ML20056G980
| ML20056G980 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/03/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9309080028 | |
| Download: ML20056G980 (7) | |
Text
F C:mmnnwrith Edistn C
1400 Opus Place O
Downers Grove, Illinois 60515 September 3, 1993 f
U. S. Nuclear Regulatory Commission Washington, D. C 20555 Attention: Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-254 and 50-265 Response to laspection Reports 50-254/93015 and 50-265/93015.
Reference:
E. Greenman letter to L. DelGeorge dated July 30,1993 transmitting NRC Inspection Report Numbers 50-254/93015 and 50-265/93015.
The referenced Inspection Report provided the results of a routine safety inspection conducted from May 18 through June 28,1993. During this period, the Unit 1 HPCI system rupture disc failure occurred and the Unit 2 HPCI system l
was found inoperable. Although this Inspection Report identified a non-cited i
violation (NCV) not requiring a written response, the NRC requested that Commonwealth Edison (CECO) provide a written response to address actions taken to identify causes and corrective actions taken to prevent recurrences for continuing safety system failures. Attached is CECO's response.
Quad Cities has performed a detailed assessment of overall station performance which identified issues that have contributed to degraded safety system performance. This detailed assessment also identified changes that will be implemented to prevent further recurrence. We welcome the opportunity to discuss these activities and others associated with improving the safety system performance at Quad Cities.
l If your staff has any questions or comments concerning this letter, please l
refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287.
i Very t ly yours, 1
Dennis Farrar, Manager i
Nuclear Regulatory Services Attachment cc: Document Control J. Martin, Region III, Regional Administrator C. Patel, NRR Project Manager T. Taylor, Senior Resident Inspector, Quad Cities
/gDI;i<
0700 %
9 09080028 930903 M
k:rpainsp:qc:93015re:1 R
l ADOCK 05000254 Q g
PDR %
i ATTACHMENT RESPONSE TO NRC INSPECTION REPORT 50-254/93015; 50-265/93015 ACTIONS TAKEN TO IDENTIFY CAUSES:
i In the past two months the Quad Cities Station has performed a detailed assessment of overall station performance. This self-assessment resulted in the identification of a number ofissues that have contributed to the degraded l
performance of the safety systems. The causes for degraded safety system l
performance are attributed to ineffective leadership and management, ineffective j
corrective actions and ineffective work processes. Specific actions related to l
improving leadership, management involvement, corrective action and work processes are detailed in the next section discussing Corrective Actions Taken to Prevent Recurrence. Actions taken to date are discussed below:
i
- 1) Problems have been identified which prevented effective
{
implementation of the Integrated Reporting Program (IRP), and Root l
Cause Analysis (RCA) program. Corrective actions have been determined that are necessary to achieve effective implementation of the IRP.
l i
The identified problems include procedural inadequacy and less than adequate performance of root cause determinations. In order to resclve these problems:
i Quad Cities revised procedural guidance to eliminate inconsistencies and
[
simplify the procedures for the RCA and the IRP. These procedures were implemented on August 25,1993.
i Quad Cities established a multi-disciplined " Process Experts Group" of root cause evaluators. The group consists ofindividuals from Operations, Maintenance, Engineering, Quality Verification and Regulatory Assurance.
The individuals have been provided additional root cause training and will j
be responsible for the performance of all Level 3 investigations. By l
establishing a core group of root cause specialists, thoroughness and l
consistency of evaluation of significant events will be improved.
Additional training of personnel and program monitoring requirements are being tracked by the Quad Cities Management Plan.
- 2) A multi-disciplinary Safety System Improvement Team was assembled consisting of representatives from the System Engineer, Engineering, Quality Verification and Maintenance Departments to identify issues on safety system performance.
This team reviewed multiple inputs including, but not limited to, the Vulnerability Assessment Team report, IPE/PRA, LERs, Reliability l
Centered Maintenance study, and maintenance work requests to identify i
k:rpa:insp:qc:9301Sre:2 l
1.
I ATTACHMENT l
RESPONSE TO NRC INSPECTION REPORT l
50-254/93015; 50-265/93015 i
l l
issues on the safety systems. The team has identified high priority issues j
on each system and corrective actions to address these issues. The j
corrective actions are being implemented into the Planning Schedule based on the priority established by the team.
l
- 3) The Vulnerability Assessment Team report that was performed in 1992 l
was updated to focus on the equipment reliability issues.
l l
A report issued August 20,1993 completed the update to the Vulnerability l
Assessment that was performed in 1992. The systems originally scoped in the November 1992 Vulnerability Assessment consisted of twelve systerns believed to contribute the most to reducing core damage frequency.
Subsequent to the initial system selection, the draft Quad Cities IPE has become available. One important system was identified (Safe Shutdown Makeup Pump) that.vas not included in the November 1992 Vulnerability Assessment. The Safe Shutdown Makeup Pump has been included in the r
Updated Vulnerability Assessment Report. The Updated Vulnerability Assessment Report focused on the equipment reliability issues within the selected systems. The November 1992 Vulnerability Assessment identified a total of forty-two vulnerabilities. The update has identified six additional vulnerabilities. Plans are being implemented to address these issues.
- 4) The Engineered Safety System Performance Monitoring (ESSPM)
Program was implemented to quantify the expected safety system availability on a day-to-day basis.
t t
Numerical values are assigned to safety system equipment based on their importance to safety. If a piece of equipment is taken out of service, the numerical value for that piece of equipment is subtracted from the total for the unit. Work planning will be performed based on maintaining system availability within established goals.
l I
k:rpa:insp:qc:93015te:3 l
ATTACIBIENT
[
l RESPONSE TO NRC INSPECTION REPORT 50-254/93015; 50-265/93015 l
l l
CORRECTIVE ACTIONS TO PREVENT RECURRENCE:
l As a result of the deficiencies, identified through our self assessment process, Quad Cities station has revised the Management Plan to address these issues.
Specific actions to improve leadership, management involvement, corrective action and work processes have been identified. Implementation of these actions are in progress. These actions include Leadership and Management Deficiencies Ineffective leadership and management j
management involvement and follow-up needs improvement accountability for safety system performance have not been clearly established i
safety system performance monitoring tools have been ineffective l
l Improvement Actions l
Establish higher expectations regarding the Safety Culture at Quad Cities to include but not be limited to: the plant will only be started-up with a l
" full deck", equipment will be returned to service in an "as new or better" condition, and programs and activities will be prioritized with respect to j
adding to the margin of safety, and procedure adherence.
Schedule: December 31,1993 Develop and implement a comprehensive self-assessment process which reflects an effective Nuclear Safety Culture.
Schedule: January 31, 1994 Establish a clear mission and objective for the system engineer program and a schedule for implementation which establishes the System Engineers with 3
control over the systems for which they are responsible and holds them accountable for system performance. - Support the development of the system manager concept through the implementation of the corporate Maintenance Strategy.
Schedule: December 31,1993 Establish performance standards and measurements for system and key component performance which reflect an aggressive safety culture. These performance standards will be included in the System Engineer's Planning k:rpa:insp:qc:9301Sre-4
f ATTACHMENT RESPONSE TO NRC INSPECTION REPORT 50-254/93015; 50-265/93015
}
and Performance Review (PPR) document as an element in ensuring accountability for system performance.
l Schedule: April 1,1994 Develop and implement a strategy ofleadership development based on the Nuclear Operations Leadership and Management Philosophy. The strategy should focus on developing effective leadership skills for the Station's Management Team, including the use of the 3-day Leadership Workshop for i
top level managers, and a method to develop leadership attributes for all l
employees. The 360 - degree performance review will be an integral j
element for individual bench-marking and feedback mechanisms.
Schedule: April 1,1994 1
Define the minimum management expectations for management involvement and follow-up.
7 Schedule: February 28,1994 Safety System Improvement Interface Implementation of the Leadership and Management Objectives will assure that proper expectations of system performance, ownership and monitoring by senior station management are integrated into the Quad Cities safety culture. Management is committed to making the System Engineers the System Owners. Management will ensure that the System Engineers have the resources required to fulfill the System Owner function. Giving the System Engineer responsibility and accountability as the System Owner ensures that adequate resources are supplied to resolve problems.
l l
l k:rpa:insp:qc:93015re:S
t ATTACHMENT RESPONSE TO NRC INSPECTION REPORT 50-254/93015; 50-265/93015
[
t I
I Corrective Actions Process l
l Deficiencies j
Ineffective corrective actions process root causes of equipment problems are not always identified corrective actions are not always implemented in a timely manner corrective actions are not always effective Improvement Actions i
Restructure and implement the Root Cause Investigation Process to include the following attributes: qualifications for personnel involved in conducting investigations; a clear definition of process requirements; the philosophy that recurrence control and identification of similar events must be broad.
Include program trending and assessment requirements to evaluate the thoroughness ofinvestigations and corrective actions.
Schedule: January 31,1994 Effectively implement the Integrated Reporting Program (IRP) through the establishment of a culture which encourages the identification ofissues at a l
low threshold. The resultant data base will provide the necessary information to effectively trend issues and identify corrective actions 1
proactively.
Schedule: January 31,1994 l
l l
l Safety System Improvement Interface l
l Identification of safety system perfonnance issues, root cause determination of the issues, corrective action identification, corrective action implementation, and corrective action effectiveness reviews will ensure that problems associated with the safety system are corrected in a timely fashion l
and are non-recurring.
l k:rpa:Insp:qc:9301Sre:6
ATTACHMENT RESPONSE TO NRC INSPECTION REPORT 50-254/93015; 50-265/93015 Work Processes Deficiencies l
l Ineffective work processes i
I equipment problems are not always resolved in a timely manner the material condition of the plant does not support reliable operation Improvement Actions l
l Establish the Recurring Equipment Problem (REP) Program as the single Station initiative that will identify, evaluate, prioritize, and resolve j
recurring equipment problems. The REP will be the single focal point for the prioritization of significant equipment issues (long standing and i
emerging equipment problems) and facilitate the appropriate scheduling of j
resolutions.
Schedule: January 31,1994 Perform and evaluate the results of material condition reviews to assess the i
effectiveness of the material condition improvement initiatives.
i Schedule: First Review December 31,1993; Second Review May 31,1994 Establish a site management group to develop the implementation strategy for the Corporate Maintenance Strategy in order to improve overall equipment reliability and material condition.
Schedule: October 30,1993.
r I
Safety System Improvement Interface i
Effective implementation of the REP Program will ensure that the high priority equipment issues are resolved. Reviewing the effectiveness of the i
material condition initiatives will ensure that the efforts to effectively implement the REP Program are doing what we expect.
l t
I 1
l i
k:rpa;insp:qc:93015re:7 l
l
_ _ _,