IR 05000254/1997001
| ML20202C916 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/30/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202C101 | List: |
| References | |
| 50-254-97-01, 50-254-97-1, 50-265-97-01, 50-265-97-1, NUDOCS 9802130074 | |
| Download: ML20202C916 (6) | |
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e , INTRODUCTION The Systematic Assessment of Licensee Performar.ce (SALP) process is used to develop the Nuclear Regulatory Commission's (NRC) conclusions regarding a licensee's safety performanc Four functional areas are assessed: Plant Operations, Maintenance, Engineering, and Plant Support. The SALP report documents the NRC's observations and insights on a licensee's performance and communicates the results to the licensee and the public. It provides a vehicle for cle v :ommunication with licensee management that focuses on plant performLnce relative to safety nsk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilitie This report is the NRC's assessment of the safety performance at Quad Cities for the period October 27,1996, through December 20,199 An NRC SALP Board, composed of the individuals listed below, met on January 7,1998, to assess perforrnance in accordance with the guidance in NRC Management Directive 8.d,
" Systematic Assessment of Licensee Performance."
Board Chairperson Geoffrey E. Grant, Director, Division of Reactor Projects, Rlli Board Members Robert A. Capra, Director, Project Directorate lll 2, NRR John M. Jacobson, Acting Deputy Director, Division of Reactor Safety, Rlll 1 PERFORMANCE ANALYSIS Operations Overall performance in operations remained good throughout the period. Efforts made in the last period to improve control room performance in communications, supervisory oversight and self-assessments were sustained this period. Personnel performance was good, and contributed to two lengthy periods of dual unit operations. Routine and transient operations were performed well. Operators exhibited good out-of service tagging performance, which was an improvement over the last period. In contrast, ineffective communications resulted in several missed surveillances. In some cases, operator tolerance of repetitive equ;pment problems negatively affected plant performance. Although daily risk management of out-of service equipment was usually a strength, overal situations indicated a lack of conservative approach to equipment availability or operabilit Control room performance was normally a strength during this period, with good communications, supeivisory oversight, and self or peer check activities. Operator response to two loss of shutdown cooling events and an inadvertent high pressure coolant injection initiation at power was prompt and appropriate. Some exceptions to good panel munitoring occurred, including operators not identifying an indication of a fuel failure for several shifts, and tolerance of alarming annunciators without taking corrective action. Physical and process changes improved the control room environment and minimized distractions to operators. The physical modifications improved supervisory panel oversight and resulted in a more organized and quieter atmosphere. Process improvements included restrictions to control room access, and movement of all but esaential functions outside the control roo PDR ADOCK 050002S4 G PDR
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Self assessments of operator performance remained strong, with management ovwiews of complex activities, poer reviews, and supervisory oversight of crews being empht.G.en Some self assessment and human performance resources were shared with the Quality anc A fety Assessment department to improve self assessment station wid Daily assessment of risk was considered a strength. However, some notable exceptions involving non-conservative operating decisions occurred. The high pressure coolant injection system was inappropriately taken out of service for surveillance testing and a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown limiting condition for operation was entered while portions of the low pressure coolant injection system were inoperable. Other areas where risk considerations were not fully considered included maintenance affecting fire pump availability and alarm capability, and maintenance affecting ultimate heat sink capabilit Although material condition of the plant improved during the period, repeat equipment problems resulting in downpowers and shutdowns indicated an operational tolerance of material condition problems. Examples included several downpower operations due to gland seal level control valve problems, and a unit shutdown initiation caused by a standby liquid control flow indicator which had been previously identified as needing replacemen While communications between operations and other departments showed improvement in some areas, important weaknesses were also apparent. Out of service errors, a previous problem area, were fewer and less significant this period. Electronic out of service tagging was implemented with few problems, indicating good coordination with maintenance and engineerin However, ineffective communications on post maintenance and surveillance activities resulted in missed testing requirements. For example, several control rods were not tected following maintenance before reaching 40 percent power after the Unit 2 refueling outage. Offgas sampling requirements were missed because of communication errors between operations and chemistry. Some failures to require testing prior to mode changes were also identified. The most significant example involved taking the reactor critical prior to hydrostatic testing of the reactor coolant system as noted in the Maintenance and Engineering functional area he performance rating in Operations is Category 2 .
' Maintenance Overall, performance in the area of maintenance was adequate. Improvements were observed in the work control process, plant material condition, and work backlog reduction. Nevertheless,
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repetitive equipment problems continued to present challenges to plant operations. Significant problems were noted in the surveillance test program and in hydrost&dic testing per the American Society of Mechanical Engineers (ASME) Code. Poor implementation of the maintenance rule prevented rulo-based actions from contributing to improved aquipment performanc Emphasis on material condition improvements resulted in reducing the non-outage corrective and safety-related backlogs. Reductions were also achieved in operator workarounds, control room corrective maintenance, and temporary alterations. Improvement was also made in safety system availability. The maintenance initiative to replace the recirculation pump motor and impeller was good. However, repetitive equipment problems impacted plant operations, causing forced shutdowns and power derates on several occasions. For example, a packing leak on a low pressure coolant injection (LPCI) check valve and a failed reactor recirculation pump seal were identified as resulting from poor quality work during the Unit 2 refueling outage. Unit 1 also
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experienced equipment problems, including a bonnet leak on a reactor core isolation cooling system valve, numerous gland seal condenser level control valve failures, repeat problems with standby liquid control pump flow indication, cracked 4160 volt breaker auxiliary switches, and low l oil levels on a reactor recirculation pum '
The maintenance rule program was poorly implemented and did not provide adequate monitoring !
of systems and components. Corporate support to ensure strong implem3ntation of a company- '
wide program and incorporation of lessons leamed from other Commonwealth Edison sites was not evident. As a result, the maintenance rule program was not an effective maintenance tool for identifying or addressing failures of the fire pumps, emergency diesel generators, the containment atmosphere monitoring system, and other equipment. Engineering support for implementation of the maintenance rule was also not effective as discussed in the Engineering
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functional are The work control process improved during the SALP period. Several task-oriented work groups were established to focus on tasks in specific areas. Effective use of the Fix-It Now (FIN) Team to complete emergent work items contributed to meeting maintenance work schedules. Good planning and execution were demonstrated during a brief planned outage on Unit 2. Work scheduling and planning and the quality of work packages were generally satisfactory with some difficulties noted on specific work activities, such as the failure to perform preventive maintenance tasks on General Electric Magne-blast breakers. Also, work histories were not consistently recorded, which complicated resolution of the amergency diesel generator air start motor problem Maintenance work was normally performed safely and in accordance with procedure Teamwork improved and increased worker knowledge snd skills were noted in the quality of work. The reduction in maintenance backlogs demonstrated the ability of maintenance personnel to get work done. Although rework was reported as low, some problems with procedure adherence and proper self checking were evident, causing notable rework items, such as the reactor recirculation pump seal and LPCI check valve packing replacements. Some recent
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improvements were noted in maintenance self assessments and trending and in the involvement
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of quality controlin maintenance activitie In the arer )f surveillance, a number of significant problems were identified with missed surveillances and procedural adequacy. The upward trend in missed surveillances was due to defective procedures, inadequate review to incorporate new Technical Specification requirements, poor scheduling, and human error. In addition, several surveillance test procedures were observed to not include all the appropriate testing. For example, not all of the required residual heat removal service water valves were included in a monthly surveillance test.
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Some substantial problems with the implementation of specific ISl/IST activities v/ere identifie Main steam safety relief valves did not receive set pressure tests within 12 months of removal as required by the ASME Code. Of greater significance, however, was the failure to perform the ASME Code required hydrostatic leakage test of the Unit 2 reactor coolant system prior to taking the reactor critical as specified by 10 CFR Part 50, Appendix G. Further, the visual examinations
, for leakage conducted during the test were found to be inadequate in several instance Performance of the hydrostatic test at power demonstrated a lack of safety focus, .noor knowledge of the testing requirements, and a lack of strong oversight by the corporate center for
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ASME Code testing expertise, initial recognition of this issue demonstrated good problem identification, however, follow up to determine the extent of the problem was neither thorough nor aggressiv The performance rating in Maintenance is Category Enaineerina Engineering performance remained adequate with some notable weaknesses. While some aspects of engineering support to the plant improved, problems were experienced with testing acceptance criteria, understanding and application of the design basis,10 CFR 50.59 safety evaluations, parts replacement, and resolution of problems. Substantial problems were encountered with fire protection safe shutdown capability in accordance with 10 CFR Part 50, Appendix R, in support of the impWmentation of the maintenance rule. Self-assessmen;s were effective at identifying problems, but resolutions of the findings were, in some cases, neither comprehensive nor timel Substantial problems were experienced in significant technical areas. Implementing procedures for safe shutdown in the event of a fire were inconsistent with the approved 10 CFR Part 50, Appendix R, " Fire Protection," safe shutdown analysis and a heavy reliance was placed on opposite unit equipment. Unit 2 was conservatively shutdown early as a result. However, the safe shutdown capability and Appendix R issues were not comprehensively resolved prior to expiration of an administrative limiting condition of operation on Unit 1, and led to the unit being shut dow Significant problems wera also identified regarding the process for changing the Appendix R licensing basis, completing the safe shutdown analysis, implementing new procedures, and establishing the operability of the new safe shutdown strategy. Engineering support for implementation of the maintenance rule was also not effective. Although portions of the maintenance rule program involving scoping, risk ranking, and risk assessment from out-of-service equipment were acceptable, inadequacies were identified in the development of performance criteria, the evaluation of maintenance preventable functional failures, the establishment of goals and monitoring, and the historical reviews of operating dat Some aspects of engineering support to the station improved. Effective use of system engineers and a project manager during a safe shutdown makeup pump system outage helped ensure that modification work progressed smoothly, in-depth reviews of design basis information and detailed system walkdowns were performed in support of the high pressure coolant injection (HPCI) system operational performance inspection. A high sensitivity toward identification and documentation of HPCI problems was noted. Engineering resources were effectively applied to resolving material condition issues; nonetheless, many material condition issues remained. Problems with the emergency diesel generator (EDG) air start system were initially not comprehensively addressed and engineering made significant errors in revising battery test acceptance criteria and maintaining the battery testing load profil The quality of engineering products was not consistent. While the threshold for identifying problems was low, poor root cause determinations and insufficient corrective actions were evident on several occasions. Improper application of the Alternate Parts Replacement Program allowed installation of parts which adversely affected the safety functions of related equipment. Corrective actions initially taken were ineffective to prevent repetition. For the refuel bridge interlocks, long term controls and corrective actions to guard against potentialinadvertent criticality were not aggressively pursued. Additionally, corrective act'ons were inadequate when intergranular stress
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corrosion cracking was found in reactor coolant system piping previously treated with the induction heating stress improvement process. However, modifications on the HPCI system were noted to be implemonted in an acceptable manner. Many functional calculations to determine important design parameters, such as the HPCI pump minimum discharge pressure at maximum reactor pressure, and the HPCI pump minimum suction water level to preclude vortexing, were identified as missing or non-retrievable and had to be reconstituted. These problems reflected continuing weaknesses in accuracy and accessibility of design basis information. A design basis documentation (DBD) group was formed to improve the DBD and to generate required or missing calculations. In addition, a line by-line validation of Updated Final Safety Analysis Report (UFSAR)
design basis information was commenced and an Engineering Assurance Group (EAG) was formed to improve the overall quality of engineering product Licensing act,a submittals were generally good. Submittals for licensing actions on the revised IPE, IPEEE, emergency core cooling suction strainer replacement, and Siemens fuel were good and staff questions were addressed responsively. A review of the UFSAR to assure all changes to the facility were included identified many changes that had not been incorporated. The review and resultant corrective actions were considered positive initiatives. However, substantial deficiencies were noted with the 10 CFR 50.59 safety evaluation process. Safety Evaluation Summary Report submittals did not include all safety evaluations and all applicable UFSAR sections were not identified during the screening process. An inadequate 10 CFR 50.59 safety evaluation screening performed for the Class 1 system boundary leakage tei.t exhibited a lack of comprehensive engineering review and allowed the pressure and leak test to ba performed while the reactor was critical, contrary to the requirements of 10 CFR Part 50, Appendix G, and the ASME Cod .lf assessment activities were effective at identifying problems, however, in some cases this was offset by untimely or il effective corrective action. Good technicalissues involving residual heat l removal pump testing were identified, but resolution of the findings was not technically rigorous or I
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comprehensive. The June 1997 maintenance rule self assessment utilized independent personnel, identified problems with implementation of the rule, and provided a clear set of major issues to address. However, these self-assessment results were not aggressively pursue The performance rating in Engineering is Category Plant Support Overall, plant support performance was good. Radiation protection and chemistry performance remained effective. Station dose was lower than projected due to strer gthened "as low as reasonably achievable" (ALARA) planning. However, problems were identified with valve work ALARA controls and maintenance of the high radiation sampling system. Both the security and emergency preparedness programs were wellimplemented. Fire protection performance was adequate. Problems were identified with the implementation of compensatory actions for fire protection deficiencies, the reliability of diesel fire pumps, and with slow corrective actions for degraded fire pump and sprinkler system flow problem Radiation protection and chemistry performance remained good. Continued emphasis on improving ALARA planning and controls kept station dose lower than projected. Station dose was also lower than anticipated due to less emergent work and reduced work scope during outage However, problems with work planning and conduct of maintenance and operations activities continued to have a negative impact on dose. Additionally, an mexpected intake of radioactive materialindicated a continuing problem with ALARA controls specific to valve work. Redioactive
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material control and redworker perfor' nance improved, but there wwe several isolated events, Routine chemistry sampling activities were well conducted and department response to the Unit 2 fuel leak was effective. However, th6re were several problems with maintenance of chemistry
- equipment, including the high radiation sample system, and w'th chemistry procedural quality,
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Reactor water quality was considered excellent, but declined due to main condenser probleto Security performance was good Routine and tactical res$ ness of security facilities, equipment, ,
and personnel were effective. However, isolated examples af ineffective mainten=nce oversight $
activities resulted in the implementation of additioesi security compensatory m asures, Positive management support and aggressive implementation of an " error reduction" program resulted in improved security force personnel performance New security computer equipment also improved officer offectiveness. Security management personnel generally demonstrated positive capability -
to identify and resolve security issues in a timely and effective manner. Individual performance inadequacies involving vehicle search and fitness for duty issues were noted and effectively corrected early in the assessment perio Overall, the emergency preparedness program was maintained in an effective state of operational readiness. Emergency response facilities, equipment, and supplies were well maintaine Management support to the program was strong and key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. Personnel performance observed during a medical drill was effective and demonstrated good teamwork. An emergency preparedness audit and self-assessment were of the appropriate scope and depth with identified issues properly tracked and resolve The fire protection program was adequately implemented. Fire brigade performance during a fire drill was good, although a weakness was identified regarding an excessive number of drill -
p participants credited for meeting training requirements. Control of combustibles was generally L good, Some compensatory actions were not adequately implemented for fire protection l deficiencies, This was of particular concem, because additional controls had been previously implemented as a result of the determination that intomal plant fires were a s',cnificant risk <
contributor in core damage frequency calculations. The majority of fire pruection er.gipment was well maintained, although a significant program weakness was identified regarding the reliability of diesel fire pumps. Corrective action development and implementation were slow for degraded fire pump and sprinkler system flow problems, resulting in several administrative limiting conditions for operation requirements being exceede The performance rating in Plant Support is Cater l J