ML20205R991
| ML20205R991 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/03/1988 |
| From: | Ross T Office of Nuclear Reactor Regulation |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8811100203 | |
| Download: ML20205R991 (9) | |
Text
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.6 November 3, 1988 MEMORANDUM FOR:
Edward G. Greenman, Director Division of Reactor Projects, RIII THRU:
Daniel R. Muller. Director Project Directorate III-2 Division of Reactor Projects - !!!,
IV, Y and Special Projects FROM:
Thierry M. Ross, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, Y and Special Projects
SUBJECT:
NRR SALP VII INPUT FOR QUAD CITIES In response to the Region III memorandum dated September 29, 1988, I am enclosing NRR's input to the SALP VII report for the period of April 1,1987 through September 30, 1988. Our assessments of particular functional areas, as documented in this enclosure, were conducted in accordance with the latest revision of NRC Manual Chapter 0516. Also, per the Region's request, attached is a list of all Technical Specification amendiants issued during the SALP period.
If you have any questions or require further information, please coritact me at 492-3016.
Thierry M. Roe,s, Project Manager Project Directorate !!!-2 Division of Reactor Projects - III, IV, Y and Special Projects
Enclosures:
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November 3, 1988 MEMORANDUM FOR:
Edward G. Greenman, Director d\\11 Division of Reactor Projects, RIII THRU:
Daniel R. Muller, Directer
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Project Directorate !!!-2 1/
DivisionofReactorProjects-!!!,lg' IV, Y and Special Projects FRON:
Thierry M. Ross, Project Manager Project Directorate !!!-2 Division of Reactor Projects - 111, IV, Y and Special Projects
SUBJECT:
HRR SALP VII INPUT FOR QUAD CITIES In response to the Region III memorandum dated September 29, 1988 I am enclosing NRR's input to the SALP VII report for the period of April 1,1987 through September 30, 1988. Our assessments of particular functional areas, as documented in this enclosure, were conducted in accordance with the latest revision of NRC Manual Chapter 0516. Also "er the Region's request, attached is a list of all Technical Specification amendments issued during the SALP period.
If you have eny questions or reciu er further information, please contact me at 492-3016.
v Thierry 7. Ross, Project Manager Project Directorate !!!-2 l
Division of Reactor Projects - !!!,
IV, V and Special Projects l
Enclosures:
)
As stated l
cc: see next page I
I
Mr. Henry E. Bliss Quad Cities Nuclear Power Station Commonwealth Edison Company Units 1 and 2 e
cc:
Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. O. Box 4350 Davenrort, Iewa $2808 Michael I. Miller Esq.
Sidley ana Austin 1
One First National Plaza Chicago, Illinois 60603 Hr. Richara Bat i
Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission t
22712 206th Avenue North Cordova, Illinois 61242 1
Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Offfice Bldg.
Rock Island, Illinois 61201 Mr. Michael E. Parker, Chief Division of Engineering Illinois Department of Nuclear Safety 1035 Outer Park Drive.
Springfield, Illinois 62704 l
Regional Administrator, Region !!!
U. S. Nuclear Regulatory Commission j
799 Roosevelt Road, Bldg. f 4 Glen Ellyn, Illinois 60117 I
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0FFICE OF NUCLEAR REACTOR REGULATION i
INPUT FOR THE SALP VII REPORT COMMONWEALTH EDIS0N COMPANY QUAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 Operations 4
During tours and inspections conducted by NRR staff, station housekeeping was considered to be very good. Most station equipment areas and butidings were s
subjected to an aggressive painting and unit specific labeling program, which were quite evident in the bright, clean appearance of station facilities and equipment, Control room c.ctivities observed by NRR staff were perfonntd in a controlled.ind orderly fashion. All operators appeared to be attentive and knowledgeable. Additionally, both units were being operated with a very low nunter of annunicators in the alanned condition, NRR conducted a special '.eam inspection of the Quad Cities emergency operating proceduras (EOPs) during the period July 18 - 29, 1988.
This inspection, was nart of a serfe', of ECP inspections for all BWR plMts with Mark I j
containr<nts.
It included a detailed review of the E0Ps and associated procedures and guidelines, a review of the licensee's verification and validation (V8V, procram for E0Ps, plant walkdowns of the E0Ps, and an evaluation of operating crew perfomance of E0Ps on the Dresden simulator, fhis inspection concluded that although the E0Ps were a technically accurate i
represenCation of the Boiling Water Reactor Owner's GroLp (BWROG) Emergency Procedure Guidelines (EPGs), Revision 4S, they Dad poor useability and provided operators with only a marginally effective actident mitigation tool.
i The quality of E0Ps et Quad Cities suffered due to the lack of an orderly and i
methodical developmental program. Additionally, fundamental steps in the developmental process had many errors and omissions.
l Listed below are several of the more significant deficienties in the E0P developmental program:
l (1) Failure to implement an effective V&V program.
(2) Plant Specific Technical Guidelines (PSTGs) and calculations did not incorporate p)4nt modifications, nor did they include justification of differences between the PSTGs and E0Ps.
Furthermore, the PSTGs had not been used in the development of the 20Ps.
(3) Evaluations were not performed to verify the adequacy of specified and/or alternative vent paths with regard to venting capacity, operability of the isolation valves, and the ability of the Standby Gas Treatment System (SBGT) to withstand the accident pressures and temperatures. Provisions were not made to vent the containment under station blackout conditions.
2-(4) Plant specific Writer's Guide did not adequately address the human engineering requirements of NUREG-0839, and was not developed before trnplementation of the E0Ps. This was a major contributar to the difficulty in E0P useability.
These deficiencies reflected a lack of management involvement and coarrittrant to the E0P uograde effort. Although the knowledge and dedication of personnel responsible for development of the E0Ps was high, this activity was inadequately staffed and poorly overseen.
In general, the overall program for control and development of E0Ps did not represent a comprehensive organizational dpproach.
Signif1Cdnt and aggressive Corrective actions have been initiated by the licensee to resolve these and other applicable deficiencies (identified by an E0P inspection at Dresden).
Securi ty NRR staff evaluated and approved the CECO license amendment applications dated November 26, 1986 and January 14, 1988, to incorporate the Quad Cities Physical Security Plan as part of the Facility Operating Licenses. This Physical Security Plan was previously revised to conform with the latest provisions of 10 CFR 73.55 for Miscellaneous Amendments and Search Requirements, and associated record reporting requirements of 10 CFR 73.70.
We found the quality of licensee resolutions to safeguards matter.1 were technically sound and consistent, demonstrating the existence of well developed policies and procedures for control of security related activities. There was consistent evidence of prior planning by the utility (including corporate level) managerrent.
Solutions to technical safeguards problems were generally sound, timely and conservative, indicating a clear understanding of the issues.
Responses to NRC concerns were generally timely, and proposed resolutions were usually 4CCeptable the first time. There are very few longstanding issues remaining to be closed.
Security organizatien positions and resporsibilities are well defined. The security staff is considered ample to implement the facility physical protection program.
The facility guard training and qualification plan is effectively implemented on a continuing basis at all levels of the security organization.
Engineering / Technical Support Several station evolutions involving support from the licensee on-site and of 7-51te technical and engireering 3rganizations were observed and/or monitored by NRR/RES staff. Described below are our assessments of the adequacy of technical and engineering activities used to support the Erosion / Corrosion
3 Monitoring Program, Chemical Decontamination of the Primary Coolant Recirculation System (PCRS), and Solidification of Radwaste.
Follcwing a team 1%spection during August 9 - 11, 1988, NRR staff concluded that the Erosion / Corrosion Monitoring Program at Quad Cities exceeded the intent of NUMARC guidelines for monitoring pipe wall thinning in single phase lines. Management and technical support of this program was evident and effective. CECO ano its contractor has demonstrated a clear understanding of the technical issues involved and implemented a timely and thorough program.
CECO's strong initiatives have resulted in one of the best nuclear plant programs inspecttd to date. Although CECO has developed implementation procedures to control their erosion / corrosion monitoring program, these procedures were not totally complete. Also, administrative procedures did not adequately define departmental responsibilities. Comprehensive procedures are considered particularly important for Quad Cities because of the station's heavy dependence upon contractors. However, even with these minor procedure oeficiencies, our overall assessrrent of the erosion / corrosion monitoring program and licensee efforts taken to address the NRC's concern with pipe wall thinning is that they are significantly better than the industry average and standards.
Under a research contract with NRC (RES). INEL has collected operating experience infomation on the PCRS decontamination processes, in April 1988, INEL observed chemical decontsmination (LOMI process) of the PCRS at Quad Cities. This particular esolution was perfonned very smoothly without any significant complications arising during the process. CECO's perfomance was indicative of a well planned, controlled, and monitored event. They and their con actors demonstrated sound technical judgment and understanding of this complex and potenticily hazardous process. However, for this very specialized evolution, little of the actual technical expertise was available within the station.
But, since LOMI '.s a unique and licensed process, strong reliance upon the contracted vendo' was not inappropriate.
Efforts ano cifficulties ex.wrienced by Ceco and its contractor (Chem-Nuclear) to solidify the lou-lesel radwaste, resulting from the aforementioned decontamination process, were observed by INEL and closely followed by RES.
i There was close comunication between the station personnel and INEL/RES during the solidification process and during resultant corrective actions taken by CECO to assess and resol'!e the problems associated with failure to completely solidify all radwaste. Responsible licensee staff was very responsive to all INEL and RES queries.
Station management involvement was very evident and effective in directing resolution of this difficult situation. However, several deficiencies were observed in the licensee's performance which could have contributed to the premature solidification problem. First, CECO's management and staff at Quad Cities defaulted almost exclusively to Chem-Nuclear fo. performing the solicification process properly.
Secondly, there were a numcer of technical uncertainties (i.e., synergistics) concerning the solicification of ion exchange resins and LOMI process chelating agents into cement, about which CECO was unaware. Thirdly, management and technical
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4 personnel did not closely control the solidification activities conducted by Chem-Nuclear until af ter problems arose. La,tly, deficiencies in the Process Control Trocedures and its implerrentation were discovered during the INEL investigation.
!#sunwary, Quad Cities personnel acted professionally and responsibly in cooperating with our principel investigator from INEL.
Furthemore, they identified the important issues involving the premature i
solicification, responded quickly to resolve these conditions, and took the necessary steps to correct the technical, procedure, and management concerns raised by NRC, INEL, and the vendors.
By and large, technical and engineering support of these complicated station evolutions (discussed above) was accomplished in a sound and timely fashion.
Corrective actions to resolve unexpected events were appropriately conservative and thorough. However, all engineering support activities necessitated the participation of significant contractor / consultant resources. The limited 4
in-house staffing of station and corporate CECO technical personnel has resulted in a heavy reliance upon outside engineering services. Consequently.
l close coordination and scrutiny of contractor activities by existing CEb staff and management is essential. On occasion, this level of oversight has been lacking; which, in one instance, resulted in an unforseen and uncontrolled process condition.
i Safety Assessment / Quality Verification During the assessrrent period, NRR issued nine Technical Specification amendnents for Unit 1 and seven for Unit 2.
Additionally, eight Safety Evaluation Reports were issued on various safety significant issues. The more important of these licensing issues and TS amendments included the following -
Appendix R exemption requests. EQ of Butyl Rubber Cables, R.G.1.97, ODCM, PCP, a
Cycle 10 Reload Reports, Piping Configuration Control, and the Standby Li.;uid l
Control System. Furthennore, several other significant licensing review activities were still ongoing (SERs not yet issued) by the end of the SALP 1
period. However, they were near enough to completion to be considered in NRR's l
SALP input. These licensing issues include:
Embedment Plate Verification Program, TS Retype Amendment, Containment Oxygen Concentration Amendtrent, i
Contiustible Gas Control, LPCI Swing Bus Design Flaw, IGSCC of Primary System
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Piping, and 10 CFR 50.62 ATWS Rule.
Corporate management was frequently involved in licensing activities.
particularly for the more complex and dif ficult issues which necessitated I
additional follow-up consnunication and/or meetings with NRC staff. Decision making was consistently at a level that indicated good management awareness and ensured proper oversight was occurring. Overall quality of technical content was good in most CECO evaluations of complex engineering issues. However, greater attention is warranted for T5 amendment applications, where there was a l
tendency by Ceco to oversimplify the analyses for "no significant hazards considerations" (e.g. Low-Low Rx Level Setpoint, Recirc. Jet Put.p Inst., and i
HPCI/RCIC Discharge Piping Fill). Also, several arrendment applications were l
incomplete or exhibited errors which required subsequer.t resubmittal by CECO to l
correct, clarify, or supplement the original (e.g. Unit 1 Reload Report, j
HPCI/RCIC Steamline Inst., Standby Liquid Control System (SBLCS), and TS Retype).
In retrospect, CECO Licensing activities did not appear to be the j
subject of any corporate perfomance critiques, audits, or independent t
assessments to ensure that their efforts were being carefully orchestrated I
within an atmosphere dedicated to enhance the pursuit of excellence.
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CECO and its contractors censistently demonstrated a clear understanding of the cosplex technical and/or safety issues associated with many of the licensing l
andregulatoryactjons. Although the technical approaches used by CECO were generally sound anU comprehensive, they frequently were not described in a thorough er.ough manner for the NRR review staff to evaluate without requatrihg additional infonnation (e.g. Appendix R exemption requests, Recire. Jet Pump Inst., Piping Configuration Control, and Embedment Plate Verification).
Furthermore, written responses to staff requests for additional information, and written resolutions to staff concerns, were often delayed (e.g. Combustible Gas Control RG 1.97. ATWS kule, Embedrent Plate, and Appendix R exemptions).
Ultimately CECe did provide adequate infonnation to demonstrate their i
approaches were conservative.
1 CECO responsiveness to NRC initiatives was exceptionally cooperative, prompt, and timely for Bulletins, Generic Letters, special inspections, and non-obligatory surveys and studies. The corporate office and station characteristically made their most knowledgeabh people available to assist a
NRR/RES staff and our contractors. Only a few longstanding regulatory issues remain that can be attributable to the licensee. Although CECO has on occasion requested time extensions for responding to regulatory actions, it was generally to allow for the opportunity to produce a better product than the original schedule provided.
Open, effective, and frequent personal communication channels existed between NRR and CECO's licensing and station personnel. Conferente calls and meetings to discuss technical issues or administratins problems occur in a proactive environment. Although licensing personnel and management staffing was limited early in the SALP period; this has been substantially corrected by increases in staffing levels of Licensing Administrators, Licensing Supervisors, and general support staff. Staffing at the Quad Cities Station has also improved to support corporate and NRC licensing actions.
Experience and competence levels of the Licensing Administrator, licensing supervisors, and corporate managers (technical and licensing) continue to remain high. As for technical and engineering support staff, CECO continues to rely predominately upon consultants and contractors for almost all safety and technical problems, or issues, involving any level of complexity. There appears to be a limited amount of in-house technical expertise availatile. Most technical personnel perform primarily as coordinators of contractor / consultant services, rarely conducting the detailed engineering or analysis tasks themselves.
The Licensing Administrator and corporate licensing-related management at all levels have developed a broad competence and high degrwe of control over the many, varied, and complicated licensing issues by virtue of their broad multi-discipline exposure and active participation in Owners Groups, NUMARC, and professional organization activities. Licensing procedures and policies were consistently and closely followed curing the entire SALP period with only one apparent exception (failure to incorporate an approved TS amendment into station controlled copies),
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6-c ATTACHMENT 1 Technical Specification Amendments
!ssued During the SALP Period AMEND NO.
UNIT DATE TITLE 102(99) 1(2) 8/6/87 4KV X-TIE Operability 103 1
12/15i87 Cycle 10 Reload 104(100) 1(2) 2/3/88 HPCI/RCIC Dircharge Pipe Fill 105(101) 1(2) 2/17/88 Orywell Pressure Instrumentation 106 1
3/28/88 Standby Liquid 'ontrol System
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107(102) 1(2) 5/10/88 HPCI/RCIC HI Stuam Flow Isolation 108(103) 1(2) 6/9/88 Physical Security Plan (104)
(25 6/17/88 Cycle 10 Reloac 109(105)
- (2) 6/23/88 Reactor Low-Low Water Level Trip Setpoint 110(106) 1(2) 6/30/88 Refluelins Floor Red Monitor Setpoint
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