IR 05000254/1993025
| ML20059G182 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/25/1993 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059G155 | List: |
| References | |
| 50-254-93-25, 50-265-93-25, NUDOCS 9311080028 | |
| Download: ML20059G182 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
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REGION Ill Report Nos. 50-254/93025(DRP); 50-265/93025(DRP)
Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30 -
Licensee: Commonwealth Edison Company U Executive Towers West Ill !
1400 Opus Place, Suite 300 *
Downers Grove, IL 60515 ,
Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2 Inspection At: Quad Cities Site, Cordova, Illinois Inspection Conducted: August 21 through September 30, 1993 Inspectors: T. E. Taylor P. F. Prescott i R. K. Walton '
J. R. Roton Approved By: /9!2f!93 i Pat-Hiland, Chief ' Date Reactor Projects Section IB
Inspection Summarv ,
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Inspection from Auaust 21 throuah September 30. 1993 (Report Nos. 50-254/93025(DRP): 50-265/93025(DRP1)
Areas Inspected: Routine, unannounced safety inspection by the resident and regional inspectors of licensee action on previously identified items, licensee event report review, operational safety verification, monthly -
maintenance observation, monthly surveillance observation, and event l Results: Of the areas inspected, four violations were identified in paragraphs 2, 4a, 4b, and 6b, One violation with two examples was. cited pertaining to inadequate procedures. One violation was identified concerning inadequate corrective actions to prevent recurrences of personnel error Another 1 violation was identified regarding a missed 50.72 report when a plant- .j condition was found outside of the design basis. Lastly, one violation was ;
identified concerning inadequate test control of core spray check valves. In I the remaining areas, no violations were identifie hk a
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EXECUTIVE SUMMARY' ;
Plant Operation ~!
Operators performance in procedural adherence and self-check was poo I Instances of failure to perform surveillance procedures as written and ;
operating wrong equipment.were identified. In addition; weaknesses in .
equipment attendants' system knowledge and pre-job briefings were identified ,
during high pressure coolant injection (HPCI) system surveillances . ;
Maintenance and Surveillance 1 Multiple equipment problems were noted during the report period. Many of the items could have been avoided, or the impact on _ plant operations 1essened, by better maintenance performanc ,
Suncort j Material condition and housekeeping improved with two exceptions. The =;
radiological waste basement area is in need of management attention; equipment i and material condition is considered poor. In addition, the Unit 2 trash >
compacting area needs management attentio Enoineerina and Technical Support '
System engineering directed closure of a valve which rendered the normal level control for the HPCI steam exhaust drain pot inoperable. This placed the HPCI system in a similar condition which caused a June 1993 rupture disc failur This identified an immediate need for aggressive management evaluation and oversight of system engineer activitie System engineer review of the adequacy of preventive maintenance '(PM)
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activities is a concern. A review, prompted by the inspectors, identified
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several vendor recommended preventive maintenance activities absent from the present diesel generator PM progra Additionally, several equipment deficiencies identified during this report period could have been avoided, or their impact on plant operations lessened,-
by better engineering efforts.
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L DETAILS i
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i l Persons Contacted i Commonwealth Edison comoany (Ceco)-
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R. Pleniewicz, Site Vice President ;
- R. Bax, Station Manager _
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l *D. Bucknell, Assistant Technical Staff Supervisor j l- J. Burkhead, Quality- Verification Program Supervisor j
- G. Campbell,-Incoming Station Manager ;
- D. Cook, Administrative Operating Engineer ;
D. Craddick, Assistant Superintendent - Maintenance 1 l
- J. Dierbeck, Maintenance Supervisor d l D. Gibson, Master Mechanic l H. Hentschel, Operations Manager ;
- D. Kanakares, Regulatory Assurance, NRC Coordinator _;
G. Klone, Operating Engineer - Unit 1 l'
J. Kopacz, Operating Engineer - Unit 2 l- J. Kudalis, Support Services Director .!
- K. Leech, Security Administrator 'l l
B. McGaffigan, Assistant Superintendent - Work'P1anning~ ;
l A. Misak, Regulatory Assurance Supervisor l
- B. Moravec, Site Engineering and Construction' Manager
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- T. O' Leary, Site Quality Verification Engineer
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B. Strub, Assistant Superintendent, Operations j
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i * Denotes those attending the exit-interview. conducted on September 30, _ -l 199 O l
The inspectors also talked with and interviewed .several other licensee- ;
i employees, including engineering, operations, ' maintenance, and contract <l L security personne . Licensee Action on Previously Identified Items (92701. 92702)
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A review of licensee responses to Notices of Violation and' followup to )
an unresolved item was performed to determine that the responses and - l stated corrective actions were timely and appropriate, that an in-depth -1 l root cause analysis was conducted, that appropriate changes in-training li or' procedures were implemented, that generic implications were addressed, and that the licensee's quality assurance (QA) program j practices and precedures, when appropriate, were strengthened-to prevent- !
recurrence. Based on this review, the following violations were close (Closed) Violation 254/92011-01a(DRP): Failure to Provide: Adequate :
Instructions for the Repair of the High Pressure Coolant Injection .!
(HPCI) Turbine Stop Valv !
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(Closed) Violation 254/92011-Olb(DRP): Failure to. Provide _ Adequate l Instructions in the Performance of Surveillance Procedures Associated With the Hydrostatic ~ Testing of the Unit 2 Reactor Vesse (Closed) Violation 254/92022-Ola(DRP): Failure to Perform Turbine Control Valve f ast Closure Scram Instrumentation Functional TestingL in Accordance with an Adequate Procedur (Closed) Violation 254/92022-Olb(DRP): Performing Valve Manipulations l in Conjunction With Surveillance Procedure WCP 1300-1, "Drywell and-Suppression Chamber Venting and Purging," Not Prescribed Within the Procedur (Closed) Violation 254/265 92025-04(DRP): Failure to Perform Troubleshooting of a Ground on the Unit 1 125 Vdc Electrical System With a Procedure Appropriate to the Circumstanc .(_ Closed) Violation 254/265 92025-06a. 06b. and 06c(DRP): Failure to Perform Activities Affecting Quality in Accordance With Prescribed Procedure (Closed) Violation 254/265 92028-01(DRP): Failure to Complete Corrective Actions in a Timely Manne (Closed) Violation 254/265 92028-02(DRP): Failure to Install a l Temporary Alteration on a Reactor Vessel Level Transmitter With an l Approved Procedure.
r (Closed) Violation 254/265 93004-03(DRP): Failure to Perform Required Logic System Functional Testing of the HPCI and RCIC System in Accordance With Technical Specification 4.5.C.5 and 4.5.E.5.
l (Closed) Violation 254/265 93008-03(DRP): Failure to Perform ,
Calibrations of the 1/2 Diesel Generator Barton Flow Meter With an ;
Approved Procedur ]
(Closed) Unresolved Item (50-254/93015-03 (DRP)): Inspection Report 50-254/93013, paragraph 5, discussed an issue concerning vendor recommended i l preventative maintenance (PM) not being' performed on emergency diesel I generators (EDGs). Various audits conducted by the licensee were ineffective in assuring the identification and incorporation of all vendor recommended EDG maintenance activities into the preventive maintenance program. Examples of vendor recommended items included: 6-year replacement schedule for lower liner seals, cylinder head caskets, and cylinder head to liner water grommets; 12-year replacement schedule for cooling water system flexible coupling seals; and 6 .vear inspectio ,
l schedule for reverse polarity of generator collector rings, governor 'I
! booster motor seals and brushes, and generator bearin l
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In 1988, a violation was issued for an audit conducted.by the licensee (Audit QAA 04-87-55) for the 1/2 EDG. .The audit was cited for not ;
verifying compliance with and determining the effectiveness of the
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documented PM progra In 1989, the licensee conducted a safety system functional inspection (SSFI) and the PM program was again reviewed. The SSFI also failed to identify components not receiving vendor recommended PM i l- '
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Quad Cities Technical Specification 6.2.A.1 required that written ,
procedures shall be established, implemented and maintained covering ;
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, of February 1978. Nuclear Operating Directive NOD- -
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TS.20 required preventive and corrective maintenance programs for EDGs to include vendor recommended activities. Failure to include the vendor recommended activities as discussed above in the EDG preventive and corrective maintenance program is considered a Violation of Technical Specification 6.2.A.1 (50-254/93025-01a(DRP)).
An example of a violation was identified regarding a failure to include ,
vendor recommended activities in emergency diesel generator preventive and corrective maintenance progra . Licensee Event Report (LER) Review (92700)
Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been, or will be, accomplished in accordance with 3 technical specifications (TS). The following LERs were considered ,
closed:
(Closed) 254/91003-L1: Specific Points In ACAD/ CAM Lines Exceed UFSAR Allowable Stres .
(Closed) 254/92001-LL: Reactor Water Cleanup Isolation On Non-Regenerative Heat Exchanger High Outer Temperatur (Closed) 254/92009-LL: . Missed Technical Specification Functional Test Requirements Due to Inadequate Procedur (Closed) 254/92015-LL: LPCI and Core Spray Valve Yokes Outside FSAR Design Basis Due to Inadequate Design Contro (Closed) 254/92022-LL: Failure of the "B" Train CR HVAC to Auto-Start From Unknown Caus (Closed) 254/92023-LL and 254/92023-Ll: IB and 2B RHR Heat Exchanger Failed to Meet Design Heat Transfer Rate Requirement Due to Fouling and Silt Accumulation During Low Flow Rate Operatio _
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1 Closed) 254/92024-LL: ESF Actuation After Val've Went ' Closed Following Loss of Instrument Air Due to Personnel Erro '
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(Closed) 254/92025-LL: Control Room HVAC Toxic Gas Analyzer Inoperable Due to a Broken Sample Pump Belt Due to Thermal Degradation of the Bel ,
i (Closed) 254/92026-LL: RCIC Flow Transmitter.0ut of Calibration: Causing y Pump Flow to be Below Technical Specification Requirement j (Closed) 254/92027-LL: Unit 1 HPCI Room Cooler Failed Beyond Design- f l Margin Due to an Accumulation of Silt and Debri I
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(Closed) 254/92029-LL: High Radiation Area Posting Concealed From View and Barrier Eliminate (Closed) 254/92030-LL: IB Reactor Recirculation Pump Trip While j Performing Automatic Depressurization System Logic Testing Due to 'i Personnel Erro i
(Closed) 265/92006-L1: Missed Onsite Review of Temporary Procedure Due I to Procedure Deficienc (Closed) 265/92014-LL: 1/2 Diesel Generator Inoperable- Due to Unit 2 5i
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Lack of Redundant Power feed from Unit 2 to 1/2 Diesel Generator Cooling 1 Water Pump Cooler Fan )
i (Closed)'265/92013-LL and 265/92013-L1: HPCI System Manually Isolated'
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(Closed) 265/92020-LL and 265/92020-Ll: Unit 2 RCIC Inoperable Due to !
Failed EGM/EGR Controlle (Closed) 265/92023-LL: ECCS Pump Room Floor Drain Check' Valves i
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Inoperable. In the review of this event, the licensee identified LER ~,
265/91009, " Failure of the Core Spray Room Drain Check Valves Due to_ !
L Foreign Material Becoming Lodged in Check Valves," as a previously .!
documented event. As part of the corrective' actions'for LER 265/91009, :j strainers were to be installed on the floor drain and discharge flange ,
associated with each ECCS corner room. However, this corrective action i was not completed, directly leading to the subsequent inoperability of !
the same check valve !
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l In the analysis of LER 265/92023, the licensee failed to address _the j l incomplete corrective action for the previous event. . The timeliness and l
'. quality of the licensee's corrective action program has been the root 4 cause of previous violations. Based on the inspectors * review, increased licensee management attention appeared warranted in the area of corrective action to assure timeliness and' qualit i
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(Closed) 265/92024-LL: HPCI Fire Protection Out-0f-Service For More l Than 14 Days. The fire protection section in technical specifications i
- . have been deleted. The requirements of the licensee's current fire protection program were not violated. This LER is close gl No violations or deviations were identifie '
-l Operational Safety Verification (71707) ;
R The inspectors observed control room operation, reviewed applicable ;
logs, and conducted discussions with control room operators. The inspectors reviewed the operability of selected emergency systems, reviewed tagout records, and verified the proper return to service of- !
affected components.
l Tours of accessible areas of the plant were- conducted to observe plant '
equipment conditions, including potential fire hazards, fluid leaks, .i excessive vibration, and to verify that equipment discrepancies were noted and being resolved by the license The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection and physical .,
security plan control l Observations: Hioh Pressure Coolant Iniection (HPCI) Drain Pot j l
On August 21, 1993, operability runs were performed for both the Unit 1 and Unit 2 HPCI systems. Prior to rolling the HPC turbines, a system engineer directed equipment attendants (EAs) to .l drain the HPCI turbine exhaust drain pots. The Unit 1 interim j procedure did not address opening the drain-valve; the Unit 2 procedure had the step, but did'not specify the valve number. At I both pre-job. briefings the system engineer discussed draining the drain pot but did not discuss any specific valve manipulation .
After both unit drain pots were drained, the system engineer i directed the EAs to close valve 18C (pot drain valve) and to close the normally open 18B valve (high level sensing line isolation). ,
Neither the system engineer nor the EA informed operations that '
the 18B valve was left in a different position than .as-found. The system engineer left instructions to drain the exhaust pots at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the successful operability runs. The following day, the EA responsible to perform the task found valve 188 closed and informed the unit nuclear shift operator (NS0). ,
Shift personnel determined the 18B valves for both units.were in-the wrong position which rendered both unit HPCI systems inoperabl :
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The system engineer believed two-valve isolation was required and :
failed to consider level switch operation effected by closing the 188 valve. Closing valve IBB isolated the drain pot from its associated high level _ switch. The surveillance procedure did not contain appropriate information for valve manipulations rendering both unit HPCI systems inoperable. The failure to have adequate surveillance procedure for performing activities important to -
safety 'is considered a Violation of Technical . Specification 6.2.A.1 (50-254/93025-Olb(DRP)). ..
i Additionally, the EAs did not question the system engineer's I directions to close the 18B valve after the pots were' draine ,
leaving 188 valves in a different configuration than as-found .
showed a lack of questioning attitude by the system engineer and the CAs. Management's expectations regarding a question ng i
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attitude as a result of.a HPCI rupture disk failure in June 1993, were ineffective as evidenced by this even This event identified a lack of self-check by the equipment attendants and system engineer in mispositioning-the 18B valve Contacting operations to review the appropriate drawings coul i have precluded the mispositioning of the 18B valves. As part of ;
correct.ive actions for a previous event,'the licensee initiated a ;
self-check program. The program was intended to enforc l management expectations during performance of various activities '
by tasking people to take necessary steps to achieve error-free performanc Additional e::amples of a lack of self-check identified during the i report period included: ;
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- On September 3, an NSO started the 1A resid'ual heat removal-(RHR) pump instead of the RHR service water pump during a surveillance activity; and
- On September 5, in equipment attendant involved in radwaste-tank processing operations, opened the wrong valve resulting i in transferring reactor building drain tank water to the contaminated condensate storage tanks (CCSTs) instead of the river discharge tan Failure to take adequate corrective actions to prevent personnel errors through the self-check program is considered a Violation of 10 CFR 50, Appendix B, Criteria XVI (50-254/93025-02(DRP)). 4 i
b. Diesel Generator (DG) Exciter Cabinet Mountina j
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l On August 24, an NRC Diagnostic. Evaluation Team (DET) identified l that the DG exciter cabinet was not seismically mounted. This condition rendered the DG outside of.its design basis. The DG'was ]
declared inoperable and the cabinet was welded to the floor- ,:
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mounts. This condition existed since initial construction. Due to a misinterpretation of 50.72 reporting requirements, the ;
licensee failed to perform the required notification. Further review of the licensee's reportability manual identified a weakness with the licensee's 50.72 interpretatio A review by 1 the licensee identified that this weakness existed at all Commonwealth Edison station The licensee's reportability manual did not contain adequate statements concerning any subsequent design basis issue with LC0 entry reportability. The licensee was l revising the reportability manual to resolve the issu Completion of this required change was expected by January 199 ;
The failure to perform the required notification is a Violation of !
the 10 CFR 50.72 (b)(ii)(B) (50-254/93025-03(DRP)).
c. Multiple Eauipment Problems i During the inspection period, a significant number of safety .
related equipment problems were noted. The number of occurrences i i
showed a lack of attention to detail, a need for engineering involvement and improved maintenance performance. Several of the ,
below equipment problems were still under review by an NRC !
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Diagnostic Evaluation Team at the close of this report period; therefore, those items remain unresolved pending completion of !
that review. Noted equipment problems included the following:
- On August 24, the root cause for several unsuccessful attempts to seal a weld leak on reactor water cleanup valve i 1-1201-145B was due to an incorrect weld procedure. This showed a lack of attention to detail and weak maintenance '
performance. The subject of inadequate weld procedure is considered an Unresolved Item (50-254/93025-04A(DRP)).
- On August 25, the oiler for the Unit 1 EDG cooling water pump outboard bearing was found on the floor. Contractors removing scaffolding may have knocked the oiler of * On August 28, NRC inspectors from DET identified that the ,
Unit 2 reactor core isolation cooling (RCIC) steam supply motor operated valve (MOV) had two of four motor end bell retaining bolts sheared off. One bolt was found painted over. This was an example of inadequate walkdowns by system engineer * On August 28, the incorrect Unit I drywell equipment drain sump pump was replaced due to poor verbal communication and configuration control problems. The subject of inadequate drawing configuration control is considered an Unresolved Item (50-254/93025-04b(DRP)).
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- On August 30, the IB residual heat removal (RHR) service water pump had the oil slinger rings off of the inboard and outboard main pump shaft due to a maintenance error during a pump overhaul in 1988. The subject of inadequate maintenance procedures is considered an Unresolved Item (50-254/93025-04c(DRP)).
- On August 31, a calibration was performed on a Unit 2 main steam line radiation monitor. The instrument was left downscale, with a 1/2 scram inserted for approximately 4 ;
hours while procedural problems were addressed. This showed a lack of planning by instrument maintenance technicians and a lack of control by operations personne '
- On August 31, an outside differential pressure transmitter plugged with rainwater, caused a higher differential pressure than actual indication for the reactor buildin This created difficulties on ventilation fan configuration for the operators. The problem occurred previously; however, no engineering resolution was: pursue * On August 31, Unit 2 shut down because the feedwater check-valve developed a bonnet leak'. Neither the work reques (WR) covering previous maintenance nor the present WR contained vendor recommendations to re-torque the bonnet under pressure. The WR was revised to include the re-torque requirements. The subject of inadequate procedures for pr.rforming check valve maintenance is considered an Uiresolved item (50-265/93025-04d(DRP)).
- On September 18, during the Unit 2 startup, the operators experienced difficulty reacuing the desired condenser vacuum. Similar problems were noted on previous Unit 2 startups. This was an example of inadequate engineering involvement and a failure of operations management to place emphasis on resolution-of recurring equipment proble * The safe shutdown makeup pump (SSMP) system had'a modification to increase the room cooler piping siz The SSMP system was returned to service on September 17. The SSMP was at day 63 of a 67-day limiting condition for operation (LCO) Several problems were noted during the modification. Examples of problems included configuration control, piping classification, and start date for fire protection compensatory measures. These errors led to the SSMP being returned to service just.before the LC0 time clock expired. This showed inadequate engineering oversight and an operations department weakness concerning identification of conditions requiring entry into the 67-day LC _ . . -. . . - . -- ..
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Some of the above items were caused by poor past performanc I These' problems could have been avoided by better engineering j walkdowns, operations personnel observations, or management ,
oversight of plant activities. Although the licensee, thr.ough ;l recent efforts, identified several of.these equipmen ;
discrepancies, continued management action is warranted to improve -
performance to reduce equipment' failures, j
- Radwaste Material Condition i
During periodic' plant tours, poor material- condition of the- .
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radwaste basement was identified. Also, poor housekeeping in the radwaste compact area was noted. Station management was aware of- 1 these degraded conditions and committed to resolve them in,the ':j near futur One example of a violation was identified regarding procedural. adequacy.- ,
Two violations were identified concerning inadequate corrective actions !
event reporting. In addition, four examples of an unresolved item were ' j '
identified concerning equipment problem . Monthly Maintenance Observation (62703) !
Station maintenance activities for both safety related and non-safety- l related systems were observed and/or reviewed to ascertain that they . t were conducted in accordance with approved procedures, regulatory guides i and industry codes or standards, and in conformance.with technical'
specification )
i The inspectors observed or reviewed portions of the following maintenance activities: ,
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1D Residual Heat Removal Pump Modification Joy Air Compressor Unit 2 62B Feedwater Check Valve 2C Residual Heat Removal Pump Modification Unit 1/2-
" Safe Shutdown Makeup Pump Cooler Line Modification A Standby Gas Treatment Fan Breaker No violations or deviations were identifie .
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6. Monthly' Surveillance Observation (617261' .,
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During the report period, the inspectors observe'd test. activitie !'
Observations made included one or more of the following attributes:
testing was performed in accordance with adequate procedures;, test :
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equipment was in calibration; test results confirmed with technical specifications and procedure requirements; test results were properly ~ i reviewed; and test deficiencies identified were properly resolved by. the -
appropriate personne ;
.t The inspectors witnessed or reviewed partions of the following test- :
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A&B: Residual Heat Removal Operability Tests ~i C RHR Service Water Quarterly Operability Tests ,
Quarterly Standby Liquid Control Pump Flow Rate Test '
Unit 2 QCIS 1000-4 Monthly High Drywell Pressure Core Spray, LPCI, and.EDG
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Functional Test QCOS 1400-4 Monthly Core Spray Operability Test !
QCOS 1400-2 Monthly Core Spray MOV Operability Test Hydrogen Addition *
Special Test -i QCOS 2301-4 HPCI Monthly Operability Test Unit 2 HPCI Monthly Operability Test Procedure adherence, communications, and equipment performance were good However, . t'ie management oversight was weak in -that the . 4 shift engineer was pr.+sent for' only a portion of the briefin *
Also, the equipment attendant (EA) was not familiar-with'the HPCI;
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turning gear operat'on and was not given any instruction prior to l
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or during the bric!in EA knowledge of system operation was a previously identified weakness and has been a root cause-for ;
previous event l
- Core Sprav Check Valves j
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valve 1-1402-9B had failed its surveillance test in April 199 !
The licensee.did not perform an operability evaluation of the - .!
failed component until requested by the.DET; The operability- -r evaluation did not address seat leakage criteria as required by ;
the ASME Section XI code and did not provide a basis for assuring that the check valve was intact.and close 'lf P
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The core spray check valves are pressure isolation valves which ;
function to limit . reverse flow through the core spray system, and ,
are included in the licensee's check valve testing program. Quad l Cities Operating Surveillance (QCOS) procedure 1400-2, Revision 1,
" Monthly Core Spray System Motor Operated Valve Operability Test," ]
noted in a caution statement that check valve leakage exists if a pressure switch upstream of the check valve alarms during performance of the test. The procedure did not address inservice test (IST) requirement of the CS valves, did not specify an allowable leak rate, and did not identify that the occurrence of the alarm during the test was a potential failure of a required IST. During performance of the test, the pressure . switch alarme '
Although documented as a potential check valve, failure, the licensee did not perform an evaluation to determine if the. valve could satisfactorily perform its intended functio In response to the inspectors' concerns, the licensee presented results of visual inservice inspections performed on 1402-9B check valves from both units within the last year which showed that the wear on the check valves was minimal. Additionally, the licensee performed a revised IST of both Unit 2 CS system check valves which quantified the leakage past the check valve seats. The total leakage was less than 1 gpm and was considered satisfactor ]
The licensee performed a revised operability evaluation of the Unit I check valves which concluded that check valve 1-1402-9A was considered degraded but was still operable. The licensee's corrective actions included revising IST procedures to require quantified leak rate tests of pressure isolation valves listed in response to NRC Generic Letter 87-06. Tests are also planned for the Unit 1 CS check valves during an upcoming outag The failure to adequately test and document test results of core spray check valve 1-1402-9A is considered a Violation of 10 CFR 50, Appendix B, Criterion XI (50-254/93025-05(DRP)).
One violation was identified concerning inadequate test contro . Safety Assessment /Ouality Verification (40500)
During the report period, the inspectors observed LER onsite reviews and the event steering committee (ESC) meetings. The ESC meeting was -
periodically monitored by senior. management; however, the level ,of management oversight chairing the meeting appeared wea One instance'
was noted where a component had failed with a known failure history; no individual was assigned the responsibility to determine the cause'of the component failures. In addition, the inspectors monitored the LER onsite review meeting which was lacking probing questions. The ES meeting and LER onsite review function were'significant overview processes.
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L Temporary Instruction (TI) 2500/028 - Employee Concerns Proaram i p The inspectors reviewed the . licensee's employee concerns program as o requested by the subject TI. On August 24, the requested information !
l was sent to Region III. The information is attached to the repor The ;
inspectors did not identify any concern '
l No violations or deviations were identifie !
" Unresolved Item Unresolved items are matters about which more information is required in c ^r to ascertain whether they are acceptable ~ items, items of :
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la acompliance or deviations. One Unresolved Item disclosed during this -
inspection is discussed in paragraph 4 . Exit Interview ,
The inspectors met with the' licensee representatives denoted in .
'f paragraph I during the inspection period and at the conclusion of-the inspection on September 3 The inspectors summarized the scope and ]
results of the inspection and discussed the likely content. of this ; inspection report. The licensee acknowledged the information and did j not indicate that any of the information disclosed during.the. inspection j could be considered proprietary in natur l
Attachment: Temporary Instruction 2500/028, Appendix _l
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Attachment EMPLOUE_ CONCERNS PROGRAMS PLANT NAME: LaSalle Licensee: CECO DOCKET #: 50-373:374'
Dresden CECO 50-237:249 Quad Cities CECO' 50-254:265 ,
Byron CECO 50-454:455 Braidwood CECO 50-456/457 Zion CECO 50-295/304 i
NOTE: Please underline yes or no if applicable and add comments !
in the space provide ;
' PROGRAM:
l.'Does the licensee have an_ employee concerns program? l (Yes or No/ Comments)
The licensee conducts a Quality First prograta .to identify and address employee concerns. Other programs ;
such as the vision through quality (VQ) search.for opportunity (SFO) exist. The VQ SFO program is more ]
oriented toward identifying and developing improvement initiatives versus a_ formal program for raising specific safety issue Therefore, the completion of this form will deal only with the QF progra . Has NRC inspected the program? Report #
The NRC had not recently inspected this progra I SCOPE: (Circle all that apply)
l-1 Is it for: Technical? (Yes, No/ Comments) Administrative? (Yes, No/ Comments) - personnel issues?' (Yes~, No/ Comments) -l The concerns ~are categorized as security,-quality,'and
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management but may, in fact, involve any of the abov . Does it cover safety as well as'non-safety issues?
-(Yes or No/Comnents) .
I Is it designed for: Nuclear safety? (Yes, No/ Comments) -j b.- personal safety? (Yes, No/ Comments) I l
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! Personnel issues - including union grievances?- ;
(Yes or fo/
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Although it can involve personnel issues, itLdoes not deal with union grievance ..
! Does the program apply to all licensee employees?' i (Yes or No/ Comments) I j Contractors?
(Yes or No/ Comments) f This program is not necessarily stre'ssed to contract.
! employees the licensee believes are not in a position j to identify Quality First issues'such as parking lot I paver l
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4 Does the licensee require its-contractors and their 'l subs to have a similar program? i (Yes'or No/ Comments)
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l CECO administers the entire progra !
i Does the licensee conduct an' exit interview upon . j terminating employees asking if'they have anyJsafety- !
concerns? i (Yes or No/ Comments) .
'i i L Upon termination, employees are given concern ,
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disclosure statements to complete. Exit interviews are !
give The percentage of terminating = employees-receiving them'is drastically ~ reduced due;to a ;
reduction in program' manpower since the beginning of ;
the yea { INDEPENDENCE:
) What is the-title of the person in charge?
I Quality First Administrator'(QFA) "
2 .. Who do they report'to? !
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Director of Station' Quality' Verification- .i
.. Are they independent-of line management? '
Yes" Reports through offsite quality verification organization . Does the.ECP use third party consultants?
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, No-However, quality verification personnel have been' .!
L utilized to do interviews. The QFA determines the :l appropriate' group to do the investigatio ; \
How is a concern about a manager or vice. president
followed up? '
This would be decided on a case'by case basi i a RESOURCES: 'l
. What is the size of staff devoted to this program? -
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s Since'the beginning of'the .. year, staff has been ' cut to one individual for all six CECO plant I What are ECP staff qualifications (technical' training, l interviewing training, investigator training, other)7 !
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No specific qualifications exist for the QFA, who has -I been involved in the program a number of year Guidelines for' interviewers are available but'there are no specific qualification REFERRALS:
l l Who has followup on concerns (ECP staff,-line ,
I management, other)?
The QFA may do the followup ~ himself or assign;itL to +
l another group including line managemen ,
, CONFIDENTIALITY: Are the reports confidential? -
(Yes or No/ Comments) Who is the identity of the alleger made known to-(senior management, ECP staff, line. management, other)?:
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'Information on the alleger identity remains with-QF *
' Can employees be: Anonymous? (Yes/No' Comments); Report by phone?- (Yes,.No/ Comments)
- A toll free number is availabl FEEDBACK: Is feedback given to.the alleger-upon completion of the followup?
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(Yes or No - If so, how?)
Feedback is given by mail or telephon . Does program reward good ideas? !
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No , Who, or at what level, makes the final decision of resolution? ,
This is determined by QFA in conjunction with line [
managemen . 'Are the resolutions of anonymous concerns disseminated? ,
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No Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)? >
No >
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i EFFECTIVENESS: "
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, How does the licensee measure the effectiveness of.the program?
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I Not measured ,
-l a Are concerns: ,
- l Trended? (Yes or lfo/ Comments)
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There are too few official " Records of Concern"- -f (ROC) to warrant trending. The QFA does-informally look for common concerns on items which do not warrant official ROC Used? (Yes or No/ Comments) ck Corrective actions are addressed in the progra ,
3 .. In the last three years how many concerns were; raised?- .;
Closed? What percentage.were substantiated?- *
The QAF screens comments and identifies those.to be- '
handled as official-Records of-Concern" (ROC).. .
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The following data is for ROCS from.1990 through Augusti l 1993 No formal ROCS have been initiated thus farLin
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- Closed % Substantiated-LaSalle 2 100 -l Byron 9 22 !
Braidwood 6 33- !
Quad Cities 3 3 '
Dresden 4 2 Zion 1 'O
Comments received during or after a refuel' outage that the QAF determines do not warrant an official ROCLare compiled and transmitted to plant management for '
informatio outag This occurs several monthsLafter the -
- How are followup techniques used'to measure ef f ectiveness -(random survey, interviews,fother)?'
No followup techniques utilized'except perhaps for contractors they see multiple times at different-CECO- ,
site , How frequently are internal audits of the ECP conducted ~
and by whom?
There are no audits of this area. The onsite quality'
verification superintendent is responsible for reviewing information copies of quality ROCS to-determine if additional QA reviews are warrante , ADMINISTRATIVE / TRAINING: Is ECP prescribed by a procedure? (Yes or'No/ Comments) H Nuclear Operations Directive (NOD)-OA.12, " Quality First Program Directive" How are employees, as well-as contractors,'made' aware:
of-this program (training, newsletter, bulletin-board,;
other)? ->
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The program is briefly describedEin Nuclear General'
Employee Training;(NGET). It may also be'mentionednin'
occasional safety meetings or departmental tailgates.,
ADDITIONAL COMMENTS: (Including characteristics'whichimake the program especially effective'orL ineffective.)
In viewing the number of official " Records of Concerns (ROC)," that are formally tracked, investigated,.and resolved, the: ef f ectiveness of the -program is questionabl e. -
No: ROCS have been generated thus f ar f or 1993.' This . ma y l>e
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partially related to the staff reduction and availability of personnel to conduct exit interviews. Due to the lack o resources, some concerns which would'have been handled as official ROCS in previous years'are-now.being handled more informally
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The person completing this form please provide the following, ;
information to the Regional Office Allegations Coordinator.and i fax it to Richard Rosano at 301-504-343 :
l NAME: TITLE: PHONE #:
David Hills / Senior Resident Inspector /815-357-8611 DATE COMPLETED: 9-6-93 ,
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