ML20207H617

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/99-01 & 50-265/99-01,per 990217 & 0401 Ltrs Which Transmitted NOV Associated with Insp Repts 50-254/98-23 & 50-265/98-23

ML20207H617
Person / Time
Site:	Quad Cities
Issue date:	06/14/1999
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-254-98-23, 50-254-99-01, 50-254-99-1, 50-265-98-23, 50-265-99-01, 50-265-99-1, NUDOCS 9906180186
Download: ML20207H617 (2)

See also: IR 05000254/1999001

Text

o

E '

.

June 14, 1999

l

.

Mr. Oliver D. Kingsley

l President, Nuclear Generation Group

1

Commonwealth Edison Company

ATTN: Regulatory Services

Executive Towers West 111

1400 Opus Place, Suite 500

Downers Grove,IL 60515 .

1

l

SUBJECT: NOTICE OF VIOLATION (QUAD CITIES INSPECTION

REPORT 50-254/99001(DRP); 50-265/99001(DRP))

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated May 12,1999, in response to our

letters dated February 17,1999, and April 1,1999, transmitting a Notice of Violation associated

with inspection Report 50-254/98023(DRP); 50-265/98023(DRP) and an additional example of

that violation associated with inspection Report 50-254/99001(DRP); 50-265/99001(DRP). We

1

have reviewed your corrective actions and have no further questions at this time. These

corrective actions will be examined during future inspections.

Sincerely,

/s/ M. A. Ring

Mark Ring, Chief

Reactor Projects Branch 1

Docket Nos. 50-254; 50-265

License Nos. DPR-29; DPR-30

See Attached Distirbution

DOCUMENT NAME: G:\ quad \qua98023.ty

To receive a copy of thle document, indicate in the box 'C' = Copy without attachrnent/ enclosure 'E' = Copy with attachrnent/ enclosure

"N" = No copy

OFFICE Rlli ,

Al l l l

NAME Ring:coM

DATE 06/M/99

OFFICIAL RECORD COPY

9906180186 990614 9

PDR ADOCK 05000254

G PM g

a

,

.

1

O. Kingsley -2-

l

ec: D. Helwig, Senior Vice President

H. Stanley, PWR Vice President j

.;

i C. Crane, BWR Vice President

R. Krich, Vice President, Regulatory Services

- DCD - Licensing I

J. Dimmette, Jr., Site Vice President

G. Barnes, Acting Quad Cities Station Manager

C. Peterson, Regulatory Affairs Manager

cc w/Itr did 5/12/99: M. Aguilar, Assistant Attorney General <

State Liaison Officer, State of Illinois

State Liaison Officer, State ofIowa

Chairman, Illinois Commerce Commission

W. Leech, Manager of Nuclear

MidAmerican Energy Company

Distribution w/ltr dtd 5/12/99:

Project Mgr., NRR

J. Caldwell, Rlli

B. Clayton, Rill

SRI Quad Cities

DRP

DRS

RlliPRR

PUBLIC IE-01

Docket File

GREENS

ff

390015

' "

i.o m m onsse.uoi a r..n i .,nn u m

• l

tjuad Enses t cocrannu 'ian .n

22 in auc,oi w enue s..o

( '4 H dO% J. ll. (>l 212 'I til

rei we . 22. i  ;

COITtEd i

SVP-99-096

May 12,1999

)

U. S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, D C 20555

Quad Cities Nuclear Power Station, Unit 1 and 2

Facility Operating License Nos. DPR-29 and DPR-30

NRC Docket Nos. 50-254 and 50-265

Subject: Supplemental Reply to Notice of Violation 50-254/98023-01 Concerning

the Out-of Service Program

References: (1) Letter from S. A. Reyr. olds (USNRC) to O. D. Kingsley (Comed),

dated February 17,1999," Notice o' Violation and Ouad Ci'ies  !

Inspection Report 50-254/98023(DRP); 50-265/98023(DRP)"

(2) Letter from J. P. Dimmette, Jr.(Comed), SVP 99-055 to USNRC,

dated March 19,1999," Response to Notice of

Violation 50-254/98023-01 Concerning the Out-of-Service

Program"

(3) Letter from S. A. Reynolds (USNRC) to O. D. Kingsley (Comed),

dated April 1,1999," Quad Citics Inspection Report

50-254/99001(DRP); 50-265/99001(DRP)"

i

Enclosed is a supplement to the Commonwealth Edison (Comed) Company reply to

Notice of Violation (NOV) 50-254/98023-01 issued to Quad Cities Nuclear Power

Station and transmitted in Reference (1). The reply to the specific violation was

included in Reference (2).

As discussed in Reference (3), Comed is supplementing the reply to NOV

50-254/98023-01 to discuss a February 18,1999, Out-of-Service (OOS) error. This

supplement discusses the reason for the OOS error and commits to further corrective

actions from that event. This reply also provides a status of previous commitments and

describes new initiatives to improve performance with regard to the OOS process and

human performance in general.

U/W 18 y)ge

s i nn.,m t..mium f

,.

.

May 12,1999

U. S. Nuclear Regulatory Commission

Page 2

L

Comed is committing to the following additional actions in response to the February 18,

1999, OOS error:

• The expectation for operating components froin standard locations will be included

in OAP 0300-02, " Conduct of Shift Operations," by June 11,1999. A Daily Order

Book entry has communicated to Operations personnel the expectation to operate

components from the standard location whenever possible. If circumstances

prevent operating a component from the standard location, the standard location

must be checked to verify that operation of the component is not prohibited.

• QCAP 2200-03, " Planning, Scheduling Operating Cycle Work," will be revised by

June 11,1999, to ensure that appropriate reviews are documented for priority A

and B1 schedule additions to verify that plant conditions support the activity. The

expectation has been reinforced with the Operations planning group that their

review of the daily schedule (including work additions) ensures the plant lineup is

correct for the performance of each scheduled task.

Any other actions described in the submittal represent intended or planned actions by

Comed. They are described for information and are not regulatory commitments.

Should you have any questions concerning this letter, please contact Mr. Wally Beck,

Acting Regulatory Assurance Manager, at (309) 654-2241, extension 3100.

Respectf y,

. _

A

.

el P. Dimmette, Jr.

Ite Vice President

Quad Cities Nuclear Power Station

Attachment: Supplemental Response to NOV 50-254/98023-01

cc: Regional Administrator-NRC Region til

NRC Senior Resident inspector-Quad Cities Nuclear Power Station

_

i .. s . .. ,

'

Att:chment

SupplImental RIply t3 NOV 50-254/98023 01  ;

Page 1 of 4

In Reference (3) the NRC noted that, if necessary, our response to NOV 50-254/98023-01

should be modified to include corrective actions sufficient to address the Out-of-Service (OOS)

tagging errors identified in Reference (3).

On February 18,1999, during the performance of a logic test surveillance Operations personnel

operated a breaker that was OOS to protect equipment. The test procedure had recently been

revised and had been added to the schedule without recognizing that the revised test would

require manipulation of a component that was OOS. During the performance of the surveillance,

the critical task coordinator and an electrician correctly identified the breaker cubicle for 2-1001-

47, RHR Shutdown Cooling Outboard Suction isolation Valve, but did not notice an OOS card

hanging from the breaker handle. The electrician opened the cubicle door, obscuring the OOS

card and proceeded to install jumpers as directed by the surveillance. After the jumpers were

installed, an operator was dispatched to assist and was requested to close the breaker per the

surveillance. The operator verified that he was on the correct component by checking the label

on the cubicie door, however, the jumpers that had just been installed prevented the door from

fully closing and the OOS card on the breaker handle remained obscured. The operator then

operated the breaker from inside the cub.Je. After the breaker was operated, the critical task

coordinator saw the OOS card and directed the operator to reopen the breaker. The root

causes of this event were inattention to detail, inadequate precautions established for operating

components from non-standard locations (inside the cubicle), and inadequate review of the

schedule to determine that the OOS needed to be cleared to perform the test.

In the response to NOV 50-254/98023-01, Comed discussed that previous corrective actions to

correct OOS problems had not been fully effective. Previous corrective actions for OOS l

problems were focused on individual events and departments and did not fully take into account 1

the broader issues of human performance. Human performance problems were due to a lack of

adequate management oversight and reinforcement of the standards and expectations at the

lowest levelin the organization.

Two new initiatives will supplement the plans previously discussed in the March 19,1999, letter

to improve human performance at Quad Cities.- One initiative is the establishment of a

multidiscipline Human Performance High Impact Team whose chartered purpose is to prevent

human error through education, behavioral changes, and program and process improvements.

This team includes individuals at various levels from various departments throughout the

station, who will work to !dentify and understand human performance issues and solutions and

will facilitate change throughout the station to improve human penormance. On April 6,1999, 1

the BWR Vice President and Quad Cities Site Vice President approved the Human Performance  ;

High Impact Team Charter.

The second initiative is rigorous implementation of the new Nuclear Generating Group (NGG)

Self-Assessment Procedure to improve Quad Cities self-criticism and the effectiveness of

processes and corrective actions. On April 14,1999, the Acting Station Manager approved a

plan for implementation of the NGG Self-Assessment Procedure. This included the designation

of two Self-Assessment t_ine Managers who will work with Line Manager Department Heads to

- implement an improved Self-Assessment Program at Quad Cities Nuclear Power Station. The

first quarter 1999 Quarterly Self-Assessment, performed in accordance with the new NGG j

Self Assessment Procedure, is scheduled to be complete by June 1,1999. The second quarter l

'

- 1999 Quarterly Self-Assessment is scheduled to be complete by July 17,1999.

,

e

.-

'

Attachm:nt

' SupplImentIl RIply to NOV 50-254/98023-01

Page 2 of 4

-CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATION

The following corrective actions were discussed in the March 19,1999, letter to the NRC and

were completed prior to the issuance of that letter.

. . On January 29,1999, a new policy, OCPP 0110, " Event Review Board," was implemented

to formalize the Senior Management Review of Human Performance events.

• On February 25-26,1999, the Quad Cities Station Site Vice President and Station Manager

issued letters to all employees reinforcing the need for high standards in procedural

adherence and in the conduct of Heightened Level of Awareness briefings. This expectation

was rolled out to the management team on March 3,1999.

• On March 12,1999, stand-down meetings were conducted by Senior Management

throughout the Comed Nuclear Generation Group. The stand-down meetings addressed

the need for improved human performance and stressed the importance of personal

accountability. Additionally, individual departments met to reinforce and discuss the

standards for prevention of errors. For applicable departments, this included discussion of

proper zone of protection for OOS activities.

• On March 17,1999, INPO representatives presented a four-hour course titled " Human

Performance, a Management Perspective." This was conducted at Quad Cities Station und

attended by Senior Management and other selected station personnel.

The following corrective actions were discussed in the March 19,1999, letter to the NRC and

completed following the issuance of that letter.  ;

• Prior to March 30,1999, items No. 28 and No. 29 of the Station Configuration Control Action

Plan were completed conceming refreshar training on OOS acceptance and walkdown

~

4

safety verification checklists for maintenance personnel.

= Prior to April 9,1999, the Maintenance Manager met with and communicated with the

,

department First une Supervisors (FLS) to reinforce the following:

!

'

. Adherence to procedures

. Maintenance control of work

e Safe work practices '

j . *- Personal Accountability

. Prior to April 10,1999, the Site Vice President, Station Manager, and Operations Manager

j held accountability sessions with each Operating Shift Manager and his management crew.

The accountability sessions included discussions on adherence to standards, the need for

change, and how that change will be sustained to achieve improved operator performance.

t-

• .

'

...

Att:chmsnt

Supplim:ntr.1 Rrply to NOV 50-254/98023-01

Page 3 of 4

• Prior to April 10,1999, an independent multidiscipline team completed a review of previous

corrective etctions associated with station PIF's, root cause trend reports, LER's, and

responses to NOVs related to OOS problems. The review was performed to ensure

adequate implementation of previous corrective actions and compliance to the station's

OOS process prior to the Unit 1 planned outage (01PO2) beginning April 10,1999. The i

team identified that the OOS process was sound but was not properly implemented due to

personnel errors.

• On April 24,1999, Nuclear Oversight (NO) completed an assessment performed during

Q1PO2 of preparation of OOS and adherence to the OOS process. The assessors used a

combination of direct field observations and paperwork reviews and found the OOS process

and the implementation of the OOS process to be acceptable.

The following additional corrective actions were taken in respcnse to the February 18,1999,

OOS error.

• An Event Review Board was conducted for the February 18,1999, OOS error described

above.

l

. On March 15,1999, the following expectation was communicated to Operations through a

Daily Order Book entry.

Always operate components from the standard location whenever possible. If

circumstances prevent operating a component from the standard location, obtain Unit j

'

Supervisor permission prior to the operation and check the standard location to verify

that operation of the component is not prohibited (i.e. OOS) or restricted (i.e. Caution

Card).

. - Prior to April 2,1999, the following expectation was reinforced with the Operations planning

group.

The Operations planning group reviews the daily schedule (including work additions) to

ensure the plant lineup is correct for the performance of each scheduled task. Emphasis

will be placed on tasks that are scheduled to be performed in a different plant mode or

condition than usually performed, or a new procedure, er a procedure that has been

significantly revised and not performed since it was revised.

CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION

The following corrective actions were discussed in the March 19,1999, letter to the NRC and

committed to in that letter.

• The above mentioned multidiscipline team will perform a self-assessment in accordance ,

with the station's program for self-assessments in May 1999. This review will be conducted j

to ensure compliance to the station's OOS program is being properly maintained. (Action

Tracking No. 0000434903)

• An effectiveness review will be conducted by July 31,1999, to assess the effectiveness of

l

corrective actions from OOS trend PIF Q1999-00045.

(Action Tracking No. 0000504901)

I

i

- , u --

.

Att: chm:nt

Supplim ntal R: ply to NOV 50-254/98023-01

Page 4 of 4

e' NO will perform a follow up assessment in September,1999, to assess the station's I

l

compliance with the OOS program and effectiveness of the corrective actions. (Action

Tracking No. 0000434905)

f

l

I

The following additional corrective actions will be taken in response to the February 18,1999, '

OOS error.

. The expectation for operating components from standard locations will be included in OAP

0300-02, Conduct of Shift Operations, by June 11,1999. (Action Tracking No. 0000551401)

= QCAP 2200-03, Planning, Scheduling Operating Cycle Work, will be revised by June 11,

1999 to ensure that appropriate reviews are documented for priority A and B1 schedule

additions and the Operations planning group review expectation stated above is

documented in these reviews. (Action Tracking No. 0000551403)

l

i'

.

l

l

L