IR 05000254/1987001
| ML20235G732 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/29/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235G715 | List: |
| References | |
| 50-254-87-01, 50-254-87-1, 50-265-87-01, 50-265-87-1, NUDOCS 8707140361 | |
| Download: ML20235G732 (31) | |
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SALP 6 SALP BOARD REPORT NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-254/87001; 50-265/87001 Inspection Report No Commonwealth Edison Company Name of Licensee Quad Cities Nuclear Power Station Name of Facility October 1, 1985 through March 31, 1987 Assessment Period h[0 N)Dbk gh4
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- SUMMARY OF RESULTS Overall, the licensee's performance was found acceptable with improvements noted since.the last SALP assessment period. Of 10 functional areas rated during this-assessment period, licensee performance in two areas improved from Category 2 to Category 1. One area exhibited an improving trend and one area declined from a Category 1 to a Category 2. Four functional areas received Category .1 ratings, six areas received Category 2 ratings and no areas received Category 3 ratings. One functional area, Fire Protection / Housekeeping, was not rated during this assessment period due to a lack of inspection information, and two of the functional areas, Outages and Training and Qualification Effectiveness, were not rated during the previous assessment perio Rating Last Rating This
. Functional Area Period Period Plant Operations 2 2 Radiological Controls 2*** 1 Maintenance ** 2 2 Surveillance 2 1 Fire Protection 2 'N/R Emergency Preparedness 1 2 Security 1 1 Outages * 2 Quality Programs and Administrative Controls Affecting Quality 2 2 Training and Qualification Effectiveness * 2 Licensing Activities 1 1 Not rated this assessment period due to limited inspection in this area during the perio *
Not Rated (new functional areas for SALP 6)
- During the previous assessment period this functional area included
" Modifications" which has been moved to the new " Outages" functional are *** The Radiation Protection portion of this functional area was rated Category i
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IV. PERFORMANCE ANALYSIS Plant Operations Analysis Evaluation of this functional area was based on results of routine inspections conducted by resident and region-based inspectors. Unit availabilities for this assessment period were approximately 77% for Unit 1 and 74%.for Unit Enforcement history in this area indicated a slight improve-ment in licensee performance since the previous assessment period. During this 18 month assessment period three
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violations (Severity Level IV) were identified in the operations area. One other violation is discussed in Section IV.I but involved operations personnel and procedures to some degre None of these violations had major safety significance. During the previous assessment period one Level III, one Level IV, and one Level V violation were identified over an 18 month period. The Severity Level III violation was issued for failure of an operator to be present at the controls at all times during operation of the facility. There have been no significant events involving operators since this violatio The number of reactor scrams did not change significantly since the previous assessment period (18 vs. 16 during SALP 5),
but the total number of scrams was high. However, only 5 of the 18 scrams occurred at greater than 15% power. Twelve of the scrams occurred on Unit 1; 6 while shutdown, 4 at less than 15% power, and 2 at or greater than 15% power. Six scrams occurred on Unit 2; 2 while shutdowr., I at less than 15% power, and 3 at or greater than 15% power. In addition, Unit 2 experienced an event at 0% power that resulted in only half the rods receiving a scram signal when a relay block dropped out during a surveillance test. Of the 18 scrams, 8 were the result of personnel errors, 2 of which were caused by operating personne Operator and management actions during' scrams and prior to restart were appropriat Investigations into the cause and subsequent corrective actions were comprehensive and satisfactor Operational events in this functional area did not indicate any notable change in performance since the previous assessment period. A 50% reduction in the number of LERs issued indicated e positive trend. However, the number of LERs caused by personnel errors remained about the same. Ten Licensee Event Reports (LERs) were submitted in the operations area during the assessment period. Of these 10 LERs, 8 were caused by personnel error. This compares to 20 LERs and 6 personnel errors in the operations area for the last SALP perio Of the 8 LERs caused by personnel errors during this assessment period, 2 resulted in reactor scrams and 1 resulted in an ESF
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c actuatio The licensee's response and subsequent corrective actions _ associated with LERs were generally adequat At the end'of the SALP period, the operations staff was short one. shift engineer and two shift foremen, partly due to increased staffing requirements imposed by a Confirmatory Action Letter (CAL) issued by the NRC in November 1986 (see Section IV.J). This required personnel to work overtime and days off in order to provide adequate shift coverage. The licensee was aware of the problem and was taking action to-increase staffing to alleviate the personnel shortag Authorities and responsibilities of the operations staff were generally well defined and usually followed. Operations personnel were experienced and knowledgeable of the plant and its characteristics and conducted themselves in a professional manne Conduct in the control room was usually businesslike and professional. The only distraction noted was the requirement for the control room operators to answer incoming calls to the facility during back shifts, weekends, and holidays. Though the updated phone system significantly reduced the operator's workload in this task, the requirement that operators answer incoming calls remains a distraction. The licensee made significant improvement in the area of control room behavior since the previous assessment period. This was an area of concern to the NRC due to past events, including an event which resulted in the Severity Level III violation discussed in SALP Management involvement to assure quality operations was eviden The station management devoted extensive effort to developing a Communication Center. The Center, which is operational, shifted much of the administrative duties, such as reviewing work requests and tagouts, from the Shift Engineer. This resulted in the Shift Engineer being able to devote more time to the operation of both units. The Communications Center does not bypass the authority of the Shift Engineer in those cases where his approval is needed. In addition, efforts to correct problems in the area of contrci room behavior, as described above, are further evidence of effective management involvement in plant operation . Conclusion
Licensee performance was rated Category 2 in this area. The i licensee was rated Category 2 during the previous assessment I perio . Board Recommendations None
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I' B. Radiological Controls i l Analysis Evaluation of this functional area was based on the results of routine inspections and speciel inspections performed i during this assessment period by region-based inspectors and observations by the resident inspector Enforcement history in this area remained about the same as during the last assessment period; two Severity Level IV violations and one Severity Level V violation were identifie These violations did not indicate any major weaknesses in licensee performance and had no major safety significanc Two vio) dions (one Severity Level IV and one Severity Level V)
were identified during the previous assessment period. Neither was of major safety significanc Licensee staffing remained strong. Key positions were filled on a priority basis, staffing was ample, and responsibilities were well define Several professional / technical personnel changes were made during the assessment period without degrading the radiation protection and chemistry program Administrative workloads were redistributed allowing health physicists to spend an increased amount of their working hours in direct observation and oversight of radiological wor i Licensee management involvement in assuring quality in this functional area was good. Audits and associated licensee responses were generally thorough. Several licensee programmatic improvements l in this functional area were implemented in response to audit findings. Corporate involvement in programs and incident investigations improved performanc Responsiveness to NRC initiatives was generally good, including the greatly improved QA/QC program in chemistry and radiochemistry, and the resolution of technical issues for achieving the levels of water quality control in the reactor system recommended by the BWR Owners Guideline Although the practice of rotating the Radiation / Chemistry Technicians (RCTs) between chemistry and health physics still persisted, engendering losses in their laboratory proficiencies, the licensee indicated an intention to discontinue the practice in the near future. Also, the licensee was slow in making new service water monitors operationa The licensee's approach to resolution of radiological technical issues was generally technically sound and timely. Tctal station doses in 1985 and 1986 were 991 and 949 person-rem, respectively. The per reactor doses were about 40 percent less than the national average for BWRs. There has been a continued downward trend in station dose since 1981. The downward trend was the result of an aggressive ALARA program which had strong management support and backin _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -
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Laboratory facilities were adequate, well-maintained, and utilized good, state-of-the-art instrumentation to do the )
required chemistry. A.QA/QC program tb assure the adequacy i of radiochemistry and chemistry analytical results was -
partially implemented. The program included control charts, 3 RCT performance tests, interlaboratory comparisons of analytical results and procedure revision The QA/QC program had substantially improved since the last assessment perio The results of the confirmatory measurements program remained satisfactory during this assessment period. Weaknesses in RCT proficiency were indicated when some technician errors were made while performing the analyses. The shortcomings in the Radiological Environmental Monitoring Program noted in the previous assessment period were correcte For liquid radwaste releases in 1986, tritium decreased by about one-third from the previous year; beta gamma activity releases increased by a factor of about 20 to 1.5 Ci due to a single incident resulting from a defective pipe linin For gaseous releases, noble gas activities of about 3000 Ci represented about a 50% decrease from the 1985 levels, while I-131 increased slightly (S%). The licensee's solid radwaste volume generation is declining because of the introduction and implementation of several volume reduction techniques. 'All released activities were well within Technical Specification limit The licensee had corrected previous problems with excessive numbers of data errors in the semiannual effluent reports by increased attention to editing. The number of personal contamination incidents and the extent of plant areas contaminated do not appear excessive. There were no radio-active materials transportation incident . Conclusion The licensee performance was rated Category 1 in this are The licensee was rated Category 2 during the previous assessment period. The improved rating was attributed to continued improvement by the licensee in the chemistry are . Board Recommendations Reduced NRC inspection effort is recommended in the area of radiological controls. No change in inspection levels in the area of chemistry is recommended until the fully implemented QA/QC program has been reviewe i
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- Maintenance i Analysis Evaluation of this functional area was based on the results of routine and special inspections conducted by resident and region-based inspectors. This functional area has changed since the last assessment period wher, modifications were included in this area. During this assessment period modi-fications were addressed under the " Outage" functional are Enforcement history did not indicate any significant regulatory concerns in this area. One Severity Level IV violation was identified this assessment period which is discussed in Section IV.I but involved n.aintenance personnel to some degree. This compares to no violations in the area of maintenance in the previous assessment period. The violation identified during this assessment period was not of major safety significanc Operational Events in the area of maintenance indicated weaknesses in the licensee's control of maintenance activitie Of 34 LERs attributable to the maintenance area, 11 were caused by personnel error. This compares to 3 LERs attributable to personnel errors in the maintenance area during the last assessment period. In addition, 7 of the total of 18 scrams were attributable to the maintenance area and 5 of these scrams were due to personnel error. There were also 8 Engineered Safety Feature (ESF) actuations due to personnel errors by the maintenance staf Management involvement to assure quality in the maintenance area was evident. Maintenance order backlogs were adequately controlled. The licensee had an average backlog of approxi-mately 1750 work requests in 1986 which was not considered excessive. Effective maintenance practices were illustrated by several indicators. Forced outage rates for the Quad Cities units were low at 2.7% for Unit I and 2.6% for Unit Good maintenance was also demonstrated by high equipment availability and an average of less than 4 control room annunciators up per month for each unit (based on a 15 month sample at greater than 50% power).
Staffing in the maintenance area was adequate. Overtime was adequately controlled and personnel were experienced and knowledgeable. Key positions were identified and authorities and responsibilities were define The condition of plant equipment was consistently monitored and trending was performed for preventive as well as corrective maintenance to ensure continued safe operation. While the licensee did not have a specific, formalized Preventive
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Maintenance (PM) program, the elements of such a program were-evident. For example, vibrational analysis, current and voltage traces for motor operated valves, and Environmental Qualification program, the " Recall Tracking List," and a section on preventive maintenance in station procedures constituted elements of a PM program. It was the licensee's goal to incorporate these elements into a broader, formalized PM progra Repair to environmentally unqualified electrical butt splices in Unit 2 was required in December 1986. Upon identification of the unqualified splices at another facility, licensee management took prompt action to shut the unit down until the repairs could be complete . Conclusion The licensee was rated Category 2 in this area. The licensee !
was rated Category 2 during the previous assessment perio . Board Recommendations None D. Surveillance Analysis Evaluation of this functional area was based on the results of several routine inspections conducted by resident and region-based inspector Enforcement history represented improved performance in this area. One Severity Level IV violation was identified during this assessment period in the area of adherence to surveillance and other procedure This violation is discussed in Section IV.I. The violation did not have major safety significance. This compares to the two Severity Level IV and four Severity Level V violations in the previous SALP perio These violations were also considered to be isolated instances and not of major safety significanc Few significant operational events were attributable to the area of surveillance during this assessment perio Eight LERs were the result of surveillance activities, but only 1 was the result of personnel error. Three reactor scrams occurred as a result of surveillance activities (one ,
at greater than 15% power), but again, only 1 was caused by personnel error. No missed surveillance were identified during this assessment perio Management involvement to assure quality in this area was extensive. This was apparent by several indicators including:
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- surveillance and inservice inspection activities were well managed and performed in a very professional manner; authorities and responsibilities were clearly defined; activities were controlled by well stated and defined procedures; the site was decertified for ASME, NA, and NPT Stamps; personnel were knowledgeable and proficient; prior planning was well developed; surveillance records were complete, well maintained, and readily available; and audit reports were complete and thorough. Weaknesses noted during the SALP 5 period, such as an inadequate procedure review process, were corrected early in the assessment period. Aggressive management involvement in this area resulted in no similar occurrences during this assessement perio .
Staffing in this area was adequate. Discussions with personnel
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necessar I The licensee's approach to resolution of technical issues from a safety standpoint was appropriate. The licensee's actions in response to NRC Generic Letter 84-11, " Inspections of BWR Stainless Steel Piping," were generally sound and conservatism was' demonstrated by the number of welds selected for examinatio The licensee's response to the Generic Letter was timely and thoroug . Conclusion The licensee was rated Category 1 in this area. The licensee was rated Category 2 during the previous assessment perio l The improved rating is attributable to no missed surveillance, improved enforcement history, and extensive management involve-ment in this area during the assessment perio . Board Recommendations Reduced NRC inspection effort in this area is recommende E. Fire Protection Analysis Evaluation of this functional area was based on the results of routine inspections conducted by the resident ir.spectors and reviews conducted by the Office of Nuclear Reactor Regulation (NRR).
Enforcement history in this area represented a slight decline in performance during the assessment period. One violation (Severity Level IV) was identified this assessment period which concerned the lack of fire detection equipment on the refuel floor which was required by the licensee's Operating
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License. An enforcement conference was-held on November 19, 1985, to discuss-this issue. The licensee has requested relief' J from.this commitment and this request is under review by the )
NRC. .One Severity Level V violation was identified during the previous SALP perio Management involvement to assure quality in the area of fire protection has been adequate; however, some deficiencies were
'noted. In addition to the violation described .3bove, some additional discrepancies were identified by the licensee at the enforcement conference on November 19, 1985. These discrepancies included cable separation concerns and protection of electrical' distribution panels from falling debris. The licensee immediately took corrective actions'to rectify these discrepancie Nearly all plant modi,fications resulting from the NRC staff fire protection review were completed. In' response to a request from NRR, the licensee has verbally committed to complete all modifications necessary to meet the requirements of 10 CFR 50, Appendix R by June 10, 1987. This commitment also included " Appendix R Safe Shutdown Procedures," and ;
implementation and completion of on-shift training. Remaining ;
technical and schedular exemptions, currently under staff review, will be issued where appropriat Management involvement in the area of housekeeping was excellen Station cleanliness continued to' improve and it was noted that l attention to cleanliness did not diminish during the refueling outage . Conclusion l The licensee was not rated in this area due to limited inspection effort during the assessment period. The licensee was rated Category 2 during the previous assessment perio The Board recognizes the licensees efforts in the area of housekeeping which led to an improved level of station cleanlines . Board Recommendations The NRC will be conducting an inspection in July 1987, to assess the licensee's compliance with 10 CFR 50, Appendix R at the Quad Cities facilit F. Emergency Preparedness Analysis Evaluation of this functional area was based on routine inspections, one exercise inspection, and one special inspection to review the status of previously identified open items conducted by regional-based inspectors during this assessment period .
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Enforcement history represented an improvement in licensee performance during this assessment period. No violations were identified compared to one violation identified during the previous assessment perio Management involvement in assuring quality in this area needed improvement. Several deficiencies were evident as indicated
'by weaknesses identified in the Quad Cities.1986 annual exercise. These weaknesses concerned communication in the Technical Support Center, adequacy of the Post Accident Sampling procedure (labeling and storage of samples), and the timeliness of the Emergency Operations Facility (EOF) activatio The licensee's approach to resolution of technical issues from a safety standpoint was adequate. However, more attention is needed to aggressively address open items. A special inspection performed prior to the end of the SALP period specifically to examine licensee progress to resolve open items, including items identified during the 1986 annual exercise, found that ,
many of the items had yet to be addressed. The licensee continued to work at resolving these issues. There were no long-standing regulatory issues attributable to the license Staffing was a problem area, with three individuals holding the position of Emergency Preparedness Coordinator at different times during the assessment period. These personnel changes, and.the apparent lack of'an adequate turnover of information to the succeeding Coordinators, led to a loss of continuity in the progra The recent selection of an experienced Rad / Chem foreman for the Emergency Preparedness Coordinator position should be an improvement in overall staffing in this functional are Staff training and qualification effectiveness were adequate, as demonstrated by the elimination of any violations during the SALP period; however, tracking and documentation of training must be improved. The methods used by the licensee to track completed training resulted in Control Room personnel missing their semiannual emergency training. The licensee identified this deficiency during a QA audit and was addressing this matte . Conclusion Licensee performance was rated Category 2 in this are The licensee was rated Category 1 in the last SALP perio The decline in rating can be attributed to a decline in performance during the annual exercise, slow progress in resolving open items, and some problems noted in the area of staffin . Board Recommendations None
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G. Security Analysis Evaluation of this functional area was based on the results of one routine security inspection conducted by a region-based physical security inspector, and routine inspections conducted by the resident inspectors to observe security activitie Enforcement history represented an improvement in licensee performanc No violations were noted in this functional area, compared to one Severity Level III violation noted during the previous assessment period for failure to adequately control access to a vital are The licensee's responsiveness to NRC initiatives was excellen !
Security management was responsive to all findings that could strengthen their program. Site management, up to the plant manager level, were cognizant of and responsive to security findings. A high level of security awareness existed within the plant workforc Security event reports (SERs) were significantly reduced during this assessment period. Seven SERs were submitted this period compared to 28 SERs during the previous assessment period. Three of the SERs were caused by personnel error, the remaining four were equipment related. None of the SERs were repetitive. Security event reports were submitted in a timel manner and corrective actions were effective and technically soun Overall staffing levels remained consistent during this assessment period. Supervision of the contract security force was strengthened by increased manning of the alarm station during normal working hours, and establishment of a full-time administrative supervisor. Position responsibilities were clearly define Site security management involvement was aggressive. High standards of performance, appearance, and demeanor were expected and achieved by the security organization. Liaison with the maintenance department was effective in assuring timely maintenance support for all security equipmen Security system improvements during this assessment period included installation of additional closed circuit television (CCTV) cameras; replacement of CCTV monitors; use of computers within the badge fabrication section and for training support ,
within the contract security department; increased office ;
space; and replacement of a major component of the perimeter {
alarm system. The need to appoint an Assistant Station
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Security Administrator was noted by licensee management. This action was completed subsequent to the end of the assessment perio _ _ _ - _ _ _ _
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. Corporate security department support continued to be effectiv ;
The Nuclear Security Administrator actively participated in !
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resolving issues and maintained close liaison with site security management. Administrative support for licensing issues was timely and technically correct. Effective communications were maintained with the NRC Region III security section. This level of corporate security support needs to continu In summary, enforcement history and security event reports improved during this assessment period. Security equipment was upgraded and continued to be well maintained. The security organization was effectively managed by competent supervisors who were responsive to NRC findings and concer . Conclusion The licensee's performance was rated Category 1 in this are The licensee was rated Category 1 during the previous assessment perio . Board Recommendations None
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H. Outages Analysis i
Evaluation of this functional area was based on the results of inspections conducted by resident and region-based inspector Two major outages for refueling occurred during the assessment period. Each unit was shut down for about three months during its refueling outag Enforcement history in this area continued to demonstrate a need for improvement in the area of design reviews when {
modifications are made to the facilit Two Severity Level IV !
violations were identified for failure to perform adequate (
design reviews in accordance with 10 CFR 50.59. Each violation )
was for several modifications which were made without adequate )
design reviews, indicating weaknesses in the licensee's program i to comply with 10 CFR 50.59. Inadequate design review was also !
identified as a weakness during the SALP 5 assessment perio j The violations issued during this assessment period indicated I that the licensee's corrective actions were not totally i effectiv The licensee's Modification Task Force created as l a result of the NRC's Safety System Outage Modification Inspection (S50MI) performed at the Dresden facility identified many weaknesses, ir.cluding inadequate 10 CFR 50.59 review The licensee has instituted corrective action programs to address identified weaknesses, including problems with j
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10 CFR 50.59 reviews. The.NRC is reviewing the licensee's programs and believes they will be adequate to correct these 1 deficiencies at all of their facilitie )
Operational events associated with outage and modification activities were additional evidence of problems in the area of ,
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design reviews when modifications are made to the plant. Of seven LERs attributable to this functional area, three were f '
caused by personnel error because of inadequate design revie Two of these were discovered as the result of ESF actuation L Management involvement to assure quality in this area was k !
adequate, with the exception of 10 CFR 50.59 reviews as described above. .Following heightened NRC attention from problems that arose during the first refueling outage, management aggressively pursued the area of outage planning resulting in fewer personnel errors and fewer ESF actuations !
during the second refueling outage of this assessment perio Management involvement was also evident in assuring quality procedures and test practices for core performance related activitie In addition, improvement was noted in the !
licensee's startup testing program and program implementatio Management controls consistently showed evidence of prior !
planning and involvement in refueling and other outage activitie Procedures were clearly written and provided corrective action for emergency situations. Personnel had a .
good understanding of work practices and procedures were !
adhered to. Fuel handlers were knowledgeable of their duties and handled fuel ~in a safe manner without error. The licensee :
experienced some problems with the new refueling bridge, which was being used for the first time, but had adequate management j support for resolving these problems in a timely manner. Fuel i movements were conducted in strict adherence to approved :
procedures with good cleanliness and radiological controls i being followed. Records were complete, well maintained, and available. Records also indicated that equipment had {a certifications which were current and complete when req.uire ;
Licensee responsiveness to NRC initiatives was demonstrated by corrective actions on previously identified items which were both timely and effective. The licensee's responses to inspector concerns were excellent. The licensee's actions taken in response to the drywell steel liner deterioration observed at Oyster Creek were timely and an acceptable thickness measurement technique was expeditiously implemente Staffing was adequate with responsibilities clearly define Discussions with personnel performing outage related activities indicated that they were knowledgeable in their job.' Records indicated that personnel were trained and qualified. In May 1986, the position of Outage Coordinator was changed to that of Assistant Superintendent of Work Planning. The thrust of the
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change was to provide long range planning for refueling outages, short outages, and outages caused by unanticipated .
trip Several work planning meetings occurred throughout the l day with the result of better communication among the various department . Conclusion The licensee was rated Category 2 in this area with an improving trend near the end of the assessment period. This area was not rated during the previous assessment perio . Board Recommendations None
. Quality Programs and Administrative Controls Affecting Quality Analysis Evaluation of this functional area was based on the results of routine inspections conducted by resident and region-based inspector Enforcement history in this area represented relatively unchanged licensee performance. Three violations (two Severity Level IV and one Severity Level V) were identified during this assessment period and three violations (one Severity Level IV and two Severity Level V) were also identified during the previous assessment period. None of these violations were of major safety significanc One Severity Level IV violation identified during this assessment period had five examples of failure to adhere to procedures. These examples involved operations, maintenance, and surveillance personnel / activities and, therefore, are referred to in each of these functional area Management involvement to assure quality in this area was evident. Activities such as Bulletin responses and inspections of safety-related supports were controlled through the use of well stated and defined procedures. Records were found to be generally complete, well maintained and available. Observations indicated that the personnel performing these activities had an adequate understanding of work practices and that procedures were adhered to. NRC reviews indicated that performance was acceptable in the areas of the licensee's QA Program annual review; QA/QC administration; the test and experiments program; the receipt, storage, and handling program; and the calibration program. Qualfly Control (QC) reviews all work requests to determine if a QC Hold Point is needed. Observations of QC personnel performing inspections indicated that they were
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knowledgeable in their duties. A noteable example of management involvement was the improvements made in the area of control room behavior as discussed in Section I '
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. Subsequent to the inspection period an inspection was performed which identified two violations concerning the licensee's LER program. Increased attention to this area by licensee management is warranted to ensure these problems are corrected. During the previous SALP period concerns were identified in the procurement area. The procurement area was not reviewed during this assessment period because of limited resource The licensee's approach to resolution of technical issues from a safety standpoint was adequate. The approach used to resolve problems identified during piping system support reviews was generally conservative and technically sound. One weakness noted in this area was inadequate design reviews unde CFR 50.59 as described in Section IV.H. In late 1986, the licensee adopted a company-wide Quality Assurance practice where a Safety System Functional Inspection (SSFI) program would be undertaken at each facility. This program would review all modifications to selected safety systems, design tests and analysis versus Final Safety Analysis Report (FSAR) specifi-cations, surveillance versus Technical Specification requirements, and field verification of these systems. Near the end of the assessment period, an SSFI was performed at Quad Cities on the High Pressure Coolant Injection (HPCI)
system because of numerous problems experienced with this system. The licensee's report on the results of the SSFI had not been issued prior to the end of the assessment perio Licensee responsiveness to NRC initiatives was appropriat One violation identified this SALP period pertained to lack of corrective action for excessively leaking containment isolation valves. Once the specific issue was identified to the licensee their actions were prompt and extensive. The licensee's responsiveness to IE Bulletins was generally timely, sound, and thoroug . Conclusion The licensee was rated Category 2 in this area. The licensee was rated Category 2 during the previous assessment perio . Board Recommendations None J. Training and Qualification Effectiveness Analysis Evaluation of this functional area was based on the results of licensed operator replacement and requalification examinations conducted during this assessment period, and regional based
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i inspections. In addition, this evaluation reflects a special
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performance based requalification training inspection and a corresponding management meeting addressing deficiencies identified through the requalification examination Enforcement history in this area represented performance that conformed to NRC regulation No violations or deviations were identified during this assessment perio Management involvement to assure quality in this functional area needed improvemen Replacement examination success rates during the assessment period were above the national average; however, requalification examinations administered during the weeks of September 15 and October 13, 1986, identified major deficiencies in the knowledge and use of normal, abnormal, and emergency procedures, and technical specifications. The pass rates for these two exams were as follows: Sept. 86 - 25% of R0s passed, 50% of SR0s passed; Oct. 86 - 85% of R0s passed, 55% of SR0s passed. In accordance with established criteria in NUREG-1021, the requalification i program was assigned an overall unsatisfactory rating. A Confirmatory Action Letter (CAL) was issued to document interim corrective action commitments. The special inspection conducted as a result of the excessive rate of examination failures identified major deficiencies'in the licensee's requalification program. These findings indicated a need for increased management attention to assure the maintenance of satisfactory operator qualification Feedback on events for training purposes was evident. Station deviations, LERs, and other event information were made part of licensed operators' required reading. Training in areas other than operator requalification training was generally good, i This was illustrated by no LERs or deviations which occurred due to poor trainin The licensee's responsiveness to NRC initiatives also needed improvement. Deficiencies dealing with the knowledge and use of emergency procedures identified during the requalification examinations had been previously identified during replacement examinations. Although this item had been discussed at length with plant site representatives, no subsequent improvements in this area were evident. In response to the CAL issued by the NRC and the special inspection conducted as a result of the unsatisfactory requalification training program, the licensee j
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committed to an accelerated requalification program and a long term requalification improvement plan during the November 13, i 1986, management meeting. The NRC has performed periodic audits j of the accelerated requalification program throughout its implementation and has noted satisfactory performanc ]
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Staffing in the operator training area was to be increased in
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conjunction with commitments made in the long-term requalifi-cation improvement plan. This was necessitated by the ,
implementation of additional training program requirement I In the radiation protection and chemistry areas, a retraining '
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program for RCTs was implemented in 1985, along with a new on-the-job training manual directed toward INP0 accreditation, i The radwaste operators have an improved training program '
involving classroom, on-the-job training, and written examination The licensee made a complete and timely submittal for INP0 accreditation and subsequently had received INPO accreditation for all of the ten areas subject to accreditation by the end of this assessment perio . Conclusion
l The licensee was rated Category 2 in this functional are J The licensee was not rated in this area during the previous assessment perio ,
i Board Recommendations J Requalification program improvements implemented near the end of the assessment period and those planned for future implementation should be continued. The increased licensee management and NRC attention should remain high in this area ,
to assure that these programmatic changes are completed and determined to be effectiv Licensing Activities Analysis Evaluation of this functional area was based on the licensee's I performance in support of significant licensing actions which !
progressed and/or were accomplished during the assessment l period. A total of 97 licensing actions were completed during .
this SALP perio l In general, the licensee demonstrated a high level of manage-ment involvement and control in assuring quality. As a direct result, most licensee submittals received by NRR have been technically and administrative 1y complete. However, during the SALP period there were two examples (e.g. " Containment Oxygen Control" and " Containment Pressure Set Point and MSIV Surveillance" Technical Specifications change requests)
of poor quality contro The deficient content of these i particular applications necessitated licensee management ;
intervention to ensure superseding resubmittals were promptly issued and technically complete. Subsequent applications have continued to represent the previous high standard of quality.
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,a . Licensee management has developed a total awareness and control of the.various licensing issues by virtue of its extensive experience in the industry, inhouse technical-expertise, and active participation in Owners Group and professional organization activities. Licensee management consistently took actions in a timely manner to ensure safety issues were properly addressed. Examples of this attribute were the responses to an NRC need for additional information regarding Technical Specification changes for restart of Quad Cities 2 in February 1987 and various Salem Anticipated Transient Without Scram (ATWS) items. Other examples have included ATWS and NUREG-0737 related Technical Specification amendments and the resolution of Generic Letter 83-43, concerning LER reporting requirement During this rating period, satisfactory resolution and completion of the following major technical issues were accomplishe Mark I Drywell Vacuum Breaker (D-20)
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Diesel Generator Reliability Technical Specification (D-18)
TMI-SI . I.D.1.2 DCRDR Summary Report (F-71)
Intergranular Stress Corrosion Cracking (IGSCC) related inspections and evaluations Satisfactory resolution and/or progress of the above-stated work demonstrated that the licensee's staff understood complex technical issues, not only in terms of their technical nature but also in terms of plant safety, plant operation, and responsiveness to regulatory concern During the assessment period several issues were identified ,
for which prompt and effective action was necessary. In i each case, the licensee quickly analyzed the problem, developed a program plan, and took the necessay action to provide interim repairs (e.g., IGSCC), or other appropriate actions, to satis-factorily resolve the issue from a safety standpoint. Another such example of this kind of problem resolution is the on going embedment plate issue, initially identified at Dresden. The licensee's actions in these cases demonstrated a sound under-standing of, and an ability to deal effectively with, complex l technical problem Open and effective communication channels exist between the NRC and the licensee's licensing staffs. Effective dialogue between both staffs have promoted timely and technically sound f responses to NRC initiatives. The licensee met all established .
commitment dates or provided a written submittal explaining )
the circumstances and established a new firm date. Where ;
applicable, conference calls with the staff were promptly i established and always included appropriate engineering, plant l and/or contractor personnel. The licensee's Nuclear Licensing Administrator and/or management in almost all cases worked very
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well with NRR to coordinate resolution of each licensing or -
technical issu The Station or Corporate office has. rarely failed to accommodate an NRC-initiated program (such as a special study, evaluative l program, or survey being conducted by or for NRC), even where
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such accommodation was clearly not obligatory. The station 3 characteristically made available~their most knowledgeable people to assist the NRC staff and/or contractor in such ;
activitie Even extraordinary staff requests (e. g., UT '
examinations for drywell shell corrosion at Quad Cities 1 .i and 2) were responded to immediately and completed successfull Commonwealth's engineering staff, in concert with the licensing staff, assured that most engineering work, either done in-house or performed under.its direction by contractors, adequately addressed the complex and technical licensing issue . Conclusion The licensee was rated Category 1 in this functional are .
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The licensee was rated Category 1 during the previous I assessment perio . Board Recommendations-None i
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- SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 1 During this assessment period, Quad Cities 1 engaged in routine full power operation or Economic Generation Control (EGC) for extended periods. Unit 1 experienced 23 forced outages, 14 ESF Actuations, and 12 reactor scrams (2 > 15% power, 4< 15%
power, and 6 with no rod movement). The average plant avail-ability during the assessment period was approximately 77%. ~
Significant outages / major events which occurred during the assessment period are summarized below:
Significant Outages / Major Events November 15 - 21, 1985: Unit I was shutdown in preparation for a scheduled maintenance outag November 24 - 26, 1985: Unit 1 was shutdown for a maintenance outage (environmental qualification).
In addition work was required on an Emergency Diesel Generator (EDG). January 5 - April 6, 1986: Unit I was shutdown for an extended refueling and maintenance outage. This was the end of Cycle 8. Planned activities during this outage included: repairs of recirculation piping; replacement of the 125V DC battery; and HFA relay wor May 15 - 18,1986: Unit 1 was shutdown for a scheduled maintenance outag Planned activities during this outage included: replacement of all Intermediate Range
, Monitors (IRM); control rod drive replacements; minor repairs to the Electro-Hydraulic Control system (EHC);
and repairs of the startup feedwater regulator valv July 8 - 9, 1986: Unit I was shutdown due to high conductivity. The licensee remained shutdown to repair leaking main condenser tube August 29 - September 5, 1986: Unit I was shutdown to repair a Main Steam Isolation Valve (MSIV) which failed during surveillance testing and a bent Low Pressure Coolant Injection (LPCI) loop 'A' valve ste November 7 - 18, 1986: Unit 1 was shutdown for a scheduled outage. Major outage activities included:
The installation of 345kV breakers; and the replacement of the 250V DC batter _ _ .--. _ _. __ __ _ ___ ______ _ ____________ _ __ _
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' December 5 - 9, 1986: Unit 1 engaged in a scheduled shutdow to repair and upgrade certain drywell penetrar. ion splices to meet Environmental Qualification (EQ) standard March 13 - 16, 1987: Unit 1 was shutdown for a planned weekend outag Major activities included: modification ,
of the Reactor Core Isolation Cooling (RCIC) low oil !
pressure trip instrumentation; inspecting the main steam condensor for tube leaks; installation of caps on the turbine instrument rack drain lines; and additional IRM replacement . Unit 2 '
During this assessment period, Quad Cities 2 engaged in routine i full power operation or Economic Generation Control (EGC) for extended periods. Unit 2 experienced 20 forced outages, 12 ESF actuations, and 6 reactor scrams (3 > 15% power, 2 < 15%,
I with no rod movement). The average plant availability during the assessment period was approximately 74%. Significant outages / major events which occurred during the assessment period are summarized below: ;
Significant Outages / Major Events October 15 - 24, 1985: Unit 2 experienced a reactor scram from 100% power due to a valving error on a low water level surveillance. The licensee elected to go to cold shutdown and performed EQ modifications in the ,
drywell . In addition the' Reactor Water Cleanup.(RWCU) '
and reactor building equipment drain pumps were repaire November 7 - 9, 1985: Unit 2 was placed in cold shutdown for maintenance on the EHC pressure regulator and to repair the inner seal of the 2B Recirculation Pump.
" February 21 - 22, 1986: Unit 2 was shutdown for a short scheduled maintenance outage to perform battery discharge test March 3 - 4, 1986: Unit 2 was placed in cold shutdown for repairs on the HPCI syste !
l May 30 - June 5, 1986: Unit 2 was shutdown for a ]
scheduled maintenance outage. Activities conducted J during the outage included: IRM repairs; checking for j main condenser tube leaks; and repair of one outboard j MSIV head ven i l
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September 7 - 11, 1986: Unit 2 was shutdown to repair the Standby Liquid Control (SBLC) syste October 11, 1986 - January 22, 1987: Unit 2 was shutdown '
for a refueling outag Major activities for the outage included: HFA relay replacement; weld overlays; recirculation loops and RWCU system decontamination; main turbine overhaul; installation of a new rod worth minimizer; and the addition of a new line breaker in the switchyar January 23 - 25, 1987: Unit 2 was shutdown to repair main condenser tube leaks and RCIC pipin February 18 - 20, 1987: Unit 2 was shutdown to repair ,
a failed drywell to torus vacuum breake Inspection Activities There were 30 inspection reports issued during this assessment period, October 1, 1985 thorugh March 31, 1987. Major or significant inspection activities are listed in paragraph 2 of this section, Special Inspection Summar . Inspection Data Facility Name: Dead Cities Unit: 1 Docket N Inspection Reports Nos.: 85001, 85026 thru 85031, 86001 thru 86021, and 87002 thru 87003, and 87005 Facility Name: Quad Cities Unit: 2 Docket No.: 50-265 Inspection Reports No.: 85001, 85029 thru 85033, 86001 thru 86021, and 87002 thru 87003, and 87005 i
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- Table I Number of Violations in Each Severity Level UNIT 1 UNIT 2 COMMON TO BOTH-Functional Areas I II III IV V I II III IV V I II III IV V A .' Plant Operations 3 Radiological Controls 1 11 Maintenance l Surveillance Fire Protection / Housekeeping 1 Emergency Preparedness Security Outages 2 Quality Programs 1 1 1 and Administrative Controls Affecting Quality Training & Qualification Effectiveness Licensing Activities UNIT 1 UNIT 2 COMMON TO BOTH TOTALS _I _I.I. III IV V
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_I _I_I. III IV V _I _I_I III IV V 3- 37 q7 Special Inspection Summary February 3-6, 1986: A special Radiological Environmental Monitoring Program (REMP) inspection was conducte Included in this inspection was review of offsite dose calculations and manual oversight review of monthly / annual reports (254/86003; 265/86003).
i August 27, 1986: An emergency preparedness exercise was I conducted during the assessment period (254/86011; 265/86011). Investigation and Allegations Review ,
No allegations relating to Quad Cities were received in Region III during this assessment perio Escalated Enforcement Actions No Civil Penalties, Orders, or other Escalated Enforcement Actions were initiated during this assessment period for Quad Citie , Licensee Conferences Held During Assessment Period November 19,1985, (Region III Offices): Enforcement Conference with licensee representatives to discuss the {
licensee's failure to implement certain fire protection license conditions at the Dresden and Quad Cities facilitie .
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- - January 10, 1986, (Region III Offices): Management meeting with licensee representatives to discuss the results of the Quad Cities SALP 5 assessmen . January 23, 1986, (Region III Offices): Management meeting with licensee Corporate and Plant Supervision to discuss intergrated leak rate testing issue . January 23, 1986, (Region III Offices): Management meeting with licensee representatives to discuss the NRC incident response pla . November 13, 1985, (Region III Offices): Management meeting with licensee representatives to discuss the results of the requalification examinations for operators at Quad Cities held during the months of September and October 198 . January 16, 1987, (Quad Cities Site): Management meeting with licensee representatives to discuss the requalification examinations given at the Quad Cities. facilit F. Confirmatory Action Letters (CALs) CAL-RIII-86-007, dated November 10, 1986: This letter i~
was in regard to the results of the Quad Cities licensed operators requalification examinations administered during the weeks of September 15, 1986, and October 13, 198 . CAL-RIII-86-007, Amendment 1, dated November 14, 1986:
This letter documented the results of the November 13, 1986, meeting between licensee representatives and Region III staff. The letter addressed the licensee's plans for upgrading the licensed operator training progra G. Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted by the Licensee CFR Part 21 Reports l I
f One 10 CFR Part 21 Report, concerning loose lugs on 250V Gould National Battery (GNB) battery cables, was issued during !
the assessment period for Units 1 and 2. This item was closed prior to the end of the assessment perio j Licensee Event Reports (LERs)
Quad Cities Unit 1 Docket No.: 50-254 LER Nos.: 85017 thru 85022, 86001 thru E6039, and 87001 thru 87004
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6 Forty-nine LERs were issued during this assessment period;.
19 LERs were the result of personnel errors; 6 LERs were the result _of procedure inadequacies; 10 LERs were the result of-component / equipment failures; and 14 LERs fell into other categories (i.e., external causes, unknown human, undefined, andother.)
Quad Cities Unit 2 ~q Docket No.: 50-265
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LER Nos.: 85020 thru 85023, 86001 thru 86021, and 87001 thru 87004 .
I Twenty-nine LERs were issued during this assessment period; 12 LERs were the result of, personnel errors; 4 LERs were the result of component / equipment failures; 3 LERs were related to design problems; and 10 LERs fell into other categories (i.e;,
external causes, unknown human, undefined, and other.)
-CAUSE AREAS SALP 5 SALP 6 Personnel / Unknown Human 15 34 Design Problems 5 3 External Causes 0 1 Procedure Inadequacies 2 6 Component / Equipmen Other- 37 15 t Unknown 0 5 l
Total' 59 78
, NOTE: The above information was derived from review of LERs performed by the NRC staff and may not completely coincide with the unit cause assignments which the licensee would mak In addition, this table is based on assigning one cause code for each LER and does not necessarily corre-spond to the identification of LERs addressed in the i Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each even The frequency of issuance of LERs increased since the previous SALP. During SALP 5 59 LERs were identified over a 16 month assessment period or an average of 3.7 per month compared to i an average of 4.3 LERs per month during this assessment period. The percentage of LERs which were caused by personnel j error / unknown human increased during this assessment period, i from 25% (during SALP 5) to 44%. 1 Analysis and Evaluation of Operational Data (AE0D)
The results of the Office of Analysis and Evaluation of ,
Operational Data (AE0D) assessment of 15 LERs for this I
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assessment period indicated a significant improvement in quality of the licensee's issued LERs. AE0D assessed an .
average score of 9.2 out of a possible 10 points, compared '
to the previous overall average score of 7.5 and a current industrial average score of 8.3. Strong points identified during the AEOD review included the licensee's discussions concerning failure mode, mechanism, and effect of failed components and the personnel errors / procedural deficiencie AE00 indicated that improvements in the identification of
' failed components in the text could be mad A recent inspection (254/87009; 255/87009) by inspectors from Region III's Quality Assurance Programs Section reached a
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different conclusion than the AE00 assessment (based on a
. limited sample). This inspection resulted in two violations related to a lack of a documented procedure for LER processing and failure to determine the cause and take corrective action to preclude repetition of the event H. Licensing Activities There were 6 NRR site visits / meetings / licensee management conferences held during the assessment period. There were 24 license amendments issued during the assessment period. There were no Commission meetings held, scheduled extensions granted, reliefs granted, exemptions granted, orders issued, or issues pending this assessment perio >
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