ML20028A741
| ML20028A741 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion, 05000000 |
| Issue date: | 06/18/1982 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20028A739 | List: |
| References | |
| 4387N, NUDOCS 8211240346 | |
| Download: ML20028A741 (24) | |
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& \\ j jjj Address Rap;y 'o e'u -l Office Bos 167 v.y Chicago, litina: 64 GO June 18, 1982 Mr. Jame s G. Keppler, Regional Administrato r ~
Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen E? lyn, I L, 60137
Subject:
Systematic Assessment o f Licensee Performance (SALP)
Commonwealth Edison Company Comments D'resden Station Units 1, 2, and 3; QDpd Cities Station Units 1 and 2; and Zion Station Units 1 and 2 NRC Docket Nos. 50-10/237/249, 50-254/265, and 50-295/304 References (1):
47 FR 12240 dated March 22, 1982.
(2):
J.
A. Hind letter to Cordell Reed dated May 26, 1982 (Dresden Station).
(3):
J.
A.
Hind letter to Co rdell Reed dated May 26, 1982 (Quad Cities Station).
1 (4):
J.
A.
Hind letter to Cordell Reed dated May 26, 1982 (Zion Station).
(5):
Co rdell Reed letter to J. G. Keppler dated Jun e 2, 1982.
Dear Mr. Keppler:
The purpose of this letter is to transmit comments as allowed in Reference (1) in response to the Systematic Assessment o f Licensee Pe rformance (SALP) reports provided in Re ferences (2), (3),
and (4).
Specific detailed enmments for each of the subject sites were presented at the public meeting o f June 2, 1982.
With respect to Dresden and Zion Stations, the more significant comments made are documented in the enclosures to this letter.
As was indicated in Reference (5), Commonwealth Edison believes that improvements could be made in the SALP process which would further induce improvement in licensee performance and promote regulatory resource conservation.
These improvements relate to the apparent lack o f definitive assessment standards' especially in the case of exceptional performance (Ca tegory 1); but also, as relates to the foundation for Category 3 performance.
It is our view that 8211240346 821118 PDR ADOCK 05000254
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PDR vi
i I
the regulatory audit process is focused on the identification of problems, an objective we believe is fully met..
However, this audit' process may not be capable of evaluating fully the positive aspects
'of licensee performance.
In as much as the SALP review interval is relatively short, the fortuitious occurrence of a number of plant performance deviations can give an inaccurate perspective o f true performance.
For these reasons, we ask only that in completing your review, appropriate consJ deration of positive performance trends both prior and subsequert to the SALP interval be considered - just as potential negative trends have already been considered.
We are avaliable at your convenience to discuss these comments.
Should you ~have any questions, please direct them to this o f fice.
Very truly yours, i
\\_h,
(,,
}x-d O
f Co rdell Reed Vice President Enclosures f
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4387N i
vii
I.
INTRODUCTION The NRC has established a program for Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon these observations. SALP is supplemental to ncrmal regulatory processes used to insure compliance with the rules and regulations. SALP is intended from a historical point to be suffici-ently diagnostic to provide a rational basis:
(1) for allocating future NRC regulatory resources, and (2) to provide meaningful guidance to licensee management to promote quality and safety of plant construction and operation.
A NRC SALP Board composed of managers and inspectors who are knowledge-able of the licensee activities, met on March 26, 1982, to review the collection of performance observations and data to assess the licensee performance in selected functional areas.
This SALP Report is the Board's assessment of the licensee safety performance at Quad-Cities, for the period of July 1, 1980 to December 31, 1981, The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held on June 2, 1982.
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1 i
II.
CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed bei.
- of little or no licensee activity or lack of meaningful obso.,;..ons.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC Initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1: Reduced NRC attention may be appropriate.
Licensee manage-ment attention and involvement are agressive and oriented toward nuclear safety; licensee resources are ample snd effectively used such that a high level of performance with respect to operational safety or con-l struction is being achieved.
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Category 2:.NRC attention should be maintained at normal levels.
L Licensee management attention and involvement are evident and are con-I corned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee management attention and involvement are acceptable and considers nuclear safety, but weaknesses are evident; licenseo resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety j
or construction is being achieved.
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III..
SUMMARY
OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Plant Operations X
2.
Radiological Controls X
3.
Maintenance X
4.
Surveillance X
5.
Fire Protection X
6.
7.
Security and Safeguards X
8.
Refueling Operations X
9.
Licensing Activities X
- 10. Environmental Controls X
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IV.
PERFOR?pNCE ANALYSES a.
Flant Operations 1.
Analysis During the eighteen month assessment period, fourteen routine safety inspections of the plant were conducted by the resident inspectors. Each inspection included several functional-areas including plant operations. The inspections revealed only one level VI violation and two infractions relating to plant operations.
The severity level VI violation was failure to notify the NRC in a timely mannar in accordance with 10 CFR 50.72.
The two infractions involved (1) the RCIC control switch which was in the wrong position (mannual vs auto) since a previous surveil-lance test and was not discovered during shift turnover, and (2) the lack of adherence to a temporary procedure resulting in the improper isolation of a hydraulic control unit. These three items were all on Unit 1; all appeared to be isolated events.
There were fourteen scrams during the assessment period, nine on Unit 1 and five on Unit 2.
Three scrams were due to per-sonnel or procedural error; eleven were related to equipment failures. This is not an abnormal experience for a two unit plant over an eighteen month period. Unit 2 has experienced a considerable reduction in scram frequency with no scrams reported during the assessment period since December 11, 1980.
One LER was submitted relating to plant operations. This involved failure to perform surveillance prior to removing a diesel for maintenance. The apparent isolated nature of this event and the absence of other LER's in this crea is indicative of very good licensee performance.
Other evaluations made by the resident inspectors include:
(a) Control Rocm Access Personnel in the control room, especially during evolutions are excessive. The presence of non-essential personnel in the control room may distract the operators may be distracted from their assigned duties. Management needs to exercise more control of this area.
(b) Housekeeping / Cleanliness Following comments from both regional and resident inspectors expressing their concerns with cleanliness, the licensee has embarked on a program to improve housekeeping and plant cleanliness.
4
4 Overall, inspections in this area disclosed no significant management control or regulatory issues. The licensee was aggressive and effective in identifying and correcting under-lying causes of plant operating difficulties. Major viola-tions did not occur during the assessment period and the i
licensee was dedicated to safe plant operation.
b.
Conclusion The licensee is rated C tegory 1 in this area.
c.
Board Recommendations None.
i 2.
Radiological Controls a.
Analysis (1) Radiation Protection Two refueling radiation protection inspections and one followup inspection to the Health Physics Appraisal were performed during the evaluation period by region based inspectors. The resident inspectors also inspected this area. Three items of noncompliance were identified, two concerning workers' failure to follow radiation protec-i tion procedures and one concerning inadequate access controls over a high radiation area.
Personal radiation exposures during this evaluation l
period were higher than average for boiling water reactors. The licensee is considering steps to reduce corrosion product buildup in primary system components in an attempt to reduce radiation levels and personal exposures.
In response to previous inspection findings, a formal ALARA program was initiated, contamination control within the plant has improved, and radiation protection staffing was expanded during this appraisal 4
period. Contract radiation protection technicians were used for the first time during the most recent refueling outage in an attempt to provide better control over 1
I radiation work.
(2) Radioactive Waste Management and Transportation Inspection of radioactive waste and transportation activities was performed by resident and region based inspectors during this evaluation period. A review of licensee event reports identified no unplanned releases or significant problems. The licensee's liquid effluents (excluding tritium), although higher than the average 5
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for other BWR's, did not exceed five percent of that permitted by the Technical Specifications. Airborne radioactive releases remained below one percent of the Technical Specification release limit. No transporta-tion problems were identified with the approximately 500 radioactive waste shipments made during the appraisal
- period, b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Rec;mmendations While assigning Category 2, the Board notes that Quad-Cities is making significant improvements where needed. The posi-tive attitude by management and commitment of resources in this area is noted by the Board.
3.
Maintenance a.
Analysis Categorization of performance in the maintenance area is l
based on events reported by the LER's and findings during inspections done by both resident and region based inspectors.
While a number of problems occurred and a high frequency of valve failures was noted, there appears to be considerable improvement in the last one-third of the assessment period.
During the period from July 1, 1980 to June 30, 1981, forty-one percent of the sixty-five LER's reported were due 1
to valve problems, mostly related to the valve operators.
This essentially continued the failure rate of valves ex-perienced during the previous year. The rate was high and appeared to indicate that improvements were needed in the
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maintenance program.
Inspection Report No. 50-254/81-03; 50-265/81-03 cites three noncompliances in the area of maintenance:
(1) Replacement material not specified properly and installed without proper documentation (Severity Level V).
(2) Temporary modification performed under a maintenance action without a 10 CFR 50.59 review done (Severity Level V).
(3) Preventive maintenance, fluid system cleanliness, housekeeping, recordkeeping, and calibrations pro-l cedures not in accordance with ANSI N18.7-1976 (Severity Level V).
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The first two appeared to be isolated cases and have been resolved. Resolution of the third noncompliance listed was mostly by clarification from CECO that ANSI N18.7-1976 does not apply to Quad-Cities.
It was noted by the resident inspectors, however, that improvements were being made in the areas of preventive maintenance and housekeeping. Recent reductions in LER's reporting " equipment failure" (particu-larly valves) and a reduction in the inadvertent scram fre-quency due to equipment failure also appear to indicate that the preventive maintenance efforts are improved.
(Other than valve seat leaks reported, there were only two valve failures reported between July 1, 1981 and December 31, 1981.)
Other noncompliances cited in the inspection reports and related to maintenance include:
(1) Adjustment of MSIV operator caused failure of the valve to close (Deficiency).
(2) Failure to notify radiation protection on disassembling radioactive equipment (Severity Level IV).
These also seem to be isolated cases for which corrective action was taken.
Two LER's related to maintenance quality were reported:
.t (1) Wood wedges found in the RHR service water pump suction.
The wedges were used during a previous dewatering of the cribhouse.
(2) RHR pump failure to start, caused by an interlock from a misadjusted valve limit switch, and not discovered because of inadequate post maintenance testing.
It is noted that both of these items occurred during non-routine maintenance, indicating a need for increased manage-ment attention in this area.
I b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations The Category 2 rating was based primarily on what appears to be improved performance in the last six months of the assessment period.
Future trends should be observed by j
NRC and inspections performed with emphasis on verification of the improved performance in the maintenance area.
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' 4.
Surveillance a.
Analysis The inspections by the Region III staff and parts of a number of inspections by the resident inspectors were performed in the area of surveillance and inservice inspection. Four noncompliances were identified:
(1) Failure to writo a deviation when surveillance data was out of specification (Severity Level V).
This noncompliance appeared to be due-to a mistake in i
recording data. The fact that the improper surveillance data was not detected in the review piocess was of more concern. The problem was determined to be an isolated case.
4 (2) Failure to return the RCIC system to its normal opera-ting mode subsequent to surveillance testing (Infraction).
This noncompliance was further aggravated by an addi-tional failure of operating personnel. The error was not discovered for two days during " Normal Control Room and Shift Turnover Panel Checks." (Associated noncom-pliance is discussed in the Plant Operations section of this report.)
(3) " Diesel Generator and System Operability Test" performed on the wrong bus (Severity Level IV).
The primary affect of this was the temporary dependence on equipment not immediately proven operable. Probably more important, it represents the type of error that can lead to damage of vital equipment by unintentional operation in a mode for which the equipment is not pre-pared. While the above represents lack of attention 1
and indicates a need for independent verification, it appears to be an isolated case.
(4) Inadequate post maintenance testing resulted in failure i
of au RHR valve interlock (Severity Level IV).
Valve maintenance and incorrect setting of the valve limit switch resulted in an inoperable permissive signal for the associated RHR pump. Valve testing failed to 3
reveal the inoperability.
It was discovered during the j
subsequent pump surveillance test.
This was an isolated event; corrective action was satisfactory.
A review of the ASME Section XI program revealed that Quad-Cities had not implemented its proposed program for I
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testing of pumps and valves. This was due to a misunder-standing between the licensee and NRR which has since been corrected. The proposed program was implemented in mid 1981.
Several LER's were reported related to surveillance.
These are covered by the noncompliances above or discussed in other sections of this report.
While there appeared to be areas needing increased attention, Quad-Cities had an acceptable overall surveillance program, especially since implementation of the ASME Section XI valve and pump test program.
b.
Conclusion The licensee is rated Category 2 in this area.
9 c.
Board Recommendations Inspections should continue on the normal schedule with particular emphasis placed on the newly implemented pump and valve test program.
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Fire Protection a.
Analysis One inspection involving thirty-six inspector hours was performed by the regional inspection staff during this evaluation period. During this inspection, three viola-tions of regulatory requirements were identified. The violations are discussed below:
(1) The licensee failed to control contractor welders resulting in welding operations in the cable tunnels with no fire prevention precautions (Severity Level IV).
(2) The licensee failed to control activities affecting fire barriers resulting in contractors core boring a hole in a fire barrier without taking required fire protection precautions (Severity Level V).
(3) The licensee failed to adequately implement established combustible materials controls procedures (Severity Level V).
l The resident inspectors identified two noncompliances during general plant inspections, one for failure to post a fire watch (Infraction), the other for failure to seal two cable tray penetrations (Severity Level V).
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Four fire protection related LER's were reported, three of which were licensee identified and not the subject of a noncompliance mentioned above. They were:
(1) Diesel fire pump out of service during cribhouse dewatering.
(2) Diesel fire pump out of service because of wood in the pump suction.
(3) Penetration fire barriers inoperable due to vibration of pioing through the penetration.
Because of the noncompliances identified above, it is apparent that more attention to the Fire Protection Program was needed, particularly with respect to contractor activities.
The LER's appear to be isolated cases. The licensee took adequate and immediate corrective action for the problems idantified and j
has made efforts to prevent further prcblems.
+
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations The Board recommends that the licensee improve its own ability to detect problems in the fire protection program.
At least one fire protection inspection should be performed j
during the SALP 3 assessment period to evaluate ongoing performance in this area.
6.
Analysis Emergency Preparedness activities at the Quad-Cities site i
were observed during the licensee's exercise and assembly drills. The licensee maintains a large corporate staff devoted to emergency preparedness and corporate management is actively involved in emergency preparedness. Although the Emergency Preparedness Implementation Appraisal (EPIA) was conducted after the SALP evaluation period, appraisals of other licensee facilities show that corporate management is usually involved in site activities. However, several significant deficiencies were identified during the EPIA for LaSalle, Zion and Dresden prior to the Quad-Cities EPIA.
During the management exit interviews for these EPIA's it was stressed to management that these generic problems should i
be corrected prior to the EPIA at Quad-Cities. This was not done. Although the licensee did not meet the July 1, 1981, installation date for the prompt public notification system, 10
a considerable amount of effort was expended by the licensee such that installation and testing of this system was com-pleted by the required deadline date of February 1, 1982.
The licensee has generally resolved enforcement and licensing issues in this ' area in a timely manner.
b.
Conclusion The licensee is rated Category 2 in this area. This rating is based primarily on the relatively large number of appraisal deficiencies previously identified at other licensee facilities which corporate management failed to have corrected at Quad-Cities.
c.
Board Recommendations The Board recognizes that two major indicators of licensee performance were identified subsequent to the SALP period.
The licensee installed the early warning system for this facility by the February 1, 1982 due date in spite of extremely severe weather. An emergency preparedness appraisal was con-ducted in January 1982. While the number of major deficiencies identified was about average compared to other appraisals in Region III, the fact that about 80 percent of these deficiencies were previously identified over a 6 to 9 month earlier period at other licensee facilities and not corrected at this facility prior to this appraisal is an indicator of insufficient manage-ment attention.
It is the Board's view that these matters should have been resolved prior to the January 1982 appraisal.
7.
Security and Safeguards a.
Analysis Six inspections have been conducted by region based inspectors during the evaluation period (five Physical becurity and one Material Control and Accountability). The resident inspecto made periodic tours of accessible protected end vital areas Eleven noncompliances were identified during this evaluatir period.
Two items of noncompliance were identified in the licensee's Material Control and Accountability (MC&A) program; both items dealt with inventory and records requirements. One item was an infraction, the other was a deficiency.
Nine items of noncompliance were identified in the licensee's Physical Security Program; eight items dealt with access requirements, and the remaining item with testing and mainten-ance. The items were categorized as two infractions, two deficiencies, four Level V violations and one Level IV violation.
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Each of the above items were satisfactorily corrected in a reasonably timely manner.
Although each noncompliance standing alone did not represent a significant programmatic deficiency, the items collectively show that management's involvement in controlling and assuring that the quality of-the security program is maintained is somewhat deficient.
These items illustrate that procedures and policies are occasionally violated, and that the licensee's audit system may not be complete or thorough enough. The licensee's management often established viable approaches to solve identified problems but, on occasion, the approaches lacked thoroughness'and de~pth.
Comparisons with our previous SALP evaluation showed a marginal decrease in the effectiveness of the system. However, further review toward the end of this SALP period showed that the licensee is taking steps to improve their security program.
Corporate security management is generally strong, and their involvement in site activities assists in ensuring that programs, policies, and procedures are sound and technically i
thorough. Corporate security management did, however,_ fail to provide a procedure or adequate guidance that could be used by the site to implement the reporting requirements of 10 CFR 73.71(d). This lack of policy guidance, for several months, could have led to possible reporting deficiencies even though no significant problems have yet been identified.
The major outstanding Safeguards issue is the designation of the entire power block structure as a vital area. This matter is still under Commission consideration.
During the evaluation period, there was a change in a key corporate security management position; no significant breach in management continuity occurred. The staffing and manage-ment of the onsite contract guard force is adequate. The morale and effectiveness of the guard force appears higher than at other sites operated by this licensee.
The combination of attributes applied to the licensee's safe-guards program toward the end of this SALP period appear to demonstrate the achievement of satisfactory security perform-ance. The resources available are adequate and reasonably effective with respect to basic operational security.
b.
Conclusion The licensee is rated Category 2 in this area.
1 c.
Board Recommendations a
The licensee should realize that the Category 2 rating is chiefly based on the licensee's apparent improvement i
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4 In their security program toward the conclusion of this SALP period.
If this improvement does not continue or decreases to the level observed in the beginning of this SALP period, the licensee can expect that the present category level will be re-evaluated during the next SALP review period. Even though improvement has been noted in the licensee's security program, an increase in NRC attention is warranted to assure that this improvement continues.
8.
Refueling Operations a.
Analysis During the assessment period, inspections conducted during refueling outages involved resident and region based inspections.
Even though refueling was only one of the areas inspected, it is noteworthy that only one related noncompliance was identified (Infraction). This was move-ment of fuel in violation of newly issued Technical Specifications and was due to a communication error. Plant safety was not compromised.
Work performed during the outages for both units included major modifications to the core spray system, Mark I containment, and reactor water cleanup system. Other work 1
involved turbine inspections and work related to TMI Action i
Items and IE Bulletins. The total outage time was approxi-mately 22 weeks for Unit 1 and 18 weeks for Unit 2.
The resident inspectors noted that refueling operations were conducted very smoothly from plant shutdown through post refueling startup. With the extensive nature of the outages, involving over 6000 fuel bundle movements, no handling pro-blems were noted, no overexposures or medical emergencies occurred, and startup after refueling was without many of the problems frequently experienced after extended outages.
b.
Conclusion The licensee is rated Gategory 1 in this area.
c.
Board Recommendations f
None.
9.
Licensing Activities a
a.
Analysis (1) Performance Elements (a) Quality of response and submittals:
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Commonwealth Edison usually provides licensing sub-mittals which are complete and technically adequate.
Their responses to technical questions and staff requests for additional information are normally on time and provide the requested information.
(b) Efforts required to obtain an acceptable response:
Timeliness-The licensee usually submits informa-tion on the date which the staff has specified.
If a response is going to be late, the licensee will inform NRC of the delay and propose a new schedule.
Effort-Because the licensee has had considerable experience with NRC regulations and requirements they generally provide an acceptable response without excessive staff effort.
Responsiveness to staff requests-The licensee's personnel are competent, well qualified engineers with plant operations background. They have been responsive to requests from the staff. They have also been responsive to the informal type of requests that are common in ongoing licensing actions.
(c) Working Knowledge:
Because of their extensive background and experience in dealing with the NRC, the licensee has developed a licensing staff which has a strong working knowledge of NRC regulations, guides, standards, and generic issues.
(d) Technical Competence:
The licensee's technical staff continues to exhibit I
a broad competence across the spectrum of technical disciplines. CECO's practice of rotating personnel 4
from operational positions into licensing and cor-porate staff positions assures that current expertise is available for use on problems identified by NRC staff.
)
(e) Conduct of meetings with NRR:
The licensee's performance at NRR meetings is above average. They come to the meeting prepared to discuss the appropriate tachnical issues and assure that the appropriate level of management is available to make any decisions that are required.
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(f) Long-standing open items:
Response to long-standing open items and generic issues has been acceptable. Some of these issues have deferred due to more pressing commitments such as equipment qualification and TMI action plan responses. However, most long standing open items have been responded to and are awaiting completion of staff review.
(g) Organization and management capabilities:
Management at Quad-Cities and at the corporate office exhibits a good understanding of regulatory require-ments and appears committed to work effectively with the NRC staff.
(h) Results of operator licensing examinations conducted:
Seven operator and senior operator licensee examina-tions have been given. Six of the applicants passed their initial examinations; the seventh individual passed the re-examination. This level of performance is above average.
(1) Performance on specific issues:
Fire Protection-The licensee worked with the staff in a constructive manner and resolved all of the fire protection open items in a manner acceptable to the scaff.
TMI action plan-The licensee has met required submittal dates for the TMI action plan. They have generally agreed to follow the staff's suggested plan of action and are implementing most of the corrective actions on a schedule i
acceptable to the staff. They have identified those items for which they cannot meet the imple-mentation dates and have provided acceptable justification.
(2) Observed Trends in Performance Performance in responding to the NRC staff's require-ments has continued at an acceptably high level.
It has been evident that CECO has been heavily impacted by the escalation of responses requested of them by NRC. They show some indication that they may be unable to keep up with all high priority, short turn-around requirements or schedules in the future.
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r-4 (3) Notable Strengths and Weaknesses (a) Strengths The experience and background in dealing with NRC results in high quality technical responses to requests and requirements with a minimal NRC staff effort. This technical competence and good management attention to solving problems with NRC is a major strength.
(b) Weaknesses None observed.
b.
Conclusion The licensee is rated Category 1 in this area.
c.
Board Recommendations None.
10.
Environmental Controls a.
Analysis (1) Confirmatory Measurements One inspection has been performed by the Independent Measurements and Environmental Protection Section during the evaluation period, in which the Region III Mobile Measurements Van was used. No items of noncom-p11ance or deviations were identified.
The licensee's performance for the Confirmatory Measure-ments sample comparison yielded one disagreement (Cs-137 4
l on particulate filter) out of 12 comparisons.
In this disagreement the licensee's result was higher and there-l fore conservative. No conclusive explanation for the discrepancy between the NRC's and licensee's results could be identified.
In a subsequent measurement of a spiked Cs-137 sample tracable to +he NBS, the 11-censee's results were low, approximately 83% of the expected value.
The licensee's performance of quality control of analytical measurements involving radiological and nonradiological analysis of reactor coolant, training of chemistry personnel, and performance checks of counting equipment are considered to be adequate.
The licensee is standardizing its chemical procedures 16
I-for analysis and calibration, and is centralizing data reporting to one location for all its nuclear plants.
Quad-Cities has been selected as the first licensee plant to implement the standardized procedures. The licensee maintains a good analytical facility. Licensee personnel are adequately trained and appear eager to do a good job.
'(2) Environmental Protection One routine and one special safety inspections were performed by the Independent Measurements and Environ-mental Protection Section during the evaluation period.
No items of noncompliance or deviations were identified.
The licensee did have a recurrence of the discharge canal overflow within a period of about 5 months after the initial washout of an access road and security fence in December 1980.
Personnel error was involved in the second event. The licensee is revising procedures to avoid recurrence of this event. The Radiological Environmental Monitoring Program has been conducted satisfactorily.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations None C
e 9
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V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data.
Facility Name: Quad-Cities, Unit 1 Docket No: 50-254 Inspection Nos. 80-16,-18, 19, 21 through No. 80-31 Nos. 81-01 through 81-22 Noncompliances and Deviations
- Severity Levels Categories Functional Areas Assessment I II III IV V VI Viol.
Infr.
Def.
Dev.
1.
Plant Operations 1
2 2.
Radiological Controls 1+(1) 3.
Maintenance (2) 1 4.
Surveillance (1) 1 5.
Fire Protection (2)
(1) 6.
Security and Safeguards (1) (4) 1+(2) 1+(2) 8.
Refueling Operations 1
9.
Licensing Activities
- 10. Environmental Controls 11.
Other (1)
TOTALS 0 0 0 (1) 1+(11) 1 0
5+(3) 2+(2) 0 1
Numbers in parenthesis indicate noncompliance common to both units.
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r-SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Facility Name: Quad-Cities, Unit 2 Docket No: 50-265 Inspection Nos. 80-20, 21, 23-through No. 80-31 Nos. 81-01.through 81-22 Noncompliances and Deviations
- Severity Levels Categories Functional Areas Assessment I II III IV V VI Viol.
Infr.
Def.
Dev.
1.
-Plant Operations 2.
Radiological Controls 1
(1) 3.
Maintenance 1
1+(2) 4.
Surveillance 2
(1) 5.
Fire Protection 1
1+(2)
(1) 6.
Security and Safeguards (1) (4)
(2)
(2) 8.
Refueling Operations 9.
Licensing Activities
- 10. Environmental Controls 11.
Other (1)
TOTALS 0 0 0 5+(1) 2+(11) 0 (3)
(2) 0 I
1 Numbers in parenthesis indicate noncompliance common to both units.
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B.
Report Data Quad-Cities Unit 1 and 2 LER's For Assessment Periods 1 and 2 Period 1 (12 Months)
Period 2 (18 Months)
Proximate Cause*
7/1/79 through 6/30/80 7/1/80 through 12/31/81 Personnel Error 5
(.4)**
12
(.7)**
Design, Manufacturing 7
(.6) 4
(.2) and Construction /
Installation External Cause 1
(.1)
Defective Procedure 2
(.2)
Component Failure 59 (4.9) 70 (3.9)
Other 1
(.1) 2
(.1)
Total 74 (6.2) 89 (4.9)
- Proximate cause is the cause assigned by the licensee according to NUREG-0161, " Instructions for Preparation of Data Entry Sheets for Licensee Event Report (LER) File."
- Numbers in parenthesis are number of events per month.
Summary LER Evaluation July 1, 1980 - June 30, 1981 An evaluation of LER's for the first twelve months of the SALP assessment period indicates an improvement in valve maintenance was needed. Valve problems comprised 41 percent of the events reported. No procedural errors and an average number of personnel errors were identified by the licensee. However, it appears that a number of equipment failures reported were attributable to these two areas.
Corrective action indicated on the LER's appeared adequate to correct failures as they occurred, but, in a number of cases, not to reduce their frequency.
Performance in this one area, particularly with valves, needed improvement. The problem is evident in the cause code assignment as well as in corrective action descriptions. For instance, most of the valve problems were identified as equipment failures.
Because of the higher failure rate than other licensees (and comparison with WASH-1400 failure data which also indicates a high failure rate), one is led to believe that a significant cause must be in maintenance, either in the area of the maintenance program (procedures) or in personnel capability. Equipment design may also be suspect.
Without identifying the proper cause, " corrective actions" continue to permit a high failure rate.
20
[
Personnel errors reported by the licensee include (1) post main-tenance operability testing inadequacy that led to failure of an RifR pump start logic, (2) surveillance of the wrong equipment train, and (3) taking a diesel out of service wflthout verifying operability of the opposite train.,
'lko LER's reported wood getting into a safety-:clated piping system and causing pump damage. Causes were coded " equipment failure" for one and " external cause" for tha oth'er.,
Neither V
s appnsrs to be the proper cause for the event f.dentified.
Another more importent LER during this SALP perfod reported i
diilling holes in containment due to a modifict.tlon design,
error. For this, the cause was properly identified and cor-rective action taken.
3 b
1 (The next paragraph covers the last six months of the assessment period.)
d j
July 1, 1981 - December 31, 1981 An evaluation of Quad-Cities LER's for the six months from July 1, 1981 to Dacember 31, 1981, indicates acceptable per-formance with considerable improvement over the first twelve months of the assessment period. The report frequency went down to 75*. of the Region III average; and, the significance and repetition of events reported was reduced.
Particularly encouraging is the reduction in valve operability failures.
"Mishapa" such as holes drilled in containment and wood in plant
' piping Systems, as reported earlier, were practically eliminated.
'Some areas represented by thn LER's needed additional attention but these were minor by comparison to the earlier experience.
C.
Licenseo Activities Activities of the if censee are described in detail in the plant operations analysis and refacling analysis sections.
D.
Inspection' Activities One major " team" ins'ection:vas' accomplished by the Quality p
Assurance Appraisal, encorrpassing some 400 inspection hours.
No significant findings.were identified.
The Institute of Nuclear Power Operations conducted an evalua-tion during the weeks of Juae 15 and 22, 1981. Within the scope of this evaluation, the team determined that the plant is in 7, satisfactory material condition and is being operated in a safe manner by qualified personnel.
Review of this evaluation by the senior resident inspector was conducted and no safety-related concerns were identified.
g
/
21
T E.
Investigations and Allegations A former licensee employee alleged that the Commonwealth Edison Company's operation of the Dresden, Quad-Cities and Zion stations creates a substantial safety hazard and therefore is reportable per 10 CFR Part 21.
The allegation was based on the conclusion that licensee management was promulgating operating directives and philosphies which were unsafe in that they authorized departure from the Technical Specifications and that the licensee's correc-tive action's were incomplete or ineffective. These allegations resulted in an extensive evaluation of the plant events, corrective action, and coporate management policies and procedures specifically addressed by the alleger. The special inspection conducted relative to this matter determined that none of the plant events cited by the alleger or others randomly selected for review created a safety hazard such that a significant threat existed to the health and safety of the public. Further, no instance was identified during the review where NRC reporting requirements had not been met, including those required by 10 CFR Part 21 or where NRC enforcement action was warranted but not taken. The inspection did determine that several areas of weakness did exist related directly or indirectly to some of the concerns expressed by the alleger. With minor exceptions, these did no apply to Quad-Cities station. The results of the special inspection are documented in a separate report and were discussed with the licensee management on May 3, 1982.
F.
Escalated Enforcement Action 1.
Civil Penalties:
None.
2.
Orders:
None.
3.
Immediate Action Letters (IALs):
- None, G.
Management Conferance October 31, 1981:
SALP Cycle 1 Conference 22