performance has besn sustained over many months. The materiel condition of several important areas has been significre.dy improved. Many Radiation Protection Improvements have been realized and the backlog of overdue corrective tctions has been eliminated.

- % ?oG.ofa T Ofty,

i KEY RESULTS DURING THE LAST QUARTER OF 1995 AND FOR THE YEAR

' INCLUDED:

Materiel Condition i

improvements in the plant's materiel condition were accomplished, including i

substantial reductions in operator workarounds and control room deficiencies, and the accomplishment of major upgrades, repairs, or overhauls to the feedwater and high pressure coolant injection systems, replacement of reactor water clean up system piping, repairs to the core shroud, and unplugging of the bottom head drain. The Unit 3 outage caused by failure of turbine blades in May 1995 was utilized to accelerate the schedule for many material condition improvements, and Unit 3 operating performance since startup in November 1995 has reflected an improved materiel condition. At the same time, despite some reductions, targets for overall reduction in the corrective i

maintenance backlog were not met, and too many preventive maintenance items ran overdue. We recognize that the overall condition of the units must continue to improve.

i Materiel condition is our primuy focus for 1996, Aside from implementing specific

(

major upgrades and reducing backlogs, major etTort will be devoted to: managing l

work so that it can be completed more efficiently; reducing rework; and improving the j

capability of Engineering to solve problems so that they do not recur.- During 1995 l

we implemented several upgrades to out on-line work management processes, l

upgraded our system engineering program, and began implementing a two phased l

program to improve the skill of our personnel. Now that Unit 3 is operating we have j

been able to exercise these programs and identify weak areas. Correcting these weaknesses is our current challenge.

i l

With respect to outage work,in November w6 stood down outage work on Unit 2 to replan it using more advanced planning techniques to achieve greater efficienco and l

better coordination of our work efforts. We have restarted Unit 2 outage work using the replanned outage schedule, which contemplates completion of the outage by February 25,1996. Achievement of this schedule is a major test of our ability to l

successfully plan and complete work. We intend to critiquc our performance and implement lessons learned during planning and execution of the Unit 3 refueling 4

outage later in 1996.

Operations l

The Dresden units were shutdown during much of 1995. During this period, j

Orations management took steps to improve operator performance and proirssionalism, including on shift coaching and critiques, more stringent performance evaluations, and stronger reinforcement of accountability for meeting performance 1-expectation. Our own management observttions, those of outside parties, and i

1 1

1

cbjective indicators cf puf:rmance indicate that these steps were successful. nese improvements were reflected in the error free startup of Unit 3 and operators' decision to manually scram the unit, following preplanned critada, in late October in the face of cooling water intake problems.

Our challenge in Operations is to successfully restart Unit 2 in the same conservative and controlled mannu, and to demonstrate successful dual unit operation. The resolution of problems related to controlling work on Out Of Service equipment is a specific challenge that is receiving prionty attention.

Workforce Traininn and Oualirv We have continued to pursue the two phased training program upgrades for site personnel. Phase One, providing upgraded fundamentals retraining and testing to ensure workforce competence for routine tasks has begun and is expected to be completed by the end of April 1996, except for Engineering personnel, who will finish in May 1996.

Phase Two covers improvements to ongoing technical training programs based on benchmarking of strong programs at other nuclear facilities. Benchmarking and program development are progressing and the upgraded programs will be phased into use during the second and third quarters of 1996. The upgraded programs provide for increased specialization of the workforce to improve proficiency on infrequently performed and technically complex tasks. De programs will require workforce members to pass tests to remain qualified to perform work.

Currently the amount of rework at Dresden is high (910%). This training effort is aimed at reducing the rework.

Radiation Protection Our Radiation Protection program achieved a number of successes in 1995 We achieved substantial reduction in the avnage daily non outage exposure dropping it from.732 person rem per day to.368 person-rem per day. Solid radwaste was

^

reduced fuera 1580 cubic feet per month to less than 500 cubic feet per month.

Despite exposure cmtrol measures, the site exposure goal of 867 person rem was exceeded by 9.2 person rem due to forced outages, rework, and work scope additions.

The overall high exposure levels wwe also due to the amount and nature of major material condition improvement efforts.

De control of radioactive materials continues to be a challenge. We continue to vigorously investigate es h new occurrence and are reevaluating the effectiveness of our earlier corrective e cus to determine what funher steps must be taken.

3

\\

Plans for 1996 During 1996, we intend to complete implementation of the Dresden Plan. This will be accomplished through our 1996 Businen Plan, which will be Anallaed shortly. Udike our previous plans, the Business Plan allocates specinc resources to our improvaraent efforts. It includes objective performance targets and measures by which to gauge whether improvement is occurring. These measures will be monitored regulaly during formal perfonnance review meetings.

Like the other Comed stations, Dresden has identified a number of actions and performance targets to he achieved by April 30,1996. Achievement of these targets, along with execution of the temninder of the Unit 2 outage and startup and continued successful operation of Unit 3, will be the most important measure of our progress in the coming months. These targets are described in Auschment 2. In May 1996 I will provide you with an undate on our performance in these areas.

Please ca.!! me or Frank Spangenberg, c,ur Regulatory Assurance Manager, if you would like to discuss these matters funhet.

Very Truly Youts, 2

tephen Perry Vice Presidant, BWR Operations cc:

Mr. James Taylor Mr. William Russell Mr. Hub Miller Mr. Pat Hiland

- Mr. John Stang Mr. Clark Vandemiet File: Numerical 3

ATTAcineNT 1 i

His Attachment describu the final 1995 results achieved in attaining each of the performance l

targets set in connection with Diesden's 1995 Focus Area Plans, which are the 1995 1mplementing plans for the 1994 96 Druden Plan. Dese targets were listed in our August 1, i

1995 quarterly status report to the NRC on implementation of the Druden Plan and i

associated Focus Aru Plans. De targets include both ongoing performance measures and i

goals for the completion of particular tasks.

j De 1995 Focus Areas contained 33 targets which had numerical goals assigned. Of thne 33 objective measurements,20 were successfully achieved.

i MANAGEMENT AND LEADERSHIP 3

l Target:

Complete assessments of management personnel having supervisory j

raponsibility to evaluate management assignments and capabilities.

1 j

Status:

Dese assessments were initiated in September 1995. They were completed for site senior management and department heads in the last l

quarter. De remaining site supervisory personnel.will be evaluated in 1996. Identified development needs and actions to addrus those nuds will be incorporated into the 1996 performance evaluation process for i

each individual.

Target:

Complete categorization of site management employees by performance level and definition of remediation plans for those identified as low performers.

i Status:

his procees was begun on September 1,1995 and was completed in December 1995. Individuals evaluated as low performers were placed on an accelerated PPR program. Over half were subsequently evaluated i

as acceptable. The others were reassigned or left the Company. A similar procus will be used during 1996 to determine whether performance problems have been remediated and what further steps l

should be taken.

t Overall effectivenus of Dresden management and leadership will be measured by success in i

achieving the performance targets described below in the other Focus Areas, i

i i

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l ATTACEMENT 1 l

HUMAN PERFORMANCE nis Focus Area encompasses:

Procedure Adequacy addresses procedural int Tquacies and their causes Training addresses training effectiveness and content Personnel Errors addresses procedure adherence, standards and accountability Industrial Safety addresses reduction ofimpe&ments to safe work performance and improvement of worker knowledge Procedurt Adequacy Target:

Complete review of 250 Dresden Administrative Procedures (DAPs) for clarity, consistency, and usei Iness.

Status:

Complete. 250 DAPs were reviewed, resulting in a deletion of 66 DAPs and revision of 100 others.

Target:

Reduce the number of procedures iri revision status to fewer than 500 (revisions have been prioritized based on plant needs). Revised goal of 300 by 12/31/95.

Status:

The number of procedures in revision status (including administrative, operating, maintenance, engineering and other categories of site procedures) has 'ocen reduced from over 900 in June 1995 to 486 in September,1995 to 287 through Daconber.

Target:

Reduce average permanent procedure revision tumaround time from approximately $0 days ir Januny 1995 to less than 30 days (interim-procedure changes are now being accomplished in approximately two hours to support field work).

Statur.

De average permanent procedure revision turnaround time has been reduced to 24 and 18 days, respectively, &aring September and December 1995.

Target:

Reduce temporary procedure changes to fewer than 50 per month (these changes are initiated when procedures are inadequate to support Status:

he temporary procedure change process has been eliminated and has bee replaced by the Interim Procedure Gange process, which permits 2 of 12

ATTAcmert 1 procedure changes needed to support work to be accomplished within two hours ne number ofinterim procedure changes per month has been 185 and 257, rapectively, during September and December 1995.

A 75% increase in the use of the Interim Procedure procus has been noted betwun the third and fourth quarters of 1995. nose changes have been due to both procedure problems and other causes, such as preparation for the new upgraded Technical Specifications and changes to accommodate plant modifications.

Training Target:

Complete development of refresher training on fundamentals for those disciplines included in the accredited maintenance and technical training programs and begin implementation of training and associated testing by October 1995. Achieve a 95% test pass rate following the first remedial training session, 9:

Status:

Phase One Refresher Training courses have bun dweloped and training has been initiated in all areas. As of December, there has bun an overall failure rate of 13%, with a 100% remediation pass rate.

Target:

Complete benchmarking of ongoing technical training programs against industry leaders and begin development of revised training.

Status:

To date, benchmarking efforts have been conducted by surveys, electronic information exchanges, and visits to the Brur.; wick, Clinton, Duane Amold, Susquehanna, Lim ^ rich, Comanche Peak, Surrey, and

. North Anna nuclear stations. Benchmarking will ccatinue throughout the training development Phase Two training will be delivered in segments, starting in the Second Quarter 1996 (July 1996 for Engineering and Rad. Protection).

Target:-

Complete 350 senior and line management evaluations of classroom training. Individual coaching will be provided to line managers who do not provide specific suggestions for improvement in at least 70% of their evaluations.

Status:

nrough the end of December 1995, Senior and Line Managers have completed 487 formal training assessments, exceeding the year end goal of 350 assessments. Of the 487,66% of the assessments contained -

suggestions which the Training Depart ment determined would improve the training or instructor performance which did not meet the goal.

3 of 12

MTACIDENT 1 Target:

Complete 220 line management evaluations of training related job performance in the field.

Status:

nrough the end of December, Senior and Line Managers have completed 479 Evaluations of training related job performance in the field, already exceeding the year end goal of 220 evaluations.

Personnel Erron (ine.luding procedure adherence)

Taryt:

Achieve four or fewer LERs caused by personnel error during July -

December 1993.

States:

One personnel error LER was recorded after July,1995.

Target:

Achieve a declining trend in the number of procedure adherence Performance Improvement Forms (pes) with a goal of fewer than 20 per month while maintaining the site overall PF generation goal of 350 per month.

Status:

ne number of procedure adherence PFs was 106 for October,81 for November, and 47 for December,1995. Although there was a distinct downward trend in procedural adherence PF's, the goal was not achieved.

Industrial Safety Terret:

Reduce the Industrial Safety Accident Rate from an average of 2.4 in 1994 to 0.9 or less in 1995, ne ISAR rate for June 1995 was 1.4.

Status:

During the fourth quarter of 1995 the ISAR dropped below the 0.9 goal to 0.8. However, two ISAR accidents in December brought the rate back up to 1.0. Thaefore, the 1995 ISAR year end total goal of 1.0 was not met.

Target:

Reduce the number of industrial safety related injuries (which includes minor first aid), froan 73 in 1994 to 55 in 1995.

Status:

There were a total of 8 injuries in the fourth quarter of 1995, ne 1995 year end total for industrial safety r^1sted injuries was 50. This goal was met.

4 of 12

i i

l-ATTAcacar? 1 4

MATERIEL CONDITION i

i Taract:

Reduce operator work arounds from over 80 in January 1995 to fewer than or equal to 42, Status:

As of December 31,1995, the number of operator work arounds has been reduced to 38. Resolved 16 and identified 5 additional operator j

wod arounds. We have met our 1995 goal. More than 76 operator workarounds were corrected in 1995.

l Target:

Reduce main control room deficiencies from 120 in January 1995 to

[

fewer than or equal to 40 by the and of the cunent Unit 2 refueling outage.

l Status:

Completed 128 control room work requests in the fourth quarter and 31 l

remain which muts the goal. A new goal of 35 control room deficiencies by the end of 1995 was established in November 1995 when the goal of 40 was reached. De new goal of 35 control room deficiencies was met. Well over 500 control room work requests were completed in 1995.

Target:

Reduce the corrective maintenance work backlog to less than 750.

Status:

As of December 31,1995, the corrective maintenance backlog was i

1049. De focus duiing the extension of the Unit 2 refuel outage has j

ban on outage work requests. As a consequence, the backlog of non.

i outage corrective work requests increased and the goal was not met..

Target:

_ Achieve a declining trend in unplanned LCOs, with a goal of fewer than 3 unplanned LCO days per week.

p i

Status:

The year ended with a December weekly averaged of 13.8 LCOOATR days per week, a quarterly average of 10.2 LCOSATR days per week j

and a yearly average of 12.3 LCOSATR days per wwk. Overall a declin:ns tred was schieved but the goal was not met. The Plant Engineering Superintendent is placing significant emphasis on resolving LCOOATRs in a timely manner, i

Target:

Establish a System Review Team for identification oflatent materiel problems and indeterminate conditions on key systems and complete i

review of three pilot system

['

Status:

De system Review Teams, each consisting of a Team Leader tQgrted by the Dresden System Manager and expe'rienced outside engineers, 5 of 12 i

l

. _... _ _.... _ _ _ _ _ - -. _ _ _. _...., _ _ _.. _. _ - - ~, _. ~., _ _ _,. - -,.. _ _., -. _ _ _ _., _. _. _ _ _ - -

ATTACEMENT 1

'ere formed in August,1995. Five (5) systems were selected for

.< view in the phase 1 pilot process. Phase I completed at the end of November,1995 and process improvements were incorporated into a streamlined Phase 2 effort Twenty one (21) systems will be reviewed in Phase 2, which is scheduled to complete by April 30,1996. 'Ihe Phase 1 results identified about seventy (70) latent problem observations which will be evaluated for implementation action by Stat on management. Reviews of the remaining systems will be scheduled by April 30,1996.

Target:

Complete materisi condition upgrades described in the April 24,1995 letter to NRC.

Status:

Sixty three percuit of the upgrades are completed and the others are on track for completion by the end of the current Unit 2 refueling outage.

Three HPCI MOVs will be tested in accordance with Generic Letter 89 10 after the Unit 2 startup.

Target:

Reduce non outage temporary alterations to fewer than 10.

Status:

The number of temporary alterations hu been reduced to 39. We targeted having fewer than 10 non outage temporary alterations by the end of D2R14 wbch was originally scheduled for completion in 1995.

We are on a schedule to rueet the goal at the end of D2R14.

Target:

Issue design packages for the 53 plant modifications approved in June 1995 for the upcoming Unit 3 refueling outage by October 1995 (outage to begin in the spring of 1996).

Status:

Design packages for all of the 53 plant modifications initially approved for and still included in,the next Unit 3 refueling outage have been issued. Seventeen addnional designs have been requested and issued by December 1995. One design added in mid December will be issued in January 1996.

Target:

Achieve unavailshinity levels equal to or better than INPO goals for key safety systems (Diesel Generators, High Pressure Coolant Injection, Isolation Condenser, low Pressure Coolant Injection, and Shutdown Cooling) during Ibe last six months of 1995. These goals were set for Dresden based on INPO industry average performance levels.

Status:

Unit 2 and Unit 3 High Pressure Systems (HPC1/ISOCOND) had unavailability levels.4% and 1.2% respectively which wers better than 6 of 12

O ATTAcENntT 1 she industry average of 1.3%. Unit 2 and Unit 3 Low Pressure Systems (LCI/ Shutdown Cooling) unavailability levels 1.6% and 0%

respectively. The industry average was.8%. Emergency Power unavailability was 1.3% compared to the industry average of 1.1%.

With the exception of Unit 3 HPCI, these systems had unavailability levels better than the industry average since the beginning of July 1995.

However, the Unit 3 High Pressure Systems unavailability for all of 1995 was better than the industry average.

Target:

Complete vacuuming the Unit I fuel / transfer pool and structural inspection of the pools, racks and fuel.

Status:

The structural inspection of the Unit I fuel / transfer pool, transfer tunnel, fuel, and racks is complete. The inspection videotape was reviewed by Sargent and Lundy, and no significant deficiencies were identified.

Cleaning operations including fuel pool and transfer tunnel vacuuming is complete. During the first quarter of 1996, it is planned to load, ship and dispose of the waste material which is stored temporarily in the transfer pool.

1 4

7 of 12

ATTACEMENT 1 WORK MANAGEMENT Target:

Improve trend of placing completed non outage work packages in the hands of the working groups before work execution, with a goal of having 100% of preschsduled packages to the working group 2 weeks before scheduled execution.

Status:

During December 1995,98% of wmpleted non-outage work packages were in the hands of the work groups two weeks before work execution.

An average on time delivery rate of 99% was achieved throughout the founh quaner.

Target:

Improve trend in on time work starts, with a goal of 35% of non outage work stans occurring within I hour of the published schedule.

Status:

Currently, starts and finishes within one day are measured. During December 1995,93% of non-outage work stans occurred within one day of the published schedule, and work was finished within one day of the published schedule 30% of the time (the ability to repon work stans within one hour is available, but will not be used until proficiency is demonstrated in starting / completing work within one shiit of the approved schedule). Failure to achieve target performan:e is primarily attributable to uneven levels of understanding of the wonk control process and teamwork among those involved in planning as,9 executing work. Initiatives are included in the 1996 Business Plan to devc!op improved teamwork while also educating key players to ensure fuit understanding and utilizatior of the process is achievable.

Target:

Achieve a declining trend in the number of work packages retumed from the work groups for revision, with a goal of fewer than 20%

returned.

Status:

he percentage of work packages retumed for revision dropped from 12% in September 1995 to 6.6% in December 1995. Our goal is being revised to fewer than 3% of work packages retumed from the work soups.

Target:

Complete development and begin tracking a performance measure for rate of rework.

Status:

Performance indicators to identify rates of rework and repeat work have been developed and been tracked since the beginning of September 1995. Rework ir defined as failure to pars a Post Maintenance Test (PMT) or having to reperform a significant ponion of the job prior to 8 of 12 1

ATTACIDGNT 1 PMT. Repeat work is defined as performance of the same maintenance on a component within six months after a job has been completed. A goal ofless than 3% combined rework and repeat work has been established, ne recorded rate in September 1995 was 3.5%; the rate in October was 9.5%. Problems in rework and repeat work identification and recording have led to recorded rates that are believed to be lower than actual. To correct this problem, meetings were held with work analysts, operations, and plant engineering to ensure that appropriate personnel understand their responsibility for reporting repeat work and rework and how these items should be recorded. Future reported rates are expected to be more accurate. A multi departmental Maintenance Assessment Group har been established which reviews causes of rework and assigr4s actions to eliminate those causes.

9 of 12

ATTACEMENT 1 PERFORMANCE MONITORING Performance Monitoring includer Corrective Action Program quality of root cause analysis, timeliness of corrective acticn implementation and ehetiveness of the conective action Self Assessment creation of a ulf critical culture Site Quality Verificasion (SQV) Effectiveness e&ctiveness and timelinen of resolution of SQV identified issues Performance targets for 1995 include:

Target:

Reduction of overdue corrective actions and investigations from highs of over 40 each in the spring of 1995 to zero.

Status:

ne numbers of ovwdue cenective actions and investigations have been reduced to 5 and 1, respectivdy,in October 1995. During the months of November and December 1995, there were zero ovudue cornetive actions and investigations, meeting the target goal.

Target:

Maintain the number of problems identifled through PFs at greater than or equal to 350 pu month.

Status:

ne number of problems identified through pes has been maintained at greater than 350 per month since this target was set in July 1995.

During October 1995, approximately 500 pes were generated. During Novembw and December 1995, the numbw of pes, howevw, declined slightly to approximately 330 and 300 per month, respectively, which was slighdy less than the goal of 350 per month. This decline is attributed to the reduction in the number of contracted pusonnel on site, implementation of the training initiative and holiday vacations.

Target:

Achieve an improving trend in cortective actions concurred with as complete during SQV and Regulatory Assurance reviews.

Status:

ne percentage of corrective actions concurred with a complete by SQV has improved from 65% in August 1995, to 91% in October 1995.

During the months of November and December 1995, the percentage again improved, ne percentage of corrective actions concurred with as complete by SQV was 94% in November, and 99% percent in Decembu, showing a continued improving trend.

10 of 12 l

ATTACEMENT 1 A review of regulatory commitments made since January 1,1993, for the purpose of determining the acceptability of closure of these commitments, was completed during December 1995. A significant percentage of the closed items were found to be acceptable, with only a vwy small numbw of closures, none relatias to nuclear safety, dumed to be inadequate. These inadequate closure issues are being addressed via the PIF process.

Target:

Reduce average event investigation completion time from 104 days in January 1995 to 65 days.

1 Status:

Average event investigation time ww reduced to an avunge of 56 days in September and October 1995. A new goal has been set to reduce this time to an average of 45 days. During the month of November, the average increued to 78,5 days due to the number ofinvestigations open greater than 90 days which were closed. In December, the average again improved, equating to 56.6 days.

Target:

Complete an extemal review of *.he performance of the corrective acticn program.

Status:

This target has been met through a combination of outside assessments:

.h Augurt 1995 INPO Assist Visit in the area of Root Cause l

Analysis an August 1995 Assist Visit by personnel from the Surrey nuclear station in the area of Trend Analysis a September 1995 asse:sment of the SQV depanment, including i

the corrective action program, by personnel from the Palisades

)

and Clinton nuclear stations.

l An assessment ofISEG was completed by an external consultant in September 1995.

I Actions to address findings and recommendations of these assessments are being defined and a ssedule for implementation will be developed.

I 11 of 12 l

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i 1

ATTACENDtT 1 i

RADIATION PROTECTION l

Target:

Redmetion in site collective radiation exposure from an averags of 1100 Ramsan 1990 94 to less than 867 rom, with a ' stretch" goal of 689 rem (significant exposure is due to high dose associated with Core Shroud i

and Reactor Water Cleanup system work).

I Status:

The yearly site collective radiation exposure was 876.1 rem. This is 9.2 roam above the station goal of 867.6 rom. The significant factors for

).

exosoding the goal are added outage scope, rework, and forced outages.

It is estimated that 132 person tem can be associated to added scope and sowork, while forced outages contributed 27.8 rem to the stations exposure.

Unis I exposure as of December 31,1995 was 26.8 rem, substantially below estimate of 45 rem and the goal of 2$ rem.

f Target:

Reduce daily non-outage exposure from 0.732 person rem per day in 1994 to less than 0.500 person rem per day, j

Status:

As of December 31, daily non outage exposure for 1995 was 0.368 l

person rem per day l

l Target:

Reduce contaminated area from 13% in 1994 to less than 5%.

i Status:

Comamminated area has been reduced to 10.33%. His is over the station i

goal a(5 percent due to the decon of Unit 3 Torus Basement proving to i

be umane dallenging than expected. Decon of the torus is being reevalented to determine the best method of recovery, Unit I areas are not included in the figures for percent of plant area i

conesuminated. The amount of Unit I contaminated area has been redmond by approximately 72000 square feet during 1995.

Target:

Rodnes solid radweste generated from over 1580 cubic feet per mor.th in 1994 to less than 700 cubic feet per month.

Status:

Dusing 1995, 5,335.1 cubic feet of DAW was generated at Dresden.

i nis is well under the station goal of 8,400 cubic feet.

Target:

Elisminate 46 of g6 " hot spots" in plant piping and equipment, j

Status:

Only 42 Hot Spots of the original 86 remain. This is below the station l

goal of a 50 percent reduction in Hot Spots. The majority of remaining Hot Spots are tied to the D3R14 refueling outage.

12 of 12 l

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ATTACHMENT 2

\\

DRESDEN STATION SIGNIFICANT ACTIONS PLANNED BY APRIL 30,1996 PERSONNEUPROGRAMS 1)

Operations Achieve enor free restart of Unit 2 Implement revised Out Of Service (005) procedure based on INPO/ Industry standards 2)

Management Development Complete evaluation of assignments and capabilities (360 degrees assessments) of management supervisory personnel Complete remediation and re evaluation of site management personnel identified as low performers during Fall 1995 evaluations 3)

Engineering Complete upgrade of System Trending Program to provide a consistent basis -

for system manager monitoring of system performance Complete Engineering Qualification Card Upgrade and Certification Guide Program to ensure that Engineering personnel are appropriately qualified for assigned tasks.

4)

Supervisory and Workforce Skills Provide Management Action Response Checklist (MARC) training to supervisors. This training covers labor relations, enforcement of standards, and how to address personnel performance problems.

Complete Phase I training and testing of site workforce to ensurs that workforce member: have the knowledge and skills for job assignments (assumes postponement of Unit 3 outage until September 1996).

Complete three day training on upgraded work control process and fully implement the upgraded process.

5)

Self-Assessment Complete development and implementation of periodic self assessment programs in Operations, Maintenance, and Radiation Protection (the Operations program is now in place).

1

ATTACHMENT 2 EOUlPMENT 1)

Replan and complete the Unit 2 refueling outage 2)

Reviews of Systems and Equipmeat Complete reviews of an additional 14 systems to identify latent / potential problems.

Complete Performance Centered Maintenance reviews of an additional 14 sy:tems.

3)

Specific Key Material Condhion Upgrade ;

lastall new feedwaterregulating valves and control system on Unit 2 Complete Zine addition modification on Unit 2 Install biometric hand geometry system to control plant access Make Unit 2 Station Blackout (SBO) diesel available Complete Generic Lauer 89-10 work on Unit 2 valves Complete Unit 2 Reactor Water Cleanup system heat exchanger and major piping replacement.

Complete addition of shielded reflective insulation to recirculation piping in Unit 2 to rr. duce drywell doses in future outages.

4)

Housekeeping Clean up 3 of 10 designated worst plant areas, a

4 2

ATTACHMENT 2 D. PERFORMANCE RESULTS TO ACHIEVE by glRIL 30.1996 PERSONNEL / PROGRAMS

!)

Operations Continue improving trend in Operations human performance (Level 3 Events) from 8 per quarter by and of September 1995 to 4 per quarter by end of March 1996.

End cyclical performance in Out Of Service related esents and achieve less than or equal to I (Levd 3 Event) per month by March 1996.

2)

General Human Perfonnance Attain aero personnel error Licensee Event Reports during the rust four months of 1996.

Achieve goal of 40 days between plant events.

Reduce ladustrial Safety Accident Rate (ISAR) to 0.8 during the first four months of 1996.

3)

Radiation Protection Achieve fewer than 25 Personnel Contamination Events during the first four months of 1996.

4)

Self Assessment / Corrective Action Program Maintain aero overdue investigations and corrective actions 5)

Work Control Achieve schedule starts within one hour 85% of the time.

6) Licensed Operator Training Achieve 95% pass rate on operator license requalification exam.

EOUIPMENT

1) Backlog Reduction Reduce corrective maintenance backlog to less than 950 (assuming no Unit 3 refueling outage).

Reduce operator works.inds to 30 Reduce control room de6ciencies to 30 Reduce non-outage temporary alternations to 10 Maintain aero overdue required surveillances beyond critical date (125% past due date period) and attain aero overdue preventive maintenance items past critical date.

1 4

3

l ATTACHMENT 2 2)

Plast / System Performance - based on backlog redoctions and accomplishment of key system upgrades, achieve targets of:

Operation of Units 2 and 3 with less than 3 LCO/DATR days per week per unit Attainment of key safety system availability levels at or above INPO comparable plant averages.

4 s

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UNITED STATES a

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. EME4EM

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June 20, 1995 1

l Mr. James J. O'Connor j

Chairman and Chief Executive Officer l

Cosmonwealth Edison Company P.O. Box 767 r

i Chicago, IL 60690 i

Dear Mr. O'Connor:

l On June 6-7, 1995, NRC senior managers met to evaluate the nuclear safety i

performance of operating reactors, fael facilities, and other materials licensees.

The NRC conducts this meeting semiannually to detemine if the safety performance of various licensees exhibits sufficient weaknesses to I

warrant increased NRC attentioie or if it is trending adversely and requires l

steps be taken to comunicate concerns to the utility's president or board of directers.

At the June 1995 Senter Management Meeting, the Dresden and Quad r

Cities Nuclear Power Stations were discussed.

The Dresden Station was placed on the NRC watch list for the second time in l

January 1992 and continues to be categorized as a Cat'egory 2 plant. Plants in this category have been identified as having weaknesses that warrant increased l

NRC attention until the licensee demonstrates a period of improved perfor-mance. A sumary of NRC discussions related to Dresden follows:

Over the past year, performance at Dresden has been cyclical.

Following two significant plant events in the fall of 1994 involv-l ing a Unit 3 trip due to operater inattention and a Unit 2 high 3

pressure coolant injection system failure, management moved decisively.and shut down both urnts to address underlying prob-lems.

During the extended shutdown, station efforts were focused on establishing new performance standards.

Positive results were i

seen including a reduction la the number of operator workaroune, the establishment of clear eperal;er expectations, a reduction in plant contaminated areas, and an error free restart-of both units, t

i The momentum developed in the latter half of 1994 has not been maintained. Failure to follow procedures and to comply with technical specification limits has again been a problem.

In January 1995, for example, a Unit 2 recirculation pump tripped due to a technician error. The plant staff restarted the pump in j

violation.of the operating procedure and the technical specifica-tions despite the urging of a Quality Assurance auditor to stop and resolve the conflicts. Management recognition and response to i

this event was weak, t

Plant material condition remains a problem at Dresden.

Limited j

improvements have been made, but the underlying problems with assessing and correcting plant material condition deficiencies 4

l hcve not yet been effectively addressed. An effective work i

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J. O'Connor -

management system to deal with the corrective maintenance backlog is needed.

In summary, Dresden's performance has not demonstrated that the root causes of basic performance problems have been corrected. Accordingly, Dresden will continue as a Category 2 plant.

Adverse trends at Quad Cities were discussed at each Senior Management meeting since January 1994. A sumary of discussions at the June 1995 meeting follows:

The new senior management team that has been in place (or most of 1995 has established a clear course of action for station improve-ment and has demonstrated firm commitment to enforcing expecta-tions. Much remains to be done to address material condition and human performance issues but the fundamental building blocks for sustained improvement appear to be in piace. Material condition has been steadily improving. The scope of the spring Unit 2 refueling outage was altered to address a number of important equipment reliability problems.

Positive steps have been taken to improve the work control process that is complicating efforts to reduce maintenance backlogs.

There have been a number of personnel errors this year in proce-dural adherence and out-of-service tagging, but management swiftly and effectively dealt with this trend. Steps were taken, for example, to improve supervisory oversight, accountability and rigor in control room operations.

Engineering resources have been increased and reorganized; continued management attention is needed to continue improvement of the technical support function.

Considering all factors, the senior managers concluded that declining trends at the Quad Cities Station have been arrested.

I urge you to continue to deal with plant material conditions and human performance issues at~ Quad Cities and ensure that recent improvements are maintained and continued.

Mr. John B. Martin, the Region !!! Admiristrator, has discussed the bases for our conclusions with members of your staff.

An NRC Comission meeting, open to the public, has been scheduled to be held in the Comissioners' Conference Room in Rockville, Maryland, on June 22 1995, to review the results of the latest meeting of NRC senior managers.,

J. O'Connor -

If you have any questions regarding this matter, do not hesitate to call me.

Sincerely, glghtmlS M DY A m n IA T8YI0' James M. Taylor Executive Director for Operations Docket Nos. 50-237, 50-249 50-254, 50-265 cc:

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January 29, 1996 Mr. James J. O'Connor Chairman and Chief Executive Officer Commonwealth Edison Company P.O. Box 767 Chicago, IL 6M90

Dear Mr. O'Connor:

On January 17-18, 1996, NRC sent'or managers met to evaluate the nuclear safety performance of operating reactors, fuel facilities and other materials licensees. The NRC conducts this meeting semiannually to determine if the safety performance of various licensees exhibits sufficient weaknesses to warrant increased NRC attention or if it is trending adversely and requires steps to be taken to communicate concerns to the utility's president or board of directors. At the January 1996 Senior Management Meeting (SM), the Dresden Nuclear Power Station was discussed.

The ' esden Station was placed on the NRC watch list for the second time in Janu.ty 1992 and remains a Category 2 plant.

Plants in this category have been identified as having weaknesses that warrant increased NRC attention until the licensec hmonstrates a period of improved performance. A summary of NRC discussions related to Dresden follows:

During the June 1995 SM, NRC noted that CoeEd had lost its momentum in improvement efforts at Dresden. Over the past six months, Comed has taken steps to regain this momentum.

Following a significant event involving violation of technical specification limits et the beginning of 1995, station management refocused attention on operations standards and accountability. As a consequence, marked improvement has been observed in control room activities. While Unit 3 was hampered with equipment problems coming out of an extended forced outage, each of three startup evolutions on the Unit was conducted in a deliberate, error free manner. Priority was given to resolving operator work-arounds and control room deficiencies with positive results. Overall, a more conservative approach to decision making has been observed at the station.

Units 2 and 3 were both shutdown for most af the past six months.

Unit 2 has been in an extended refueling outage and Unit 3 was shut down to repair a failed turbine generator. Steps were taken to resolve a number of longstanding equipment problems during these outages. However, considerable work remains to be done with respect to material condition. The backlog of equipment deficiencies remains high while problems with work planning und-coordination have persisted. Station management acted to 'aprove work control and planning, but significant results have yet to be observed. Weaknesses in worker skill levels continue to hamper progress in this area.

4

l.

Mr. James J. O'Connor.

The number of radiological protection'and maintenance related personnel errors also continued to be high, particularly during the dual unit outage, Indicating efforts to consunicate management st&ndards and expectations have not been fully effective.

Engineering support to the station improved through increased staffing and involvement in plant activities but efforts to better identify equipment problems through plant walkdowns and systes reviews need to continue.

Continued significant management attention is needed to assure improvement efforte are sustained and effective at Dresden. This is particularly important in light of the long time that Dresden has been a Category 2 plant and its history of cyclic performance. While performance improvements have again been observed in some areas, effectiveness of recent management changes and improvement efforts will only become clear as the Unit 2 outage is

. completed, the Unit is restarted and operated along with Unit 3 for a period of time.

Mr. Hubert J. Miller, the Region III Administrator, has discussed the bases for our conclusions with members of your staff.

An NRC Commission meeting, open to the public, has been scheduled to be held in the Comissioners' Conference Room in Rockville, Maryland, on January 31,1996, at 10:00 a.m., to review the results of the latest meeting of NRC senior managers.

If you have any questions regarding this matter, do not hesitate to call me.

Sincerely, ongmai s!9'C DT

,k a s: L.isi a James M. Taylor Executive Director for Operations Docket Nos. 50-237, 50-249 cc: See next page DISTRIBUTION: See attached page DOCUMENT MAME: G:\\SECY2\\DRES196.LTR To noin e mpy or mis een

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SUMMARY

OF SENIOR MANAGEMENT MEETING RESULTS

~

l MEETING DATES CATEGORY 3 CATEGORY 2 CATEGORY 1 TRENDING LETTER DISCUSSED January 17-18, 1996 Browns Ferry 1 Browns Ferry 3 Hope Creek l

Dresden 2 & 3 lodian Point 3 Millstone 1,2, & 3 June 6-7,1995 Browns Ferry 1 & 3 Dresden 2 & 3 Indian Point 3 January 18-19, 1995 Browns Ferry 1 & 3 Dresden 2 & 3 South Texas 1 & 2 Cooper Indian Point 3 Quad Cities 1 & 2 June 7 8,1994 Browns Ferry 1 & 3 Dresden 2 & 3 Brunswick 1 & 2 Cooper Indian Point 3 LaSalle 1 & 2 South Texas 1 & 2 Quad Cities 1 & 2 i

V 1

i r

SUMMARY

OF SENIOR MANAGEMENT MEETING RESULTS (Continued)

MEETING DATES CATEGORY 3 CATEGORY 2 CATEGORY 1 TIENDING LETTER DISCUSSED January 11-13,1994 Browns Ferry 1 & 3 Brunswick 1 & 2 FitiPatrick Cooper Dresden 2 & 3 LaSalle 1 & 2 l

Indian Point 3 Quad Cities 1 & 2 South Texas 1 & 2

~

l June 14-16,1993 Browns Ferry 1 & 3 Brunswick 1 & 2 Perry Dresden 2 & 3 FitzPatrick W

Indian Point 3 I N South Texas 1 & 2

  • 5 l

January 26-28, 1993 Browns Ferry 1 & 3 Brunswick 1 & 2 Zion 1 & 2 Dresden 2 & 3 FitzPatrick June 15-16,1992 Browns Ferry 1 & 3 Brunswick 1 & 2 Browns Ferry 2 Dresden 2 & 3 FitrPatrick Zion 1 & 2 i

)

January 14-15,1992 Browns Ferry 1 & 3 Browns Ferry 2 Calvert CInffs 1 & 2 Dresden 2 & 3 FitzPatrick Zion 1 & 2 June 4 5,1991 Browns Ferry 1 & 3 Browns Ferry 2 Nine Mde Point 1 & 2 Calvert Cliffs 1 & 2 Zion 1 & 2 5

l i

2

SUMMARY

OF SENIOR MANAGEMENT MEETING RESULTS (Continued)

MEETING DATES CATEGORY 3 CATEGORY 2 CATEGORY 1 TRENDING LETTER DISCUSSED January 8-9, 1991 Beowns Ferry 1 & 3 Calvert Cliffs 1 & 2 Nine Mile Point 1 & 2 Zbn 1 & 2 I

June 12-13.1990 Browns Ferry 1,2, & 3 Calvert Cliffs 1 & 2 Surry 1 & 2 Nine Mile Point 1 & 2 January 22-23,1990 Browns Ferry 1,2, & 3 Calvert Cliffs 1 & 2 Peach Bottom 2 & 3 Nine Mile Point 1 & 2 Pilgrim Surry 1 & 2 Turkey Point 3 & 4 l

May 17-18.1989 Browns Ferry 1,2 & 3 Calvert Cliffs 1 & 2 Fermi 2 Nine Mile Point 1 & 2 Fort Calhoun Peach Bottom 2 & 3 Sequoyah 1 & 2 j

Pligrim Surry 1 & 2 Turkey Point 3 & 4 3

SUMMARY

OF SENIOR MANAGEMENT MEETING RESULTS (Continued)

MEETING DATES CATEGORY 3 CATEGORY 2 CATEGORY 1 TRENDING LETTER DISCUSSED December 6-7, 1986 Browns Ferry 1. 2, & 3 Calvert Cliffs 1 & 2 Dresden 2 & 3 Pear,h Bottom 2 & 3 Fermi 2 Rancho Se:o Pilgrim Fort Calhoun Nine Mile Point 1 & 2

~

Sequoyah 1 & 2 Turkey Point June 28-2?,1988 Browns Ferry 1,2, & 3 Dresden 2 & 3 Fort St. Vrain reach Bottom 2 & 3 Fermi 2 Pilgrim Fort Calhoun Sequoyah 1 Nine Mile Point 1 Rancho Seco Sequoyah 2 Turkey Point 3 & 4 1

November 16-18, 1987 Browns Ferry 1,2, & 3 Dresden 2 & 3 Palisades Peach Bottom 2 & 3 Fermi 2 Pilgrim Fort St. Vrain Rancho Seco Turkey Point 3 & 4 i

Sequoyah 1 & 2 June 2-3,1987 Browns Ferry 1,2, & 3 Dresden 2 & 3 Peach Bottom 2 & 3 Fermi 2 Pilgrim Fort St. Vrain Rancho Seco Palisades Sequoyah 1 & 2 Turkey Point 3 & 4 i

October 21-22, 1986 Browns Ferry 1,2, & 3 Fermi 2 Davis-Besse Fort St. Vrain Peach Bottom 2 & 3 LaSalle 1 & 2 1

4 Palisades Pilgrim Turkey Point 3 & 4 Rancho Seco Sequoyah 1 & 2 j

4 e 44

]

SUMMARY

OF SENIOR MANAGEMENT MEETING RESULTS (Continued)

MEETING DATES CATEGORY 3 CATEGORY 2 CATEGORY 1 TRENDING LETTER DISCUSSED April 23-24,1986*

Browns Feny 1,2, & 3 Davis-Besse Fermi 2 j

LaSalle 1 & 2

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Peach Bottom 2 & 3 Migrim Rancho Seco

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Sequoyah 1 & 2 Turkey Point 3 & 4 i

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Comed Progress in Resolving issued Raised in Chairman Jackson's March 22. 1996 Letter to Mr. O'Connor PROGRESS AGAINST PLANS AND MILESTONES - (POSITIVE) l Dresden Station Improvement Plan - Positive Progress January 30, 1996, update on the Dresden Station Improvement Plan provided an accurate description of progress Some self-criticism was provided with respect to reducing the station l

backlog of non-outage corrective maintenance a significant amount of bulk work has been accomplished l

In the area of Performance Monitoring, recent NRC inspection findings indicate weaknesses in implementing effective corrective actions.

I Examples include:

LPCI heat exchanger corner room steel I

Out of Service program implementation System lineup checklists implementation l

Locked valve program implementation Emergency Service Water Foreign Material Exclusion Control Progress Toward April 30 Milestones - Positive Progress 40 goals established in December 1995 35 of the 40 goals may be achieved by April 30 Goals that were not achieved included:

Reduce operations human performance events (4/qtr)

Reduce out-of-scrvice errors (1/mo.)

Zero personnel error LERs

< 40 days between plant events (29 longest)

Zero overdue corrective actions Reducing the non-outage backlog to <950 may not be achieved, but a significant amount of emergent work was accomplished Reducing the number of operator work arounds, control room deficiencies and kann temporary alterations had a visible impact WORKFORCE UNDERSTANDING AND IMPLEMENTATION OF STANDARDS - (STILL A CHALLDEE)

Performance Standards - (Positive in CR)

Centrol Room standards are improved and a noted strength Outside the control room standards are not being fully implemented Eramples include:

Poor implementation of the out-of-service program Poor Implementation of the valve & electrical lineup checklists Known resin spill went uncorr.cted for over a year Test of emergency diesel not done in accordance with procedure Unit 2 drywell inspection by NpC found numerous problems Worker Skills - (Still a Problem)

Implementation problems with out-of-service program continues High amount of rework (10%)

Attention to detail lacking (e.g. work on emergency diesel and reactor feedpump)

{

Training initiative started to address worker skills i

1

MATERIAL CONDITION IMPROVEMENT EFFORTS - (POSITIVE PROGRESS)

Significant improvements were made during the 1995/96 Unit 2 outage.

Safety improvements included:

Overhaul of LPCI, HPCI, and core spray motors Feedwater modifications to allow 3-element control Replaced all Scram Solenoid Pilot valve assemblies Reactor Water Cleanup Heat Exchanger and piping replacement Cleared Reactor Vessel Botton Head Drain Implemented Core Shroud repair Reduced the number of operator work-arounds Reduced the number of control room deficiencies l

Modified structural steel in LPCI Heat Exchanger corner rooms Work Control - (Still a Bottleneck)

Transferred outage work management to contractor staff (8/95)

Aggressive management action taken by stopping 1995 Unit 2 outage work in November and rebaselining the outage Large amount of work accomplished following the outage restart with fewer resources Rolling maintenance schedule and electronic work control just started PLANT SYSTEM ASSESSMENT - ONGOING Latent System Assessment Completion

- Review of 26 systems are essentially complete.

Deficiencies - On average about 20-30 items were identified per system.

Corrections - Still under evaluation.

Equipment Deficiencies Identified - (Problems Still Being Found)

FAST CRUISE at end of Unit 2 outage effective in finding some problems that might have gone undetected Long standing problems recently identified include:

Scram Instrument Volume 1 out of 2 Logic Single Failure (10/95)

Scram Discharge Volume Structural Steel Supports (11/95)

Fuel Pool Cooling Pump Trips from Overloaded Bus (2/96)

Reactor Recirc Pump Seal Purge Line Missing Isolation (3/96)

I RESOURCES - FADE 00 ATE) 0 & M costs plus Capital Recently, to accelerate improvement efforts, the company provided increased funding of about $120 Million (0 & M + 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.

Adequate resources continue to be given to Dresden

't 2

MANAGEMENT CHANGES - (POSITIVE)

The management ' team" at Dresden has been significantly changed.

The most notable change is the Site Vice President, Mr. Steve Perry, will no longer i

have responsibility for other CosEd BWRs and will concentrate his efforts on l

Dresden. Other Dresden management changes include:

i Engineering Manager

- Raj Kundalkar replaced Frank Spangenberg Reg Assurance Manager

- Frank Spangenberg assumed new position SQV Director

- Dennis Winchester replaced Rita Stohls i -

Support Services Dir.

- Pete Tsomes replaced Rita Radtke Maintenance Supt.

- Preston Sr..ord replaced U2 & U3 Supts.

Work Control Supt.

- Robert Fisher replaced Dave Wallick It is too soon to tell if the above changes are going to be effective in continuing a positive trend; however, the changes made appear to have a positive influence in the station's daily activities.

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UNiilO Sl Ali S NUCLE AR REGULATORY COMMISS:ON s.

c,, o.m o, Mr James J. O'Contior Chairman and Chief Executive Officer Commonwealth Edison Company P 0. Ilox 767 Chscago. Illines 60690

Dear Mr O'Connor:

The Commission continues to be concerned about the performance of Commonwealth (dison's nuclear facilities, particularly the inability of Commonwealth [dison to establish lasting and effective programs to improve performance at the Dresden Station.

As you know, the Dresden station has been on the U.S.

Naclear Pegulatory Commission's (NRC's) Watch List for six of the last nine years.

Since January 1992, Dresden has never been removed from the NRC Watch

!ist as a Category 2 plant, a plant identified as having weaknesses that aarrant intrened NRC attention until the licensee can demonstrate a period of improved perf oniance, On January 17-lf,1996, NRC senior managers met to evaluate the nuclear safety performance of aperating reactors.

With regard to Dresden, the decision was made that it r,imain on the NRC Watch List as a Category 2 plant because of the continuing prtblems in the areas of material condition, work management, and radiation protection, as well as weaknesses in worker level skills.

Although the NRC staff has observed some safety performance improvement in the past six months, it is not clear whether recent management changes and other improvement efforts will be effective in continuing this initial trend.

Consequently, we request that you brief the Commission on the status of efforts to improve performance at Dresden since you last briefed us on November 16, 1995.

In eddition to describing progress being made in meeting specific scheduled actions, milestones, and focus area goals set out in the Dresden Station improvement Plan, your briefing should include a description of the degree to which performance standards are understood and are being implemented by the Station workforce.

Also, you should describe the results of material g

condition improvements efforts, including steps you have taken to ensure that i

important equipment deficiencies have been fully identified and those affecting system function have been resolved.

The Commission is particularly interested in learning more details of your plant system assessmcnts (for both systems that are safety-related and important to "afety), especially the progress made in complet ng those assessments, the deficiencies ' hat have been identified. and your plans for correcting those deficiencies.

Finally, you should alsn address the ability of Commonwealth Edison Company to devote sufficient resources to sustain improved performance at the Dresden Station over the long term without negatively affecting the safe operation of the other nuclear facilities of the Commonwealth Edison Company.

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It.e uttise of t he Sec ret at y wil'. contact you to arratitw a date f or the t o. ission freet inq, which we would project as May 1996, t o pt ovide you If you have any questions concerning the isdequat e t ime f or preparat ion.

required auenda f oi the meeting, please contact John licyle. Secretary of the tor.ission at (301) 415 1969.

Sincerely.

.[,

N'~ e k Shirley Ann Jackson i

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4 the Ot t u e of t he Set ret ary will contact you to arrange a date f or the (e

ission meeting, wh uh we would project as May 1996, to provide you adego.tt e t i~e t ar preparat ion.

If you have any quest ions concerning the ret:uired agenda f or the meeting, please contact John Hoyle, Secret ary of the to.nission at (301) 415 1969.

Sincerely.

Original signed by Shirley Ann Jackson Shirley Ann Jackson

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BACKGROUND INFORMATION ON COMED Commonwealth Edison Company (Comed) underwent a restructuring in June 1994, whereby it became a wholly owned subsidiary of Unicom.

The purpose of the 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.

4 In recent years, the performance of Commonwealth Edison Company (Comed) plants.

has been inconsistent and a concern to the NRC.

Comed had traditionally prometed from within and as a result benefitted little from outside experience.

During its ambitious plant construction program during the 1970's t

and early 1980's, many of the company's more talented managers were moved from site to site to complete construction and get the units licensed and started up.

Lixewise, corporate attention and resources were focused on the newer units while they were in the latter stages of construction and licensing. As a result, the older plants generally got fewer resources and less quality management attention.

Plant material condition and operating standards and practices declined.

SECY-92-228, " Performance of Commonwealth Edison Company Plants,' dated June 25, 1992, described Comed's major weaknesses.

These weaknesses were:

(1) lack of effective management attention and application of resources; (2) weak corporate oversight of nuclear operations; (3) poor problem recognition and failure to ensure lasting corrective actions; (4.) lack of adequate engineering support; and (5) an inability or reluctance to learn from experiences at Comed and other utilities.

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 December 1988 and was returned to the Watch List in January 1992.

Zion was placed on the Watch List in January 1991. After some improvement it was removed from the list in January 1993; however, the rate of performance improvement has not been sustained.

Declining performance at Quad Cities was discussed at the June 1991 and June 1993 SMs; a Diagnostic 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, Unit 1, which was permanently shut down in 1978.

In January 1994, a significant 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 was considered to be a better than average performer, however, about a year ago declining performance was observed; personnel errors and equipment problems indicate that performance has declined in Operations and Maintenance.

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 Dresden is the only one of the Comed plants on the Watch List.

However, the performance at LaSalle, Quad Cities.

Zion, and Braidwood remains a staff concern.

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

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l company's engineering capability; actions to improve craft skills; benchmarking their performance against other utilities; and (maybe most importantly) hiring management individuals from outside the company.

These individuals included several corporate vice presidents, site vice presidents, plant managers, and various senior and mid-level plant management individuals.

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.

More recently, managers with proven track records have been hired and some improvements in expectations and performance have been noted, particularly at Quad Cities.

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d Current Issues and Concerns Most Recent SALP Scores

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Plant SALP Feriod SALP Scores (1)

Braidwood 02/94-09/95 2,2,2,1 Byron 03 93-08/94 1,1,1,1 f

l 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

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i CemEd 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. While some improvements have b'een observed, 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.

Quad cities has had an effective management team in place for about 15 months and it appears to be 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 4

attention. The most recent Unit 2 outage significantly improved some major equipment deficiencies. -Similar improvements are being implemented in the Unit 1 outage which started on February 10, 1996.

However, the maintenance backlog remains high, the work' control process is still weak, and material condition needs further improvement. Some recent safety equipment performance problems were due to ineffective root cause evaluations (HPCS, RCIC, emergency diesel generator e

reliability)

Over the past six months Dresden, Unit 3 was returned to power operation and has operated continuously for over 165 days. Dresden Unit 2 has just completed a 10 month refueling outage in which many safety related material condition issues were completed. The conduct of operations has a

been very good; fuel load activities during the recent Unit 2 outage-went well. However, personnC performance outside the control room continues to demonstrate weak configuratkr. control indicating that performance and expectations are still no; fully understood and L

implemented by the entire work force. Maintenance activities have struggled and efforts to improv6 the work control process have been 1

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limited. Some improvement in Engineering support to the station has been noted, but the engineering organization is still in a state of transition.

Performance in the area of Plant Support has been good with respect to security and fire protection; however, weak performance in radiation protection continued with only slight improvement noted.

In addition, Mr. J. Stephen Perry, who has been the principal change agent within Comed emphasizing a conservativa operations philosophy, has become the permanent Site Vice President. Mr Perry had previously held the position of Vice President of BWR Operations and was the acting Site Vice President. A Commission Meeting to discuss the performance at Dresden is scheduled for May 13, 1996.

Comed has tried to address problems at Zion with a management team that 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 1990 time frame (when the NRC performed a DET assessment), in many aspects, it has been stagnhnt for the last few years. Operational errors and slow progress in correcting a large backlog of material condition problems are the NRC's most significant performance concerns at Zion.

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 sig'nificant material condition deficiencies 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.

Braidwood, was long considered to be a better than average performer.

However, NRC staff observed signs of declining performance about a year ago due to some of the same weaknesses that exist at the older Comed plants:

e.g., problems with poor craft capability, configuration-control (control of equipment lineups), engineering, and corrective actions.

As such, material condition declined. The licensee made several key management changes and has increased problem identification efforts in recent months.

The effectiveness of these changes is not yet determined.

Byron is a good performer. Although it has lost several key management individuals to other Comed stations no change in performance has been evident. - _ -___ - __

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u RESOURCES-a Recently, to accelerate improvement efforts, the company provided increased funding (about $120 million 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 j

LaSalle to fix poor designs, Steam Generators e

The Byron I and Braidwood I steam generator tubes are subject to outside diameter stress corrosion cracking (00 SCC) at the tube support plates p

(TSPs). It is believed that the 00 SCC at the TSPs is attributable to the use of carbon steel TSPs, the type of crevice between the tube and TSP, p

i and prior secondary side chemistry control.

in addition, during the Byron I sid-cycle outage in the fall of 1995, approximately 2500.

t circumferential crack indications were discovered in tubes in the i

tubesheet area. All tubes with such indications were either sleeved.or l

plugged. As a consequence of approximately 15% of the tubes now removed from service, Byron I can not operate at full power.

The unit is now

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down for a scheduled refueling outage and further 3G tube inspections.

L With approximately 2/3 of the steam generator tubes inspected, preliminary results to date indicate that about an additional 2500 circumferential cracks have developed in the five months of operation j

since the last. inspection.

The latest inspections indicate very few 00 SCC indications greater than 3 volts.

Braidwood 1 is scheduled for a mid cycle SG tube inspection in the fall of 1996, i

-The licensee's long-term solution is to replace the steam generators;

.Braidwood is scheduled to be done in the fall of 1998 and Byron in the i

spring of 1999.

In the short term, the licensee is taking steps to safely maintain as high a power output as pnssible with the degraded steam generators. At present the licensee is required to repair or-i.

remove from service-those tubes that have eddy current voltages greater than 3 volts and all tubes with circumferential crack indications. The i

staff approv6d the 3 volt criteria based on the expansion of selected F

tubes into the TSPs, thus preventing a rupture of.any degraded tubes in the event of a main steamline break.

Technical Soecification Unaradg1 t

All of the Comed sites _are upgrading their Technical Specifications i-(TS).

Dresden and Quad Cities which have custom TS are converting to the old version of the Standard Technical Spectfications. That conversation _is close to completion. Zion is converting to the Improved Standard Technical Specifications (13TS) with full implementation scheduled for June 1996.. Applications from Byron, Braidwood, and LaSalle for conversion to iSTS'are expected in August 1996.

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i Emeroency Operations Facility (EOF)

In February 1996, the staff approved the use of the corporate EOF in-Downers Grove as an interim EOF, in the event activation is required, until the nearsite EOF is staffed and operational, Because the corporate EOF is more than 20 miles from any of the Comed sites, Comission approval was required for the change. The licensee now has a request in front cf 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 also require Connission approvr.l.

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