ML20136E474

SALP Repts 50-254/85-01 & 50-265/85-01 for June 1984 - Sept 1985

ML20136E474
Person / Time
Site:	Quad Cities
Issue date:	01/03/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136E459	List: ML20136E455 ML20136E474
References
50-254-85-01, 50-254-85-1, 50-265-85-01, 50-265-85-1, NUDOCS 8601070029
Download: ML20136E474 (38)

See also: IR 05000254/1985001

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SALP 5

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SALP BOARD REPORT

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U. S. NUCLEAR REGULATORY COMMISSION

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' SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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50-254/85001: 50-265/85001

Inspection Report

Commonwealth Edison Company

Name of Licensee

Quad Cities Nuclear Power Station

Name of Facility

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June 1, 1984 through September 30, 1985

Assessment Period

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B601070029 860103

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ADOCK 05000254

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I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and to evaluate licensee performance based upon this infor-

mation. SALP is supplemental to normal regulatory processes used to ensure

compliance to NRC rules and regulations. SALP is intended to be sufficiently

diagnostic to provide a rational basis for allocating NRC resources and to

provide meaningful guidance to the licensee's management to promote quality

and safety of plant construction and operation.

A NRC SALP Board, composed of staff members listed below, met on November 13,

1985, to review the collection of performance observations and data to assess

the licensee's performance in accordance with the guidance in NRC Manual

Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of

the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety

performance at Quad Cities Nuclear Power Station for the period June 1, 1984

through September 30, 1985.

SALP Board for Quad-Cities Nuclear Power Station:

Name Title

J. A. Hind Director, Division of Radiological

Safety and Safeguards

C. J. Paperiello Director, Division of Reactor Safety

D. Vassallo Chief, Operating Reactors Branch 2, NRR

N. J. Chrissotimos Chief, Reactor Projects Branch 2

R. L. Greger Chief, Facilities Radiation Protection

Section

G. C. Wright Chief, Reactor Projects Section 2C

M. A. Ring Chief, Test Programs Section

R. B. Landsman Project Manager, Reactor Projects

Section 2C

R. Bevan Quad Cities Project Manager, NRR

A. L. Madison Senior Resident Inspector

A. Morrongiello Resident Inspector

P. R. Rescheske Reactor Inspector

R. A. Hasse Reactor Inspector

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II. CRITERIA

The licensee's performance is assessed in selected functional areas

depending on whether the facility is in a construction, preoperational,

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 becauss

of little or no licensee activities or lack of meaningful observations.

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 a 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's 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 aggressive and oriented toward nuclear

safety. Licensee resources are ample and effectively used so that a high

level of performance with respect to operational safety or construction

is being achieved.

. Category 2: NRC attention should be maintained at normal levels. Licen-

see management attention and involvement are evident and management is

concerned 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. Licen-

see management attention and involvement is acceptable and considers

nuclear safety, but weaknesses are evident. Licensee resources appear

to be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety or construction is being

achieved.

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Trend: The SALP Board has also categorized the performance trend in each

functional area rated over the course of the SALP assessment period. The

categorization describes the general or prevailing tendency (the perfor-

mance gradient) during the SALP period. The performance trends are

defined as follows:

Improved: Licensee performance has generally improved over the course

of the SALP assessment period.

Same: Licensee performance has remained essentially constant over

the course of the SALP assessment period.

Declined: Licensee performance has generally declined over the course

of the SALP assessment period.

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III. SUMMARY OF RESULTS

The overall regulatory performance of the Quad Cities facility has

continued at a high level during the assessment period. Improved

performance in the area of reactor operations is noted. The Regulatory

Performance Improvement Plan appears to have been a major factor in

bringing about the improvement in regulatory performance.

Rating Last Rating This

Functional Area Period Period Trend

A. Plant Operations 3 2 Improving

B. Radiological Controls 2 2* Same

C. Maintenance / Modifications 2 2 Improving

D. Surveillance and

Inservice Testing 1 2 Same

E. Fire Protection /

Housekeeping 2 2 Same

F. Emergency Preparedness 1 1 Same

G. Security 1 1 Same

H. . Refueling 1 1 Same

I. Quality Programs and

Administrative Controls 2 2 Same

- J. Licensing Activities 1 1 Same

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• The Radiation Protection portion of this functional area-is rated Category 1.

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IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

Portions of ten routine inspections were performed by the

resident inspectors covering plant operations. Also, two

special inspections were performed by resident and regional

personnel covering the operations area. Three violations

were identified as follows:

a. Severity Level V - Failure to report automatic actuation

of Engineered Safety Feature (265/85007-01).

b. Severity Level IV - Failure to perform adequate shift

turnover (265/85019-01).

c. Severity Level III - Failure of the Unit 1 operator to be

present at the controls at all times during the operation

of the facility (254/84023-01).

The first violation was due to a misinterpretation of new

reporting requirements and appeared to be isolated in nature.

The second violation was the root cause for a sequence of events

which resulted in the Reactor Core Isolation Cooling (RCIC)

system flow control switch being left in manual. Management

responsiveness was good and no other similar violations were

identified.

The third violation represented a matter of major concern to

the NRC and resulted from a special inspection in response to

the October 25, 1984 scram of Unit 2 during which the Unit 1

operator left the controls of his unit. An Enforcement Con-

ference was held on November 5,1984 with members of corporate

and plant management. There were no additional substantive

events involving operators subsequent to this event, indicating

that management controls instituted were responsive. Escalated

enforcement was taken and a Civil Penalty of $50,000 was levied.

The small number of Violations is a result of an aggressive

effort by licensee management to identify potential problems

before they become regulatory concerns. This coupled with a

cooperative and concientious worker attitude has resulted in

improved performance, especially in the latter half of the

evaluation period.

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Control room behavior had been of concern at Quad Cites due to

past events including the October 25, 1984, scram of Unit 2.

Several problems were noted by the NRC and the licensee as a

result of.these events, and licensee management aggressively

addressed these. This includes the issuance of numerous

procedures and a manual entitled " Good Operating Practices."

The professional conduct of operating personnel is of concern

to management and union personnel. Operators are attentive to

their units and alarms are always acknowledged and analyzed

immediately. Reading material is restricted to work / job

related material and other distractions such as radios are not

allowed. Graffiti is not sanctioned at Quad Cities and does

not exist in the control room. Eating is allowed in the

control room, but tais has not proven to be a problem in the

past.

Most operators are concerned with their professional appearance

and maintain reasonable standards. However, there is a minority

that rebel against such restrictions. The licensee is aware of

these anomalies and is working with the union to improve this

condition.

The first special inspection was a team inspection by senior

inspectors to review overall licensee performance and provide

an in-depth assessment of selected areas including operations.

No violations were identified in the operations area and

overall licensee performance was found to be acceptable.

The second special inspection was in response to the

October 25, 1984, scram of Unit 2 during which the Unit 1

operator left the controls of his unit. Also during the scram,

one control rod had failed to insert properly and a valving

error was found to be the cause. The inspection targeted two

concerns: (1) the behavior of control room personnel during

the event, and (2) any damage which may have been caused to

the control rod drive (CRD) as a result of the valving error.

A Confirmatory Action Letter (CAL) was issued on October 26, ,

1984 by Region III delineating several actions the licensee was

to perform prior to restart of Unit 2. These included replace-

ment of the affected CRD and examination of its internals;

verification of all other valves in the CRD system; investigation

of the root cause of the valving error and subsequent lockwiring

of all similar valves in the CRD system; and identification of

any improper control room behavier and appropriate corrective

actions.

The inspection resulted in escalated enforcement as noted

above.

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Corrective actions as a result of this inspection included

those actions taken to comply with the CAL, and the issuance of

-several procedures and procedure changes and a manual entitled

" Good Operating Practices." The procedure changes addressed

the ambiguousness and lack of restrictions on where the unit

operator may go-in the control room, by increased clarification

and the use of diagrams. Also, additional training was given

to supervisory personnel to ensure understanding and compliance.

Additionally, the licensee has instituted a control room task

force to work on further improvements in control room behavior

and performance. This voluntary effort is supported by manage-

ment and union personnel.

Periodic management conferences were held to discuss licensee

progress in the ongoing corporate-wide Regulatory Performance

Improvement Plan (RPIP). The RPIP has resulted in improvement

in overall licensee' performance especially in the latter half

of the evaluation period. The RPIP was well stated, properly

disseminated, and provided understandable policies that required

decision making be consistently at a level that ensures adequate

management review. Corrective actions associated with violations

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and LERs were prompt and effective and ensured that minor viola-

tions were not repetitive and major violations were rare.

Corporate management was frequently involved in site activities.

Site management's attitude and attention to regulatory matters

and inspector concerns was aggressive and provided for

technically sound, conservative, and thorough responses and

actions in almost all cases. Examples of inspector concerns

which were adequately addressed by the licensee before they

became regulatory issues are: (1) The August 1984 resident

inspection identified a concern that the instrument technicians

were not adequately communicating with operations personnel and

were causing unnecessary actuations of safety equipment. The

licensee provided immediate management attention in this area

and instituted additional controls to eliminate this concern.

(2) Also identified in the August 1984 resident inspection report

was a concern that the maintenance personnel may have the

required procedure available, but not open and being followed

step-by-step. This issue was also immediately resolved and no

further instances were identified.

There was consistent evidence of prior planning and assignment

of work activities. Staffing appeared to be adequate and no

difficulties were identified with overtime or work backlog.

The training program was well defined and was implemented

with dedicated resources for the majority of the staff. The

licensee has committed to comply with the INPO guidelines on

training and is on schedule or ahead in certain instances with

their implementation of this.

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Twenty LERs were submitted in.the operations area during~the.

-assessment period. .This was a reduction by a factor of three

from the previous assessment period. Six of the LER's were

attributed to personnel error of which three resulted in the

violations'noted above. Two of the LERs were due to procedure

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deficiencies andLthe remainder were caused by equipment mal-

function. -While the percentage of personnel errors has

increased, the actual number has remained approximately the

same whereas the significance of _ these errors has been reduced.

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Seven reactor scrams occurred on Unit 1, three of which occurred

while shutdown, and nine on Unit 2, three of which occurred

.while shutdown. ~Six of the sixteen scrams were caused by

personnel error (i.ncluding contractor personnel), one by

. procedural deficiencies,- c ra tna remainder were caused by

. equipment malfunctions. _While the number of operational scrams

. remains the same as the last evaluation period, most occurred

at the beginning of the period. Increased ~ management attention

in this area has resulted.in improvement as. witnessed by the

trouble-free startup of Unit 2 following an extended refueling /

maintenance outage-in June, 1985~, and the absence of reactor

scrams for either unit throughout the latter portion of the.

evaluation period.

During the report period, examinations were administered to nine

reactor operator and nine senior reactor candidates. The overall

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pass rate for the candidates was 77%, which was not significantly

'different from the national average. Requalification

-examinations were not administered by the NRC at the Quad Cities

station.

2. Conclusions

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_The licensee is rated Category 2 in this area. Although

performance in this area was judged to be poor at the

beginning of the assessment period, improvement in both

performance and management involvement have been observed

during the last half of the assessment period.

3. Board Recommendations

None.

B. Radiological Controls

1. Analysis

Eight routine inspections and one special inspection were .

performed during this assessment period by region based ]

. inspectors. These inspections included confirmatory measure- ,

ments, environmental monitoring, chemistry and radiochemistry,

waste generator requirements, operational radiation protection,

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and radwaste management. In addition, the resident inspectors

routinely inspected the licensee's activities in this area,

concentrating on implementation of the ALARA program, and a

special operational team inspection reviewed activities in this

area. Two violations were identified as follows:

Severity Level IV --Failure to control the R gate to the

northeast residual heat removal area (265/84017-02).

Severity Level V - Failure to collect and analyze

technical specification required service water grab

samples due to inoperable service water monitors on both

units (254/85321-01; 265/85024-01)

Management provides good support for the radiation protection

program in manpower, facilities, and equipment as evidenced by

additional contamination control facilities, additional ALARA

staffing, and increased number of ALARA reviews. Onsite

program management and management support in the radiation

protection program along with the continuing good attitude of

the workers appears largely responsible for the licensee's good

performance in this area. Stronger management involyement in

chemistry and radiochemistry is warranted as indicated by

weaknesses in Radchem Technicians (RCT) performance on vendor

supplied blind samples and additional attention is needed in

RCT training as indicated by inspector observed shortcomings in

sample collection and handling practices by RCTs. Stronger

management involvement in radwaste and environmental monitoring

is also needed as indicated by discrepancies noted in this

report in the radiological environmental monitoring program and

by the slow pronress in installation of new service water

monitors. The monitors, originally scheduled for December 1984

installation to coincide with the new Radiological Effluent

Technical Specification (RETS), are still not operable.

Absence of these rsonitors places the plant in an LCO actica

statement requirir.g grab sample surveillance every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A

failure to take the required sample resulted in a violation

identified during this period.

Station and corporate quality audits are complete, timely, and

thorough; corrective actions are adequate and timely; health

physics expertise is represented in both the onsite and

corporate QA organizations. The need for enhanced RCT training

was identified and is discussed below. The licensee's

radiological occurrence and personal contamination report

systems have been enhanced to ensure correction of internally

identified programmatic problems, including disciplinary

actions. Reportable events are properly identified and analyzed

and reported in a timely manner.

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There is consistent evidence of responsiveness to NRC concerns

as evidenced by establishment of an enhanced contractor rad / chem

technician training program, and prior planning as evidenced by

enhanced ALARA pre-job reviews and continued effectiveness of

recirculation system decontaminations. In response to an NRC

observed weakness concerning sample collection and handling

practices, licensee management discussed the matter with all

applicable personnel and agreed to increase supervisory

oversight of these activities; the licensee also committed to

make hardware changes to decrease difficulty in sampling the

river discharge tank which contributed to the problem.

Licensee staffing remains relatively strong, although the plant

Radiation Protection Manager (RPM) was transferred to the

licensee's corporate organization and replaced as Rad Chem

Supervisor by the former plant chemist. This and other '

organizational changes during this assessment period have

resulted in three intervening management positions between the

RPM and the Plant Manager. This organizational structure could

hinder communication of radiation protection concerns from the

RPM to upper level management. Key positions are filled on a

priority basis, staffing is ample, and responsibilities are

well defined. Program support was increased with the addition

of a laboratory foreman to direct laboratory activities, two

chemistry coordinators, ALARA health physicists, and an ALARA

planner. During recent outages, the licensee has required

minimal use of contract radiation protection technicians.

There is minimal turnover in the rad / chem department; position

vacancies develop mainly from promotions.

RCT training has been generally satisfactory; although weaknesses

in sample collection and handling practices on the part of two

RCTs were observed during a confirmatory measurements inspection.

The licensee was already in the process of improving RCT training

with development of an OJT Training Manual requiring demonstra-

tion of proficiency in an extensive list of required chemistry

and radiochemistry analyses. The licensee also plans to increase

annual RCT refresher training from one to two weeks. However,

the licensee's long standing policy of rotating chemistry and

health physics assignments could limit RCT proficiency in the

. laboratory. Retraining in radiation protection matters has

been enhanced in response to an internal QA audit finding. The

enhancement includes more extensive classroom presentation of

theory, and routinely conducted " tailgate" sessions where

current radiological plant conditions, changes to procedures

and policies, and industry-wide radiological occurrences are

discussed. Also, the training program for contract technicians

has been enhanced by inclusion of more extensive training of

plant procedures and policies. The training and qualification

program contributes to an adequate understanding of work and

adherence to procedures.

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The licensee's approach to radiological protection issues has

been sound in most cases. For instance, an ongoing contamina-

tion control problem during control rod reworking is being

resolved by construction of a new facility designed specifically.

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for this' work. Also, storage areas, ventilation, shielding, and

work / transfer area separation has improved, and a new tool and

equipment decontamination area, now operational, should minimize

recurrence of previous problems.

' Effectiveness of the ALARA program has continued to improve

during this assessment period. Increased ALARA awareness by

the. stat.fon' staff, periodic meetings with the maintenance

. department, addition of appropriate manpower to support the

ALARA organization, and pervasive management support have

resulted in more extensive pre-job' planning and post-job

reviews. A continuing contamination reduction and control

program has.been enhanced by construction of a tool and equip-

ment decontamination facility, and redesign of the control

rod drive maintenance facility.

Total worker doses during this assessment period, about 770

person-rems per. unit in 1984 and estimated to be about 550

person-rems per unit for 1985, represent significant decreases

(50 to 70 percent) over the licensee's annual average doses

over the last five years, and are 30 to 50 percent below the

average of U.-S. boiling water reactors.

Licensee implementation of 10 CFR 20.311 and 10-CFR 61

requirements for classifying and shipping solid radwaste has

been satisfactory except for minor, easily corrected discrep-

ancies on some manifests. However, completion of procedure

revisions to reflect current practices has been somewhat slow.

Liquid and gaseous radwaste effluents continued in the average

range for U. S. boiling water reactors with a slight downward

trend in liquid effluent owing to improved waste treatroent

techniques. However, repeated occurrence of minor errors and

omissions in the semiannual effluent reports indicated a need

for better review before publication.

. The laboratory QC' program -in chemistry was generally acceptable.

Overall,' laboratory equipment was reasonably well maintained and

adequate to perform necessary analyses. -However, continued

attention is needed in QC to-improve RCT performance. Approxi-

mately 18 percent of 1984 RCT analyses of vendor supplied blind

check samples had to be repeated to meet acceptance criteria.

This failure rate may reflect the long intervals between

successive laboratory assignments for individual RCTs. Improve-

ments are also,needed in the trending of counting room instrument

performance. The licensee's current practice of plotting monthly

average rather than daily QC data is not conducive to timely

recognition of trends in instrument performance.

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The station continued to perform satisfactorily in confirmatory

measurements with 36 agreements out of 39 comparisons during

1984 and 38 agreements out of 40 comparisons during 1985. The

three disagreements during 1984 were resolved after the licensee

recalibrated his gas geometry for effluent samples. A Sr-89

disagreement in the 1984 liquid waste sample resulted primarily

because the sample was not sent to the licensee contractor for

analysis in a timely manner, resulting in decay of Sr-89 through

several half-lives before analysis was performed. The radio-

logical environmental monitoring program (REMP) appears well

implemented, largely under contract. No problems were noted in

the operability or calibration of the environs stations or the

contractor's QC program. Only one minor anomalous result

(slightly elevated gross beta activity in the Spray Canal

Blowdown) was observed and was found to result from a con-

taminated container. However, management oversight of the REMP,

primarily in the corporate office, has been weak with continuing

discrepancies noted for nonroutine reporting levels for fish,

milk, and surface water. Following a special inspection at the

corporate office, the licensee agreed to provide closer manage-

ment oversight of the program and to resolve the discrepancies

between the various documents describing the REMP.

The station was in the process of developing and implementing a

BWR Water Chemical Program in response to corporate management

directives. Reasonable progress has been made in identifying

needed modifications to process instrumentation with contracts

scheduled to be let in the fall of 1985. Revision of analytical

procedures for this program was also in progress and the licensee

had committed to implement standards, in accordance with the BWR

Owners Group guidelines, for chlorides, pH, conductivity, and

solids. These standards were considerably more restrictive than

previous standards.

2. Conclusion

The licensee is rated Category 1 in radiation protection, but .

is rated Category 2 in chemistry, radwaste and environmental

monitoring. The licensee's performance in reducing the plant

radiation environment and in the substantial downward trend in

worker doses reflect SALP 1 performance in the area of radiation

protection. The overall rating for this area is Salp 2.

3. Board Recommendations

None.

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C. Maintenance / Modifications

1. Analysis

The resident and regional inspectors routinely inspected the

licensee's activities in this area, concentrating on implemen-

tation of procedures and design modifications.

In addition, a special inspection was performed by Region based

inspectors to determine the reasons for several faulty plant

modifications which were identified by the resident inspectors

during a major maintenance and refueling outage for Unit 1 at

the beginning of the assessment period. The special inspection

identified one violation with four examples:

Severity Level IV - Failure to adequately control design

changes (254/85002-01; 265/85002-01).

The specific examples involved the improper installation of

jumpers in the standby gas treatment system (SBGTS) resulting

in the system being declared inoperable due to the failure of

the electrical heaters; failure to adequately analyze a piping

modification to the Unit 1 drain line resulting in a vibration

problem; improper installation of anti-hammer circuits for the

Unit 1 LPCI valves resulting in damaged valve stems; and the

improper installation of steam jet air ejector suction valves

in Unit I resulting in the system being inoperable.

Analysis of these events'by the NRC indicated a lack of adequate

design reviews, post-modification testing,- design analysis, and

in the case of the SBGTS, an inadequate procedure for temporary

modifications. These problems were indicative of weaknesses in

. management involvement and training in the design change and

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modification process. Because of the significance of the items,

an Enforcement Conference was held with the licensee on March 15,

1985 in Region III to discuss the violation and licensee

corrective actions. Based upon the licensee's presentation,

previous enforcement history, and relative safety significance

of the individual violations, no escalated enforcement action

was taken by the NRC.

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This was the only violation identified in the Maintenance /

Modification area during this evaluation period. This is a

significant improvement over the six violations identified

during the previous evaluation period.

Significant Regional inspection effort was dedicated to examine

the Quad Cities Inservice Inspection Program. For the areas

examined, the inspectors determined that the management control

systems were effective in that activities had received prior

planning and priorities have been assigned. Policies were

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adequately stated and generally understood. The licensee's

actions in response to NRC initiatives indicated they understood

the issues and their reviews were generally timely, thorough,

with technically sound conservative solutions. Records and

calculations were found to be generally complete, well

maintained, and available. The records also indicate that

equipment and material certifications were current and complete,

and personnel were properly trained and certified. The approach

used to evaluate and analyze piping systems and supports was

generally conservative, technically sound, and thorough. Audits

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were generally complete, timely, and thorough. Observations

indicate personnel have an adequate understanding of work

practices and that procedures were adhered to. Discussions with

personnel indicated they were knowledgeable in their job.

As with all plants, the licensee was required to complete

environmental qualifications by November 30, 1985. The

licensee aggressively worked to complete Environmental

Qualification Modifications on required equipment. Several

small planned outages were accomplished in order to comply with

the dead line. All work was performed in a thorough and

professional manner and management maintained effective control

throughout the process.

As noted earlier, Unit 1 conducted a major maintenance and

refueling outage at the beginning of the refueling outage for

the work to be performed. There was evidence of prior planning

and daily managenent meetings were conducted to ensure proper

priorization and resolution of issues. Maintenance activities

generally were acceptable. However, the resident inspectors

identified several concerns with modification which led to the

special inspection and violation discussed earlier.

Unit 2 also underwent a major maintenance and refueling outage

during the assessment period. There was consistent evidence of

prior planning and assignment of priorities. As with Unit 1,

daily management meetings were held to ensure that activities

were prcperly controlled and to ensure timely resolution to all

technical issues. Adequate staffing levels were maintained to

minimize the amount of overtime required. Contrary to Unit 1,

maintenance activities were well controlled and no modification

concerns were identified indicating the licensee learned from

the experience and improved its performance. The quality of

work performed is evidenced by the smooth return to operation

(ahead of schedule) and the continued uninterrupted operation

of Unit 2 throughout the remainder of the assessment period.

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The licensee has continued to improve throughout the assessment

period because of increased management attention and the

aggressive attitude.of the maintenance staff. Maintenance

order backlogs and overtime have been well controlled. The

condition of plant equipment was consistently monitored and

trending was performed for preventive as well as corrective

maintenance to ensure continued safe operation.

Three LERs were issued as a result of personnel error in the

maintenance area and two were issued concerning modifications.

The safety. significance of the maintenance errors (one caused

by contractors) was not severe and the licensee took prompt and

effective corrective actions. The modification errors were

addressed by regional inspectors as noted above.

2. Conclusion

The licensee is rated Category 2 in this area. The

maintenance / modifications area has improved from the last SALP

rating, but problems continue in the area of modifications.

3. Board Recommendations

None

D. Surveillance and service Testing

1. Analysis

During the assessment period, the resident and regional

inspectors routinely inspected this area, concentrating on

implementation of procedures'. Six violations were identified:

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a. Severity Lewl IV - Two safety-related pressure switches

which provide for a fail safe damper operation were not

calibrated as a result of not being on the safety-related

calibration list (254/84011-01; 265/84010-02).

b. Severity Level V - Failure to provide adequate

administrative instructions, detailed technical

- instructions, or test result evaluation directions to

properly implement the pump and valve inservice test

program under Section XI of the ASME Code (254/85009-01;

265/85010-01).

c. Severity Level 1 - Failure to control a field change

with control measures commensurate with those applied to

the original design (265/85018-05).

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d. Severity Level V - Failure to perform local leak rate

tests on a flange since its original installation

(265/84007-02).

e. Severity Level IV - Failure to measure the leakage rate

of a flange before its repair (265/84007/-01).

f. Severity Level V - Inappropriate written procedures;

numerous examples in which the instructions or the data

sheets were inadequate for performing the required test

(265/85023-01).

This is an increase from the one violation identified in the

previous assessment period. With regards to item a, the

licensee subsequently identified eight more pressure switches

in a similar condition. The corrective action was prompt and

effective as evidenced by the lack of subsequent repetition.

This item is not considered a significant problem.

With one exception (item b above), the licensee implemented an

inservice testing progra'n and was conducting pump and valve

inservice tests in accordance with appropriate schedule and

approved test procedures. Thus, this was considered an isolated

instance and not indicative of a programmtic breakdown.

Item c identified the existance of a field change that had been

installed prior to the updated Quality Assurance program. It

was noted that the current program would not have permitted the

field change. However, the Violation identified the need to

review past practices to ensure complete compliance with newer

requirements.

Items d and e were identified during an inspection of the Unit

2 Containment Integrated Leak Rate Test (CILRT). These items

were considered exceptions in an otherwise acceptable program.

Violation f, and other problems identified during the startup

core performance testing inspections appear to be due to an

inadequate procedure review process. Improvements are needed

with regards to the thoroughness of reviews - specifically, to

correct procedural deficiencies and to maintain procedures to

reflect current methodology. Management involvement and

control in assuring quality of written procedures should be

increased. Also, training for the personnel performing

procedure reviews should be improved.

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Significant Regional Inspection effort was dedicated to the

review of the Inservice Testing and Inservice Inspection

programs. The licensee was noted to have an excellent vibration

program, separate from inservice testing requirements,

implemented by the plant maintenance department. The program

included monthly measurements of both motor and pump vibrations;

horizontal, vertical, and axial measurements were taken using

appropriate equipment and techniques; data was logged such that

trends could be observed; and trends were evaluated by a well

trained, competent individual in the vibration area. The

licensee cited several examples where the testing and data

evaluation was used successfully for the early identification of

equipment degradation. Maintenance was scheduled and corrective

action taken to avert more significant damage. The licensee also

cited an additional benefit in that suspected problems have been

confirmed not to exist by vibration tests, thereby preventing the

need for more extensive preventive maintenance, troubleshooting,

or equipment outage.

In regards to valve surveillance testing, Motor Operated Valve

(MOV) current trace techniques have been under consideration to

monitor valve condition. In addition, maintenance procedures

are currently under development for " environmentally qualified"

valves used in harsh environments; however, no proceduralized,

formal preventive maintenance program has been in effect for.

. valves. The licensee meets the code requirements for a M0V

surveillance and has preventive maintenance procedures under

development, no violations were identified. However, a review

of licensee event reports for this SALP period indicates a

number of valve failures that may have been prevented by a more

effective preventive maintenance program.

One LER was issued ccncerning a missed surveillance found

during a supervisory review. The safety significance of the

missed surveillance was nominal and the performance in this

area has improved over previous assessment periods.

With the exceptions neted above, surveillance procedures were

well stated, and defined and were strictly adhered to. The

management control -systems were effective in that activities

had received prior planning and priorities had been assigned.

Surveillance records were found to be complete, well maintained,

and readily available for review. Required reports and asso-

ciated analysis were submitted within the line constraint

imposed. In the case involving a report submitted concerning

excessive local leak rate test results, the analysis section was

considered excellent by the Region III staff. Response to NRC

initiatives, inspector-identified concerns and safety issues

were timely, technically sound, and thorough in almost all cases.

An example of thorough resolution was the licensee's prompt

actions pertaining to water in containment pressure sensing

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lines identified during the Unit 2 CILRT. The licensee inspected

all containment pressure sensing lines for the presenese of water

prior to Unit startup. Events and deviations are promptly and

completely reported. Staffing training and qualification is

adequate to minimize ov(rtime and maintain the surveillance

program up to date.

2. Conclusion

The licensee is rated Category 2 in this area. This is a decline

from the last SALP period based on the number and nature of the

violations identified.

3. Board Recommendations

None.

E. Fire Protection / Housekeeping

1. Analysis

Throughout the assessment period, the resident inspectors have

observed the implementation of the licensee program in areas of

fire protection and housekeeping.

At the start of the assessment period the licensee was involved

in a refueling outage on Unit 1. Also, during the assessment

period the licensee completed a major maintenance and refueling

outage on Unit 2. Observations of general site conditions

throughout the assessment period indicated that an already

effective housekeeping program as noted in SALP 4 had improved.

This is a direct result of management's involvement and

attention in this area.

The resident inspectors also observed that routine fire preven-

tion is practiced at the facility. During this assessment

period, one violation was identified as follows:

Severity Level V - Inadequate fire barrier.

(254/84011-06; 265/84010-06)

This was considered an isolated occurrence and not indicative

of programmatic weaknesses. The licensee has a very effective

fire prevention program as a result of management's aggressive

attitude coupled with the cooperation of the plant staff.

Enhancements to the program include increased staffing with

the addition of a fire protection engineer, the expansion of

l training for fire brigade members and contractor personnel, and

the development and implementation of a maintenance history and

trending program for fire protection equipment.

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With regard to final implementation of the Fire Protection

requirements of 10 CFR 50, Appendix R as they apply to Quad

Cities, there are a number of outstanding issues. These issues

are the subject of ongoing discussion between the licensee and

the NRC.

2. Conclusion

The licensee is rated Category 2 in this area due to the many

open issues of Appendix R.

3. Board Recommendations

The board noted that shortly after the close of the SALP 5

period a fire protection inspection was conducted which

indicated potentially significant weaknesses in the implemen-

tation of existing fire protection requirements. These

weaknesses, some of which were identified by the licensee, are

currently under review by the licensee in an effort to effect

programmatic improvements.

F. Emergency Preparedness

1. Analysis

Four inspections were conducted during the period to evaluate

the following aspects of the licensee's emergency preparedness

program: emergency detection and classification; protective

action decision making; emergency notifications; emergency

communications systems; shift augmentation provisions; emergency

preparedness training; independent audits of emergency prepared-

ness; and implementation of changes to the emergency preparedness

program. Two inspections dealt with observations of annual

exercises.

One violation was identified during these inspections:

Severity Level V - Failure to complete required training

before assigning two persons to key positions in the

onsite emergency organization (254/85010-01; 265/85011-01).

The licensee's corrective actions were thorough and were

scheduled to be completed in a timely manner. The violation

was not indicative of a programmatic breakdown in the scheduling

of emergency preparedness training.

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Management involvement and control in assuring quality generally

remained positive towards improving the emergency preparedness

program, as had been apparent during the previous SALP period.

There are few long standing staff concerns regarding the

licensee's emergency preparedness program. Required corrective

actions to staff concerns were technically sound, thorough,

timely, and demonstrated a clear understanding of the issues.

However, as evident from repeat observations made during the

last two annual exercises, less attention had been given towards

implementing suggested improvements, such as recordkeeping in

some emergency response facilities. Independent audits of the

program were adequate in scope and depth. An effective system

had been implemented for tracking and documenting corrective

measures on action items identified during internal drills, and

exercises. Audit and tracking system records were complete,

well maintained, and readily available. Administrative proce-

dures were adhered to regarding the preparation, review, and

distribution of the emergency plan and implementing procedures.

Records associated with actual Emergency Plan activations

through June 1985 indicated that all situations had been

properly classified. The NRC and the States of Illinois and

Iowa were initially notified of these emergency declarations in

a timely manner.

The licensee has maintained a prioritized roster of adequate

numbers of personnel to fill well-defined, key positions in the

emergency organization. With the exception of the two persons

involved in the aforementioned violation, all persons had

completed the required training prior to being assigned to their

emergency positions. Semiannual, off-hours drills have been

conducted to successfully demonstrate the capability to augment

on shift personnel in a timely manner.

Proficiency of persons assigned to the onsite emergency

organization has largely been mairtained through annual

required reading of relevant procedures and by participation

in drills and exercises. However, walkthroughs at the beginning

of the assessment period with sixteen individuals assigned

emergency duties indicated that most had an inadequate knowledge

of some training program learning objectives stated in the

Emergency Plan. The licensee has committed to adding the

Training Supervisor to the Onsite Review Committee to better

ensure that persons newly assigned to emergency positions will

first have completed required training. Position-specific

lesson plans were being completed by corporate staff to improve

the training given annually to persons ir. the onsite emergency

organization.

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2. Conclusion

The licensee is rated Category 1 in this area, with the trend

essentially the same throughout the period.

3. Board Recommendations

None.

G. Security

1. Analysis

-Three inspections were conducted by ragion-based security

specialists during the assessment period. Periodic inspections

of limited scope were also conducted by the resident inspectors.

One violation was identified during the inspection effort in

September 1984 as follows:

Severity Level III - Failure to adequately control access

to a vital area. (214/84020-01; 265/84018-01)

The civil penalty for tFis violation was totally mitigated

because of the licenser's self-identification and prompt

reporting of the event, prompt and extensive corrective

actions, and the past excellent performance in the area of

security. No violations were cited during the previous SALP

period.

The security program continues to be effectively and

efficiently managed by the licensee and tha contract security

management cadre. Liaison between those management elements

appears effective and responsive to resolving issues.

Procedural guidar.ce is detailed and censistently applied.

Security awareness of the plant workforce appears high.

The licensee is consistently responsive to NRC concerns. One

inspection noted concerns about timely maintenarice for certain

security equipment and limited space for security training

administrator functions. Both concerns were totally resolved

in a timely manner. Additional personnel resources and new

equipment purchases resolved the maintenance support concern

and additional office space was constructed for security force

use. Concerns and observations received the same exceptionally

high level of management attention normally associated with

violations. The security management is responsive to all

findings that can strengthen their security program, rather

'

than concentrating on just minimum compliance required by the

security plan. There are no unresolved or open items pertaining

to security operations.

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The staffing level for the contract security force is adequate

and overtime is closely monitored and controlled. Day-to-day ,

supervision of the security shift is strong and assures '

consistent performance. A contract security officer has been

assigned, on a full-time basis, to monitor and coordinate

maintenance support for security-related equipment. Recent

emphasis has been placed on safeguards contingency event

training. This emphasis should continue into the next

assessment period.

Corporate security department support has been excellent during

the assessment period. A corporate Assistant Nuclear Security

Administrator position has been established (ANSA) to improve

coordination / liaison of site security acti+.ies and security

licensing issues. The ANSA closely monitor: inspection results

and licensing issues. Effective lines of communication exist

among the site, corporate, and NRC Region III security section.

The previous SALP report noted that corporate security involve-

ment should continue to be increased to relay analyses of

security deficiencies and other issues from other licensee

sites in order that similar deficiencies are prevented in the

Quad Cities security program. This objective has been met by

addition of the ANSA position and the results have been

effective. This high level of corporate security support and

direction should continue.

Licensee reports of Safeguards events are submitted in a timely

manner and in sufficient detail to allow analysis to be

performed. Corrective actions are effective and technically

sound. In the early part of the assessment period, unplanned

security computer outages were a concern. The reports of those

outages represented about 60% of the total. When the scope of

this problem was identified by the licensee significant

corrective action was taken and the issue was resolved. In

the last five months of the assessment period only one outage

was reported. The remaining events did not represent an unusual

or abnormal amount or type of Security Event Reports.

Senior site management has actively supported the security

program through general support of recurity budget items. The

. security computer system was signif cantly upgraded during this

assessment period, all x-ray and ext.losive detector units were

replaced with high grade state-of-the-art equipment, and

several closed circuit television cameras have been replaced.

An alternate alarm monitoring system has been installed and is

undergoing testing. Future security budget plans include

replacement equipment proposals.

In summary, even though one significant violation occurred,

this licensee has demonstrcted consistent performance at a

high level of efficiency, c ontinues to strengthen the security

program by upgrading critical security equipment, and is

responsive to NRC concerns and comments.

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2. Conclusion

The licensee is rated Category 1 in this area. This is the

same rating as in the previous SALP period.

~

3. Board Recommendations

None.

H. Refueling

1. Analysis

Evaluation of this functional area is based on portions of

eight inspections by the resident inspector and one inspection

by a Region III specialist. No significant areas of concern

and no violations were identified in this area during the

assessment period. This is a result of management's involvement

and attention in this area.

The inspection activities consisted of reviewing refueling

equipmrnt, test and check out procedures, fuel handling

procedt.res, refueling related surveillances, and results of

these completed procedures and surveillances. No core

alterations were conducted during the inspection period.

However, work performed during the assessment period included:

removal of spent fuel storage racks and their replacement with

new high density storage racks, removal of old refueling

bridges and replacement with new refueling bridges, as well

as operations related to a refueling outage.

The resident inspectors noted that refueling operations were

conducted very well from plant shutdown to post refueling

startup. It should be noted that no handling problems

occurred and no medical emergencies or overexposures cccurred.

Documentation of completed refueling operations verified that

all work was conducted satisfactorily and within the time frame

required.

-There is consistent evidence of prior planning and assignment

of priorities. Procedures and policies are well stated and

strictly adhered to. Staffing is adequate with positions and

responsibilities clearly delineated.

2. Conclusion

'

The licensee is rated a Category 1 in this area. The licensee

has maintained the same high level of performance as in a

previous SALP assessment.

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3. Board Recommendations

None.

I. Quality Programs and Administrative Controls

1. Analysis

l

This functional area was examined during two regional inspections

within the assessment period. The resident inspectors also

routinely made observations in this area. These inspections

were performed to determine the adequacy of the procurement

program implementation, the adequacy of the offsite review

function and support staff activities, and the adequacy of the

audit, nonroutine reporting, and test and measuring equipment

activities. One of the Regional inspections was a special

inspection of the CECO procurement program and its implementation

at all operating sites.

During these inspections, three violations were disclosed:

a. Severity Level IV - Nine examples of failure to follow

procedures (254/84015-07; 265/84013-07).

b. Severity Level V - Two examples of failure to perform

adequate suitability of application evaluations

(254/84015-09; 265/84013-09).

c. Severity Level V - Failure to provide prcper storage

protection for safety-related valves (254/85017-04;

265/85019-03).

With respect to the first violation, the examples involved

purchase orders failing to impose requirements specified by the

procurement program. While no single example had major safety

significance, collectively they indicate repeated failure to

implement programmatic requirements indicating the need for

added management attention in this area.

With egards to the second violation, one example led to the

use of a breaker not-seismically or environmentally qualified

in a safety-related application. The licensee immediately

replaced the breaker with a qualified breaker. There was some

safety significance to this example since the seismic and

environmental qualification of the breaker was indeterminate.

The second example involved the safety-related use of a 3" gate

valve not meeting the original specifications. The evaluation

performed to justify its use was not accomplished in accordance

with the design change process. This example was of minor

safety significance. The licensee has implemented procedure

changes which should preclude the recurrence of the violations.

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The third violation was identified during routine resident

inspections of storage facilities. It was considered an

isolated occurrence and not indicative of a progammatic

breakdown.

In addition to the Quad Cities specific items addressed above,

six other items of concern were disclosed relating to the CECO

corporate procurement program during the special inspection

noted above. - These items were of concern in that they

represented programmatic weaknesses that provided a potential

for the procurement, installation, and use of unqualified

items. The licensee's proposed actions related to these items

appear.to mitigate some of these weaknesses; however, further

NRC review is required before these items can be dispositioned.

Overall, the procurement area was found to be controlled by

sometimes poorly stated programs containing some weaknesses.

Weaknesses in program implementation indicated the lack of

management attention in the procurement area and the need for

more effective staff training. The licensee has initiated

corrective action in this area during the SALP 'eriod.

The licensee's recent reorganization was designed to strengthen

administrative controls and ensure continued compliance with

NRC requirements and commitments. Specifically, a compliance

coordinator position was established. This position is site

criented but receives corporate support. Also, a realignment

'

of all technical and administrative services under a more

senior management position and the assignment of maintenance

and operation to an equally senior management level should

provide for more positive control of plant administrative

activities. The aggressive attitude demonstrated by enagement

should ensure that decisions are made at an adequat .avel and

that corrective actions are taken promptly with souna technical

solutions.

The licensee has increased the staffing of the Quality Control

(QC) group and has a policy of rotating maintenance personnel

through QC to provide a fresh view and to also provide

maintenance with a greater understanding of the quality

program.

While licensee event reports (LER) specifically related to this

area are not reported as such, LERs from other rated areas must

also be factored into Quality Programs and Administrative

Control, LERs are almost always well written, technically

< accurate and thorough, with only a few minor discrepancies

noted throughout the rating period. While the overall number

of LERs was reduced, the number of personnel errors was not.

Additional management attention in this area is warranted.

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2. Conclusion

The licensee is rated a Category 2 in this area.

3. Board Recommendations

None.

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Licensing Activities

1. Analysis

a. Methodology

The basis for this appraisal was the licensee's performance

in support of licensing actions that were either completed

or had a significant level of activity during the current

rating period. These actions, consisting of amendment

requests, exemption requests, responses to generic letters,

TMI items, and other actions, include the following specific

h

items:

(1) Multiplant Action Items (MPAs) completed or having a

significant level of review action completed include:

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NUREG-0737 Item (12 items completed for both

units)

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NUREG-0737 Technical Specifications

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NUREG-0737 Supplement 1 items'-

Emergency Facilities, station

.

SPOS in progress review, station

DCRDR in progress review, station

DCRDR Audit Review completed for

station and Report issued

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Control of Heavy Loads (C-10), Units 1 and 2,

complete

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Appendix I (RETS) Technical Specification

(A-02), Units'1 and 2, complete

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Environmental Qualifications Exemption (B-60),

Units 1 and 2, complete

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Licensee's Environmental Qualifications Program,

Units 1 and 2, complete

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Mark I Containment LTP review completed for

Units 1 and 2

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Inservice Inspection Program review for Units 1

and 2, nearly complete

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Inservice Testing (Pumps and Valves) Program

review for Units 1 and 2, nearly completed

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Hydrogen Recombiner requirements for Units 1

and 2, in review

(2) Plant Specific Action Items completed or having a

significant level of review include:

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IGSCC Inspection and Repair program for Unit 1

(Cycle 9), complete

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IGSCC Inspection and Repair program for Unit 2

(Cycle 8), complete

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Environmental Qualification Schedular Extension

for Units 1 and 2, complete

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Environmental Qualification Review, SE, for

Units 1 and 2, complete

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Exemption from ILRT requirement Unit 2, complete

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Process Control Program review Units 1 and 2,

complete

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Administrative Control Technical Specification

Changes, Units 1 and 2, in review

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Appendix J Exemption Requests, Units 1 and 2,

complete

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Containment Pressure Set-Point and MSIV surveil-

lance Technical Specification changes, Units 1

and 2, review complete

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Increased LHGR Technical Specification limit,

. Unit 2, complete

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Cycle 8 operation Technical Specification

revisions, Unit 2, complete

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Hafnium Control Rod use, Technical Specification

changes, Unit 2, complete

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Cycle 9 operation Technical Specification

revision, Unit 1, complete

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b. Management Involvement and Control in Assuring Quality

'1

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Op: Commonwealth Edison management has an awareness of the

.~' various licensing issues by virtue of its extensive i

@ experience in the industry, inhouse technical expertise

'

and active participation in Owners Group and professional

~ organization activities. Commonwealth management takes

actions in a timely manner to ensure safety issues are

properly addressed. Examples of this attribute in'this

report period are the responses to our need for effective

'

-action and/or information regarding their electric power

transient event May 7, 1985, the RHR Pump operability

issues of July-1985, and the 125 VDC power supply

' deficiencies.

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c. gApproach to Resolution of Technical Issues from a

y.~ Safety Standpoint

~" Commonwealth's large and well qualified engineering staff,

, -in concert with an astbte licensing staff, assures that

Is most engineering wcrk, e%her done inhouse or performed

~

under its 'direction by contractors, adequately and timely

addresses complex technic'al issues.

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• During this report period,- satisfactory resolution and

L ,j e , completion of the following major _ programs was accomplished:

'

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Control of Heavy Loads (C-10) Appendix I (A-02)

4

Environmental Qualification of Equipment (B-60) Mark I

'

Long Term Containment Program Implementation (0-01)

i The resolution of the above-stated work demonstrates that

'

f the licensee's staff understands complex technical' issues,

~y ~

not only in terms of their technical nature but also in'

. terms of plant safety, plant operation, and' responsiveness

to regulatory concerns.

'

During the report period severalLissues were identified

for which prompt and effective action was appropriate. In

each case, the licensee promptly evaluated the problem and

.

" took action to provide interim repairs or other appro-

/ priate actions to satisfactorily resolve the issue from a

a safet;; standpoint. The licensee's actions in this case

C , demonstrated sound understanding of and ability to deal

y effectively with complex technical problems. The

i licensee's proposed program for long-term solution to

'

IGSCC concerns for the Quad Cities Units has yet to be

"

fully evaluated in that a specific plan of action has not

i been proposed. The concept, as presented in their meeting

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with us on July 23, 1985, is a considerable departure from

the conventional aoproach, but demonstrates both careful

technical considerations and originality of approach to

that concern.

d. Responsiveness to NRC Initiatives

Open and effective communication channels exist between

the NRC and Commonwealth Edison licensing staffs.

Effective dialogue between the staffs promote prompt and

technically sound responses to NRC initiatives. The

licensee meets all established commitment dates or

provides a written submittal explaining the circumstances

and establishes a new firm date. Conference calls with

the staff are promptly established and include appropriate

engineering, plant and/or contractor personnel. The

Commonwealth Nuclear Licensing Administrator and/or his

management in almost all cases promptly and effectively

resolve issues.

The Station or Corporate office have rarely if ever failed

to accommodate a NRC-initiated program (such as a special

study, evaluative program, or survey) being conducted by

or for NRC, even where such accommodation is clearly not

obligatory. The Station characteristically makes available

their most knowledgeable people to assist the NRC staff

and/or contractor in such activities.

e. Housekeeping

The NRR Project Manager has had a number of occasions to

observe housekeeping conditions at Quad Cities Station.

The most recent was a site visit October 9-12, 1984,

related to resolution of USI A-45, Decay Heat Removal

Capability. Because of the nature of this visit, sensitive

areas of the plant were visited and observed. During this

visit, areas in the reactor building at all levels were

visited, as was the control room, turbine building at upper

and lower levels, machine shop, administrative offices,

main meeting room, and connecting passageways. Also visited

were the auxiliary electric rooms and associated cable

tunnels under the control room, areas of particular sensi-

tivity from the fire protection standpoint.

It was noted that all the areas visited were clean and

free of trash, with little or no stored or transient

combustibles evident beyond operational requirements. The

control room was clean, orderly, and transactions were

business-like. There was no evidence of food or drink or

reading material not related to plant operation.

Housekeeping at the Station is generally very good.

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f. Fire Protection

Nearly all plant modifications resulting from the NRC

staff fire protection review have been completed, and

exemptions were issued where appropriate.

In late 1983, NRC issued a clarification of the requirements

of Appendix R. In response to the NRC clarification, the

licensee then initiated an independent review of their fire

protection program. This resulted in additional changes in

their fire protection program, and additional exemptions

were requested beyond those resulting from the original NRC

fire protection review. These are currently under NRC

staff review.

2. Conclusion

An overall performance rating of Category 1 has been assigned

in the licensing area.

3. Board Recommendations

None.

.

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V. SUPPORTING DATA AND SUMMARIES

A. Licensee Activities

Units 1 and 2 engaged in routine power operation throughout most of

SALP 5. A major scheduled outage for plant refueling, modification,

maintenance, and inspection of recirculation piping pursuant to

Commission Order 7590-01 was in progress at the beginning of the

assessment period for Unit I and completed on August 16, 1984. A

similar outage began on March 17, 1985 and was completed on Juna 5,

1985 for Unit 2.

The remaining outages throughout the period are summarized below:

Unit 1

December 2 to 4, 1984 Repair recirculation suction

valve

May 7 to 17, 1985 Routine maintenance

May 30 to June 1, 1985 Routine maintenance

Unit 2

June 2 to 4, 1984 Repair Transformer 21

October 25 to 27, 1984 Replace CRD pursuant to CAL

December 21 to 29, 1984 Repair main transformer

January 16 to 22, 1985 Repair main condenser boot

June 15 to June 16, 1985 Repair EHC oil leak

Unit 1 scrammed seven times (three occurred while shutdown) and Unit

2 nine times (three occurred while shutdown). Two of the Unit 1

scrams and five of the Unit 2 scrams were attributed to equipment

malfunction and required minor maintenance prior to returning the

units to service. One of the Unit 2 scrams was caused by a hole in

the main condenser boot ar.d required an extended outage to replace

the boot. Two scrams occurred at power for Unit 1, which were

attributable to perscanel error, including contractors. While

shutdown, two scrams for Unit 1 and two scrams for Unit 2 were

attributed to personnel error. The remaining scram on Unit 2 was

caused by a procedural deficiency. Licensee management corrective

actions following these trips were reviewed by the resident

inspectors and found to be appropriate. The above personnel errors

were taken into account and factored into the licensee's Regulatory

Improvement Plan. In all cases, the plants responded as designed.

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.B. Inspection Activities

An Operational Team Inspection was conducted by Region III on

September 24-28, 1984 to assess overall licensee performance and

provide an indepth assessment of selected areas. including

operations. .The inspectors found the operations staff to be an

effective operating organization.

FEMA issued a' report addressing the emergency exercise, which

concluded that an adequate level of offsite radiological prepared-

ness-had been demonstrated-to protect the public in the event of a

radiological accident at the Quad Cities Nuclear Power Station.

Violation data for Quad Cities is presented in Table I which

includes inspection reports 84008 through 85026 for Unit 1 and

84007 through 85029 for Unit 2.

TABLE 1

INSPECTION ACTIVITY AND ENFORCEMENT

No. of Violations in Each Severity Level

Functional Unit 1 Unit 2 Site

' Areas III IV V III IV V III IV V.

A. Plant Operations 1 1 1 1 1

B. Radiological Controls 1 1 1 1 1

C. Maintenance / Modifications 1 1 2

D. Surveillance and

Inservice Testing 1 1 1 4 1 4

E. Fire Protection 1 1 1

F. Emergency Preparedness 1 1 1

G. Security 1 1 1

H. Refueling

I. Quality Programe and

Administrative Cuatrols 1 2 1 2 1 2

J. Licensing Activi"o; _ _ _ _ _ _ _ _ _

TOTALS 2 3 6 1 6 10 2 6 10 l

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C. Investigations and Allegations Review

During a radiation protection inspection, reviews were made as followups

to inquiries from attorneys representing a former contractor employee who

claimed injuries while working at Quad Cities Station during the third

and ' fourth calendar quarters of 1983. No violations of regulatory

requirements were identified; the attorneys and the U. S. Representative

were so informed.

An inspection was also performed to investigate allegations

anonymously made by a formerly employed contract radiation

protection technician. No violations related to the allegations

were identified. Possible programmatic improvements were discussed

with licensee personnel. Since then, improvements in contract

radiation protection training, respiratory protective equipment

cleaning and handling, and radioactive materials handling have been

made by the licensee.

D. Escalated Enforcement Actions

A Civil Penalty in the amount of $50,000 was issued in 1985 for a

violation involving the Unit 1 operator not being at the Unit

Controls. Details are to be found in Inspection Report (254/84023).

E. Management Conferences Held During Appraisal Period

1. Confirmatory Action Letters (CAL)

A CAL was issued October 26, 1984 to confirm licensee action

regarding replacement of CRD 38-51 and resolution of concern

with operator at controls.

2. Management Conferences

a. September 7, 1984 (Glen Ellyn, Illinois)

Meeting to discuss licensee performance in regards to

their Regulatory Performance Improvement Plan (RPIP).

b. September 17, 1984 (Glen Ellyn, Illinois)

.

Management meeting to review Systematic Assessment of

Licensee Performance (SALP 4).

c. January 18, 1985 (Glen Ellyn, Illinois)

Meeting to discuss various items related to emergency

preparedness.

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.

d. March 7, 1985 (Glen Ellyn, Illinois)

Meeting to discuss licensee performance in regard to their

RPIP.

e. June 24,1985 (LaSalle County Station)

Meeting to discuss licensee performance in regard to their

RPIP.

f. July 16,1985 (Glen Ellyn, Illinois)

Meeting to discuss additional aspects of the licensee's

RPIP.

3. Enforcement Conferences

a. October 18, 1984 (Telephone)

Discussion to review the security event of September 1984

where the licensee failed to control access to a vital

area.

b. November 5, 1984 (Glen Ellyn, Illinois)

Meeting to discuss the Unit 2 event of October 25, 1984,

and the associated control room operations staff

activities. -

.

c. March 15, 1985 (Glen Ellyn, Illinois)

Meeting to discuss design control deficiencies.

F. Review of Licensee Event Reports and 10 CFR 21 Reports

1. Licensee Event Reports (LERs)

LERs issued during the 16 month Salp 5 period are presented

below:

Unit 1 Unit 2

LERs No. LERs No.

84-06 through 84-18 84-05 through 84-14

85-01 through 85-16 85-01 through 85-20

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Proximate Cause Code * Number During Salp 5

Personnel Error (A) 15

Design Deficiency (B) 5

Defective Manufacturing,

Construction / Installation (D) 2

Others (X) 37

TOTAL 59

• Proximate cause is the cause assigned by the licensee according

-to NUREG-1022, " Licensee Event Report System."

LERs were issued at a slower rate during the SALP 5 assessment

period than during SALP 4. The increase in personnel errors

was partly due to the increased reporting requirements

concerning scrams while shutdown and errors found in the

modifications area. Additional discussion on modification

problems is presented in Section IV.3. The reduction in

overall LERs is significant and, especially in the equipment

failure area, indicative of an improving trend.

The Office for Analysis and Evaluation of Operational Data

(AEOD) reviewed the LERs for this period and concluded that,

in general, these LERs are of acceptable quality. However,

they identified some minor deficiencies. A copy of the AE00

report has been provided to the licensee so that the specific

deficiencies noted can be corrected in future reports.

2. 10 CFR 21 Reports

No 10 CFR 21 reports were submitted during the assessment

period.

G. Licensing Actions

1. NRR Site and Corporate Office Visits

October 9-12, 1984 Site Visit on USIA-45, Ultimate Decay

Heat Removal Requirements.

January 28, 1985 Site Visit on USIA-45, Ultimate Decay

Heat Removal Requirements.

March 4, 1985 Meeting at Corporate Office on current

regulatory requirements for LWRs.

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April 12-13, 1985 Site Visit to get information on

Decontamination Study.

June 10-13, 1985 Site Visit for DCRDR Audit Review.

2. Commission Briefing

None.

3. Schedular Extension Granted

July 30, 1984 Equipment Qualification, Units 1 and 2.

4. Relief Granted

None.

5. Exemption Granted

July 6, 1984, certain requirements of Appendix J, Units 1 and

2.

6. License Amendments Issued

Unit 1

Amendment No. 88, issued June 6, 1984; Revised Technical

Specification on Time Delay Settings for HPCI and RCIC

actuation.

Amendment No. 89, issued June 19, 1984; Radiological Effluent

Technical Specifications (RETS) to satisfy Appendix I

requirements.

Amendment No. 90, issued August 2, 1984; Technical Specification

changes and additions for MAPLHGR limits; changes for newly

installed Analog Trip System; and changes for newly installed

Scram Discharge Systen.

Unit 2

Amendment No. 83, revised June 6, 1984; Revised Technical

Specification on Time Delay Settings for HPCI and RCIC

actuations.

Amendment No. 84, revised June 19, 1984; Radiological Effluent

Technical Specification (RETS) to satisfy Appendix I

requirements.

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Y _ ___ _ _ _ _ _ - _ - _ _ _ _ - _ - _ _ . _ -

-

o- ..

,

... -

.. ( ,

Amendment No. 85, issued February 25, 1985; Temporary increase

in LHGR limits to perr:it Barrier Fuel Ramp testing.

Amendment No.-86, issued May 30, 1985; new and extended MAPLHGR

limits; changes for newly installed Analog Trip System; and

changes for newly installed Scram Discharge System.

Amendment No. 87, issued May 30, 1985; Technical Specification

change to allow use of Hafnium control rod material.

7. Emergency / Exigent Technical Specification

Exigent Technical Specification on RHR Pump Operability

completed (but not-issued when licensee was able to restore

operability at the'last moment) for issuance July 30, 1985.

8. Orders Issued

June 12, 1984, Order confirming licensee commitments on

Emergency Response capability, Units 1 and 2.

9. NRR/ Licensee Management Conference

Conference in Bethesda on July 23, 1985 regarding Commonwealth

Edison's proposed alternative plan for IGSCC-susceptible pipe

replacement.

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