ML20205E284
| ML20205E284 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/17/1988 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 5189K, EA-88-161, NUDOCS 8810270347 | |
| Download: ML20205E284 (40) | |
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October 17, 1988 I
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Mr. Jeunes cLloberman, Director
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Offles of Enforcement,
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U.S. Nuclear, Regulatory Conenission.,
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Subject Quad Cities Station Units 1 and,2 l
"Response to Notice of Violation (NOV) j Associated with Inspection Report
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Nos. 50-254/48011 and 50-265/88012
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Enforcement Action EA-48-161" i
HEC._DositLNoa. 50-254 an s(L-211_
Reference (a): Letter from A.B. Davis to J.J. O'Connor dated September 15, 1988
Dear Mt. Lieberman:
This is conononwealth Edison Company's (Edison) response tc che Nuclear Regulatory Comunission's (NRC or Commission) Notice of Violation (NOV) and proposed imposition of Civil penalty for certain events involving the maintenance and modirication of electrical equipment at Edison's Quad Citles Nuclear power plant. Even though tSese e*?ents occurred some time ago, Edison recognises that they are properly matters of concern.
Indeed, as you noted, i
well before the NRC inspection which led to this NOV, Edison had recognised the need to upgrade its maintenance and modification programs, including the j
maintenance and modification of 91ectrical equipment.
Edison has acted on these needs by implementing broad, comprehensive prograves to upgrade mainton-ance and modification procedures at all of its nuclear plants, including Quad Cities. Some elements of that program are discussed below as they apply to the particular items in the NOV.
In addition, a comprehensive overview of the entire program to improve maintenance is provided in an attachment.
A review of the progress made by this program to upgrade maintenance at Quad Cities shows that the station has improved its maintenance practices significantly and is continuing to improve maintenance at an accelerated pace.
Unfortunately, the demonstrable progress that has occurred was not easily y(
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J. Lieberman October l's, 1988 discernible at the time of the inspection that resulted in the items of noncompliance addressed here. An attempt has bsen made to describe our improvement initletiveness in this area.
Edison has also described the tinhancements made at Quad Cities to improve its performance of root cause analyses.
Sta ting in March of 1987, l
before the HRC conducted the inspection underlying this NOV, Quad Citles began to provide Management Oversite Risk Tree Analysis (MORT) training for cognisant personnel. This training has now substantially improved Quad Cities j
performance in this area.
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Edison has enclosed a check for $75,000 as payment of Violation I.A concerning an undetected hard 1round in the DC system.
I In view of the escalated penalty for Violation I.A.,
however, Edison requests that you reconsider the penalty for Violation I.B.
A separate, full penalty for Violation I.D, failure to analyse D.C. grounds under 10 CFR 50.59, partially duplicates the escainted penalty for Violatisn I.A.
This is because the continued opetation with D.C. grounds masked the presence of the hard ground, t'.as contributing to the length of time that it went undetected.
Therefore, the failure to recognise the circumstances which led to the event underlying violation I.A. was inextricably intertwined with the station's practice with respect to operating with grounds in the D.C. system in general, i
It was not clent to the station that 10 CFR 50.59 had ever been interpreted to require a formal review for unintended, self-initiated events which eventually would be rectified as compared with a modification to the plant. Consequently, the basis for escalating the penalty for Violation I.A rests in substantia) measure on the same underlying basis for imposing a full penalty at Severity l
Level !!! for Violation I.B.
For this reason, Edison requests the Commission f
l to esercise its discretion to reconsider the imposition of a full Severity l
Level !!! penalty for Violation I.B.
Edison's reply to the various violations is attached.
The reply acknowledges that improvements in maintenance were needed and describes how 1
those improvementes
(*) had been initiated before the inspection which t
revealed these violations; and (2) are continuing to upgrade maintenance at Quad Cities.
Edison believes that progress in improving maintenan7e at Quad Cities supports the NRC's esercise of discretion to reccasider the civil penalty imposed for Violation I.B.
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e J. Lieberman
-3 October 17, 1988 If you have further questions ^regarding this matter, please direct them to this office.
4 Very truly yours, t
L. O. De10eorge l
Assistant Vice Presi nt I
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i Attachments At Reply to a Notice of Violation 8: Answer to a Notice of Violation C: Applicability of Mitigation to Violation 1.B.
Di Reply to Notice of Violation for Violations Not Assessed a Civil Penalty El Overview of Commonwealth Edison Maintenance Program at Quad Cities Station
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Enclosures Remittance for Quad Cities 875,000 civil Penalty l
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cet Quad Cities Resident Inspector T. Moss - MRR j
A.B. Davis - NRC Region !!!, Administrator l
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s "ATTAC) MENT _A" CCttiONMEALTILIDlSQtL.CCtiPANI BEPLY_T0Jf0TICLOLJIOLATION As a result of the inspection conducted on April 18-22, May 2-6, 11, 31, and June 1, 1988, the following violations were identified:
Violations _ Assessed _a_CLv11_Fenaltyi A.
Quad Cities Technical Specification 3.9.E.1 requires in part that whenever the reactor is in Startup/ Hot Standby or Run Mode and the unit or shared diesel generators and/or their respective associated buses are made oc found inoperable escept as provided for in 3.9.E.2 (performance of maintenance), operability shall be restored within seven days or the reactor shall be placed in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
"ontrary to the above, from approximately July 11, 1986, to January 3, 1987, Quad Cities Unit 2 continued in operatloc with the 1/2 r,mergency Diesel Generator (EDG) being inoperable for a reason other than maintenance. The 1/2 EDG was incapable of automatically performing its intended safety function for Unit 2 due to an undetected failure (blown control power fuse) in the circaltry of the automatic start relay (ASR).
l This is a Severity L.evel !!! violation (Civil Penalty - 875,000).
i DISCVSSI0ti Quad Cities' investigation and review of this event showed that it was related to the unintentional installation of a hard ground during a fire protection modification on the 1/2 diesel generator. After installation, 1
the hard ground was nasked from discovery due to the presence of other j
grounds of the type ivhich, under industry practice, had not been considered necessary to remove as a condition for continued operation.
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However, the hard ground might have been discovered had the unexpected action by a non-safety related relay teen investigated as part of the post-modification test, but such testing was not required under the old I
modification program which was in place when the modification was completed.
S.>metime after the hard ground had been installed, a control power fuse blew in the circuitry for the autematic start relay. The blown fuse could not be revealed by the successful monthly manual start j
surveillances of this circuit, but was sevealed by the automatic start l
surveillance. This event may have been avoided had the post-modification testing procedures now in effect been followed. Nevertheless, this event also has led to the institution of a new, more aggressive polley for the ta eatment of DC grounds. That new aggressive policy is described below.
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- I ADMISSIDLOE_Y10LAT101:
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Quad Cities Station acknowledges that the 1/2 Emergency Diesel Generator
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was incapable of performing its intended safety function for Unit Two due to an undetected failure in the automatic start circuitry and therefore,
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1 admits the violation.
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REA&QtE_f_Dit Tur VIQ1.ATIDLIF. ADNITIEQt
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l-This violation occurred due to a design error in the electrical print used for the installation of the fire protection modification. Modification j
M4 1/2-84-12 required the use of a spare terminal point in the cubicle and
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1 had incorrectly designated a terminal point which was already in use as a i
ground point on the current transformers for the monitoring circuitry on
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the bus.
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Y The inadequacy of the old modification process contributed to this event
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j by not emphasising the need to investigate all unespected results of post-
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i CORRECT IVE_STE l' S_7 HAT _HAYZ_BE EILIAK EtLAN D_.IHE_RISV LTS_ACHI EYED :
Upon failure of the autostart circuitry in January 1987, the Station
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corrected the wiring configuration to eliminate the ground. The
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auto-start circuits for the Unit One and Unit Tw-Diesel Generator and 1/2 Diesel Generatnr to Unit 1 were also checked for similar problems ned none l
were found. This checking of identical equipment in the sister unit and
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of comparable equipment in both units is indicative of Quad Cities more aggressive approach to investigating the root cause of unespected i
occurrences. More generally, a new modification program has been in place i
since April 1987. The new progr6m requires field walkdowns both before i
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and after lueta11ation of a modification. This process is espected to
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j enhance the station's ability to identify r.nd correct discrepancies la modifications prior to release for operation.
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Other improvements and additional s.spects of the new modification program j
that have been Instituted includet 1
j Adoption of a Substation Construction Department procedure which i
i requires that a Quality Control inspector inspect drawing
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revisions. This will ensure that the most recent drawing j
revision la utillsed when modifications are being installed.
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Broadened consideration of the impacts of each Safety Related f
modification by requiring the Corporate Boiling Water Reactor Engineering Department (BNRED) to review the pending and related I
notifications which cither could be affected by the proposed l
modification or could affect that modification.
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. Enhancement of Safety Related modification approval letters to specify modification test acceptance criteria. Honconforming test results require BWRED approval.
Additional design controls have also been instituted. These include 1) a Substation Construction practice (implemented in January 1987) that requires a Work Coordinator to verify that the Quality Control inspection was performed to the latest drawings and 2) new design document control procedures which were implemented in April 1988.
CORRECT 1YLSTEFSJll1CILMILLBLTAKEM_IQ_EREVINT_EllTHER YlOLATICHS:
A special Modification Task Force review was convened to evaluate this event to determine it there were any lessons to be learned from it.
After two meetings, the Task Force concluded that this event would have a low probability of occurrence if the modification had been done completely under the new modification process. Nevertheless, the Task Force recommended thit the opt 19nal desagner walkdown for electrical cable examinations and panel or cabinet airing be made mandatory as a result of this event.
D ATLMilEtLIU L LCCHPLI AN CLMI LLB E_ ACli! EY E D rull compliance will be achieved upon formal adoption of the Task Force recommendation. Such adoption is expected by November 30, 1988.
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"ATTACIMDrLB" CCHHotiMIALTILIRISQtLCCHEAtIUS AF. SNEE_TO. A_ NOTICE._Or_Y10L AIICti e
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V10LAT10t(S.ASSESSER i.CIVlL_FINALTLICE).
B.
10 CFR 50.59(b)(1) requires that the licensee maintain recorda of changes in the facility, to the estent that the changes constitute changes in the faellity as described in the Safety Analysis Report.
Thoso records must include a written safety evaluation which provides the bases for determining that the change does not involve an unreviewe6 safety question.
A proposed change involves an onreviewed safety question if the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report may be increased.
Final Safety Analysis Report Section 8.2.3.2.2 states, "The 125 volt battery system operates ungrounded with a ground detector alarm set to annunciate the first ground.
In addition, the ground fault resistance, and the time at which a ground fault occurs, is recorded by a recording voltmeter. Thus, multiple grounds, the only reasonable mode failure, are extremely unlikely."
Contrary to the above, at the time of the inspection the licensee did not have a written safety evaluation for operating the ungrounded ESS DIV 1 125 volt battery system from Februany 1986 until July 1986 with reveral grounds, constituting a change ir. the facility as described in the safety analysis report.
This change involves an unreviewed tinfety question because It increases the probability of occurrence of u malfunction caused by the ESS DIV 1 125 volt battery system.
This is a Severity Level III violation (c
'l Penalty - 850,000).
i DISCUSSIOtt:
Quad Cities evaluated the safety significance of operating with substantial grounds in the DC system but had not formally processed that evaluation in accordance with 10 CFR 50.59.
After each substantial DC ground was located, its implications for safety were considered at the Plan of the Day meeting and a decision was made on whether the plant could continue to ope ate safely. These evaluations and determinations were not formally documented.
i Since this event, Ceco has instituted a generle polley for dealing with grounds. Three categories of grounds have been established and appropriate actions for grounds in each category have been specified.
This policy is based on an empert engineering analysis.
This analysis establishes the levels of stations' response appropriate for the various categories of grounds.
2-In audition, Quad Cities has adopted a more aggressive program for focuslag management attention on safety issues.
That program is set out in the "Quad Cities Station Plant Focusing on Safety Issues." The herdt of the plan le the requirement to prepare a documented safety evaluatico for legitimate issues sffecting the safe operation of the plant.
These evaluations w!11 be prepared for all off-normal operating conditions and wl41 be logged and tracked through to resolution.
An evaluntion of an salsting abnormal operating condition will be a Justification for cooF!rned Operation (JCO).
An evaluation performed in anticipation of an abocra C operating condition will include a screening process to da termine whethe*
a review under 10 CFR 50.59 will be necessary. Thus, the program else includes a heightened sensitivity to the need to perform evaltmtloca "ader 10 CFR 50.59.
It also includes a more rigorous approach to 50,t9
_l evaluations.
In this case, running the plant with grounds masked the ground whic aal been inadvertently hard-wired into the ungrounded DC system.
1he t/ for Violation I.A was escalated because the situation went undetected for a substantial period. This failure to detect was due to the masking of the I
hard g';ound by the other grounds. Therefore, a full CP here duplicates the reasons for escalating the CP for Violation I. A.
Accordingly, Edison requests that the NRC exercise its discretion and reconsider this CP.
ALHISSILtL0f_ VIOLATION:
Quad Cit ies acknowledges that no formal evaluation of continued operation with grounds in the De system was performed pursuant to 10 CFR 50.59.
REASWS_fDILT11LV10LATILtLAND_DISCUSSILtLDE IKTENUATUM_CIRCUMSIMiCES:
Quad Cities evaluated the safety significance of DC grounds but did not i
formally document those evaluations pursuant to 10 CFR 50.59.
Quad Cities believed that such formal documentation was not intended to be required by 10 CFR 50.59 for transient events which occurred unintentionally.
As has been previously indicated, the esistence of a hard ground, which should have been evaluated as a modification to the plant, was not detected.
CORRECT 1YC_STEFS_T11AT 11AVLDEDLIAEDLANILRESVLTS._AC111EYID Quad C! Lies has adopted an interim generic policy for dealing promptly with DC grounds in accordance with their safety significance. That policy establishes the following actions for various classes of DC grounds grounds below 72 volts DC will be citared in the usual course of operations
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grounds between 72 volta DC and 115 volts DC will be searched for immediately. Once lechted, follow-up clearance will be tracked at the morning Plan of the Day Meeting.
grounds above 115 volts will at irt a 14 day clock for location and either removal or justification of continued operation (JCO) for grounds which are located and may be isolated temporarily, operatlou may continue under a JCO provided that the station conducts a weekly surveillance for new grounds by isolating the located ground for grounds which cannot be located, operation may continue under a JC0 provided that corporate management is notified.
(contacting corporate management provides a corporate review and ensures corporate consistency in implementing this 9:ounds policy)
In addition, operators have been trained on the new interim ground policy and the development of a formal corporate policy on DC grounds has been initiated.
More generally, Quad Cities has instituted a plan designed to enhance the focusing of management attention on safety issues. This plan includes enhanced application of the role of formally documented reviews under 10 CFR 50.59.
CORRECTIVE _ STEPS IllAT_HILtJLIAKEILTQ. AVOID _EURTiiER_Y10LATIfXiS t Corporate policy appil:able to all CECO stations on DC grounds will be established by January 1, 1989 All operators will be trained on the new corporate policy on DC groun0s.
DATE_MR.W1CILTULL CCtiPLI ANCE_NILLBE. ACillEVED:
The station will be in full compliance by January 31, 1989, the date by which training on the Corporate Policy on DC grounds will be implemeated at all Commonwealth Edison Stations.
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"AITACIMDtTJ:"
AEPLIfABILITLQf_MLI1GATICtLIQ V10LAT10H_143 Commonwealth Edison believes that there is an adequate basis for mitigating the proposed $30,000 Civil penalty related to Violation I.B in the Notice of Violation (NOV). The five factors in Section V.B of 10 CTR Part 2.
Appendix C are addressed below.
l PROMPT IDCHTII.1EATICtLAHk_RErQRTING:
Although a base penalty may be reduced by 50% af the licensee promptly identifies and reports a violation to the NRC, Commonwealth Ellson is not seeking mitigation on the civil penalty under this factor.
Quad Cities neither identified nor reported a violation of 10 CTR 50.59 because it believed that its process for evaluating plant operation with grounds was appropriate under the circumstances. Quad Cities did informally l
analyse operation with grounds in the 125 v DC system and, based on this i
l analysis, concluded that operating with these grounds was justifiable.
The station did not recognise that a formal, writtsu evaluation was required as their intention was to ultimately identify the source of the grounds and to restore conditions to those described in the TSAR, Thus, because the station did not intend that operating with these particular grounds would be a permanent modification to the fac!11ty, the station did not believe that a j
written safety evaluation was requitad.
Accordingly, the station did not i
realise that operating without a wa ltten safety evaluation would consti*,ute a l
reportable event.
CORRECTIVE _ACTICtiS t Unusually prompt and extensive corrective actions, including actions to prevent recurrence, support the reduction of a civil penalty by as avch as 50%.
Commorvealth Edison's actions taken in response to item I.B were estensive, comprehencive and entended far beyond the narrow confines of having a written safety evaluation for operating with particular grounds.
Edison hac instituted a new policy of classifying and responding to grounds.
This policy is based on an esport engineeting analysis. Thus. Edison's corrective actions go far beyond this specific situation to ensure that grounds will be dealt with appropriately in the future.
1 Given the nature of this violation and the extenuating circumstances 1
l regarding it, the corrective actions (i.e.. Quad Cities Station Plan for Tocusing on Safety Issues) were taken as promptly as possible, consistent with the nature of these actions and full credit should be given for P,h.s timeliness.
As a result, the penk1ty should be reduced by the f ull 50%.
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r 2-PASI_EERTORMANCE Commonwealth Edison recognises that a civil penalty may be reduced by up to 100% of the base amount for good prior performance.
Edison acknowledges that as a matter of practice, we did not perform written evaluations for operating with grounds on a system.
However, our past performance involving safety evaluations has been good. A review of l
violations identified by the NRC for a three year period has not shown any j
past violations for not performing adequate evaluations. As a result, we i
believe Quad Cit 10s' prior performance in this area warrants full mitigation.
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PRICP._ NOTICE Because Commonwealth Edison has operated systems with grounds in the i
i past, and believes this to be a common practice within the nucleer industry, l
we were unaware of the need to review transient graunds as an unreviewed i
safety questions under 50.59.
Because of our belief and since no other i
notifications vere provided by other agencies of the unacceptability of thit
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practice, the element of escalation on the basis of prior notice ir. not i
applicable in this instance.
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HULTIFLILOCCURRENCES i
The baJe civil peralty may be increased ad much as 50% where multiple J
examples of a particular violation are ident!Eled during the inspection period.
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evaluation for operating with grounds, therefore, as discussed earlier, we were unaware that a violation was occurring. Once we became aware of the need to perform safety evaluations for operating with grounds, we revised our practices. Therefore, although there have been separate incidents, where Quad Cities has operated with grounds without a written evaluation, any separate
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incidents should be classified as one violation and not be considered multiple occurrences for penalty determination.
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AITACIMDfI_D REI1 LIQ _ NOTICE OF VIQLAILQH EDE Yl0Mn0HSJIQI_ ASSESSED A CIVIL PENALTY II. A.
10 CFR Part 50, Appendix D, Criterlon III, Design Control, requires that measures be established to assure that appliaable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, as of June 1, 1988, the licensee's design control program did not assure that the design basis was correctly translated into drawings.
For example:
1.
The "Diesel Emergency Auto Start Edlay" circuit shown on drawing No. 4E-1350B, Revision AC, was also rhown on drewing No.
4E-1656H, Revision J.
However, the test switch was omitted from the circuit on drawing No. 4E-1656H, while the relay designations for ASR-1 relay and the switchgear cubicle number for 127B13-1X3 (3-4) relay contact were not shown on drawing No. 4E-1350B.
2.
Discrepancies were identified in the electrical design drawings associated with Units 1 and 1, 125 Vdc ground detection system -
Drawing No. 4E-1685B, Revision Y and No. 4E-2685B, Revision S, did not represent the ground detection circuitry as it was installed in the field.
In addition, S/D 4E-2575S, Revision S, Annunciator Window No. 54, "125V Battery Ground" circuitry did not show the negative ground contact (11-12) in the alarm circuit.
This is a Severity Level IV violation.
(Note: The correct identification of the discrepant drawings by the NRC is as stated above; the drawing numbers listed in the NOV by the NRC in two instances were incorrect)
DISCUSSION:
Ceco is aware that some electrical drawings, especially for older plants, contain minor inconsistenclos or deviations from ar-built configurations.
Ceco shares the NRC's ccncern that drawings involving safety significant equipment should be accurate. Therefore, although drawing errors often are minor in nature, Ceco recognizes the need to look further into the accuiacy of drawings. To conduct the review of this issue, CECO has convened a task force of knowledgeable personnel from the stations, engineering and production services.
This task force will develop a plan for addressing the issue of drawing accuracy.
. CECO believes that this approach is appropriate for several reasons. The older plants have been operating safely for several years and are subjected to extensive surveillance programs. Moreover, the new modification program, as was demonstrated recently, has been effective in identifying drawing errors. These circumstances support CECO's systematic approach to determining what additional steps to take on drawing accuracy.
ADNISSIOtLOT VIOLAII0ti Quad Cities acknowledges that some drawings are inconsistent or inaccurate.
BEAS0 tis _E0lLYl0LAT10ti Quad Cities believes that drawing inaccuracles in some cases resulted from an inadequate implementation of drawing control programs in effect under the old modification program.
CORR E CTLYE_S TIES._TH AT_ll AVE _D E EILTAKEILAll D_.Ill E_RE SU LIS_ACliLEYE D :
The identified discrepant drawings are in the process of being corrected.
CO R R E.CT I V E_ S T E PS_TilAT_H IL L_D E_TA KELLTD_AE0lD_EllRTilE ILYlOL ATIDtiS As discussed above, CECO recognizes that the issue of drawing accuracy is broader than just the discrepancies in the two drawings which are the subject of this violation. Therefore, CECO has convened the task force described above to formulate a plan for dealing with the accuracy of drawings.
In the interim, Ceco believes that the history of plant operation, ongoing surveillances and the new procedures implementing the new modification program support the determination that this approach to the matter is appropriate.
DATE_ HH EtL EULL_COM ELI A!1C E_M I LL_DILAClll EY ED :
The discrepant drawings identified by the NRC ur. der this inspection will be corrected by November 15, 1988.
The drawing tank force expects that an action plan will be agreed to by all of CECO's stations by May 31, 1989.
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II.B.
10 CFR Part to, Appendix B, Criterion V, Instruction, Procedures, and Drawings, requires that activities affecting quality be prescribed by documented instruction, procedure, or drawings of a type appropriate to the circumstances, and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of June-1, 1988, certain activities affecting quality were either not prescribed or were not carried out in accordance with documented instructions or procedures of a type appropriate to the circumstances, in that:
1.
The licensee did not have a procedure for or accomplish the lubrication of bearings and performance of certain other specified preventive maintenance activities on Limitorquo motor operated valve (MOV) actuators at la or 36 month intervals, although such activities were activities affecting quality, were appropriate to the circumstances, and were recommended in the vendor manual.
2.
The licensee falled to perform preventive maintenance on 47 of 93 horizontal 4.16 kV electrical circuit breakers at the required interval, as required by procedure QEPM 200-1, "Inspection and Maintenance of 4.16 kV Horizontal Circuit Breakers", Revision 1.
This a Severity Level IV violation.
l II.B.1 PFmlliLTDRQUILAC211ATORS DISCUSS 10tl Edison recognized that previous maintenance on motor operated valves, 4
including Limitorques, had not been comprehensive and well-documented.
Therefore,. starting in 1984, Edison initiated Interim measures to inspect end refurbish these valves to ensure their continued availability. These measures were restructured into a two phase program in 1986.
Phase I involves inspection and lubrication of valve stem and stem nut, and the inspection of grense for quantity and Adontity.
Phaso I also includes environmental qualification surveillances and the documenting of inspections.
Phase I also includes the repair and overhaul of all MOVs that fall inspection.
Phase I inspections were scheduled to be performed on half of all MOVs on a Unit per refuel outage and are due to be complete by the en1 of the next Unit 1 refuel outage. The overall program will continue until Phase II of the upgraded maintenance program becomes fully operational.
Phase II will involve the integration of the results of I
recently upgraded maintenance procedures, diagnostic testing, periodic inspections, and training into a comprehensive maintenance progras.
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CECO acknowledges that certain preventive maintenance activities have not been performed at the vendor recommended Intervals on Limitorque motor operated valve actuators.
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REAS0t(S FOR_TiiE..VIOLAIlott The concern' raised by the NRC inspection team was that the thrust bearing on the Limitorque SMB-4 was not greased per the vendor recommended interval. The "Add-on" thrust bearing housing is not part of the standard SMB MOV.
As such, this assembly is'not included in the lubrication recommendations made by the. vendor manual (SMB-I-182).
The close tolerances of the thrust assembly prevent addition of grease without forcing lubrication past the seals (and outside the housing). Due to the low RPM sustained by the thrust bearing, relatively little lubrication is required. The design tolerances prevent no more than a ght flim of grease to be present in the preloaded assembly. Nevertheless, Quad Cities prior approach to preventive maintenance did not follow any vendor recommended intervals. The maintenance activity observed by the inspector which resulted in this violation was the first time inspection activity for inclusion of this valve into Phase I of the program described above which was initiated in 1986. The Quad Cities Maintenance Department did not routinely grease limitorque actuators during the Phase I program described above as the type of grease in the sctuator was i
unknown.
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CORRECILVE_SIEPS TIIAI IIAYE_BEEH_TAKEILAND_ RESEIS_AC111EVED:
As was stated previously, Quad Cities started in 1984 to overhaul and refurbish MOVs and bring them to an improved condition. The current results of this program are as follows:
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Approximately 80% of the inspections are complete with 75 of 92 i
Safety-Related HOVs overhauled and 42 of 154 balance of plant l
MOVs overhauled.
l Unit 2 100% of the laispections are complete with $2 of 86 Safety-Related MOVs overhauled and 52 of 149 balance of plant MOVs overhauled.
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t-r CORRECTIVE STEPS THAT_)iR L_DE TAKEN TO AVOID FURTHER VIOLATIgiS The Phase II MOV maintenance program discussed earlier will Identify prevent 1ve maintenance activities and frequencies based on an evaluation for each valve. This evaluation will consider such items, as vendor recommendations, actuator orientation, environment, usage factor, and importance to operation. The resultant prescribed tasks will be tracked by the company General Surveillance Computer Program.
DATE_NHEN FULL _COMPLINiCLif1LL_RK_ACUIZYEQ P
P Implementation of the Phase II program is anticipated to begin with
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the next refuel outage on the Unit 2 currently scheduled for December 1989.
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, II.B.2 AEY_RREAKEES DISCUSSION:
Prior to 1985, Quad Cities had no formal, documented maintenance program for 4.16 kV electrical circuit breakers. Nevertheless, some preventive maintenance has been documented for these breakers during this period.
In 1985, Quad Cities adopted a preventive maintenance procedure for these breakers. That procedure (currently QEPM 200-1, Rev. 1.) called for 1.sriodic maintenance every three years. That maintenance was not performed completely for the reasons described below.
However, the failure rate of these breakers at Quad Cities did not exceed the industry average failure rate as reported using NPRDS.
Quad Cities now recognizes the need to implement fully all preventive maintenance procedures. To accomplish this, Quad Cities Maintenance Department began the comprehensive implementation on a tracking system called General Surveillance Program (GSRV) in early 1988. The details of this program are also described below.
GSRV will track preventive maintenance for 4.16kV breakers.
In the interim, until GSRV is fully implemented and the preventive maintenance program is on schedule, Quad Cities has initiaF.d certain specific preventive maintenance activities to ensure continued safe plant operation. These interim measures also are described below.
ADiiISS101 Lor _Yl0LAIL0tO Quad Cities acknowledges that preventive maintenance was not performed at the intorvals specified by procedures.
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REAS0 tis _E0lLVl0LATIOti l
Several circumstances contributed to an incomplete performance of the maintenances required by QEPM 200-1, Rev. 1.
Maintenance of these breakers during operation requires the availability l
of spare, replacement breakers.
Spares are limited because these breakers l
are no longer manufactured. Only four spare breakers are available on site.
Even these few are not always available because they, too, must be i
repaired occasionally. These conditions severely limited the extent to which preventive nalntenance could be performed during operation.
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Maintenance of these brea~xers during refueling was limited by the lengths 4
1 of those outages. Moreover, some brenhers required substantial maintenance periods because they had to be shipped off-site to the manufacturer for more extensive overhauls than possible in the fleid.
5
, COREZCTIVE STEPS TAKEN AND REEllLIS ACli1XyJQs Quad Cities is currently in the process.of implementing a computerised prcYontive maintenance program that will eventually include all preventive maintenances involving fixed maintenance periods. That program, called GSRV, will list each breaker by serial number so that timely maintenance will be performed on each breaker no matter how many times it changes location in the plant. GSRV will be used to generate a preventive maintenance schedule which will be updated on a regular basis. Thir will provide the station adequate time to plan for upcoming maintenances.
All 4.16 kV breakers are tracked by serial number, but all maintenances required by QEPM 200-1, Rev. I have not yet been completed. To lucrease the plant's capability to perform maintenance on the breakers while the plant is operating, G.E.
Is searching for additional spare breakers.
If no new spares are discovered, the maintenance program may not be current until the end of the upcoming refueling outage for each unit. However, if G.E.
la successful in its search for additional spares, and operating conditions permit, maintenance could be performed on an accelerated basis.
In the Interim, Quad Cities has prioritized preventive maintenance for the horisontal 4.16 kV breakers based on the importance of those breakers to i
plant operation.
Sixteen breakers, eight per unit, have been identified as critical for operatico.
All eight Unit 2 breakers received preventive maintennnce during plant shutdown.
Five of the eight Unit 1 breakers have received maintenance. The other three are tested on monthly surveillances and preventive maintenance will be performed during the next refueling outage.
Of the remaining 71 breakers not considered critical to safe operation, 31 have had preventive maintenance in the last three years. Preventive maintenance for the rest will be completed as permitted by the availabi-i
!!ty of spares but no later than the end of the next refueling outage for each unit.
Quad Cities is also addressing incomplete preventive maintenance for other i
equipment. Anything identified in this review as requiring additional preventive maintenance will be included into the on-going GSRV Program.
i CO R RECTIV E_ STEPS _T0_D E_TA KEILIQ_ AVOID _G PIHER_Y10L ATI 0tLL0lLITEMSlL B il l
ANk_IL B.2 i
Quad Cities intends to use GSRV to track all equipment requiring periodic preventive maintenance. Quad Cities will review maintenance records to i
determine the extent to which maintenance has not been accomplished and I
will use safety considerations to prioritise maintenance to be l
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accomplished in the interlm.
l DATE_MHEILG LLCOH111 ANCZ_tf1LLB E_ACHIIYZD_E0E_LTEHLILALAND_I L Ri2 The appropriate preventive maintenance will be completed on each unit by the end oC their next refueling outage, currently scheduled for completion i
in September 1989 for Unit 1 and March 1990 for Unit 2.
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II.C.
10 CFR Part 50, Appendix B, Criterion XVI, requires measures to be established to assure that conditions adverse to quality and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause'of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the following conditions adverse to quality were either not promptly identified or promptly corrected 1.
On November 8, 1986, the 1/2 Emergency Diesel / Generator was manually started and connected to Bus 13-1 to provide power to Unit 1 during modification work in the electrical switchyard.
The 1/2 Emergency Diesel / Generator feed breaker to Bus 13-1 subsequently tripped due to activation of the underencitation relay. The licensee'c corrective action included modification of the auto-start circuits however, such corrective action did not
~
correct the problem of activation of the underencitation relay when manually starting the 1/2 Emergency Diesel / Generator.
2.
During a monthly surveillance test on October 5, 1987, 4.16 kV breaker 152-2329, which connects the 1/2 Emergency Diesel / Generator with Bus 23-1, failed to close.
Corrective 1
action included cleaning and lubricating the trip latch rollers of breaker 152-2329 in accordance with an electrical preventive maintenance procedures however, as of June 1, 1988, the licensee had not implemented corrective action to prevent recurrence in i
that neither inspections nor preventive maintenance had been performed on the identical Unit 1 Emergency Diesel / Generator 4.16 j
kV breaker latch mechanism.
3.
In 1980, tho licensee identified recurring problems with binding of auxillary contacts in 480 volt motor control centers; however, corrective action was not effected untli July 1987.
l 4.
In 1984, parallel isolation valves were replaced in Units 1 and l
2.
Due to operating problems, it was determined later in 1984 l
j that a Unit 1 isolation valve was incorrectly installed and l
unable to isolate the condenser vacuum pump to prevent offgas I
radiation releases during reactor startup. Adequate corrective action was taken for Unit '.; however, a similar problem on Unit 2
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j was not identifled and corrected until May 1988.
j This is a Severity Level IV violation.
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.- DISCUSS 10H r
These events stemmed from a.'.ack of appreciation of the need to take broad ranging actior.s in response to specific events.
Since then, Qvad Cities has adopted a more vigorous approach to identifying the root causes of events and to cont,ldering their broader implications.
For example, Quad Cities' ability to ' identify effective corrective actions has been enhanced I
l by training station personnel in the MORT which is a process used to find the root cause of events. Moreover, Quad Cities has modified its processes fos DVRs and LERs to formally incorporate the 'need to consider the effects Of an event on Jdentical equipment on the other unit and on sjmilar equipment on both units. Quad Cities also is developing a progrnm for analyzing recurring mainter.ance problems and for sharing the results of that analysis with other plants which have similar equipment.
Other, more general enhancements of maintenance will also adiress concerns regarding the prompt identification and correction of maintenance related problems. These include:
The establishment of formal guidance for malntenance by the development of a comprehensive Corporate Directive on "Conduct of Maintenance."
Assignment of additional maintenance work analysts and maintenance supervisor administrators to each of the maintenance departirents.
ADMLSS LON_QE_Yl0LATLQH:
l Quad Cities Station acknowledges that the above conditions were not promptly Identified or promptly corrected.
REASONSJ RR_TilG_Yl0LATION:
The above conditions were not promptly identified or promptly corrected due to inadequate root cause analysis.
t CORRECTIVE _STEESJIIALilAVE_BEEN IAKEILNfDJ11EJESULTSJCHIEYED:
i 1.
Edison helleves that the incomplete corrective action, which did not
't fully uddress activation of the under excitatfor. relay, was an isolated event which is unlikely to recur. This belief is based on 4
the continulng review of LERs and DVRs by CECO's Huclear Safety Department. That review does not show the kind of event recurrence that would be expected if corrective actions were inadequate.
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~i Moreover, the problem identified-in ItemtII.C.1-turned;out to be quite i
difficult to resolve;and Is st1111being studied.
A' modification is
-being developed that will eliminate.the problem of activation of the underencitation. relay when manually starting the 1/2 Emergency Diesel-Generator. As an interim measure,. station procedures have been revised to ensure that if the EDG falls to auto-start the ED3'is not manually started..Instead, the EDG auto-start relay is manipulated locally to start the EDG.
This ensures the underencitation relay does not cause.the.EDG to tripiduring an emergoney manual ctart. The
' interim station procedures ensure continued (>ofe EDG operation while
.I the modification is being pursued.
2.
The event in Item II.C.2 did not result from a failure to take such a broad view but, rather, from the limitations which affected the
~
breaker lubrication schedule discussed above with~the respect to Item II.B.2.
However, Quad Cities has increased its awarenass of the need to consider the broader Impilcations of an event as it mar affect l
identical equipment on the other unit or similar equlpme', on both units. This increased awareness has been formally incorporate 1 in station procedures by changes in the processing of DVRs and LERs.
3.
CECO is aware of the need for the free flow of Information between similar stations like cresden and Quad Cities. However, because the f
volume of information genarated at each station is so great'. the transfer of a specific piece of information often needs a triggering l
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event.
For example, in this case, the informal instruction provided to Dresden in 1984 was not transferred to Quad Cities because the 1
station was not experiencing the same problem at the time, although Dresden had experienced the binding of auxillary contacts since 1980.
In 1984, the failure rate for these contacts at Quad Cities was within 4
the average rate reported industry-wide. Only later, in 1986, when j
the failure rate started to lucrease at Quad Cities, the Station began j
searching for an explanation and came upon the earlier instruction to Dresden. Thus, Quad Cities did not wait seven years to take corrective
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j actions, but, rather, promptly began searching for a solution to its
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j problem when it was manifested. Nevertheless in the future, an even
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qu ic.*e c resolution of a problem at a plans should be obtained by using the ststion d developing program for analyzing recurring maintenance
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probless.
i In addition, the following action plan has been implemented to prevent i
j recurrence of the specific event in Item II.C.3:
.i The lubricant on the plunger guides in environmentally qualified (EQ) j and safety related motor control centers (MCC) is being replaced j
during scheduled ref ueling otitages with Aero-Shell 97 grease as j
recommended by GE.
This will continue until all aus111ary contact
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j plunger guides in the EQ and safety related MCCS are lubricated during j
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_- - - _ _,. - -.., _ - ~ _ _ _ _ _. _, _,, _,. _ _ _.
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.- the next two refuel cycles on each unit. Lubrication op a more accelerated schedule is not required because the approximately 1% of failures distributed over the past five (5) years is not considered to be either significant or excessive.
If an adequate trend involving aux 111ary contacts develops, Quad Cities would accelerate the schedule for lubrication of these affected contects.
4.
The possibility that t.he event for Unit 1 could also have af fected Unit 2 was considered and, as it turned out, wrongfully rejected on the basis of the Station's understandlng of the circumstances at the time.
Indeed, those circumstances a.td their Implications had been presented to NRC personnel at Region III.
This experience has served to reinforce the Station's enhanced appreciation of the need to apply the lessons learned to similar station equipment.
In addition, the specific corrective acticns for the event identified in Item II.C.4 were:
(1) revisions of Station Procedure QMMP 1515-3, and (2) replacement of the improperly oriented butterfly valve using that procedure.
The procedure will prevent recurrence by requiring the scribing of a line on the operator end of the valve stem parallel to the valve disc to ensure proper valve orientation.
Further corrective action was taken by identliying all safety related butterfly valves on Units 1 and 2 to confirm that they are properly oriented. This has been accomplished for all b.t the following valves:
1-1301-56, Reactor Core Injection Coolant suppression chamber Alternate Suction valves 1-2301-56, High Pressure Coolant Injection suppression chamber alternate suction valves and 1/2-5741-331, Control Room Outside Air Damper. A review of the maintenance history for these velves shows that they have not been disassembled for maintenance since installat.lon.
The 1-1301-56 and 1-2301-56 valves require a unit outage to complete verification and will be verified at the next outage of sufficient length.
The 1/2-5741-331 requires maintenance acsistance to verify proper orientation.
A work package is currently in development and is expected to be completed by October 21, 1988.
Station DVRs/LERs procedures have also been revised to require the consideration af actions which may be necessary on the other unit and/or like equipment to correct additional potential problems.
CQ R R E CTIYL STE PS _Til ATJ I LL_ D E_TA K EtLT0_ AVOI D _IT RTilE IL Y10LAT10t!S The new modificatlon process which defines more rigorous post modification testing and Engineering involvement will ensure that modifications are effective and corrective actions are comprehensive. This should preclude reoccurrence of such violations as that involving the EDG.
The previously described revisions to the LER/DVR process should preclude the reoccur-rence of those remaining examples identitled in this violation.
The procedures now require a review for potential impact on the other unit, or almilar equipment.
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DATEJHEN rULL CCHFJlflCE WILL BE ACHIEVED The procedural changes instituted for EDG ensure compliance at this time.
s Full compliance' will ;>e achieved by the end of the upcoming Unit 1 refueling outage, curJently scheduled for September 1989, with completion of verification of the butterfly valve's orientation.
For the auxiliary
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contacts, maintenance will be completed during refueling outages currently scheduled for November 1900 for Unit 1 and June 1991 for Unit 2.
II.D 10 CFR 50, Appendia B, Criterion KVII, requires that a comprehensive system of planned and periodic audits will be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
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Contrary to the above, during the period of November 30 to December 4, i
1987, the licensee conducted an audit (Audit QAA 04-87-55) of the i
maintenance program, which as described in the audit plan, included
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preventive maintenance, however, with the exception of four or five Environmental Qualification items, the audit did not verify compliance with and determine the ef fectiveness of the documented preventive 1
maintenance program in that the examination of four or five items in one specific area does not constitute an audit of the full program.
This is a Severity Level IV violation (Supplement 1).
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ADMISS10tLQr VIoLATIDti Commonwealth Edison Company acknowledges that QAA Audit 04-87-55 of the maintenar.ce program did not verify compliance with and determine the l
effectiveness of the Call preventive maintenance program.
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REASCHS_IOR._TitL.Y.10LAIl0H l
j The Commonwealth Edison Quality Assurance (QA) auditing program is a system of multiple audits and surveillances which provide diversified I
coverage of each audited area by several QA personnel over an entire year.
Single assessments of an entire program are performed only when a i
need becomes apparent.
The diversified and multiple coverage results in more frequent and more varied assessments of an area and minimizes the i
time between reviews of each area.
- lthough this approach provides for broader and more f requent coverage (
an area. Commonwealth Edison i
recognizes that because of the sampling nature of audits and surveillances, a specific item may be missed and that an extended and
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comprehensive one-time assessment may provide greater depth.
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.- 13 CORRICTIVE SIEES_THAT HAVE l'EEN TAKEN AND RESULTS ACHIEVf,D Prompt action was taken to conduct a training session at Quad Cities for.
the QA auditors to reemphas1*ee QA management's audit and surveillance expectations regarding documentation and review of objective evidence.
The one-day refresher training course was conducted on July 9, 1988 and included the followings a.
USNRC Inspection Report 50-254/88011 and 50-254/88002 l
b.
CECO Audit No. QAA 04-87-55 c.
I.E. Information Notice No. 88-35 "Inadequate Licensee Performed Vendor audits" 4
d.
Ceco QA Memorandum 5 dated 1/11/88, "Off-Site Auditing" L
e.
Various examples of auditing techniques f.
1.E. Rulletin 88-05, "Nonconforming Materials Supplied by Piping Suppliers...."
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j The emphasis of the training session was to Improve auditing and the review of auditing results by supervisors and lead auditors.
In that regard, the following Audit checklists were also discussedt i
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- "Audit Objective Evidence Checklist" This Is a guideline for review of the identified objective evidence for a checklist element prior to determining the status J
of the element.
s r
"Audit Deficiency Checklist" This checklist provides guidance for review of audit deficiencies prior to their issuance.
4
- "Audit Deficiency Follow-up Checklist" This checklist provides guidance for review of a response or
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commitments to an audit deficiency and to determine whether the t
corrective action will be adequate to close the deficiency.
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.. On September 23, 1988, a session was held with the D', rectors of Quality Assurance, Station Quality Assurance Superintendents and the QA Group Leaders for each Statlat specifically to agair, address the following two subjects:
1.
Auditing Review a.
Responsibil.tles for auditing pertaining to preparation,
'e, reporting and follow-up.
perform h.
Areas that need improvement by Leads and Supervisory personnel.
2.
Performance-Based Auditing a.
Investigative Approaches In addition to the aforementioned training, Commonwealth Edison immediately addressed the NRC's concerns regarding the previous O.A.
audits of the preventive maintenance program.
An additional audit (QAA 04-88-47) was conducted May 17-26, 1988, which was structured as a composite examination of the preventive maintenance program complementing the broadly distributed reviews noted earlier.
Also, audits specifically covering preventive maintenance are scheduled to be completed in the latter part of 1988 at each of our stations and to be included in the 1989 rudit and surveillance schedules for each station.
As demonstrated by the these actions, Commonwealth Edison has acted positively and aggressively to address the NRC concerns in this area.
CORRECTIVILSIEES_HJitCitJi1LLDI_AKELTQ_EREVENT FURTilEIL11QLAILQHS Commonwealth Edison's comprehensive multiple and varied verification program of audits and surveillances will continue to provide a satis-f actory assessment of the status of preventive maintenance as well as the other arebs required to be audited. The material presented in the special training sessions, discussed previously, will continue to be given as part of the annual refresher training and initial auditor training and on an ad hoc basis where performance enhancement is considered necessary.
DATILHilEIL EU L L_COH L'L I MICILM I LkBILACilI EV ED The completion of the composite examination of the preventive maintenance program, conducted May 17-26, 1988, demonstrated full compliance.
Additional training was conducted July 9, 1988. Other program enhancements may be made based on the continuing review of the auditing process.
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-L "ATIACIMMI_E" QVEityJEW OF COMMONWEALTii.EDISCH. MAINTENANCE PROGRAM AT_ QUAD CITIES STATION The conduct of maintenance at nuclear power stations has been of growing concern to Edis'on just as it has been throughout the nuclear industry.
As early as 1983, Edison recognised that it was no longer sufficient to leave the formulation of maintenance programs to the individual stations based on their experience and engineering judgement.
Accordingly, in 1983 Edison took the first of many steps to upgrade and ndort uniform maintenance requirements by issuing a corporate directive which esteb11shed clear programmatic require-ments.
Subsequently, in 1984, Edison participated in the maintenance working group established by NUMARC.
1 By 1986, Edison established its own maintenance task force and embarked on critical self-evaluations of the maintenance programs at.its t
plants. This self-evaluation led to the review and upgrading of maintenance procedures, the establishment of work package guidelines, the placing of greater emphasis on planning and scheduling and to the review of maintenance 1'
staffing. Nevertheless, Edison recognized that more needed to be done.
So, in 1987, Edison conducted a maintenance self-assessment through a multi-disciplined review of the stations maintenance programs. This review concluded that Edison should accelerate its implementation of the task force's f
earlier recommendations.
In addition, Edison initiated a reformulation of the l
corporate conduct of maintenance directive and an improved data base for maintenance related activities and occurrences.
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In 1988, Edison issued a new, comprehensive conduct of maintenance directive which addressed all aspects of maintenance. The directive was
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developed as a joint ef fort with the participation of the assistant
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superintendents of maintenance at all of Edison's stations. The directive covers maintenance philosophy, responsibilities, standards, goals, objectives and organisation.
It upgrades maintenance procedures and the preventive 4
maintenance programs and, in general, conforms to the INPO guidelines.
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The directive is currently being implemented at all of Zdison's plants.
Each plant is responsible for taking the lead on implementing i
assigned aspects of the directive.
Each plant's experiences are expected to
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provide the bases for more ef ficient implementation of those particular I
j aspects of the directive at the other plants. The directive is expected to be
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fully in force by April, 1991, i
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In addition, Edison is also continuing to improve its assessment of the plant's conduct of maintenance and has developed performance indicators i
and a regular, periodic performance review process. This process includen l
feedback to the stations to continually upgrade their performance.
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Quad Cities, naturally, is implementing the corporate conduct of maintenance directive.
In addition, Quad Cities has been steadily upgrading its maintenance program.
The scope and effectiveness of the current maintenance program at Quad Cities was recent1'y described at a meeting with B. Davis and other Region III personnel (see Enclosure). That program Identified a dozen strengths including early use of vibration and oil analyses, control of-the maintenance backlog, use of computerized maintenance histories, implementation of a computerized storeroom and the Institution of several innovative practices.
Moreover, Quad Cities is improving its performance in areas identifled as I
l needlng upgrading, including the scheduling of preventive maintenance, the system for controlling maintenance work and the determination of the causes of l
maintenance-related events.
In the area of preventive meintenance, the curront program Involves surveillances of over 4,000 items.
Enhancements currently in progress include a comprehensive program to determine more accurately the preventive maintenance periods for the 25 systems most likely to affect safety or economics of operation. The 25 systems were chosen by a panel of station personnel who represented a broad diversity of station functions.
For the top 15 of these systems, a statistical technique called "Time Series Analysis" is being i
utilized to determine f ailure history as a function of operating time. These
[
results will thrin be used to set more ef fective preventive maintenance l
periods.
After these periods are set, their correctness will be eva5uated by l
observing whether failure rates fall to the irreducible level of controlled random events.
If the failure rates do not reach this level, new maintenence l
procedures will be determined. The process will be repeated until failure rateJ are reduced to the minimum attainable.
t Separately, all maintenance procedures are being reviewed and rewritten. This procedure rewrite is far more than an editorial process.
I Rather, it involves a review of substantive maintenance issues and, thus, the I
program touchos on almost all areas of maintenance.
Another ongoing program designed to enhance rotating equipment analysis, is the predictive maintenance project currently in progress.
The project involves several steps.
l 1.
The first step la the identification and evaluation of current j
vibration analysis practice, including equipment monitoring selection, test instruments, data storage and analysis techniques.
1 2.
The second step is prioritization of the equipment to ne monitored based on critical function and prior equipment operating and maintenance 51stor9 i
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The current list of equipment will be. modified as necesrary based on-i step 92.
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4.
The test equipment inventory will be supplemented as necessary based i
on the results of the evaluation and the particular monitoring needs
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of the aslected equipment.
'1he data acquisition, processing, storage und analysis techniques will be modifle,d as necessary to support the i
depth of predictive studies required for the particular type and application of rotating equipment'(e.g. narrow band parameters, alarr I
points) to be monitored. The monitoring requirements will be y
component specific in the case of critical equipment and generic'in the case of non-critical components.
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The enhanced program will be implemented and reviewed for 5.
effectiveners in scheduling major preventive maintenance actions and l
In detecting low level it.crewstal degradation prior to the point of actual equipment failure.
6.
The predictive maintenance program will interface with the post maintenance testing program for integration of common test criteria
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and results.
I Quad Cities has also been addressing the issues identified in the 8
inspection report under consideration here.
For example, motor operated valves (HOV) have been the subject of an ongoing two-phese enhancement l
l program.
Phase I, begun in 1986, was designed to insure that all MOVs are in l
j reliable operating condition and to provide a complete data base for
{
evaluating the effectiveness of both corrective and preventive maintenance.
All MOVs are being inspected for specified uechanical and. environmental f
qualifications items.
All MOVs which fall inspection will be repaired or
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j overhauled. The current status of this program is shown on the attached I
charts.
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r Phase II of the MOV program will be a comprehensive program t',
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integrate the results of tests, inspections and work requests. This part of l
the program will be conducted by a MOV coord*nator.
l This review shows that the uporade of Edison's corporate maint'enance program and Quad Cities' own maintenance improvement initiatives began well
)
before the inspection which led to this NOV and are continuing at an i
l accelerated pace.
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CURRENT HAINTENA E E P E N e
PROG M STRENGINS LONGSTANDINGPREVENTIVEMAINTENCEPROGN VIBRATIONANALYSIS OilANALYSl$
LUBRICATIONPROGM R0VIINEEQUIPMENTINSPECTIONS XN0WLEDGEABLE AND C0 KIENT10VS E K FORCE EffECTIVECONTROLOfCORRECTIVEMAINTENA~NCEBACX EFFECTIVE CONT E Of PERSONNEL ASSIGNED TO A TA ROTATINGPERSONNEL C0HPUTERilE0MAINTENCEWlsTORY HATERIALCONDITIONOfTHEPLANT EXTENSIVEUSEOfVEERREPRESENTATIVES COMPUTERilE0STORER00N EffECTIVESECURITYHAINTENAEE RELIABILITY-RELATEDPROGW
0JRRENT HAINTE N CE PROG N (CONT'0)
INN 0VATIVEMAINTENAEEPRACTICES H0V LIHli SWITCH TEST DEVICE ISTUSEOfCR0 CHANGE 0VTRIG USEOfLIVELOADPACKING e
HAINTENA E E PROG W INITIATIVES SAFETY-RELATED AUXILLARY CONTACTS e
PROBLEMRESOLUTION10ENTIflE0IN1987 106 Of 382 00NE ON UNIT 1 WITH COMPLETION e
SCHEWLEDBYENDOfSECONDREFUELOUTAGE 202 Of 382 00N! ON UNIT 2 WITH COMPLETION e
SCHEWLEDBYENDOfNEXTREFUEL SAFETY-RELATED4KVBREAXERS AllUNIT1&2BREAXERSWIllBEWITHINA3 YEAR I
INSPECTIONCYCLEBYENDOfNEXTUNIT2 Refuel SAFETY-RELATEDH0V'S j
67 Of 86 UNIT 1 VALVES OVERHAULED SIKE 198 i
81Of86 UNIT 2VALVESOVERHUALE0SINCE1985
- NOTE:NRC INSPECTION 10ENTIflE0 C0 KERNS IN THESE AREAS
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m WORK CONTROL ASSISTANT SUPERINTENDFNT MAINTENAN12 L. PETRI MASit R
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INSTRtasENT MASTER MASYER MECHANIC ELECTRICIAN MECHANIC
._ D. RAJCEVICH_
D. CRADDICK J. FISH SUPERVISOR SUPE _RViSOR SUPERViSOS ADMINISTRATION ADMINISTRATION ADhilNISTRAT'80N
.______PACILIO
- _ _ _. _ _ _
DELLABETTA
- WILSON *
~~~~~ WORK ANA_LYSi~ ~ ~
WORK ANALYST WORK ANALYST ~
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RICHARDSON CHR1SMAN EDMONDSON COOK
- SMITH WEAVER LOy
- PETERS
- SONDGER0TH
- MAZE
- VAN LOO
- ARNOLD
- DETWEILOR
- l 14e. Veu.onneI t *. u n l
' ~ - - -
t 1
[
NUCLEAR EXPERIENCE
=
DEPARTMENT HEADS MAINTENANCE
)
STAFF SIZE / # OF YEARS 100_
l J:
1 STORES MNT STAFF IM EM MM 1::
- I MANAGEMENT STAFF DH YEARS EXPERIENCE DATA COMPILED 8-18-88 l
FIGURE 6-2
O i
- e I
NUCLEAR EXPERIENCE
=
MAINTENANCE i
MAN-YEARS 350 a:-y,
,., ' +
300 w,
,m z.
S e' u i
> ? ;.J '-, s 250
'IN90Af>s
,.,c.
, se s '
e, /g.::', ' - -
200
't in, f.
I
/
150
- ' *i,, '
a!Mg,11s,, -
~
, 'f1:..;
'm
, a e 8. '
100
' Q?.M
' 55g
~
c
- Sc r
. i:l
...g.
50 i<-
s wM,,:-limp
- g -:.
5,
~y-
, f-fd,
!!is g
z,.
y.
< g; -
tem:g w :
,e'sp,'
STORES MNT STAFF IM EM MM MANAGEMENT STAFF ONLY DATA COMPILED 8-18-88 L
FIGURE 6-2
i l
PERSONNEL ERROR DVRs I
MAINTENANCE 15 14-13-12-
)
11-l 10-i f 9, l f
)
8-j i
7-J 6~
I i
5-J i
4-3-
j l
2-i_
3 n
l
~
v i
I i
i i
i 4
i i
i i
4 i
i i
I i
i i
i 8
J F
M A
M J
J A
S O
N D
J F
M A
M J
J A
S O
i 6
l 1987 1988 i
[
IM MM i
COL).C" 0: FATi!A\\Ci 0.A) C ":ES % ::M).!MENii)
- .00 )iRCEN" CA)"iR
$!)","88" IF.iEN"i)
ORGANIZATION & ADMINISTRATION
- .99:.
TRAINING & QUALIFICATION
- .989 FACILITIES, TOOLS, EQUIPMENT G
- .996FIP TYPESOFMAINTENANCE G
- .990 MAINTENANCEPROCEDURES
- .990 PLAflNING, SCHEDULING,C0 ORDINATION G
- .990 CONTROL 0FMAINTENANCEACTIVIIES
- .989 POSTMAINTENANCETESTING
- .990 PROCUREMENTOFPARTS& MATERIAL
- .989 STORESACTIVITIES
- .989 CONTROL 0FTESTEQUIPMENT
- .990 MANTENANCEEQU:PMENT&TOOLCONTROL
- .99:.
- .990 MANAGEiENT::NVOLVEMENT G
- .990 MA:NTENANCE H:: STORY G
- .990 ANALYS::SOFMA:NTENANCEPROBLEMS G
- .989 "0"A.
G
- .287B
=
BACKLOG N0HUTAGE CORRECTIVE WORK REQUESTS
-x-QUAD 1,200-1,000-12 Y%
y%A
?,_j A
=
/
r
^
is 800-x r
W f -r' r
5 eaa-4
=
as
.A x-r
=
4ee_
sa f
L 200-edCOPJMitTE G0AL 7
i c
i i
i i
i i
i i
OCT DEC F2 APR M
AUG OCT DEC FB APR M AM mped 1986 1987 1988 J
l 1
J j
i 4
}
l l -e-STATION
-I-EM
-x-IM
-e-DAD
-+- TECH STAFF.
PENDlH N0W C0ER0L ROOM WR QUAD CITIES (#8dP9 4a-v TOP QUARTiE a
m e
t 30-g%
2 5o 20-Nr x-o E
V N.
1 be_*-
N i
.a x'
Ax g
1 s
n--s
"~~" A, x
1, r
r r
r
,4~ =
e =
AUG qcpndecs 1986 1987 1988 h
1 i
4 l
~
4 I ncret 3 i ng Trend of 4KV Breaker t rv.,pec t i ons S i nce 1993 35 d
i' 30 a
l 25 1
o
/
20 33
/
0
/
D 10 l
l
/
0 -9 1993 1994 1985 1996 1997 1998 1er O
5/ A
+
NS/ A Total i
r
]
l 1
b I
1 k
,')
1
- .. 3 Unit 1 Safety 9 elated Aux Contact A*7 ease status since 3987 AeressM (27.w) y y/
/
/
- "oiniru (70 n) 7 I
Regroanod 106 l
Romainingt 276 I
9 l
i i
Unit 2 Safety Aelated AUX Contact Ft7 ease Status Since 1997 Post NRC (5.8%)
N.
A.
N L
g 2
1 i
Aeqreased (49.0%)
/
nemining c45 n) y
- -=l f
- = _.-
/
15 ?
/p@.w' Regreased:
202 Remaining:
186 Post NRC :
24
.