ML20197K079

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Notifies of Planned Insp Effort for Next 6 Months at Plant. Encl Info Provided to Minimize Resource Impact on Licensee Staff & to Allow for Scheduling Conflicts & Personnel Availability to Be Resolved in Advance
ML20197K079
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 12/02/1998
From: Reynolds S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
NUDOCS 9812160078
Download: ML20197K079 (45)


Text

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  1. pa u!og'o UNITED STATES i

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NUCLEAR REGULATORY COMMISSION o

REGION ill

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j 801 WARRENVILLE ROAD l

2 LISLE. ILLINOIS 60532-4351

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December 2, 1998 l

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. Mr. Oliver D. Kingsley

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1.

President, Nuclear Generation Group l

Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West til l

1400 Opus Place, Suite 500 Downers Grove,IL 60515

SUBJECT:

MID-YEAR INSPECTION RESOURCE PLANNING MEETING - QUAD CITIES

Dear Mr. Kingsley:

On November 4,1998, the NRC staff held an inspection resource planning meeting (IRPM).

The IRPM provided a coordinated mechanism for Region ill to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in April 1999. to this letter advises you of our planned inspection effort for the next 6 months at Quad Cities.

This attached information is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature. contains a historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that was considered during the IRPM. The PIM includes only items from inspection reports or other docketed correspondence between the NRC and Commonwealth Edison Company.

1 i

I 9812160078 981202 PDR ADOCK 05000254 G

PDR

.m O. Kingsley We willinform you of any changes to the inspection plan. If you have any questions, please contact me at 630-829-9703.

Sincerely,

/s/ S. A. Reynolds Steven A. Reynolds, Deputy Director Division of Reactor Safety.

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

Enclosures:

1.

Inspection Plan 2.

Plant Issues Matrix cc w/encis:.

D. Helwig, Senior Vice President H. Stanley, PWR Vice President C. Crane, BWR Vice President R. Krich, Regulatory Services Manager

. D. Greene, Licensing Director DCD - Licensing J. Dimmette, Jr., Site Vice President W. Pearce, Quad Cities Station Manager C. Peterson, Regulatory Affairs Manager R. Hubbard M. Aguilar, Assistant Attorney General State Liaison Officer Chairman, Illinois Commerce Commission W. Leech, Manager of Nuclear f

MidAmerican Energy Company DOCUMENT NAME: :G:\\ quad \\insppin7.qua To receive a copy of thie document. Indicate in the box 'C' = Copy without attachment / enclosure *E' = Copy with attachment / enclosure "N* = No copy OFFICE Rlil

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Rill g

Rlli g

LerchIdpk Rin M Reynolds h l_

NAME l

DATE 12/ W98 12/ O/98 12/ L /98 l

OFFICIAL RECORD COPY t

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l O. Kingsley.

Distribution:

l SAR (E-Mail) l RPC (E-Mail) l Project Mgr., NRR w/encls J. Caldwell, Rill w/encls C. Pederson, Rlli w/encls B. Clayton, Rlli w/encls i

SRI Quad Cities w/encis DRP w/encls TSS w/encls i

DRS (2) w/encls gpl-Rill PRR w/ cls PUBLIC I 1 w/encls Docket Fil w/encls GREENS LEO (E-Mail)

DOCDESK (E-Mail) g000

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QUAD CITIES 4

INSPECTION / ACTIVITY PLAN IP - Inspection Procedure Tl-Temporary Instruction Core - Minimum NRC Inspection Program (mandatory all plants)

Regional Initiative - Discretionary inspections NUMBER OF TYPE OF INSPECTION NRC INSPECTION /

/

TITLE I PROGRAM INSPECTORS PLANNED DATES ACTIVITY-ACTIVITY AREA

/

COMMENTS INDIVIDUALS IP73753 Inservice Inspection 1

Outage (Nov/Dec Core 1998)

IP83729 Radiation 1

November 30-Regional Protection / Outage December 4,1998 Initiative @

Activities IP81700 Security 1

December 14 - 18, Core 1998 IP82701 EP Program 1

January 4 - 8,1999 Core IP84750 Chemistry / Effluents 1

January 25 - 29, Core 1999 IP71707 Operational 2

February 1 - 5, Regional Assessment 1999 Initiative @

IP62700 Maintenance and 3

March 8 - 12,1999 Regional Breakers Initiative @

IP83729 Rad Protection /

1 March 8 - 12,1999 Regional Outage Activities initiative @

Tl2515/139 Testing of Safety 3

TBD Regional Related Logic April / May Initiative @

Circuits i

Notes:

@ Followup on previously identified issues.

@ Followup on previously identified configuration management concerns.

G Followup for Generic Letter 96-01. Date to be determined (TBD).

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e 11/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = "SALP" : SALP Area = *AWMultiple' ; Beginning Data = *10/1/1997*, Ending Date = *10/1/1998*

DATE !

TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1

9/30/1998 moming report Self-All/ Multiple 1B Unit 1 scrammed at 2:06 a.m. CDT on September 30,1998 due to low Revealed reactor water level. Previously, equipment operators were in the process of removing the "A" reactor feed pump from service, ("B" and "C" reactor feed pumps were providing feedwater). While performing the out-of-service tagout, the equipment operators valved out the "A" reactor feedwater flow transmitter. The transmitter apparently generated a full flow indication signal for the" A" feedwater pump which was provided to the feedwater control system, causing an indicated feedwater flow much higher than steam flow. With the reactor feed system in three-element control, the feedwater control system began reducing actual flow. A computer alarm alerted control room operators to the decrease in feedwater flow. The reactor scrammed automatically on low reactor water level. The reactor feed system was taken to single element control and feedwater regulating valves operwi in response. Reactor water level decreased as low as -20 inches (108 inches above top of active fuel, normal level is 30 inches) before rebounding. A reactor feedwater pump trip occurred at on high reactor water levei (about 48 inches). Reactor water level increased above 60 inches before retuming to normal.

2 1/30/1938 Misc IR 97001.SLP NRC All/ Multiple The functional areas of Operations and Plant Support were rated as IR 97001.SLP Category 2. The areas of Maintenance and Engir eering were rated as Category 3. Although the ratings were the same as in SALP 13, it is my view that conduct of nuclear activities in connection with the Quad Cities facility declined from the previous assessment period.

4 4

Page 1 of 2

11/25/1998 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items that have a clear date of occurrence usa the actual date. If the actual date is not known, use th; ch DATE the issue was identified. For issues that do not have an actual date or a date of identifica* ion, use the LER or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC inspection Peport or LER for Lcensee Event Report.

- - - ~ - -

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance Operations, Plant Support and All/ Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements Eels are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal eel

  • Escalated Enforcement issue - Waitina Final NRC Action escalated enforcement action in accordance B - During Transients with the " General Statement of Policy and C - Programs and Processes LER License Event Report to the NRC l

Procedure for NRC Enforcement Action 2

Material Condition:

Licensing Licensing Issue from NRR (Enforcement Policy). NUREG-1600.

l Misc Miscellaneous (Emergency Preparedness Finding. etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Negative Individual Poor Licensee Performance identified by the Eels and the PIM entries 3

Human Performance:

may be modified when the final decisions A - Work Performance Positive Individual Good Licensee Performance m m de. Befom the NRC makes its B - Knowledge, Ski lIs, and Abilities Strength Overall Strong Licensee Performance enforcement decision, the licensee will be C - Work Environment URI,g Unresolved inspection item provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering / Design:

VIO/SL-il Notice of Violation - Seventy Level 11 (2) request a predecisional enforcement A - Design VIO/SL-III Notice of Violation - Severity Level fit conference.

B - Engineering Support

" URIs are unresolved items about which C - Programs and Processes VIO/SL-IV Notice of Violation - Seventy Level IV

Weakness Overall Weak Licensee Performance 5

Problem identification and Resolution:

wh her h ue n que t on s a A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - Analysis C - Resolution the NRC has not reached its final

' Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identification by an event (e.g.. equipment breakdown) conclusions are made.

. Other identification unknown Page 2 of 2

11/ 5/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and sMM Codes (Ascending): search Column = *SALP' ; SALP Area = "Eng:neering". Beginning Date = *10/1/1997* : Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1

9/1/1998 Positive IR 98013 NRC Engineering 4B The inspectors concluded that the licensee's troubleshooting efforts were thorough in determining the root cause of the Unit 2 high pressure coolant injection tuming gear failure (Section E1.3).

2 9/1/1998 Negative IR 98013 NRC Engineering 4C The inspectors determined that the licensee, in app!ying Regulatory Guide 1.9, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants," in determining emergency diesel generator reliability, did not properly address emergency diesel generator start failures. Two additional examples of incorrectly classified starts were identified (Section E1.2).

3 7/24/1998 NCV LER 94013 NRC Engineering 4A The licensee identified that the relays that control the heating, ventilation, and air conditioning (HVAO) for the emergency diesel generators (EDGs) could be impacted by a single fire in a single zone of the turbine building.

This was an unanalyzed condition for safe shutdown during a fire.

However, this design problem had limited safety significance because the licensee had adequate time to take compensatory measures to cool the diesel generator rooms. The failure to assure that applicable design requirements were met is a non-cited violation of 10 CFR Part 50, Appendix B, Criterion 111.

4 7/24/1998 Positive IR 98015 NRC Engineering 4B System engineering involvement in the corrective action process was good for the eleven specific items.

5 7/24/1998 Positive IR 98015 NRC Engineering 4C For the eleven issues reviewed, the corrective actions and root cause analyses were acceptable.

6 7/16/1998 NCV IR 98012 Ucensee Engineering 4C The licensee identified that during a shutdown of Unit 2 in February 1997, the primary containment function of pressure suppression would have been bypassed for a short period during deinerting of the containment.

The procedures that allowed this alignment were subsequently changed.

This was a non-cited violation of Technical

, Specification 3.7.K.3 (Section E8.20).

7-7/16/1998 VIO/SL-IV.

IR 98012 NRC Engineering 4C Oualification of commercial grade relays for use in a safety function as emergency diesel generator time delay relays failed to account for environmental concems such as vibration. This was considered a -

violation of 10 CFR Part 50, Appendix B, Criterion 11 (Section E 8.18).

Page 1 of 12^

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* ; SALP Area = *Engineenng'. Beginning Data = *10/1/1997*. Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 8

7/16/1998 VIO/SL-IV 1R 98012 NRC Engineering 4C Engineers did not follow the process for changing safety-related setpoints in 1996 when the second-level undervoltage setpoint was revised. As a result, no 10 CFR 50.59 review was conducted and the Updated Final Safety Analysis Report was not updated. This was considered to be a violation of 10 CFR Part 50, Appendix B, Criterion V (Section E8.19).

9 7/16/1998 Negative IR 98012 NRC Engineering 4C The inspectors found that the level of review to justify important changes to the reactor protection system testing was insufficient. Later review and improved administrative controls were added to ensure that reactor protection system jumpers were not left in place after system testing (Section E1.2).

10 5/29/1998 Negative IR 98009 NRC Engineering 2A Equipment problems with emergency diesel generators continued this period. The Unit 1 emergency diesel generator failed to start on demand during surveillance testing. The cause of the failure was a malfunctioning autostart logic relay. Other problems were identified by the licensee and corrected prior to their affecting diesel operability. The causes of these failures were still under review by the licensee (Section E1.3).

11 5/29/1998 VIO/SL-IV 1R 98009 NRC Engineering 48 A design change to replace the defective humidifier for the computer room was canceled in May 1995. No safety evaluation for this non-conformance with the UFSAR was performed, in violation of 10 CFR 50.59 requirements (Section E8.6).

12 5/29/1998 VIO/SL-IV IR 98009 NRC Engineering 48 issues involving the need to revise instrument calculations identified in 1991 and 1992 were not resolved prior to 1998. Some TS related setpoints were determined to have a non-conservative margin of error.

The Vulnerability Assessment Team report tracking item for this issue was closed without apparent justification. This was a violation of 10 CFR Part 50, Appendix B requirements. Five instances of exceeding TS required setpoints for the scram discharge volume were identified by the licensee (Section E1.2)

Page 2 of 12

H/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *sALP', SALP Area =

  • Engineering" ; Beginning Data = *10/1/1997*, Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 13 5/22/1998 VIO/SL-il Letter dated NRC Engineering 4A in response to the safe shutdown issue, Comed changed its safe 9/11/98 shutdown procedures to permit the use of the station blackout diesel generator in lieu of the emergency diesel generators without first performing a safety evaluation to confirm that the departure from the Updated Final Safety Analysis Report (UFSAR) did not constitute an unreviewed safety question. The required safety evaluation was performed after substantial intervention by the NRC staff. When performed, the NRC staff identified that the safety evaluation was deficient because it did not consider all necessary manual actions required to operate the station blackout diesel generator. EA 98-175 14 5/22/1998 Licensing IR 98011 NRC Engineering 4B Although the technical weaknesses associated with the post-fire safe shutdown methodology showed that the licensee had not strictly met all the conditions specified in the CAL, the inspection team concluded that the licensee's SSA and post-fire safe shutdown operating procedures did provide a minimally acceptable interim methodology which, when augmented with the compensatory measures, provided sufficient confidence to permit the restart of both units. The inspection team considered such compensatory measures to be acceptable only as short-term corrective actions with an objective of the licensee achieving full compliance with Appendix R to 10 CFR Part 50.

15 5/22/1998 VIO/SL-Il Letter dated NRC Engineering 4C The violations in the Notice represent inadequacies in Comed's capability 9/11/98 to shutdown the Quad Cities facility following a postulated design basis fire. These violations indicated a broad lack of understanding on the part of the Quad Cities' staff for the importance of having analyzed, proceduralized, and validated means for achieving and maintaining safe shutdown following a design basis fire. EA 98-175 16 5/22/1998 Licensing Letter dated NRC Engineering SC Based on the NRC inspection activities identified above, the 5/22/98 compensatory actions you have committed to put in place before startup of Unit 2, discussions between your staff and the NRC during the bi-weekly public meetings, and our review of your docketed correspondence, I have determined that your actions pursuant to CAL R!il-98-001 are adequate to close the CAL Page 3 of 12

H/ 5/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = *SALP" ; SALP Area =

  • Engineering * ; Beginning Data = *10/1/1997". Ending Date = *10/1/199(s" DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 17 5/18/1998 Negative IR 98011 NRC Engineering 48 On May 18,1998, the inspection team retumed to the site and reviewed the results of the licensee's reassessment of the TB-Il fire area. The inspection team identified a number of deficiencies which appeared to confirm the team's earlier assessment that the licensee had not identified all areas where it was not in compliance with 10 CFR Part 50, Appendix R. When the team identified these deficiencies to the licensee, the licensee committed to implement compensatory measures and maintain them until an adequate resolution to the technical issues could be attained.

18 5/8/1998 Negative IR 98011 NRC Engineering 4B During the week of May 4 - 8,1998, NRC conducted a special startup inspection to review the licensee's revised SSA and procedures.

However, after three days onsite, the inspection team leaders and Region ill management had identified sufficient weaknesses to conclude that the conditions of the CAL were not entirely satisfied. Specifically, the analysis methodology and post-fire safe shutdown capability were found to not satisfy the technical requirements of 10 CFR Part 50, Appendix R, Sections Ill.G.1 and lil.G.3. Specific weaknesses included: (1) inadequate evaluation of, and level of protection provided for,125Vdc control power to 4 kV Switchgear; (2) inadequate and non-conservative assumptions regarding the number of spurious equipment operations that could occur during a " fire; and (3) deficiencies in operating procedures developed to implement the post-fire safe shutdown capability. Because of these deficiencies, the inspection team was unable to conclude that the SSA was adequately validated.

19 4/29/1998 Ucensing IR 98011 Licensee Engineering 4B On April 29,1998, the licensee formally docketed its response to the Appendix R confirmatory action letter and concluded that all conditions necessary to restart the plant had been met.

20 4/17/1998 Positive IR 98008 NRC Engineering 28 System engineers were experienced and displayed a good knowledge of their assigned systems. The inspectors determined that the maintenance rule staff's efforts to improve system engineers' knowledge and opinion of the maintenance ru!e program were effective.

21 4/15/1998 Negative IR 97023 NRC Engineering 1C The licensee did not take adequate actions to evaluate mu!tiple precursors identified since 1987 that indicated potential deficiencies in the safe shutdown analysis and its implementing procedums (Section F3.1).

Page 4 of 12

11/ 5/1998 PLANT ISSUES MATRIX Quad Cities search Sorted by Date (Descending) and sMM Codes (Ascending): Search Colurnn = "SALP" ; SALP Area =

  • Engineering" ; Beginning Data = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 22 4/15/1998 VIO/SL-IV 1R 97023 NRC Engineering SC Inadequacies were identified in the licensee's corrective actions to resolve post-fire safe shutdown issues (Section F3.3):

,A violation of 10 CFR 50, Appendix B, Criterion 11, was identified for failure to properly train or qualify personnel to implement manual manipulation of safety related breakers as compensatory actions.

23 4/15/1998 Negative IR 97023 NRC Engineering SC Inadequacies were identified in the licensee's corrective actions to resolve post-fire safe shutdown issues (Section F3.3):

,The operability review performed for exiting the 67-day administrative limiting condition of operation (LCO) was not according to any approved procedure or process. Several calculations referenced in the operability review contained assumptions or conclusions not applicable to plant-specific conditions.

24 4/15/1998 Weakness IR 97023 NRC Engineering SC Inadequacies were identified in the licensee's corrective actions to resolve post-fire safe shutdown issues (Section F3.3):

,The review and approval process for the safe shutdown procedures was weak since the procedures did not receive the cross discipline review to ascertain the ability to achieve and maintain safe shutdown condition.

25 4/15/1998 eel IR 97023 NRC Engineering SC Inadequacies were identified in the licensee's corrective actions to resolve post-fire safe shutdown issues (Section F3.3):

,An apparent violation was ider tified for the failure to perform a safety evaluation for the use of the station blackout diesel generators (SBO DG) in lieu of the FSAR described emergency diesel generators (EDG) until prompted by the NRC. In addition, the initial safety evaluation for this change was inadequate since the licensee subsequently identified that this change involved an unreviewed safety question.

26 4/15/1998 eel IR 97023 NRC Engineering SC-

- An apparent violation of 10 CFR 50.48 was identified for certain fire areas containing safe shutdown related equipment. The equipment would be so 4

damaged that safe shutdown conditions would not be achieved and maintained if a postulated fire occurred in these fire areas (Section F3.2).

s 27 3/31/1998 Positive IR 98004 NRC Engineering 4B There were more preparations (meetings, drawing reviews and subsequent walkdowns) by the examiners for the Unit 1 pressure test than other similar pressure tests. The examiners identified leakage which required repair prior to unit startup (Section E5.1).

Page 5 of 12

M/ 5/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP*, SALP Area =

  • Engineering" : Beginning Data = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 28 3/31/1998 Negative IR 98004 NRC Engineering 48 Although licensee efforts to investigate emergency diesel generator time delay relay failures were good, significant reliability problems still existed.

Engineering justification for dedicating the relays as safety-related parts did not address vulnerabilities of the relays to vibration. Engineering justification for exceeding Updated Final Safety Analysis Report limits for the relay settings was not thorough (Section E3.1).

29 3/31/1998 Positive IR 98004 NRC Engineering SC-The prompt investigation team identified the cause of the Unit 1 emergency diesel generator failure to run on March 17,1998, to be a fuse block failure. The licensee took proper corrective actions to address the problem (Section E1.3).

30 3/31/1998 Negative IR 19004 NRC Engineering SC The licensee was not successful in determining the root cause of the Unit 1 emergency diese! generator failure to start in January 1998.

Nonetheless, operations declared the Unit 1 emergency diesel generator operable. No specific actions were recommended to improve airstart system performance which was a suspected contributor to the start failure. Similar failures had occurred in the past (Section E1.1).

31 3/26/1998 VIO/SL-IV IR 98005 NRC Engineering 4C Adequate controls were in place to ensure that at-risk work packages developed in parallel with the design package would assure components would not be declared operable until completion of all design documentation. Use of the at-risk process was not routine and work completed appeared well-coordinated between the work analyst, design and construction staff. While generation of at-risk work packages was allowed by the Work Request initiation procedure, at-risk work was contrary to the Plant Design Change Process procedure. This was considered a procedural adherence violation.

32 3/26/1998 Positive IR 98005 NRC Engineering 4C Allowances, with precautions, for development of emergency and immediate modifications were adequately accounted for in the Quad Cities OA Program and ir. corporate and station procedures. Use of these types of modifications was not common and, when used, adequate contro's existed to ensure minimum prerequisites, limitations, and 4

operational restrictions were considered, including completion of 10 CFR 50.59 screenings cr safety evaluations.

Page 6 of 12

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; sALP Area =

  • Engineering * ; Beginning Date = *10/1/1997*. Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION i

33 3/4/1998 Licensing Letter dtd 4/1/98 NRC Engineering 4C At Quad Cities the submittals from Comed have been generally good.

They usually provided sufficient information for the staff to provide an evaluation. Several Requests for Additional Information (RAl) were required on complex issues such as seismic qualification of electrical and mechanical equipment (unresolved safety issue A-46), IPEEE, and pressure locking and pressure binding of power operated gate valves (GL 95-07). Two issues needing closer attention by Comed include a response needed for a RAI issued 05/28/97 for GL 95-07 and closure of R.G.1.97 issues. Inadequate review of two submittals was also noted where the " Summary Report of Changes, Tests and Experiments Completed" dated October 31,1997, included two safety evaluation descriptions that incorrectly stated there was a reduction in the margin of safety and the *O2C15 Core Operating Limits Report, Revision 1* dated November 4,1997, included propriety information that was not requested to be held in confidence.

4 34 2/13/1998 Negative IR 97022 NRC Engineering 4A 3A The HPCI system electrical calculations reviewed were generally acceptable, but numerous examples of inattention to detail and weaknesses in the design verification review process affected the quality of the analyses. Also, for some of the calculations reviewed, the tracking of assumptions and of results which may impact other calculations or procedures was weak.

35 2/13/1998 VIO/SL-IV IR 97022 NRC Engineering 4A 3A The sample of HPCI system modifications reviewed was acceptable; however, a violation of design control was identified. Other minor issues raised by the inspectors were satisfactorily addressed by the licensee.

36 2/13/1998 Misc IR 97022 NRC Engineering 4B Overall, the inservice testing and Technical Specification (TS) surveillance testing specifically related to the HPCI system were satisfactory. Based on a recent trend of TS surveillance noncompliance and potential programmatic testing inadequacies, the licensee had undertaken a root cause investigation to evaluate the trend and recommend correcti e actions to prevent recurrence. The effectiveness v

of these actions could not yet be determined.

37 2/13/1998 IR 97022 NRC Engineering 4B The inspectors reviewed commitments from Comed's March 28,1997, response to the NRC's request for information pursuant to 10 CFR i

50.54(f). The inspectors concluded that eighteen 10 CFR 50.54(f) commitments were closed.

Page 7 of 12

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"' 5"SS8 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascendir:g): Search Colurnn = *SALP* ; SALP Area =

  • Engineering * ; Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

I DATE TYPE SOURCE ID BY SALP l SMM CODES DESCRIPTION 38 2/13/1998 VIO/SL-IV IR 97022 NRC Engineering 48 3A Contrary to procedural requirements, the 50.59 screenings for two temporary alterations failed to evaluate the physical installation of all instrumentation installed by the alteration.

39 2/13/1998 Weakness IR 97022 NRC Engineering 4C Quad Cities design basis information weaknesses were also exhibited with numerous errors identified with the HPCI system design basis document (DBD). However, the licensee was aware of the DBD chortcomings and had designated the DBDs as "information only" peiu completion of a validation process.

40 2/13/1998 V.~eakness IR 97022 NRC Engineering 4C The inspe ctors noted that important calculations that form part of the Quad Cities HPCI design basis were not easily retrievable, or did not exist. For example, at the inspection onset, the licensee lacked a calculation to ensure that the HPCI design basis flow of 5000 gpm could be delivered against reactor pressure to support the acceptance criteria in i

the Technical Specification surveillance procedure. The inspectors also noted that the design basis for various safety related systems was not claarly established. However, the licensee had irvitiated actions such as the Design Basis initiative UFSAR review and was planning generation of approximately 15 missing analyses.

41 2/13/1998 Negative IR 97022 NRC Engineering 4C While overall, the HPCI system mechanical calculations reviewed were found to be acceptable, weaknesses were noted with nonconservative assumptions in an initial " white paper" analysis and with not consistently accounting for instrument inaccuracies.

421 2/13/1998 Positive IR 97022 NRC Engineering. 4C The inspectors c,cndWi that the HPCI room cooler was being adequately cleaned and inspected pursuant to GL 89-13 commitments.

Flow and differential pressure were trended and monitored for degradation and cleaning was scheduled on a regular basis.

43 2/13/1998 Positive IR 97022 NRC Engineering 4C Inaccurate figures and text in the UFSAR were identified but the inspectors also noted ongoing licensee efforts to improve UFSAR accuracy such as line by line reviews of the UFSAR design information and an initiative to ensure all facility changes had been incorporated into the UFSAR.

Page 8 of 12

11/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Cod 9s (Ascending): Search Column = "SALP' SALP Area =

  • Engineering *, Beginning Data = *10/1/1997*, Ending Date e "10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 44 2/13/1998 VIO/SL-IV IR 97022 NRC Engineering 4C While the 50.59 safety evaluations reviewed were adequate with supportable conclusions, weaknesses were identified with the overall 50.59 program. These weaknesses included poorly written safety evaluations, incomplete summary report submittals to the NRC, difficult to retrieve screenings, and incomplete corrective actions to identified deficiencies. The incomplete summary report submittals were considered a violation of procedural requirements. The Off-Site review group, however, was providing good assessments and comments.

45 2/13/1998 i3 97022 NRC Engineering 4C The inspectors reviewed the actions taken by Quad Cities staff for eight Systematic Evaluation Program (SEP) topics and concluded that the actions taken were sufficient for closure of these items. NRC review of nine remaining SEP items was ongoing.

46 2/10/1998 LER LER 254/98009 Licensee Engineering 4A Method of daily temperature verification of standbv Jguid control system pump suction heat tracing operablility using instaked temperature switches did not account for ca!ibration tolerance which allowed use of temperature switch settings that did not support the TS requirement resulting in inability to ensure suctions line temperature was above the minimum a' lowed value.

47 2/6/1998 Negative IR 97028 NRC Engineering 4B The inspactors concluded there were instances where engineering evaluations were not completed or were not of sufficient quality in areas such as snubber requirements, EDG ventilation, and electromatic relief valve vibration issues.

48 2/6/1998 Positive IR 97028 NRC Enginscring 4B However, the inspectors noted instances where engineering support of maintenance activities for the radwaste system was good and som9 aspects of troubleshcoting for an electromatic relief valve failure were good.

49 2/6/1998 Negative IR 97028 NRC Engineering 4B 3A The inspectors were concemed with the quality of system engineering walkdowns which could result in conditions adverse to quality not being identified.

50 2/6/1998 Negative IR 97028 NRC Engineering 4B 4C The lack of fo!!ow-through on long-term EDG improvement plans was a weakness made more significant by reccm EDG failures.

Page 9 of 12

11/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = "SALP", SALP Area =

  • Engineering *, Seginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 51 1/28/1998 LER LER 254/98006 Licensee Engineering 4A Reactor building post loss of coolant accident temperatures are higher than values used for the environmental qualification of electrical equipment due to unvalidated engineering judgment, the cause of which cannot be detcrmined.

52 1/16/1998 Weakness IR 989011 NRC Engineering 4B To confirm the actions to be taken by the licensee to resolve Appendix R issues at Quad Cities, NRC issued a confirmatory action letter (CAL) to Comed on January 16,1998. As described in the CAL, the licensee committed to take several actions prior to restarting the plant, including:

1. Revision and Validation of the Safe Shutdown Analysis, 2.

Development of Safe Shutdown Procedures, and 3. Identification and Resolution of Appendix R Discrepancies 53 1/15/1998 LER LER 254/98007 Ucensee Engineering 4A The design basis of the Quad Cities station reactor building superstructure is not in literal conformance with UFSAR description of class loading combinations. This is due to the fact that the FSAR, when originally written, lacked sufficient detail in description of class I loading combinations for addressing infrequent loading conditions (such as the crane) concurrent with a seismic event.

54 12/30/1997 LER LER 254/98005 Licensee Engineering 39 3C Failure to complete periodic visual inspections for reactor coolant sources outside primary containment, as required by TS were due to a prograrpmatic breakdown in scheduling and tracking of system inspections and ineffective program oversight.

55 12/20/1997 IR 97026 NRC Engineering 3C The inspectors concluded the 10 CFR Part 50, Appendix R safe shutdown procedure training of the crew of operators was good. Initially, the QCARP was not adequate to ensure specific actions were completed within the time required. After revising the procedure, operators demonstrated the ability to execute the OCARP in a timely manner. The inspectors identified waikways were not adequately lit in accordance with Appendix R requirements. Teamwork / Skill Level

'56 12/20/1997 IR 97026 NRC Engineering 43 The standby liquid control (SBLC) pumps periodically failed the in-service test (IST) due to low indicated flow. A long term solution to replace the flowmeters had been delayed due to higher priority engineering work.

Engineering / Design Deficiency Page 10 of 12

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M/25/1998 PLANT ISSUES MATRIX Quad Cities f

search sorted by Date (Descending) and sMM Codes (Ascerdng): search Column = "sALP" ; sALP Area = *Engineerint,, tiegirnng Date = *10/1/1997" Ending Data = *10/1/1998*

l DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 57 12/20/1997 IR 97026 NRC Engineering 48 The technical engineering approach to resolve the emerging 10 CFR Part 50, Appendix R safe shutdown issues was good. That is, the decision to simplify the method and reconstruct the design and licensing basis was appropriate. However, the NRC continued to have concems regarding the process for changing the licensing basis, implementing new procedures, and establishing the operability of the new safe shutdown method. Invoived Management 58 12/4/1997 eel IR 97027 NRC Engineering 3A An example of a violaison of 10 CFR 50.59(b)(1) was identified for failure to perform an adequate safety evaluation of the Unit 2 ASME Code,Section XI, Class 1 leakage test (at power). The inadequate safety evaluation screening performed for this test was of particular concem, since operation of Unit 2 prior to completing this test constituted an apparent unreviewed safety question. EngineeringiDesign Deficiency

.59 12/1/1997 LER LER 254/97024 Licensee Engineering 4B A required 10CFR50.59 summary evaluation for a change to the UFSAR was not submitted to the NRC due to an administrative oversight error.

60 11/3/1997 Weakness IR 97021 NRC Engineering 5B The inspectors concluded that significant flaws in the 10 CFR 50, Appendix R, Safe Shutdown procedures required the licensee to re-engineer the safe shutdown procedures at Quad Cities. Unit 2 was shut down in a conservative measure to reduce risk, while the licensee kept Unit 1 at power with compensatory actions in place, determining that safe shutdown could not be assured for all Appendix R fires. Inadequate Oversight 61 11/3/1997 Negative IR 97021 NRC Engineering SC The inspectors concluded that the refuel bridge interlocks were not in conformance with the UFSAR design basis and licensee corrective actions to date were incomplete. While initial compensatory actions appeared to be sufficient to guard against potential inadvertent criticality, longer term controls, corrective actions to address this potentially safety significant design discrepancy, had not been aggressively pursued.

Additiona!!y, the LER descriptions of the condition and corrective actions were confusing and lacked adequate information to properly evaluate the

g33gg, Page 11 of 12

11/25/1998 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date DATE the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC inspection Report or LER for Licensee Event Report.

ID CY identification oi who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/ Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements Eels are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal EEP Escalated Enforcement Issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients LER License Event Report to the NRC with the " General Statement of Policy and C - Programs and Processes Procedure for NRC Enforcement Action" Licensing Licensing issue from NRR (Enforcement Policy). NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding, etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Negative Individual Poor Licensee Performance ident;fied by the Eels and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance am made. Before the NRC makes its Strength Overall Strong Licensee Performance B - Knowledge, Skills, and Abilities enforcement decision, the hcensee will be C - Work Environment URl" Unresolved Inspection item provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering / Design:

VIO/SL-II Notice of Violation - Severity Level 11 (2) request a predecisional enforcement A - Design VIO/SL-III Notice of Violation - Severity Level lli conference.

B - Engineering Support VIO/SL-IV Notice of Violation - Severity Level tV

" URis are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance 5

Problem I entification and Resolution:

wh h ue acceptable item, a ocviation, a ID BY nonconformance, or a violation. However, B - AnaW the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identification by an event (e.g., equipment breakdown) conclusions are made.

Other identification unknown Page 12 of 12

11/ 5/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = " Maintenance * ; Beginring Data = *10/1/1997* ; Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1

9/1/1998 NCV IR 98013 Licensee Maintenance 2B The licensee's identification of additional missed surveillance tests in response to a previous notice of violation was noteworthy. Corrective actions have been effective and no missed surveillance tests have been identified in over 6 months. The additional missed surveillance tests were considered to be a non-cited violation (Section M8.2).

2 9/1/1998 NCV IR 998013 Licensee Maintenance 2B The licensee ultimately determined the root cause of the scram discharge instrument volume transmitter failure after incorrectly identifying two other causes. Maintenance personnel failed to correctly reference the vendor manual when interchanging electronic boards between transmitters. The parts evaluation process also missed this error which resulted in the scram discharge instrument volume transmitter being inoperable for 18 days. This condition resulted in a non-cited violation (Section M2.4).

3 9/1/1998 NCV IR 98013 NRC Maintenance 2B Three separate maintenance errors delayed work or affected p! ant conditions, but did not jeopardize operability of safety systems.

Configuration control problems occurred which were not prevented by second checks. One non-cited violation was issued for the failure to properly implement a maintenance work package (Section M2.1).

4 9/1/1998 Negative IR 98013 NRC Maintenance 28 One of the observed priority maintenance activities was completed successfully, but completed 5 days later than originally scheduled, with no major scope changes to the work. Weaknesses in work package preparation and coordination, communication between departments, knowledge of environmentally qualified splice techniques, parts qualification, and engineering and operations department support were evident. These types of problems were partial contributors to a 50 percent completion rate of corrective maintenance (Secticn M1.4) 5 9/1/1998 Positive IR 98013 NRC Maintenance 2B The licensee continued to reduce the corrective maintenance non-outage backlog. Although some of the reported reduction was due to cancellation of work requests, the inspectors did not identify any inappropriate cancellations (Section M1.3).

6 9/1/1998 Negative IR 98013 Licensee Maintenance 3A Poor maintenance package records resulted in an additional entry of maintenance workers into a locked high radiation area to plan corrective maintenance (Section M1.4).

7 9/1/1998 Positive IR 98013 NRC Maintenance 3A Condensate pump maintenance ac'ivities observed were performed correctly and in accordance with procedures. For most of the activities observed, supervisors visited the work site on a limited basis.

Page 1 of 10

)

11/25/m8 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP", SALP Area = " Maintenance" Beginning Data = *10/1/1997*, Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 8

9/1/1998 NCV LER 254/97013-Self-Maintenance 3A Reactor Core Isolation Cooling Area High Temperature Switch Would not 00, IR 98013 Revealed Actuate Due to Excess Sealing Vamish Applied by Technician. During channel functional testing, instrument technicians found that the 1-1360-14D temperature switch would not actuate due to a previous technician error. Excess sealing vamish had been applied after the previous calibration.

9 9/1/1998 Negative IR 98913 NRC Maintenance SA The 2A 125 Vdc battery charger failed a 4-hour load test when the feed breaker to the charger tripped. This was a repetitive problem, and no root cause was determined. The test was rerun satisfactorily and further actions were planned to determine the root cause. The test procedure initia!!y allowed for preconditioning of the equipment prior to the test (Section M2.2).

10 9/1/1998 Positive IR 98013 Licensee Maintenance SC The licensee successfully resolved a repetitive problem with control rod drive hydraulic control unit annunciators. Operator response to the most recent occurrence was improved over the response to a previous event (Section M2.3).

11 7/16/1998 IR98012 NRC Maintenance 2A Three events during the period, caused by turbine generator equipment problems, required operators to remove the turbine generator from operation to repair the defective conditions. The inspectors concluded that the maintenance activities and prompt investigation reports were timely and appropriate. However, the operators continued to be cha!!enged by equipment problems (Section M2.1).

12 7/16/1998 Negative IR 98012 Licensee Maintenance 2B Four average power range monitors were declared inoperable due to the failure to complete the required survei!!ance tests within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entering Mode 3. Technical Specification 3.1.A.1 was entered and required the channels to be in the trip condition within one hour. The surveillance tests were completed shortly after and the average power range monitors were egain operable (Section M1.1).

13 7/16/1998 Negative IR 98012 Self-Maintenance SC The licensee's investigation failed to accurately determine the cause of Revealed the scram discharge volume transmitter failure and later another scram discharge volume spurious trip signal occurred (Section M1.1).

Page 2 of 10

n/25n998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP' ; SALF Area = " Maintenance *, Beginning Data = *10/1/1997*, Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 14 5/29/1998 VIO/SL-IV IR 98009 Licensee Maintenance 1C During work on traversing incore probe components in April 1998, instrument Maintenance personnel did not comply with the out-of-service program and personnel protection controls. The failure to conduct work on this system in a safe and controlled manner was a violation of out-of-service procedures and TS requirements. Due to certain radiation protection requirements, and due to the low dose rate of the detector at the time of the evolution, there was no substantial potential for a radiological overexposure (Section M1.4).

15 5/29/1998 Positive

!R 98009 NRC Maintenance 2B The licensee was effectively tracking the numerous problems encountered with electrical circuit breakers, and was repairing these problems in a timely manner (Section M2.1).

4 16 5/29/1998 Negative IR 98009 NRC Maintenance 2B Poor quality maintenance resulted in the loss of one of two sources of offsite power. The investigation of this event was both timely and thorough. The inspectors also identified that the rework aspects of this event had not been identified by the licensee (Section M1.1).

17 5/29/1998 VIO/SL-IV IR 98009 NRC Maintenance 3B Maintenance workers failed to perform steps in an approved procedure and failed to change the procedure prior to continuing the maintenance actions. Maintenance supervision guidance contributed to the conclusion that this violation of TS requirements was acceptable (Section M1.3).

18 4/17/1998 Positive IR 98006 NRC Maintenance 2B The process for evaluating events and problems for functional failures and maintenance preventable functional failures had been revised and strengthened. Guidance for assessing events and problems was strengthened and a monthly requirement to evaluate maintenance rule system performance was instituted.

19 4/17/1998 Positive IR 98008 NRC Maintenance 2B Performance criteria established to demonstrate the effectiveness of preventive maintenance of (a)(2) systems and functions had been extensively revised, were appropriate, and were properly justified.

20 4/17/1998 Strength IR 98008 NRC Maintenance 2B Based on reviews of the licensee's risk ranking methodology and results, the inspectors concluded that the licensee's approach to establishing the risk ranking for SSCs within the scope of the maintenance rule was good. Two functions, identified during the baseline inspection as improperly classified as low safety significance, were now correctly classified.

' Page 3 of 10

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area =

  • Maintenance" - Beginrtrg Data = *10/1/1997*, Ending Date = *10/1/1998*

i DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 21 4/17/1998 Negative IR 98008 NRC Maintenance 2B The ir,spectors noted many SSCs and functions were classified as (a)(1) and observed that a significant portion of SSCs and functions modeled in the individual Plant Examination had exceeded performance criteria. This led the inspectors to question whether the current baseline core damage frequency estimate was valid and whether the licensec understood the undertying cause for so many systems not performing up to station expectations.

22 4/17/1998 Positive IR 98008 NRC Maintenance 2B Implementation of goals and monitoring for systems and functions classified (a)(1) was improved. Inappropriate goals, identified during the September 1997 baseline inspection, had been corrected. Adequate goals had been developed for those functions noted in the baseline report as having goals and corrective action plans under development. Goals and corrective action plans for all SSCs and functions classified as (a)(1)

~

were considered acceptable.

23 4/17/1998 Strength IR98008 NRC Maintenance 2B Sccping of structures, systems, and components (SSCs) was considered 4

acceptable. A complete rescoping effort properly identified structures, 4

systems, and components, and functions required to be in the maintenance rule program scope; no omissions were identified.

24 4/17/1998 Positive IR 98008 NRC Maintenance SA SC Two 1998 corporate self-assessments of the Quad Cities maintenance rule program implementation were thorough and provided good information for the station's maintenance rule staff. In tum, the maintenance rule staff adequately responded to the issues raised in a timely manner.

25 3/31/1998 Positive IR 98004 Self-Maintenance 2A Reactor bottom head drain piping failed an in-service pressure test. The Revealed licensee conservatively used a reactor drain plug and a freeze seal to isolate the piping for repair (Section M1.2).

26 3/31/1998 VIO/SL-IV IR 98004 Licensee Maintenance 2B Quad Cities was overdue on completion of a number of surveillance and preventive maintenance items. The licensee was scheduling surveillances and preventive maintenance items to be performed past the due date for the items. A violation was issued for failure to perform snubber surveillances in the appropriate periodicity Section M1.5).

Page 4 of 10

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *sALP* ; SALP Area =

  • Maintenance * ; Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 27 3/31/1998 VIO/SL-IV 1R 98004 Licensee Maintenance 28 All source range nuclear instruments on both units were rendered inoperable because of failure to perform Technical Specification required functional testing. Previot,s corrective actions were not sufficient to ensure surveillances were performed in a timely manner. This was considered a violation of surveillance testing (Section M1.4).

' 28 3/31/1998 VIO/SL-IV IR 98004

'Ucensee Maintenance 2B The licensee identified standby liquid control system temperature switches, used to satisfy a Technical Specification surveillance requirement, were set below the required minimum temperature. There were prior opportunities to identify this missed surveillance violation (Section M1.3).

29 3/31/1998 Positive IR 98004 Licensee Maintenance 3A An instrument technician found electronic controller modules which were improperty assembled by a contracted repair company. This condition was properly reported to alert other facilities of a potential nonconforming condition (Section M1.2).

30 3/31/1998 VIO/SL-IV IR 98004 Licensee Maintenance 3B A maintenance contractor operated valves with out-of-service (danger) tags attached. This issue was considered a violation of the licensee's administrative procedures, and demonstrated poor safety practices and ineffective control of contractor activities (Section M1.2).

31 3/31/1998 Negative IR 98004 Licensee Maintenance SC The licensee's corrective actions for previously identified testing deficiencies with the emergency diesel generator air start system were not technically adequate, and procedure reviews failed to identify the problems (Section M3.1).

32 2/13/1998 Strength IR 97022 NRC Maintenance 28 The maintenance training program was adequate to assure qualified maintenance technicians. The training facilities were very good and were considered a strength.

33 2/13/1998 Strength IR 97022 NRC Maintenance 2B Maintenance activities were well controlled. The assignment of work week managers to coordinate activities was considered a strength.

34 2/13/1998 Weakness IR 97022 NRC Maintenance 2B SA During walkdowns on the Unit 1 and 2 High Pressure Coolant injection (HPCI) systems, minor problems with material condition were identrfied.

These minor problems did not affect the operability of either units' HPCI systems. Minor procedure errors were also identified with both the Unit 1 and 2 HPCI system checklists used to locally verify valve positions.

Page 5 of 10

"/2s/iw8 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP', SALP Area = " Maintenance", Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 35 2/13/1998 Positive IR 97022 NRC Maintenance 2B SA Licensee maintenance procedures were technically adequate, sufficient to perform the required maintenance and inspection tasks and had the necessary provisions to identify and evaluate deficiencies.

36 2/13/1998 LER LER 254/98010 Licensee Maintenance 3A TS surveillance interval for snubber visial inspections was exceeded due to personnel error when an incorrect surveillance credit date was entered into the electronic work control system predefine schedule as a result of a change in frequency codes for conversion to the upgraded TSs.

37 2/13/1998 Positive IR 97022 NRC Maintenance 3A 3B The performance by an instrument technician during an observed surveillance was good. The technician precise'y followed the procedure and demonstrated a good level of skillin the use of the test equipment involved.

38 2/6/1998 Weakness IR 97028 NRC Maintenance 2A 2B The licensee discovered that all three EDGs had out-of-tolerance time delay relay settings. The maintenance work history showed that preventive maintenance to calibrate the relays was not performed per the established schedule, and relays in the past had exhibited a high failure rate.

39 2/6/1998 Negative IR 97028 NRC Maintenance 2B 3A The inspectors ide:'.tified that weaknesses existed in documenting work history information previously provided by a vendor. In addition, wiring errors resulted in a safety-related system being inoperable longer than scheduled.

40 2/6/1998 Negative IR 97028 NRC Maintenance 3A 2B During a surveillance test, the inspectors noted the procedure adherence policy was not followed. The inspectors also found problems with the use of independent verifution methods.

41 2/6/1998 Negative IR 97028 NRC Maintenance 3A SC Lack of control of foreign material (electrical tape) resulted in a condition which cot:Id have adversely affected EDG performance and may have contributed to the failure of the EDG to start. The licensee's investigation of this particular aspect of the event was initial!y inconclusive and did not include recommended corrective actions to prevent recurrence.

42 2/6/1998 1/eakness IR 97028 NRC Maintenance SA SC The quality control (OC) organization implemented overview inspections to replace non-mandatory hold peints in maintenance activities. The Quad Cities Maintenance staff did not substitute the verification of hold point activities with maintenance supervisor verifications as initially intended by management.

Page 6 of 10

n/25/m8 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP', SALP Area = " Maintenance *, Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 43 1/27/1998 LER LER 254/98008 Licensee Maintenance 2A Residual heat removal shutdown cooling common suction header was inoperable due to inadequate installation instructions resulting in mechanical failura of a mechanical shock arrestor (snubber).

44 1/3/1998 LER LER 254/98002 Licensee Maintenance 2B A required drywell high pressure instrument channel relay monthly surveillance interval was exceeded due to an inadequate test procedure that was caused by an inadequate procedure verification and revision during implementation of the TS upgrade program.

45 12/20/1997 Weakness IR 97026 NRC Maintenance 2A Corrective actions to identified 4 kV breaker problems in 1996 and 1997 remained incomplete at the end of the inspection period. A number of safety-related breakers had not been refurbished in more than 28 years.

Vendor recommended maintenance tasks for GE 4 kV breakers were not being performed.

46 12/20/1997 IR 97026 NRC Maintenance 28 Some maintenance activities were not well coordinated with the operations department to minimize abnormal system lineups (feedwater control). One safety-related system prob lem (control rod drive) was not repaired or tracked in a corrective action system. Teamwork / Skill Level 47 12/20/1997 IR 97026 NRC Maintenance 2B Recommended preventive maintenance tasks were not identified or performed for some plant equipment modifications including the station blackout diesel generators and the Merlin-Gerin 4 kV breakers that were installed more than two years ago. Other/NA 48 12/20/1997 IR 97026 NRC Maintenance 2B The station identified examples of a violation involving missed Technical Specification required surveillances. A root cause evaluation was performed to address previous Technical Specification noncompliances.

However, only one of three of the new issues was identified as a result of corrective actions from the root cause evaluation. Inadequate Procedure / instruction 49 12/20/1997 IR 97026 NRC Maintenance 2B Two instances involving valve reassembly errors by contracted maintenance personnel were not detected prior to retuming the unit to power operations, which resulted in a procedure violation. In addition, proposed corrective actions did not appear to be effective to ensure similar problems would not recur. Parsonnel Performance Deficiency Page 7 of 10

u/ 5/m8 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = 'SALP* ; SALP Area = *Mdntenance', Beginning Date = *10/1/1997* ; Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 50 12/20/1997 IR 97026 NRC Maintenance 3A Two maintenance activities observed indicated a lack of appropriate caution on the part of the workers performing critical rigging tasks at the point where there was increased potential for equipment damage.

Personnel Performance Deficiency 51 12/18/1997 LER LER 254/97027 Self-Maintenance 2A Unit 1 and 1/2 EDGs were sirr.ultaneously inoperable while Unit 1 was at Revealed power due to time delay relay 2 failing to meet acceptance criteria.

52 12/17/1997 LER LER 254/97030 Licensee Maintenance 2B instrument line excess flow check valves testing was performed at less than nominal reactor pressure due to apparent inadequate procedures.

53 12/17/1997 LER LER 254 97029 Licensee Maintenance 2B Unit 1 and 2 rod block monitor channel functional testing was not accomplished within seven days prior to startup as required by the TS individual surveillance requirement due to misinterpretation of TS and inadequate procedure validation when implementing upgraded TSs.

54 12/4/1997 IR 97027 NRC Maintenance 1C One violation of 10 CFR 50, Appendix B, Criterion XVil was identified for failure to maintain retrievable copies of completed Class 1 pressure tests performed during the 1995 refueling outages for Unit 1 and Unit 2.

Other/NA 55 12/4/1997 IR 97027 NRC Maintenance 4B A violation of Technical Specification (TS) 4.0.E (with five examples) was identified for failure to meet or adequatey complete ASME Code,Section XI, Class 1 and 2 pressure tests, which indicated a programmatic breakdown in implementation of these requirements. Other/NA 56 12/4/1997 IR 97027 NRC Maintenance SA One violation of 10 CFR 50, Appendix D Criterion XVI was identified for failure to promptly initiate tne corrective action process for the Unit 1 failed reactor vessel flange inner O-ring seal. Personnel Performance Deficiency 57 11/21/1997 LER LER 265/97012 Self-Maintenance 2A 1A Loss of Shutdown cooling due to the loss of power to the reactor Revealed protection bus 28.A low voltage setting on the voltage regulating transformer caused the EPA breaker to trip.

58 11/7/1997 LER LER 254/97025 Ucensee Maintenance 2B 3A APRMs flow bias were not calibrated to a flow signal within the required interval due to inadequate change management when implementing upgraded TSs. In addition, this calibration was not performed prior to entering power operation mode for units 1 and 2 due to misinterpretation of TSs.

Page 8 of 10

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area =

  • Maintenance" Beginning Date = *10/1/1997 Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTIOM 59 11/3/1997 Strength IR 97021 NRC Maintenance 2B The licensee's work control process had improved the ability to plan, schedule, and execute work and resulted in a decline in the non-outage power block backlog. Two items inhibited better performance in the work week planning process. These items included suspension of the work week planning self-assessment and weak input to the work planning process by systems engineering. Involved Management 60 11/3/1997 URI IR 97021 Lansee Maintenance 2B The licensee discovered two additional instances, in maintenance and operations, where surveillance tests required by TSs had not been completed. Personnel Performance Deficiency 61 11/3/1997 Negative IR 97021 NRC Maintenance 2B The inspectors identified occurrences where licensee maintenance procedures were not in accordance with Vendor Equipment Technical Instructions (VETI) manual requiremants. The inspectors also noted an Engineering Report (ER) written on a lys. ting steam valve job was not given a high priority for repair. This delay resulted in a maintenance activity affecting availability of plant equipment).

62 10/29/1997 LER LER 254/97023 Licensee Maintenance 3A 2B A required TS surveillance was not performed prior to reactor moda change on four occasions due to inadequate procedures associated with implementation of the TS upgrade program.

63 10/11/1997 Positive IR 97021 NRC Maintenance 1C Good outage planning and execution resulted in completion of a planned outage in less time than expected. Team.vork/ Skill Level Page 9 of 10

11/25/1998 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual Jate is not known, use the date DME the issue was idantified. For issues that do not have an actual date or a date of identification, use the LER or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC Inspection Report or LER for Licensee Event Report ID CY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/ Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codfs - see table.

1 DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviatim from NRC Requirements Eels are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal escalated enforcement action in accordance B - During Transients EEI*

Escalated Enforcement issue - Waiting Final NRC Action with the

  • General Statement of Policy and C - Programs and Processes l LER License Event Report to the NRC Procedure for NRC Enforcement Action 2

Material Condition:

l Licensing Licensing issue from NRR (Enforcer.:ent Policy), NUREG-1600.

Misc Miscellaneous (Emergency Preparedness Finding. etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes j Negative Individual Poor Licensee Performance idenMicd by the Eels and the PIM entries 3

Human Performance:

l Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Farformance are made. Before the NRC makes its B - Knowledge Skills, and Abilities l Strength Overall Strong Licensee Performance enforcement decision, the licensee wdl be C - Work Environment URI" Unresolved Inspection item provided with an opportunity to either l

. VIO/SL-l Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering / Design:

, VIO/SL-!!

Notice of Violation - Severity Level 11 (2) request a predecisional enforcement A - Design

VIO/SL-ill Notice of Violation - Severity Level lli conference.

B - Engineering Support

    • URis are unresolved items about which C - Programs and Processes
VIO/SL-IV Notice of Violation - Severity Level IV determin l ~~eakness Overall Weak Licensee Performance P

Rdh wh uo et s

A - Identification acceptable item, a deviation, a B - Analysis ID BY nonconformance, or a violation. However, C - Resolution the NRC has not reached its final Licensee The licensed utility conclusions on the issues, and the PIM I NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identification by an event (e.g.. equipment breakdown) conclusions are made.

Other Identification unknown Page 10 of 10

11/ 5/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) ard SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area =

  • Operations *, Beginning Date = *10/1/1997*. Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION i

1 9/1/1998 NOV 1R 98013 Licensee Operations 1A An event involving miscommunication between operators caused the control room emergency ventilation system to trip and become inoperable. A non-cited violation was issued for the improperly implemented surveillance procedure (Section 08.2).

2 8/16/1998 NCV IR 98013 Licensee Operations 3A Operators discovered four high pressure coolant injection system and reactor core isolation cooling system vent valves in the wrong position.

Procedure usage by the operator and independent verification problems were contributors to the error. This was considered a non-cited violation (Section O2.1).

3 7/16/1998 IR98012 NRC Operations 1A Due to recurrent maintenance problems and an inability to determine a cause of valve failure, operators were required to increase the frequency of cycling with the Unit 2 recirculation system sample valves. A failure on the recirculation system sample line resulted in operators needing to vent primary containment to atmosphere to avoid an engineered safety features actuation. However, the inspectors concluded the licensee met Technical Specification requirements (Section O2.4).

4 7/16/1998 Negative IR 98012 NRC Operations 1A Poor communication led to an operator error which resulted in the trip of the control room ventilation system. A confusing procedure and inappropriate procedure usage also contributed to the error (Section 01.3).

5.

7/16/1998 IR 98012 NRC Operations 1B Concurrent startups of Unit 1 and Unit 2 were completed without any significant problems. However, several equipment failures occurred and required reactor protection system or containment isolation system channels to be tripped and Unit 1 to be in a Technical Specification shutdown action statement. Additionally, control rods were extremely difficult to withdraw which became a significant distraction to normal operator performance and resulted in rods being moved past the intended positions several times (Section O2.3),

6 7/16/1998 Positive IR 98012 NRC Operations 18 During Unit 1 startup, the inspectors observed good heightened level of awareness briefings and overall good operator performance (Section O1.2).

Page 1 of 8

" /25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALP Area = " Operations" Beginning Date = *10/1/1997*

Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 7

7/16/1998 Positive IR 98012 NRC Operations 1B Three events during the period, caused by turbine generator equpment problems, required operators to remove the turbine generator from operation. The inspectors concluded that the operators responded to the events appropriately. However, the operators continued to be challenged by equipment problems (Section M2.1).

8 7/16/1998 VIO/SL-IV IR 98012 NRC Operations 1C The inspectors identified errors associated with operations surveillance tests that involved different and diverse operations subdisciplines including staff, supervisory, and management positions. One of these resulted in a violation. The inspectors were concemed that attributes of quality established and supported by management were not being implemented by the operations organization (Sec%n 04.1).

9 6/27/1998 IR 98012 Self-Operations 1B The Unit 1 reactor tripped on June 27 from full power due to a failed Revealed scram discharge volume level transmitter coincident with a surveillance test of the average power range monitor. All systems functioned properly and operator response to the transient was good. The licensee's investigation failed to accurately determine the cause of the scram discharge volume transmitter failure, and several weeks later another spurious signal occurred shortly before a scheduled reactor protection system test (Section O2.1).

10 6/14/1998 Negative IR 98012 NRC Operations 1C Equipment problems resulting from electrical storms affected various plant systems. Operations management decisions on degraded control rod drive accumulators did not use formal operability determination mechanisms, did not fully take into account Updated Final Safety Analysis Report requirements, and did not use engineering assistance to determine operability when design criteria were not met (Section O2.5).

11 5/29/1998 VIO/SL-IV IR 98009 NRC Operations 1A The inspectors and licensee both identified a negative trend in out-of-service performance. The licensee's evaluation of a failure to protect divers during a pump start was downgraded to an apparent cause evaluation, and the quality of the apparent cause evaluation and subsequent corrective action was poor. Operations management did not initially consider the event significant even though personnel safety and system performance could have oeen adversely affected (Section 04.1).

Page 2 of 8

"/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = "Operatiens". Beginning Date = *10/1/1997* ; Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 12 5/29/1998 Positive IR 98009 NRC Operations 1B Operators carefully controlled Unit 2 startup activities. Operator performance was good although the different operating crews exhibited different standards with respect to communications. A number of equipment problems occurred and operators responded appropriately (Section O2.1).

4

' 13 5/29/1998 Positive IR 98009 NRC Operations 18 The control rod hydraulic and air systems were in good material condition, and were in the appropriate configuration for the current plant conditions (Section O2.2).

14 5/29/1998 Positive IR 98009 NRC Operations 1B Control room operator actions in response to the loss of an offsite power supply were in accordance with procedures and were accomplished using both self-check and peer-check techniques (Section M1.1).

15 5/29/1998 VIO/SL-IV IR 98009 NRC Operations 3B An individual operated out-of-service equipment in violation of plant procedures and Technical Specifications (TS). The out-of-service hung on the refuel bridge was insufficient to ensure the refuel bridge would not move when operation was attempted from the bridge control pendant.

This event was also significant because the out-of-service was being used as an equivalent method of reactivity controls for interlocks that did not meet Updated Final Safety Analysis Report (UFSAR) requirements (Section O4.2).

16 4/1/1998 Negative

!R 98303 OL NRC Operations 1C Administration of the examination revealed one applicant performance IR 98303 OL issue needing additional review by the Quad Cities Nuclear Power Station Training and Operations Departments. On two occasions during simulator transients, license applicants reached setpoints, imposed by an administrative procedure, that required a specified action such as a reactor scram or emergency depressurization. The applicants executed those actions even though they had been informed that the action was unnecessary and the plant was being adequately controlled by crew members. Although the simulated reactor was placed in a safe condition in each of the two cases, the transient initiated on the plant was unnecessary and could have been avoided. (Section OS.S.b)

Page 3 of 8

" /25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP' ; SALP Area = ' Operations *, Beginning Data = *10/1/1997*, Ending Date. *1fr1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 17 4/1/1998 IR 98303 OL NRC Operations 1C An NRC developed initial operator licensing examination was administered to three license applicants [two Senior Reactor Operator (SRO) applicants, and one Senior Reactor Operator Limited to Fuel Handling (LSRO) applicant]. All three applicants passed all portions of their respective examinations. The LSRO was issued a license. The two SRO applicants were not issued operating licenses as they have not completed all requirements to be issued a license. Ucenses will be issued upon completion of all Quad Cities Nuclear Power Station training program requirements; ie, one additional month of responsible power plant experience at Quad Cities Nuclear Power Station. (Section O5.1)

' 18 3/31/1998 VIO/SL-IV IR 98004 Licensee Operations 1A Non-licensed operators improperly retumed a safety-related breaker to service and logged the equipment as being available for five days before detecting the deficient condition. The failure to properly retum the component to service was considered a violation of procedures (Section 01.2).

19 3/31/1998 Negative IR 98004 Licensee Operations 3A Non-licensed operators injected incorrect grease into the station blackout diesel generator fuel oil transfer pump, which could have made the pump inoperable due to grease incompatibility. Initial corrective actions did not address extended operation of the pumps with incompatible grease and were considered weak (Section 01.2).

20 3/20/1998 Positive IR 98303 OL NRC Operations 1C The training and operations departments staff provided significant assistance in preparing the examination for administration to the applicants. (Sections 05.1,05.2, O5.3 and O5.4) 21 3/20/1998 Positive IR 98303 OL NRC Operations 38 The applicants appeared well prepared to take the examination.

(Sections 05.2, O5.3 and 05.4) 22 2/13/1998 Positive IR 97022 NRC Operations 1C 3B The level of knowledge of two operators interviewed conceming the HPCI system was good.

23 2/13/1998 VIO/SL-IV IR 97022 NRC Operations 1C SA Some problems with HPCI system procedures were identified. One procedure, concemed with local operation of the HPCI system, was inadequate. This was considered a violation of NRC requirements.

24 2/6/1998 VIO/SL-IV 1R 97028 NRC Operations 1A 4C The licensee did not complete a 10 CFR 50.59 evaluation for the change in the status of the normal ventilation fan to the shared EDG roor.1 This was considered a failure to maintain the plant configuration in accordance with the Updated Final Safety Analysis Report (UFSAR)

Page 4 of 8

11/25/1998 PLANT ISSUES MATRIX Quad Cities search sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = ' Operations", Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE l

SOURCE ID BY SALP SMM CODES DESCRIPTION 25 2/6/1998 Negative IR 97028 NRC Operations 1C The licensee did not proactively prepare for the effects of cold weather on equipment deemed important to safety.

26 2/6/1998 Negative IR 97028 NRC Operations 1C 3A Two operators, using the licensee's independent verification methods, failed to establish correct cooling water valve position for the Unit 2 EDG, rendering it inoperable during some of the time that the Unit 1 EDG was also inoperable (Section 01.3). In addition, two individuals preparing a retum to service package caused a Unit 2 EDG air start valve to be out of the required position. These events were indicative of a weakness in independer.t verification.

27 2/6/1998 Negative IR 97028 NRC Operations 3A 1A Technician error, inadequate communication and the misinterpretation of a procedure led to the unexpected start of the Unit 1 emergency diesel generator (EDG). Licensee investigation of operator performance during the event was insightful.

28 1/13/1998 Positive IR 97024.OL NRC Operations 1C The examination materials used to examine the operators provided an effective evaluation tool for evaluating operator skills; however, the Category B (classroom written examination) examination was considered weak.

29 1/13/1998 Positive IR 97024.0L NRC Operations 3A 1C Control room operators were found to be professional and businesslike in the execution of their operator responsibilities.

30 1/13/1998 Positive IR 97024.0L NRC Operations 3B 1C The licensed operator requalification program was providing operators with the skills necessary to properly fulfill their job functions.

31 1/5/1998 LER LER 254/98001 Self-Operations 1A Unit 1 EDG received an inadvertent start signal when a relay was bumped Revealed during testing, the EDG failed to start as would be expected on receipt of this signal, and the EDG was inadvertantly started 15 minutes later due to an error by an operator who was responding to the failure to start.

32 12/20/1997 IR 97026 NRC Operations 1A The inspectors noted a weakness in the equipment operator surveillance procedure in that the procedure did not include checks of the pumps required for the interim attemate safe shutdown method (IASM).

Inadequate Procedure / Instruction 33 12/20/1997 IR 97026 NRC Operations 1A The inspectors noted some instances where conduct in the control room did not meet the expectations of licensee management for professionalism. Personnel Performance Deficiency Page 5 of 8

PLANT ISSUES MATRIX ii/25/ima Quad Cities Search Sorted by Date (Descending) and SMM Codes (nscending): Search Colurnn = *SALP* ; SALP Area = " Operations

  • Beginning Date = "10/1/1997". Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 34 12/20/1997 IR 97026 NRC Operations 1A Until prompted by the inspectors, operations' management was not aware of the adverse trend in unidentified leakage in the Unit 1 drywell. The inspectors concluded the evaluation of the leak was in compliance with Technical Specifications (TSs) and allowed by the Code. Inadequate Oversight 35 12/20/1997 IR 97026 NRC Operations 1B 2A Equipment issues challenged operators who responded appropriately.

However, in a number of cases, longer term corrective actions to fix the equipment issues had not been completed. Other/NA 36 12/20/1997 IR 97026 NRC Operations 1C The establishment of root ccuse experts and investigators appeared to be a good initiative. However, the inspectors found that RCE investigators were being pulled away from their assigned duties to perform other functions. Inadequate Oversight 37 12/20/1997 1R 97026 NRC Operations 1C Transition to the electronic out of service (EOOS) program was smooth and effective. Self-assessment of the OOS program was aggressive and consistent with the performance expectations of operations' management, involved Management 38 12/20/1997 IR 97026 NRC Operations SC The quality and safety assessment group continued to identify corrective action program issues, some of which were previously identified as a weakness. Similarly, the inspectors noted specific issues of weak corrective actions in this and previous inspection reports where corrective actions did not prevent recurrence. The inspectors concluded the effectiveness of the new CAP to ensure that corrective actions were in place to prevent recurrence of previously identified deficiencies had not yet been demonstrated. Other/NA 39 12/10/1997 LER LER 254 98003 Self-Operations 1A TS LCO was exceeded when both standby gas treatment subsystems Revealed were inoperable because both the unit 1 and the unit 2 EDGs were inoperable due to inadequate procedure development and review.

40 11/25/1997 LER LER 254/97026 Licensee Operations 28 3A Technical Specification required instrument channel checks were not documented prior to entering the applicable mode due to inadequate procedure hvelopment and review.

41 11/3/1997 URI IR 97021 NRC Operations 1A The inspectors concluded operating procedures allowed bypassing the pressure suppression function of the primary containment during de-inerting evolutions. The licensee's evaluation of this condition did not address reportability. Personnel Performance Deficiency Page 6 of 8

" /25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP' ; SALP Area = " Operations

  • Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE l

TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 42 11/3/1997 Negative IR 97921 NRC Operations 1A The inspectors identified that operator response to some control room annunciators which is normally good, was weak; and prioritization of maintenance to support some cold weather preparations was inadequate. Personnel Performance Deficiercy 43 11/3/1997 Positive IR 97021 NRC Operations 1B The licensee continued to have periodic equipment problems which affected unit operations. However, operators continued to demonstrate good control during complex plant manipulations. One additional instance of Operations missing a Technical Specification (TS) required survei!!ance test was identified. Teamwork / Skill Level 44 11/3/1997 Negative IR 97921 Self-Operations 2A Improper filter assemblies were installed in Unit 1 stator water cooling Revealed system. Equipment Malfunction 45 10/15/1997 LER LER 254/97022 Licensee Operations 1A The control room HVAC system was declared inop due to inadequate cooling water flow which was caused by a system perturbation. It was suspected that a relief valve lifted, robbing flow.

Page 7 of 8

11/25/1998 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal ed: ting.

The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date DATE the issue was identified. For issues that do not have an actual date or a date of identification use the LER or inspection report dcte.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC inspection Report or LER for Licensee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/ Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements Eels are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal escalated enforcement action in accordance B - During Transients eel

  • Escalated Enforcement issue - Waiting Final NRC Action LER License Event Report to the NRC with the
  • General Statement of Policy ar}d C - Programs and Processes Procedure for NRC Enforcement Action 2

Material Condition:

Licensing Licensing issue from NRR (Enforcement Policy). NUREG-1600.

Misc Miscellaneous (Emergency Preparedness Finding etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Negative Individual Poor Licensee Performance identified by the Eels and the PIM entries 3

Human Performance:

l Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities iStrength OveraII Strong Licensee Performance enforcement decision, the licensee will be C - Work Environment I URl*'

Unresolved Inspection item provided with an opportunity to either i VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineenng/ Design:

I VIO/SL-il Notice of Violation - Seventy Level II (2) request a predecisional enforcement A - Design VIO/SL-t!I Notice of Violation - Severity Level lli conference.

B - Engineenng Support

0 5

Problem identification and Resolution:

Weakness Overa!! Weak Licensee Performance e

uest A - Identification acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B-Analysis C - Resolution the NRC has not reached its final e

l Licensee The licensed utility conclusions on the issues, and the PIM

!NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identification by an event (e.g., equipment breakdown) conclusions are made.

Other identifcation unknown Page 8 of 8

11/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *FALP* ; SALP Area =

  • Plant Support'. Beginning Date = *10/1/1997*. Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1

8/28/1998 Strength 1R 98014 NRC Plant 1C Overall performance during the 1998 Emergency Preparedness exercise Support was effective and demonstrated that your emergency ptan implementation activities met regulatory requirements. The performance of the staffs in the Con!rol Room Simulator, Technical Support Center, Operations Support Center and Emergency Operations Facility contributed to safety by taking appropriate actions to mitigate the simulated accicent and protect the public. They met the exercise objectives in an acceptable manner while complying with emergency plan aW regulatory requirements. Staff and management effectively cumpleted self-critiques.

2 8/14/1998 Positive IR 98016 NRC Plant 1C The licensee implemented good ALARA controls for the movement of IR 98016 Support highly activated components in the spent fuel pool and took prompt and effective actions after higher than expected dose rates were encountered during the job (Section R4.3).

3 8/14/1998 Positive IR 98016 NRC Plant 1C Radiological controls implemented for the demineralizer filter element Support replacement were effective. The radiation work permit appropriately addressed radiological concems and included ALARA pre-job briefing notes. Radiation protection technicians and workers demonstrated good communication and radiation worker practices (Soctien.4 2).

o 4

8/14/1998 Positive IR 98016 NRC Plant 1C Radiological controls for the Units 1 and 2 spent fuel pool work were Support effective. The As-Low-As-Is-Reasonably-Achievable (ALARA) plan appropriately addressed past lessons-leamed, potentially high radiological conditions and included reasonable contingency plans. The subsequent shipping of the material removed from the pool was also well conducted (Section R4.1).

5 8/14/1998 Negative IR 98016 NRC Plant 1C Radiological postinga and container labeling were well maintained, and Support appropriately informed workers of current plant radiological conditions.

Overall, housekeeping was good, except for the laundry-tool decon building maintenance decontamination area. In addition, drain hoses from heat exhangers in the Unit 2 reactor building were not properly secured and were inconsistently labeled. (Section R2.2).

Page 1 of 9

'1/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP*. SALP Area =

  • Plant Support' ; Beginning Dato = *10/1/1997*, Ending Data = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 6

8/14/1998 Positive IR 98016 NRC Plant 1C High and locked high radiation areas were well controlled and were Support maintained in good condition with only minor housekeeping problems observed. Workers were familiar with access control requirements and RP staff was observed reinforcing these expectations in work areas (Section R2.1).

7 8/14/1998 Positive IR 98016 NRC Plant 1C The inspectors concluded that the station was effectively planning and Support coordinating work to reduce source term and; therefore, overall station dose (Section R1.5).

8 8/14/1998 Positive IR 98016 NRC Plant 1C The routine contamination and dose rate survey program was effectively Support implemented. Surveys were performed as required and appropriately documented. A technician observed during the inspection was knowledgeable of the procedure and the area to be surveyed, and demonstrated good survey techniques (Section R1.4).

9 8/14/1998 Positive iR 98016 NRC Plant 1C Air sampling was conducted consistent with NRC regulations and industry Support practice. Air samplers were well maintained and workers were observed correctly performing air sampling activities. However, there were several minor examples identified where procedural guidance needed additional clarification and where mistakes in air sampling records had not been identified through licensee supervisory reviews (Section R1.3).

10 8/14/1998 Positive IR 98016 NRC Plant 1C In-vitro and in-vivo analyses were being performed properly and were Support consistent with industry standards. However, the inspectors questioned whether a decrease in the frequency of quality control checks for the whole body counter would provide sufficient OC data to obtain an accurate indication of detector performance. This was being evaluated by the licensee (Section R1.2).

11 8/14/1998 Strength IR 98016 NRC Plant 1C Overall, the extemal exposure control program was being effectively Support implement 6d in accordance with station procedures and regulatory requirements. Radiation Protection (RP) staff were knowledgeable of procedures and processes. However, several minor deficiencies regarding procedure adherence and record keeping were identified.

These deficiencies were being evaluated and corrected by RP management (Section R1.1).

Page 2 of 9

"/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = *SALP* ; SALP Area =

  • Plant Support', Beginrung Date = *10/1/1997" ; Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 12 7/16/1998 Negative IR 98012 NRC Plant 1C The inspectors identified numerous administrative problems associated Support with the fire protection compensatory actions but concluded that the regulatory commitments were satisfied. The inspectors were concemed with the quality of documentation supporting required fire watch tours and the quality of correspondence in the May 22,1998, letter to the NRC

,f4ction F2.1).

13 5/29/1998 Positive IR 98009 NRC Plant 1C Good radiological controls were noted during the performance of Support traversing incore probe activities. These controls remained in place to provide personnel protection from radiological hazards, even though the out-of-service program protections were not left in place (Section M1.4).

Chemistri and Radiation Protection personnel responded conservatively 14 5/29/1998 Positive IR 98009 Licensee Plant 3B j

Support and quickly to a release of radioactive xenon-133 in the chemistry laboratory. No adverse personnel or environmental hazards resulted from this release (Section R4.1).

15 4/17/1998 Positive IR 98010 NRC Plant 1C Radiological postings of equipment and facilities, and labeling of Support containers were in accordance with procedures. Housekeeping was considered good. Minor inspector identified posting and housekeeping discrepancies were promptly corrected by radiation protection personnel (Section R2.3).

16 4/17/1998 Positive IR 98010 NRC Plant 1C The area radiation monitors (ARM) and continuous air monitors (CAM)

Support calibration, testing, and maintenance program was well implemented.

However, the ARM trending and component evaluation process, and radiation protection's oversight of changes to the ARM procedures was in need of improvement (Section R2.1).

17 4/17/1998 Positive IR 98010 NRC Plant 1C The 1996 and 1997 effluent reports were generated in accordance with Support the Offsite Dose Calculation Manual, with the total activity released well below applicable regulatory limits. The reports also appropriately documented any abnormal releases (Section R1.4).

18 4/17/1998 Strength IR 98010 NRC Plant 1C The liquid and gaseous effluent monitoring programs were effectively Support implemented. Effluent monitor operability was good, with calibrations and checks performed in accordance with procedures and at the required frequencies. Effluent release data indicated that releases were well below regulatory limits (Section R1.3).

Page 3 of 9

" /25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) ard SMM Codes (Ascending): Search Column = "SALP" ; sALP Area = " Plant Support' ; Beginning Date = *10/1/1997*, Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 19 4/17/1998 Positive IR98010 NRC Plant 1C The as-low-as-is-reasonably-achievable (AI. ARA) plan for the Unit 1 Support bottom vessel drain line repair was detailed, and included evaluations of the additional dose as work progressed. The radiation work plan requirements incorporated ALARA plan contingencies and special instructions. The total dose for the bottom vessel drain line repair appropriately increased due to an expanded scope of work to include expanding the length of time the freeze seal remained in place, and problems with installing and welding the replacement pipe section (Section R1.2).

20 4/17/1998 Positive IR 98010 NRC Plant 2B Required surveillances and tests of the engineered safety feature filtration Support systems were well implemented and performed in accordance with procedures. The test results indicated that the Technical Specification acceptance criteria were met. The material condition of the filter systems was good (Section R2.2).

21 4/17/1998 NCV 1R 98010 Licensee Plant 3B Radiation protection's response to an individual who ignored ED alarms Support was considered good and corrective actions were appropriate. One Non-Cited Violation of NRC requirements was identified (Section R1.1).

22 4/17/1998 Positivo IR 98010 NRC Plant 5A Audits of the chemistry and RP programs were sufficiently detailed to Support identify deficiencies and areas where improvements could be made.

Corrective actions for the chemistry audit had been effectively implemented. Radiation protection was developing a corrective action plan for the deficiencies identified in the recently completed RP audit (Section R7.1).

23 4/3/1998 Positive IR 98007 NRC Plant 1C The vehicle barrier system and protected area detection aids were Support effective in meeting their designed functions. (Section S2) 24 4/3/1998 Positive IR 98007 NRC Plant 1C Security alarm station activities were conducted in an effective manner.

Support Access functions related to personnel and package control were conducted in accordance with regulatory requirements. (Section S1) 25 4f3/1998 Positive IR 98007 NRC Plant 1C Security and plant personnel demonstrated an effective level of Support awareness and knowledge of security requirements. (Section S4)

Page 4 of 9

"/25/m8 F'LANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Coturnn = "SALP". SALP Area = " Plant Support", Beginning Date = *10/1/1997*

Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 26 4/3/1998 Negative IR 98007 NRC Piant 1C Management controls were not effective on three occasions to ensure Support that licensee corrective actions were properly implemented. On two occasions maintenance management failed to recognize that corrective action was not implemented. On one occasion security management's corrective action was not total!y effective in preventing a similar problem.

(Section S7) 27 4/3/1998 Positive IR 98007 NRC Plant 1C Security procecures and required documentation were well written and Support accurately described the required task or event. (Section S3) 28 3/31/1998 Positive IR 98004 NRC Plant 1C Repair of the Unit 1 reactor water cleanup drain line and disassembly of Support the Unit 1 "A" residual heat removal pump were two maintenance activities performed in higher radiation areas. The use of as low as reasonably achievable initiatives were effective for the residual heat removal pump repairs (Section M1.2).

29 3/31/1998 Positive IR 98004 NBC Plant 2B The Unit 1 scram discharge headers were recently hydrolased to reduce Support dose rates for hydraulic control unit work and to reduce dose rates in the general area (Section R1.2).

30 3/31/1998 Negative IR 98004 NRC Plant 2B The licensee was not aggressive in ensuring that radiation and Support contamination levels did not impact examiners and were kept as low as reasonably achievable in the Unit 1 drywell (Section R1.1).

31 2/5/1998 Weakness IR 98002 NRC Plant 1C Q1P01 outage ALARA plans and radiation work permits were Support comprehensive and observed radiation worker practices wers good.

However, an inconsistency was identified in that ALARA initiatives were not always listed in RWPs.

32 2/5/1998 Positive IR 98002 NRC Plant 2A The licensee was taking good corrective actions to bring the radioactive Support waste systems back to their normal flow paths and to reduce the number of outstanding work requests.

33 2/5/1998 NCV IR 98002 NRC Plant 3A A Non-Cited Violation was identified for allowing materials outside the Support radiologica!!y posted area (RPA) with direct radiation measurements above background levels. The Licensee initiated prompt and extensive corrective actions once the contaminated material was identified outside the RPA.

Page 5 of 9

M/25/1998 PLANT ISSUES MATRIX Quad Citie-s Search Sorted by Date (Descending) and SMM Codes (Ascerdng)- Search Co!umn = *SALP* ; CALP Area =

  • Plant Support *, Beginning Date = *10/1/1997*, Ending Date = *10n/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 34 2/5/1998 Positive IR 98002 NRC Plant 3A The radiological posting of facilities and equipment was good.

Support Radiological housekeeping was good, except in the Laundry-Tool Decon building maintenance shop. Labeling of containers was generally effective, with inspector identified deficiencies promptly corrected by radiation protection personnel.

35 2/5/1998 Positive IR 98002 NRC Plant 3C Radiological controls for tools and equipment used in RPAs were Support generally effective. Routine toci crib and storage area surveys performed by the licensee and independent surveys performed by the inspectors during the inspection confirmed the effectiveness of the radiological controls for tools and equipment. A bar coding system was being developed to improve the accountability and tracking of tools.

36 2/5/1998 VIO/SL-IV IR 98002 NRC Plant 3C One violation was identified for face shields in contaminated areas that Support were not issued by the radiation protection department. In addition, the face shields were left on the floor of contaminated areas, which could lead to the contamination of individuals using those face shields.

37 2/5/1998 Negative IR 98002 NRC Plant 5A The calibration and maintenance program for the portable instruments Support reviewed was sufficiently implemented. Several program weaknesses were identified by the inspectors, including poor response of some instruments at the lower end of their capability and the lack of a dedicated calibration crew.

38 12/20/1997 IR 97026 NRC Plant 3B The inspectors concluded the emergency drill successfully demonstrated Support the licensee's capabilities to implement the emergency plans and procedures. Offsite notifications and activation of the Technical Support Center were within time limits. Control room performance was good.

39 11/7/1997 IR 97925 NRC Plant The respiratory protection program was well implemented, except for the Support storage. of respirators where several full storage bins did not have dividers. Storage in this manner could lead to the deformation of the respirator face pieces and to problems obtaining a proper seal when used (Section R1.3). Inadequate Oversight Page 6 of 9

"/25/t998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALP Area = " Plant Support * ; Beginning Date = *10/1/1997*

Ending Date = *10/1/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 40 11/7/1997 Negative IR 97025 NRC Plant 1C in May 1997, a pressure test of Unit 2 reactor vessel and associated Support piping was performed at 800 pounds per square inch (psi) by pressurizing the system with the control rod drive (CRD) pumps and walking down the dry weil to identify leaks. The inspectors concluded that problems in the planning and conduct of testing resulted in unnecesary dose to workers.

The two re-performances of the test were expected to result in a total dose of about 300 mitirem to personnel. Other/NA 41 11 6/1997 Positive IR 97025 NRC Plant 1C The 1997 station dose was lower than projected largely due to reduced Support scope of work and lack of significant emergent work during the O2R14 refueling outage and to better work planning and execu. ion during the recent 02P01 maintenance outage.

42 11R/1997 Positive IR 97025 NRC Plant 1C The station was effectively planning and coordinating work to reduce be Support source term and, therelcre, the overall station dose. Teamwork / Skill Level 43 11H/1997 Misc IR 97025 NRC Plant 2B Overall housekeeping and posting were good; however, housekeeping in Support the Laundry-Tool-Decon Building mechanical maintenance shop was poor.

44 11H/1997 Positive

!R 97025 NRC Plant 2B Records of spilis and unusual occurrences involving the spread c!

Support radioactive contamination as required by 10 CFR 50 5(g) and station procedures were effectively maintained.

45 11/3/1997 Positive IR 97021 NRC Plant 1C The performance of the fire brigade was good with minor problems. The Support post drill critique was effectively used as a tool to build lessons leamed into the licensee's process. Involved Management 46 11/3/1997 Negative IR 97021 NRC Plant 3C The inspectors concluded that insensitivity to radiological practices Support resulted in a spread of contamination. Personnel Performance Deficiency 47 10/10/1997 Strength IR 97019 NRC Plant 1C Overali, the EP program had been maintained in an effective state of Support operational readiness. Emergency response facilities, equipment, and supplies had been well maintained. Management support to the program was strong and interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. Personnel performance observed during a medical drill was effective and demonstrated good teamwork. Involved Management Page 7 of 9

M/25/1998 PLANT ISSUES MATRIX Quad Cities Search Sorted by Data (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = " Plant Support", Beginning Date = "10/1/1997*

Ending Date = "1c/1/1998" DATE TYPE SOURCE ID BY SALP SMM CODES !

DESCRIPTION 48 10/6/1997 Strength IR 97020 NRC Plant 1A Secunty performance was effective. Security force members Support demonstrated a strong working knowledge and implementation of security requirements. Security equipment performance was acceptable.

Security manager's support and actions to address and resolve security-related problems were timely and effective. Involved Management 49 10/6/1997 Strength IR 97020 NRC Plant 1C The establishment and implementation of a program to reduce security Support force personnel errors was a strength. Errors related to secunty force performance have been reduced. Involved Management 50 10/6/1997 Negative IR 97020 NRC Plant 1C Maintenance activities relating to the repair and oversight of those repair Support activities for security camera wiper problems were neither effective nor teidy. Those deficiencies required the implementation of security compensatory measures to maintain surveillance program requirements. Inadequate Oversight 51 10/6/1997 Negative IR 97020 NRC Plant 2A The failure of an active security vehicle barrier to operate demonstrated Support an inadequacy in your security preventative maintenance program. The significance of the barrier's failure was that vehicle traffic to the protected area was impeded during that time period. Inadequate Oversight Page 8 of 9

11/25/1998 l

GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC intemal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

l SOURCE The document that contains the issue information: IR for NRC Inspection Report or LER for Licensee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and A!!iMultiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

L TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements Eels are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal eel

  • Escalated Enforcement issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients LER License Event Report to the NRC with the " General Statement of Policy arid C - Programs and Processes Procedure for NRC Enforcement Action, Ucensing Licensing issue from NRR (Enforcement Policy). NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding. etc.)

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Negative Indrvidual Poor Licensee Performance identified by the Eels and the PIM entries 3

Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strength Overall Strong Licensee Performance are m de. Before the NRC makes its B - Knowledge, Skills, and Abilities enforcement decision, the licensee will be C - Work Environment URI*3 Unresolved Inspection item provided with an opportunity to either VIO/SL-l Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering / Design:

VIO/SL-II Notice of Violation - Severity Level 11 (2) request a predecisional enforcement A - Design VIO/SL-ill Notice of Violation - Severity Level Ill conference.

B - Engineering Support VIO!SL-IV Notice of Violation - Severity Level IV

    • URis are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance 5

Pro mi tification and Resolution:

h e e in e s

acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - AnaW.s the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identification by an event (e.g., equipment breakdown) conclusions are made.

Other identfication unknown Page 9 of 9

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