IR 05000237/2016007

NRC Problem Identification and Resolution Inspection Report 05000237/2016007; 05000249/2016007, April 11, 2016 Through April 29, 2016

ML16152A101
Person / Time
Site:	Dresden
Issue date:	05/31/2016
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2016007
Download: ML16152A101 (28)

Text

May 31, 2016

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000237/2016007; 05000249/2016007

Dear Mr. Hanson:

On April 29, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Dresden Nuclear Power Station, Units 2 and 3. The NRC inspection team discussed the results of this inspection with Mr. P. Karaba and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

Based on the inspection sample, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety. Discussed in the enclosed report is an identified weakness associated with the quality of some of your self-assessments.

Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25

Enclosure:

IR 05000237/2016007; 05000249/2016007

REGION III==

Docket Nos: 50-237; 50-249 License Nos: DPR-19; DPR-25 Report No: 05000237/2016007; 05000249/2016007 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Dates: April 11 through April 29, 2016 Inspectors: J. Rutkowski, Project Engineer and Team Leader G. Hausman, Senior Reactor Inspector G. ODwyer, Reactor Engineer C. Phillips, Project Engineer M. Porfirio, Resident Inspector, Illinois Emergency Management Agency Approved by: J. Cameron, Chief Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000237/2016007; 05000249/2016007; 04/11/2016 - 04/29/2016;

Dresden Nuclear Power Station, Units 2 and 3; Biennial Problem Identification and Resolution Inspection Report This inspection was performed by four NRC regional inspectors and the site Illinois Emergency Management Agency inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 5, dated February 2014.

Problem Identification and Resolution On the basis of the sample selected for review, the team determined that implementation of the corrective action (CA) program at the Dresden Nuclear Power Station, Units 2 and 3, was generally good. The licensee demonstrated a low threshold for identifying problems and entering them in the CA program. Items entered into the CA program were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies although weaknesses with self-assessments were identified in one department. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns directly into the CA program or through their supervisors but some non-supervisory personnel questioned the value of identifying concerns for what they perceived as low-level issues.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in IP 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees corrective action (CA) program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CA program since the last NRC Problem Identification and Resolution (PI&R) inspection completed in March 2014. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed action requests/issue reports (ARs) generated as a result of facility personnels daily plant activities. The inspectors also reviewed a selection of work orders (WOs), performance indicator reports, system health reports, and completed investigations from the licensees various investigation methods, which included root cause evaluations (RCE) and apparent cause evaluations (ACE).

The inspectors selected electronic board components used in safety-related equipment to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these and associated components through effective implementation of station monitoring programs. A five year review of the electronic component was undertaken to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. The inspectors also performed a partial system walkdown of emergency diesel generators and equipment associated with a station battery room ventilation to review if conditions of the equipment was appropriately represented in plant health reports, work orders, and the CA program.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys CA program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined whether licensee personnel were identifying station issues at the proper threshold, entering the station issues into the stations CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations.

The inspectors also reviewed corrective actions from licensees ARs 01513452, NRC Preliminary White Finding-Flood Mitigation Procedure, 02445040, NRC Report 2014-005 Preliminary White Finding for ERV, and 02437067, FWLC 2-0640-33 Failed; Resulting in Loss of Baily FWLC SYS which were not completed by the licensee as of closeout inspections for the associated violations.

Documents reviewed are listed in the Attachment to this report.

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of ARs and information from interviews, the inspectors determined that the licensee has a low threshold for initiating ARs, and from the ARs reviewed, the threshold was appropriate and that all station departments were active in generating ARs. The inspectors did not identify any safety significant item that was not entered into the CA program. Some personnel stated that they might not document low-level issues, due to the perception that those issues would not be effectively addressed through the CA program. The inspectors also determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The inspectors assessed the effectiveness of problem identification as adequate to support nuclear safety.

Observations The inspectors found that issues were being identified and captured in the licensees CA program. The licensee initiated approximately 13,000 ARs in calendar year 2015.

The licensee identified that approximately 1727 ARs were in the approved status (reviewed) but assigned action was not complete. There were also approximately 795 issue reports in an approved status that were categorized as a condition not required to be in the formal CA program (categorized as an NCAP). The inspectors noted that licensees procedures allowed for closing some low-level ARs to the work order system.

The inspectors noted that at the time of the inspection there were approximately 2403 open work orders (WOs) with the majority of the orders classified as not critical. The inspectors concluded that the number of open ARs and WOs appeared consistent with industry averages.

The inspectors reviewed open corrective WOs, open corrective action items, and system health reports for the last five years for electronic component history. The inspectors also discussed the licensees aging management program for those components with system engineers and physically verified the apparent physical conditions of some equipment containing those components with a system engineer. The inspectors did not identify any major conflicts between actual system conditions and the condition of the systems as represented in WOs, system health reports, and CA program documents.

Additional details are provided in Section

.1 b.(2).

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensees overall performance in the prioritization and evaluation of issues was generally appropriate. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were appropriately screened by the originating departments, the Station Ownership Committee (SOC), Management Review Committee, and Operations shift management for items potentially impacting equipment operability. Evaluations in apparent cause and root cause reports reviewed by the inspectors were appropriate to support nuclear safety; however, the inspectors noted numerous examples in which it was not clear whether specified corrective actions had been completed from the review of completed ARs. Also the inspectors found some corrective actions were rescheduled beyond the initial scheduled completion dates and some developed actions were rescheduled several times.

Observations The inspectors identified no items in the backlogs of the CA program or maintenance WO system that were risk significant, either individually or collectively, although the inspectors noted several instances of multiple extensions for actions. The inspectors also noted several instances where they questioned whether actions classified as an Action Tracking Item (ACIT) should have been specified as CAs. The inspectors questioned the ease of an ACIT being changed or cancelled with minimal or no review; the inspectors did not identify any examples of where an ACIT actions would have changed if it had been categorized as a CA. The inspectors reviewed the licensees WO backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

The inspectors had difficulty in following the activities in several ARs to final completion due to the lack of documented results and only references to other document numbers.

Some examples were:

• AR 01239089, Failed Equipment Is Obsolete - Engineering Required for Eval, showed status as complete and the SOC in the Action Request Details stated WR [work request] generated to replace 2-3241-98, however, only one AR assignment was identified and the in-progress notes did not identify the WR number or the results of the engineering evaluation. The In-Progress Notes did state EC 385199 generated on 7/13/11 to replace 2-3241-98, but there was no reference to the results of the engineering evaluation or when a replacement was installed.

• AR 01398536, U3 MPT Protective Relay Obsolete with No Replacement; showed the AR status as complete and the SOC in the Action Request Details stated OAD have 3 relays that can be refurb/repaired and Stores has been notified of the relays on hand. Closed to actions taken. The AR did not indicate any assignments that scheduled actions to address and track the issue to resolution. With no In-Progress Notes available to determine what action the licensee took, the completion status of any required actions could not be determined.

• AR1493744 was written to address obsolete meterological tower wind sensors. The AR was closed with a statement that a contract to obtain new sensors was initiated, but did not state the final outcome and whether parts were delivered.

• AR2602903 identified that the station lift pump transformer TR-41 was obsolete, but did not clearly state how the issue would be addressed.

The licensee satisfactorily answered the inspectors questions and provided documentation that the issues had been resolved. However, as stated, these conclusions could not be reached based on a review of the CA program entries alone.

5 Year Review for Obsolescence and Age Degradation The inspectors performed a review of the licensees CA Program and associated documents focusing on electronic components to determine whether any obsolescence and aging issues existed for the last five years. The inspectors review and evaluation were focused on obsolescence and aging issues to ensure corrective actions were:

complete, accurate, and timely; considered extent of condition; provided appropriate classification and prioritization; provided identification of root and contributing causes; appropriately focused actions taken that resulted in the correction of the identified problem; identified negative trends; operating experience was adequately evaluated for applicability; and applicable lessons learned were communicated to appropriate organizations. The inspectors determined that the licensee established an Obsolescence Steering Committee (OSC) in accordance with Procedure ER-AA-550, Equipment Obsolescence Process, Revision 2, which requires quarterly meetings to discuss, maintain and resolve a Top Ten List of obsolescence components. In addition, the OSC presents the obsolescence Top Ten List to the Plant Health Committee (PHC)on a semi-annual frequency. No findings were identified.

The inspectors review concentrated on the last five years of CA program actions associated with obsolescence and aging issues of the Unit 2 and Unit 3 Containment Oxygen Analyzer and the actions associated with the Control Room Habitability Calculations.

Through interviews and reviews of CA program documents, the inspectors found that during the time period between April 10, 2011, and April 29, 2016, the Unit 2 and Unit 3 Primary Containment Oxygen Analyzers were out-of-service for 374 days and 140 days, respectively. Unit 3 continued to remain out-of-service as of April 29, 2016. The inspectors observed that at one time Unit 2 and Unit 3 were out-of-service for 200 and 62 consecutive days, respectively. The Primary Containment Oxygen Analyzers are required to be operational per technical specification (TS) 3.6.3.1. If the Primary Containment Oxygen Analyzers are not operational, a manual sample must be taken every 7 days to verify the primary containment oxygen is within limits. This requires chemistry and radiation protection technicians to obtain the sample. The sample takes 4 man-hours to complete. As a result, a conservative 54 samples (i.e., 216 man-hours)and 20 samples (i.e., 80 man-hours) were required to maintain Unit 2 and Unit 3 TS requirements, respectively.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the CAs appeared generally appropriate for the identified issues. Those CAs addressing selected NRC documented violations were also determined to be generally effective and usually timely. The inspectors review of Corrective Actions to Prevent Reoccurrence (CAPRs) did not identify subsequent recurrence of the addressed issues. The inspectors review of the previous five years of the licensees efforts to address issues with electronic components did not identify any recent negative trends or inability by the licensee to address long-term issues.

Observations A maintenance fundamentals self-assessment (AR 2502328) completed in July 2015 listed two deficiencies. Maintenance workers and first line supervisors were not consistently applying all of the maintenance fundamentals. This conclusion was based on a series of ARs and observations made by the assessors. The sole action from these two deficiencies was to present a single slide at the beginning of the maintenance cycle training in April 2016 which was almost a year after the assessment was completed.

The Nuclear Oversight (NOS) assessments of maintenance in 2012, 2014, and 2016 all identified issues with the control of quality parts. Although these conditions adverse to quality were addressed on an individual basis the trend was not addressed effectively which resulted in the recurring deficiency.

Corrective Actions Associated with Root Cause Evaluations for White NRC Findings associated with Flood Mitigation Procedure, and Failed Electromagnetic Relief Valve At the NRC closeout of inspections associated with cited violations, not all of the corrective actions that the licensee had developed were completed. However, the actions that were completed were deemed sufficient to close the violations. However, the NRC requires that those actions not completed also require eventual inspection.

During this inspection the inspectors reviewed:

• AR 01513452, NRC: Preliminary White Finding - Flood Mitigation Procedure.

Corrective actions reviewed were deemed acceptable. The following items/assignments in the AR remained opened at the time of this inspection and remain to be reviewed in a subsequent inspection: 41 and 42.

• AR 2445040, NRC Report 2014-005 Preliminary White Finding for ERV.

Corrective actions reviewed were deemed acceptable. The following items/assignments in the report remained opened at the time of this inspection and remain to be reviewed in a subsequent inspection: 25, 28, 35, and 36.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating operating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed whether corrective actions, as a result of OE, were identified, and effectively and timely implemented.

In addition, the inspectors review included a sample portion of OE driven corrective actions resulting from 10 CFR Part 21 reports. The inspectors verified the licensee adequately evaluated the vendors issues for applicability to the station. The inspectors also confirmed the licensee correctly justified whether programmatic controls were in place that would prevent similar issues at the site. In addition, the inspectors verified that the licensee initiated actions to detect, prevent, monitor and correct conditions to prevent future occurrences related to the vendors report.

Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.

Observations The team noted that root and apparent cause evaluations were required to evaluate whether internal or external operating experience was available associated with the event or failure being examined, and whether the evaluation and actions to address those items had been effective. Additionally, all root cause evaluations reviewed included an assessment as to whether the issue being evaluated had potential application to other similar components or plants.

The inspectors had one observation in the area of OE. AR 2578767, 10 CFR 21 Notifications Not Reviewed At Dresden, discussed that during the performance of the biennial OE program review performed in 2015, the licensee identified that three 10 CFR Part 21 reports from 2014, that did not specifically identify Dresden Station as being impacted by the report, were not evaluated for applicability to the station by the licensee.

The inspectors reviewed 10 CFR Part 21 report number 2016-009 from the NRC public web site on April 27, 2016. This 10 CFR Part 21 report did not state that it was specifically applicable to Dresden Station. The inspectors selected this report because of its potential applicability to Dresden Station. Exelon internally generates a Daily Industry Events Report (DIER) that compiles all industry OE every week day. The station was notified of this 10 CFR Part 21 report (2016-009) via the DIER on March 18, 2016. At the time the inspectors reviewed this report on April 27, 2016, the licensee had not yet assigned an action to review the report for applicability, a period of about 40 days. The licensees procedure PI-AA-115-1003, Processing of Level 3 OPEX Evaluations, Revision 2, Step 4.2.1 had a requirement to assign an action to review 10 CFR Part 21 reports for applicability with a completion date goal within 30 days of the time the action was assigned. There was, however, no time period specified for the assignment to review the Part 21 report after the receipt of the report. The licensee acknowledged this as an issue at the exit meeting on April 29, 2016. However, the issue was not placed into the CA program until May 9, 2016, when questioned by the inspectors.

b. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

Assessment The inspectors concluded that most self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold with some exceptions in one department. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.

Observations The inspectors reviewed three radiation protection (RP) department self-assessments.

Of the three RP assessments there was only one deficiency identified. One of these assessments was a review of all the areas the NRC planned to inspect over the next year (AR 1613009). No deficiencies were identified. The inspectors also reviewed AR 2614410 which identified that corporate RP had performed four assessments in the past year. Three of those assessments had no strengths, recommendations, or deficiencies.

The fourth discussed a recommendation but no assignment to address that recommendation was put into the CA Program. The assessments performed by NOS in the RP area in 2015, however, had found seven deficiencies that were addressed (AR 2422723). Based on these observations, the inspectors concluded that the self-assessments performed by the station and corporate RP staff of the stations RP department were not effective.

b. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from 2012 and 2014 organization effectiveness surveys and meeting minutes of the Safety Culture Monitoring Panel.

As part of the overall inspection effort, inspectors discussed department and station programs with a variety of people. In addition, the inspectors held scheduled interviews with 59 non-supervisory individuals, in groups of four to eleven people, from various departments to assess their willingness to raise nuclear safety issues. Additionally other personnel were randomly asked their views of the effectiveness of the CA program.

The individuals for the scheduled interviews were randomly selected to provide a distribution across the various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews included discussion on any changes in the plant environment over the last 12 months. Other items discussed included:

• knowledge and understanding of the CA program;

• effectiveness and efficiency of the CA program;

• willingness to use the CA program; and

• knowledge and understanding of ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator; reviewed program logs from 2014 and 2015; and reviewed two case files.

Assessment The inspectors did not identify any issues of concern regarding the licensees SCWE.

Information obtained during the interviews indicated that an environment was established where the majority of licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CA program and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised; and safety significant issues could be freely communicated to supervision. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews even with 2014 survey issues identifying conditions that potentially might act to inhibit discussion of items.

Observations Non-supervisory personnel in the interviewed groups stated that at their level there were no issues with working with and communicating with workers in other groups. Several of the groups interviewed expressed concerns with their supervisors qualifications or a lack of support from their department managers.

All interviewees indicated that they could and would bring up safety issues with supervision, management, or through the CA program. Several of the groups stated the view that the CA program was ineffective for addressing low-level issues. None of the interviewed personnel stated that there was intimidation or retaliation when they brought up issues. Those same interviewees predominantly said they would use the ECP but saw no need to have to resort to the ECP for issue reporting.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 29, 2016, the inspectors presented the inspection results to the Site Vice President, Mr. P. Karaba, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary and that all material considered proprietary by the licensee was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Karaba, Site Vice President

J. Washko, Station Plant Manager

G. Baxa, Senior Regulatory Engineer

F. Gogliotti, Director, Site Engineering

G. Morrow, Operations Director

S. Matzke, Corrective Action Program Manager

D. Walker, Regulatory Assurance - NRC Coordinator

Nuclear Regulatory Commission

J. Cameron, Chief, Division of Reactor Projects, Branch 4

G. Roach, Senior Resident Inspector

IEMA

M. Porfirio, Resident Inspector, Illinois Emergency Management Agency

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None