IR 05000254/1999012

Insp Repts 50-254/99-12 & 50-265/99-12 on 990628-0716. Violations Noted.Major Areas Inspected:Corrective Action Process Which Included Methods Used for Identification, Cause Investigation & Correction of Quality Related Items

ML20210U017
Person / Time
Site:	Quad Cities
Issue date:	08/13/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210T998	List: IR 05000254/1999012 ML20210T994
References
50-254-99-12, 50-265-99-12, NUDOCS 9908190209
Download: ML20210U017 (14)

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t U.S. NUCLEAR REGULATORY COMMISSION REGION 111 r

Docket Nos: 50-254; 50-265 License Nos: DPR-29; DPR-30 l

Report Nos: 50-254/99012(DRS); 50-265/99012(DRS)

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Licensee: The Commonwealth Edison Company Facility: Quad Cities Nuclear Generating Station

, Units 1 and 2 l

l Location 22710 206* Avenue North

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Cordova, IL 61242 Inspection Dates: June 28 through July 16,1999

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inspectors: H. A. Walker, Lead Inspector R. Mendez, Reactor Engineer C. E. Miller, Senior Resident inspector Approved by: J. M. Jacobson, Chief, ,

Mechanical Engineering Branch Division of Reactor Safety l

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I 9908190209 990813 PDR l

G ADOCK 05000265 l_ PDR

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, SUMMARY OF FINDINGS Quad Cities Nuclear Power Station, Units 1 & 2 NRC Inspection Report 50-254/99012(DRS); 50-265/99012(DRS)

, The report covers a two week inspection by two Region based inspectors and one resident inspector. This was an announced inspection to review the corrective action process which included the methods used for identification, cause investigation and correction of quality related problems. The inspectors used inspection procedure IP 71152," identification and Resolution of Problems," to conduct the inspectio Inspection findings were assessed according to potential risk significance, and were assigned colors of GREEN, WHITE, YELLOW, or RED. GREEN findings are indicative of issues that, while not necessarily desirable, represent little risk to safety. WHITE findings would indicate issues with some increased risk to safety, and which may require additional NRC inspection YELLOW findings would be indicative of more serious issues with higher potential risk to safe performance and would require the NRC to take additional actions. RED findings represent an unacceptable loss of margin to safety and would result in the NRC taking significant actions that could include ordering the plant shut down. The findings, considered in total with other inspection findings and performance indicators, will be used to determine overall plant performanc Reactor Safety issues Green. Two instances of inadequate or untimely corrective actions, noted during the inspection, were categorized by the significance determination process as being of low risk significance. These items were:

. Corrective actions to address a January 1998 Unit 1 emergency diesel generator (EDG) failure to start were postponed in some cases and in others only partially completed, (Reference Report Section 40A1.3, page 5 )

- Excessive thrust con'ditions, found during testing of motor operated valves (MOVs) from March 1997 through July 2,1999, were not identified to management and did not receive apprcpriate corrective action to preclude recurrence. As a result, the cause of the problem was not identified and appropriate corrective action was not taken. This is a non-cited violatio (Reference Report Section 40A1.4, page 6) The root cause report and the corrective actions, approved by the Plant Operations Review Committee and the Corrective Action Review Board, did not fully address the repetitive problem of excessive use of overtime. There were 177 instances between February 1 and 28,1999, where station procedures were not followed to control overtime of plant workers. Further corrective actions were being developed to ensure that overtime violations did not continue. There were no known incidents where the excessive use of overtime directly impacted or affected the safety of the plant; however, the repetitive failure to follow procedures to control overtime is a non-cited violatio (Reference Report Section 40A1.4, page 8)

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- Report Details Summary of Plant Status Units 1 and 2 operated at or near full power for the entire inspection perio ~

' OTHER ACTMTIES (OA)

40A1 Identification and Resolution of Problems

.1 . Corrective Action Prooram Rqying Inspection Scope The inspectors assessed the methods used at Quad Cities for problem identification, cause determination and correction. The inspection included a review of applicable procedures and records for adequate documentation, appropriate reviews and corrective -

actions. The corrective action program and its effectiveness was discussed with

. selected licensee personnel which included management and supervision as well as

~ engineering and craftsme Observations and Findings No safety significant problems were identified in this are '2

. Problem identification Inspection Scope The inspectors selected and reviewed 42 problem identifmation forms (PlFs), previously

. categorized by licensee personnel as "significant conditions adverse to quality," for proper documentation and classification. Plant personnel were interviewed to determine their willingness to document problem <

. Observations and Findings interviews with personnel of various disciplines indicated that most workers were not hesitant to write PlFs and report problems. The inspectors verified that licensee personnel were cognizant of and understood the corrective action process and that adequate communications existed for the prompt identification and resolution of i problems. The inspectors noted that licensee personnel were writing an average of 4000

. to 5000 PlFs per year. This number indicated that the threshold for using PlFs to document problems was relatively low.

!' No safety significant problems were identifed in this area.

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.3 Problem Resolution and Correcton Inspecton Scope The inspectors reviewed 42 PlFs, previously categorized by licensee personnel as

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significant conditions adverse to quality," to verify proper corrective actions, adequate priorities, cause determination, and actions taken as well as proper status and tracking of actions. Corrective action effectiveness was evaluated when possible.

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. - b'. Observations and Findings The PlFs, used for problem identification, were usually closed after the problem was evaluated, required actions were determined and planned actions were entered into the Action Tracking System. . In some cases, the PlF was closed when another document

' such as an engineering request or a work request was written. Closing the PlF prior to completion of required actions has some risks involved because the items could be closed prior to completion of required action For some of the PlFs reviewed, appropriate actons were not performed or the actions completed were inadequate. An example is noted belo Emergency Diesel Generator Failure to Start Problem: A root cause investigation followed a failure of the Unit 1 emergency diesel generator (EDG) to start in January 1998. Root cause report Q1998-00722 dealt with the 1998 failure and other EDG start failures at Quad Cities. Many corrective actions recommended in this report were completed, others were partially complete, several were rescheduled, and some were not performed at al One significant action to improve the reliability of the EDGs with an air start system modification was recommended in1992 by an engineering firm hired to

. compare Quad Cities plant design with the requirements of 10CFR50 Appendix A. This recommendation to add an additional bank of air start motors was rejected by station management at that time. Later, due to continued EDG starting problems, the station reconsidered the recommendation. This item was entered in the nuclear tracking system as item # 007-200-97-QRCR01-0 Licensee personnel stated that the modification was scheduled for installation in the year 2000 oven though the modification had not been funded or designe The failure to take adequate and timely corrective actions on EDG starting i problems was previously documented in NRC Inspection report 50-254/98004; I 50-265/9800 Based on occasional EDG start failures, redundant EDGs and available off site power this issue was determined to be of low risk significanoe and was categorized as " Green." The problem was entered in the corrective action system as tracking system item # 007-200-97-QRCR01-0 l l

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.4 Safety Review Committees a. Inspechon Scope The inspectors reviewed the methods used by the four separate and independent review groups at Quad Cities to verify adoquacy, control and compliance with regulatory requirements. The review included tue controlling procedures and selected records of activities and attendance at selec6J group meetings when possible. In addition, the functions, activities and findin'Js of the four groups were discussed with cognizant licensee personnel including selected committee member b. Observations and Findings Most reviews and assesment completed by the independent review committees were good and actions and recommendations were appropriate. A few items were noted where the actions were inadequate. These items are discussed belo .~ Event Screening Committee (ESC)

i The inspectors noted several cases during Event Screening Committee (ESC)

meetings which indicated appropriate attention was not being focused on risk i significant problems. During motor operated valve (MOV) testing, over thrust issues were documented on test reports from March 1997 through July 2,1999, but PlFs were not written. The conditions were not properly identified to management and the problem cause and corrective actions were not addresse After discussions of these issues with the inspectors, licensee personnel identified the over thrusting problems as significant conditions adverse to quality and appropnate cause investigation and corrective actions to preclude repetition

. were initiate Unit 2 outboard drywell spray valve 2-1001-2338 failed to open during i surveillance testing on June 29,1999. The valve opened and closed satisfactorily after manual operation. The ESC review did not require cause

= investigation and action to prevent recurrence for this proble PlF Q1999-02249 identified that the 2-1001-198 residual heat removal cross-tie valve closed at over 30,000 pounds of thrust higher than the as-left thrust setting of about 48000 pounds. The thrust for this valve was far outside the expected thrust window for the valve and exceeded the calculated limits for several valve components. The ESC did not require or recommend cause investigation and no action item was assigned to take further action on the issue. No comparison was made with the over-thrust condition found on this valve and other valves such as the dryv, ell spray valve described in the previous paragraph. The committee did

- not ask for a trend on over-thrusting conditions although several other valves, tested since November of 1998, were found with significant excessive thrus '

. The inspectors asked for trending information on over-thrust conditions and found that since 1997, at least 10 valves tested had exhibited as-found thrust conditions of at least 20 percent higher than the as-loft conditions. One valve tested in late

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~ I 1998 showed over 43,000 pounds of excess thrust which was a 78 percent increase over the as-left setting. PlFs were not written for most of these valves; ,

therefore, the excessive thrust problem did not show up as a trend. Two of the valves (high pressure coolant injection valves 1-2301-4 and 1-2301-8) were later determined by licensee personnel to not meet thrust limits and required engineering evaluations to determine the operability of the valves. Other valves were not evaluated for similar thrust variances, which could make calculations for thrust limits invalid Criterion XVI" Corrective Action" of 10 CFR 50 requires that conditions adverse to quality be promptly identified and corrected. For significant conditions adverse to quality, the causes of the conditions must be determined and corrective action taken to preclude repetition. Contrary to the above requirements, significant conditions adverse to quality, found during testing of l MOVs from March 1997 through July 2,1999, did not receive appropriate L corrective action to preclude repetition. The problems were not identi'ied to management as significant conditions adverse to quality and the cause of the problem and required corrective actions were not determined or performed.

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l Following inspector discussions with licensee engineers and management,

! licensee personnel began a thorough investigation into the problems mentioned above, including performing operability evaluations for.the valves L found outside the acceptable thrust windows. Although these evaluations had not been completed, MOVs tested operated satisfactorily with the exception of the valve described in the first paragraph of this Section. The failure to take effective corrective actions on this issue was considered a Non-Cited Violation (50-254/9901241; 50-254/99012-01) in accordance with NRC enforcement

L polic Since nine of the ten valves found outside the acceptable thrust windows functioned as required during testing, the issue was determined to be of low risk significance and was categorized as " Green." Several PlFs had been written on this problem; therefore, the problem was appropriately entered into the corrective i action syste . Corrective Action Review Board (CARB)

No safety significant findings were identified in this are . Plant Operations Review Committee (PORC)

The Plant Operations Review Committee (PORC) was responsible for on-site i review of problems and proposed corrective actions. The PORC reviewed a l root cause report detailing multiple failures to adequately address Generic i Letter 82-12 " Nuclear Power Plant Staff Working Hours." The root cause report l corrective actions, which were approved by the PORC and the CARB, did not I appear to fully address the scope of the problem. After reviewing the corrective actions for at least eleven PlFs written on the overtime problem since 1998, the inspectors found that the corrective actions taken were similar to previous actions on this issue, which were not effective. The root cause package did not detail j how the actions proposed differed with the previous unsuccessful attempts to !

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correct the problem. PlF Q1999-01349 was written to identify 177 instances from February 1,1999, through February 28,1999, where station procedures were not followed to control overtime of worker The failure to follow Quad Cities Administrative Procedure 2400-03," Overtime Guidelines," Revision 6, which is a procedure required by Regulatory Guide 1.33, f is a violation of Section 6.8.A.1 of the Technical Specification. Since this violation was identified by licensee personnel, the issue was entered in the licensee's corrective action program as PIF Q1999-01349. Corrective actions were being developed by licensee personnel. This violation is considered a Non-Cited Violation (50-254/99012-02; 50-265/99012 02) in accordance with NRC enforcement polic Since there were no known incidents where the excessive use of overtime directly impacted or affected the safety of the plant or plant personnel, this issue was determined to be of low risk significanc . Nuclear Safety Review Board (NSRB)

The Nuclear Safety Review Board (NSRB) was responsible for off-site review of problems and proposed corrective action No safety significant findings were identified in this are .5 Operatina Exoerience Feedback a. Insoection Scope The inspectors reviewed the methods used to control and evaluate outside or industry information and problem notifications such as Generic Letters, Information Notices, Service Information Letters (SILs), etc. The review was to verify that licensee personnel received and evaluated the information and that corrective actions were taken when appropriate. The review included the controlling procedure and records of actions taken on selected problem notification document :

b. Observations and Findinos The methods used for evaluating operating experience feedback appeared to be adequate and were functioning properly; however, some problems were note In 1991, General Electric issued SIL 536, which identified failures of hydraulic control unit (HCU) liquid level switches caused by high velocity nitrogen impinging on the switches when the HCU accumulator was being charged or discharged. These level switches sensed the water level in the lower portion of the nitrogen tank piping and actuation of the level switch would indicate internal leakage across the accumulator piston seals. The licensee's response to the SIL stated that no action was required since the accumulator charging procedures did not require use of the HCU cartridge valve. The present procedure (OCOP 0300-06) for charging the HCU accumulators required the

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use of the cartridge valve to throttle nitrogen flow. Licensee personnel issued PlF Q1999-02335 to determine why the vendor recommendations were not followe The inspectors noted that some of the older SILs, issued more than 15 years ago, lacked adequate documentation of the actions taken. Some of the records for the older SILs stated that the recommended actions were fully implemented or in some cases were not implemented. The reasons for not implementing the i SILs were often not documented. Licensee personnel informed the inspectors that there was an intemal commitment to re-review all SILs issued by G In another case, GE SIL 155, issued in 1979 for problems with SBM type swthes, was inadequately addressed and no action was taken to address the described problem. The issue was reopened in 1997 as the result of a 1996 failure of SBM switches at LaSalle. PIF Q1997-00703 was written on the problem and actions had been taken or were planned to change out the switche .6 Audits and Surveillances Inspection Scooe

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The inspectors reviewed the methods used to perform and control Nuclear Oversight audits and surveillances. The review included the controlling procedures and selected 1997,1998 and 1999 audit and surveillance records as well as discussions with l

cognizant licensee personnel. In addition, the inspectors verified that the corrective L action program was being audited at least once every six month b .' Observations and findinos I

l No significant findings were identified in this are ]

.7 Review of Non-Cited Violations )

1 Inspection Scope j l- The inspectors reviewed a list of the non-cited violations (NCVs) issued during the past two years and selected seven of the NCVs for further review.

I Observations and Findinas For the seven NCVs reviewed, the described cause investigations and actions to prevent recurrence were appropriate. For two of the NCVs, the described actions did not include immediate actions to correct the described problems. Licensee personnelinvestigated and determined that the appropriate remedial actions had been taken. PlF Q1999-0231 was wiitten on the failure to document the required remedial action No safety significant problems were identified in this are A5 Manaoement Meetinos

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'.1 Exit Meeting Summary The inspectors presented the inspection results to Mr. J. P. Dimmette, Jr. and other members of licensee management in an exit meeting on July 16,1999. The inspectors noted that no documents provided during the inspection were identifed as preprietar Licensee personnel acknowledged the information presented and agreed that no proprietary information was provided to the inspector .

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' PARTIAL LIST OF PERSONS CONTACTED Commonwealth Edison Company

' G. Bemes, Station Manager-W. Beck, Deputy Regulatory Assurance Manage R. Chrzanowski, Nuclear Oversight, Assessment Manager .

' J. Dimmette, Jr., Site Vice President T. Fuhs, NRC Coordinator, Regulatory Assurance :

K. Gladrosich, Nuclear Oversight Manager V. Kico, Corporate Corrective Action Program Manager R. Kvick, Vice President for Key Services P. O'Neal, Corrective Action Program Analyst J. Perry, Vice President C Peterson, Regulatory Assurance Manager

' J. Purkis, System Engineering Manager C. VanDenburg,' Corrective Action Program Manager *

D.Wozniak, Engineer Manager NBC ,

L. Collins, Resident inspector J. Jacobson, Chief, Mechanical Engineering Branch M. Ring, Chief, Projects Branch One -

INSPECTION PROCEDURES USED IP 71152, " identification and Resolution of Problems."

lTEMS OPENED, CLOSED, AND DISCUSSED OPENED No NRC inspection items were identified during this inspectio CLOSED

, No items identified in previous NRC inspections were closed during this inspectio DISCUSSED 1-No items identified in previous NRC inspections were reviewed or discussed during this inspection, p 10

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LIST OF DOCUMENTS REVIEWED

' The following is a list of licensee documents reviewed during the inspection, including documents prepared by others for the licensee. Inclusion of a document on this list does not imply that NRC inspectors reviewed the entire documents, but, rather that selected sections or portons of the documents were evaluated as pad of the overallinspecton effort. In addition, inclusion of a document on this list does not imply NRC acceptance of the document, unless specifically stated in the body of the 'nspecton repor Corrective Action Program Det.cription CAP-1, " Problem identification Form Threshold Information Handbook," Revision CAP-2, "Significant Apparent Cause Evaluation (SACE) Handbook," Revision CAP-3, " Root Cause invet,tigation and Report Handbook," Revision CAP-4, " Trend Investigation and Report Handbook," Revision CAP-5, " Effectiveness Review Handbook," Revision 0.-

CAP-6, " Coding and Trending Handbook," Revision Procedures QARP 1000-01, " Safe Shutdown Procedure C1," Revision 1 QCAP 1100-04," Procedure Revision, Revision and Approval," Revision 2 QCGP 1-5, " Master Start-up Checklist," Revision 2 QCIS 1000-01,"High Drywell Pressure Scram Calibration and Functional Test," Revision QCIS 1000-02, "High Drywell Pressure Scram Functional Test," Revision ,

QCMM 1515-24, "Hancock 7150W, integral Bonnet, Globe Valve Maintenance," Revision QCMMS 6600-02, " Emergency Diesel Generator Preventative Maintenance Quarterly inspection," Revision 1 QCMMS 6600-05, " Emergency Diesel Generator Six Year Preventative Maintenance inspecton,"_ Revision QCOP 0300-06, "CRD Accumulator Charging," Revision QCOS 1600-41, " Weekly Torus to Reactor Building Vacuum Breaker Position Verification,"

Revision QCOS 6600-08, " Quarterly % Diesel Generator Cooling Water to Unit 1 and Unit 2 ECCS Room Coolers Flow Test," Revision ' QCTP 0500-10, " Reactor Vessel Designed Cycles," Revision OCTS 0410-02, ." Secondary Containment Capability Test," Revis~en NSP-AP-1004, " Corrective Action Program Process," Revision NSP-AP-4004," Corrective Action Program Procedure," Revision Problem identification Forms (PlFs)

Q1995-0223 Recirculation MG set increased speed from 95.5 % to 100 % on its ow Q1996-00515 Multitude of problems with SecFD-6 caused delays in Bus 14-1 OO .

Q1997-00703 Three SBM control switches were found to have cracked Lexon cam follower Q1997-02566 - Shims added to the U-1/2 and U-2 Diesel air start motor Q1997-02633 Critical Dimension not verified on Parts Evaluation for U-2, U-1/2 EDG "

Q1997-02735 Failure to Submit 90 Day Special Report 11-L . . . .

_ _ _ _ . h L Q1997-03147 LERs Resulting From Not Complying with Tech Specs

' Q1997-04506 Ability to Perform Extemal Flood Protection Measures in a Timely Manner Q1997-04891 Unit i EDG Failed Time Delay Relay Q1997-05050 Review of Dresden Reactor Building Elevated Temperature Calculation Findings-

- Q1998-00014 Potential LER Due to inadequate Relay Verification Q1998-00181 Surveillances Past Critical Due Date Q1998-00240 System Leak Detection Surveillance Exceeded Critical Date Q1998-00709 - Licensee identified, non-repetitive, and corrected errors in the EDG

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loading analysi i Q1998-0072 Past Diesel Generator Start Failures

- Q1998-03170 Scram Discharge Volume Level Transmitter Circuit Board Q1998-04926 Fuel bundle mis-positione Q1998-04972 Fuel bundle mis-positione Q1998-05431 Basement entrances to the 1 A and 1B comer rooms were not barricaded and posted as a.high radiation are Q1999-00231 Failure to provide a description of the immediate corrective actions taken for PlFs 98-04972 and 98-05431 Q1999-00317 Release of material outside the RPA with direct radiation measurements above backgroun . Q1999-00745 Scram Discharge Volume Level Transmitters Out of Calibration After Cleaning Q1999-00901 PORC Approved TMOD With inadequate Testing Criteria Q1999-01349 Nuclear Oversight identified inadequate Management Controls of Generic Letter 82-12 Overtime Q1999-01871 Unit 2 Reactor Building Secondary Containment issue Q1999-01940 Failure of Breaker to Fully Close Q199901942 Breaker Failed After Being Received From Vendor Q1999-01948 Computer UPS Battery Failed Surveillance Q1999-01953 1B Core Spray Room Cooler Trip Alarm

- Q1999-01957 2A Recirculation MG Set Vent Fan Trip Q1999-01961 Unit % EDG Component Cooling Water Pump Failure Q1999-01978 Apparent Discrepancies in Operability Evaluation Q1999-02240 Breaker Intemal Linkage Was Twisted and Damaged Q1999-02249 As-Found Thrust Values Exceed Calculation Structural Limits for MO

~2-1001-19B" Q1999-02274 Discrepancy Between Unit 2 RFP Flow Indicators and Total Flow Q1999-02335 Sll 536 Recommendations not implemented at Quad Cities Q1999-02341 ' Valves calculated structural & seismic limits potentially exceeded in past i tes Q1999-02351 ~ 82-12 TIR actions may not be adequat Q1999-02356 Conditions where PlFs should have been generate Q1999-02391 - U1 EDG Failure to Start during QCOS 6600-01 Monthly Surveillance Q1999-03921 Missed Vacuum Breaker Tech Spec Surveillance l Q1999-05018 Potentis! Missed Technical Specification Primary Containment Sump Flow Surveillance

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Assessenent and Audits

, . CE-98-05 Comed Engineering Audit-NOA-04-99-018 Engineering Self Assessment and OPEX NOA-04-99-020 . VETIP Program .

- NOA-04-99421 - Corrective Action Program NOA-04-99-046 - Engineering industry Experience Review QAA-04-98-002 Fire Protection Program QAS-04-98-005 Fire Protection Program Audi QAS-04-98-007 Maintenance Rule Program QAS-04-98-055 Flow Accelerated Corrosion Program QAS-04-98-056 Simulator Training QAS-04-98-074 - Operation Briefings, Peer Checks and Discrete Component Operation Progra QAS-04-98-077 - Confiruration s Control Training -l QAS-04-98-081 Environmental Qualification Program i

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LIST OF ACRONYMS USED ATM Action Tracking Management CARB Corrective Action Review Board EDG= Emergency Diesel Generator ESC Event Screening Committee GE General Electric HCU Hydraulic Control Unit LER Licensee Event Report MOV Motor Operated Valves NCV Non-cited Violation NSRB Nuclear Safety Review Board NTS Nuclear Tracking System PORC Plant Operations Review Committee PIF Problem identification Form SIL Service Information Letter UPS Un interruptible Power Supply

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