IR 05000254/2012007

IR 05000254-12-007, 05000265-12-007; 08/13/2012 - 08/31/2012; Quad Cities Nuclear Power Station, Units 1 and 2; Problem Identification and Resolution

ML12276A449
Person / Time
Site:	Quad Cities
Issue date:	10/02/2012
From:	Ring M NRC/RGN-III/DRP/B1
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-12-007
Download: ML12276A449 (24)

Text

October 2, 2012

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - PROBLEM IDENTIFICATION AND RESOLUTION 05000254/2012007 AND 05000265/2012007

Dear Mr. Pacilio:

On August 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Quad Cities Nuclear Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results which were discussed on August 31, 2012, with Mr. T. Hanley and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the inspection samples, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Quad Cities Nuclear Power Station was highly effective. Licensee-identified problems were entered into the corrective action program at a low threshold. Problems were effectively prioritized and evaluated commensurate with the safety significance of the problems. Corrective actions were effectively implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Operating experience was entered into the corrective action program and appropriately evaluated. The use of operating experience was incorporated into daily activities. Lessons learned from industry operating experience were effectively applied when appropriate. Audits and self-assessments were effectively used to identify problems, and appropriate actions were implemented to correct issues identified.

One NRC-identified finding of very low safety significance (Green) was identified. The finding involved a violation of NRC requirements. However, because of the very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy. If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Quad Cities Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Quad Cities Nuclear

Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by R. Orlikowski for/

Mark A. Ring, Branch Chief Branch 1 Division of Reactor Projects Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30

Enclosure:

Inspection Report 05000254/2012007; 05000265/2012007 w/Attachment: Supplemental Information

REGION III Docket Nos: 50-254; 50-265 License Nos: DPR-29; DPR-30 Report No: 05000254/2012007 and 05000265/2012007 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Dates: August 13 through August 31, 2012 Inspectors: R. Orlikowski, Project Engineer (Team Lead) J. McGhee, Senior Resident Inspector D. Jones, Reactor Inspector J. Hafeez, Reactor Inspector C. Mathews, Illinois Emergency Management Agency

Approved by: M. Ring, Chief Branch 1 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000254/2012007, 05000265/2012007; 08/13/2012 - 08/31/2012; Quad Cities Nuclear Power Station, Units 1 and 2; Problem Identification and Resolution.

This inspection was performed by three NRC regional inspectors, the senior resident inspector, and the onsite Illinois Emergency Management Agency inspector. One Green finding was identified by the inspectors. The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's pr ogram for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Quad Cities Nuclear Power Station was highly effective. The licensee had a low threshold for identifying problems and entering them into the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate wi th their safety significance; and corrective actions were implemented in a timely manner, co mmensurate with the safety significance. Operating experience was entered into the corrective action program and appropriately evaluated for applicability to station activities and equipment. The use of operating experience was integrated into daily activities. Audits and self-assessments were performed at appropriate frequencies and at an appropriate level to identify issues. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP. Inspectors did not identify any impediments to the establishment of a safety conscious work environment at the Quad Cities Nuclear Power Plant.

A. NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A finding of very low safety significance (Green) and associated NCV of 10 CFR 50, Appendix B, Criterion II, "Quality Assurance Program" was identified by the inspectors when they determined that a licensee-specified corrective action to prevent recurrence (CAPR) of a significant event was not completed as required by a quality assurance program implementing procedure, LS-AA-125, "Corrective Action Program (CAP) Procedure." Inspectors determined that the failure to complete the CAPR and install auxiliary contactors that had undergone enhanced testing (designated PQI testing in the licensee's documentation) before installation was a performance deficiency entered into the licensee's CAP as IR 1409378. Immediate corrective actions included performing a functional evaluation of installed components and quarantine of remaining spare parts. This finding was more than minor because the CAPR established criteria that should have prevented installation of the parts until testing was performed, but the parts were installed in the plant and the components were returned to service, thus impacting the reactor safety, initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Inspectors performed a SDP Phase 1 screening using IMC 0609 Attachment 4 and Appendix A Exhibit 1, Initiating Events Screening Questions," and answered all of the questions, "No." Therefore, the finding screened as very low safety significance or

Green.

The inspectors identified that this finding has a cross-cutting aspect in the area of Human Performance - Work Practices, in that, licensee personnel did not follow procedures (H.4(b)). Inspectors determined that the primary contributor to this finding was that procurement personnel did not follow procedure SM-AC-3019, "Parts Quality Process," which stated in Attachment 6 that "the station shall inform the test facility of any unique or special test requirements for the equipment. Otherwise, Exelon PowerLabs will apply standard PQI testing criteria for the item." Procurement personnel did not identify the enhanced PQI testing requirement to PowerLabs when the part was sent for testing. (Section 4OA2.1.b(3))

B. Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of problem identification and resolution as defined in Inspection Procedure 71152. .1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensee's corrective action program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel. The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last NRC problem identification and resolution inspection in August 2010. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed issue reports generated as a result of facility personnel's performance in daily plant activities. In addition, the inspectors reviewed issue reports (IRs) and a selection of completed investigations from the licensee's various investigation methods, which included root cause, apparent cause, equipment apparent cause, common cause, and quick human performance investigations.

The inspectors selected the low pressure coolant injection system for a detailed review. The inspectors' review was to determine whether the licensee staff were properly monitoring and evaluating the performance of the system through effective implementation of station monitoring programs.

A 5-year review was performed to assess the licensee staff's efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the low pressure coolant injection system. During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's corrective action program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the

station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports. This included completed investigations and NRC findings, including non-cited violations.

b. Assessment

(1) Effectiveness of Problem Identification Issues were generally being identified at a low threshold, evaluated appropriately, and corrected in the CAP. Workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared, computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. These processes included determining the issue's significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the station was generally effective at prioritizing issues commensurate with their safety significance. The inspectors observed that the majority of issues identified were of low-level and were either closed to trend, closed to actions taken, or characterized at a level appropriate for a condition evaluation. Issues were being appropriately screened by both the Station Oversight Committee and Management Review Committee. There were no items in the operations, engineering, or maintenance backlogs that were risk-significant, individually or collectively.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions The effectiveness of corrective actions for the items reviewed by the inspectors was generally appropriate for the identified issues. Over the 2-year period encompassed by the inspection, the inspectors identified no significant examples where problems recurred. Additionally, during review of the effectiveness of licensee corrective actions to address an issue with foreign material found in some switch auxiliary contactors, the team identified that the licensee failed to implement the actions required by a corrective action to prevent recurrence (CAPR).

Observations

• Timeliness of Followup Actions Inspectors reviewed IR 1172248 which documented that the 2C residual heat removal service water breaker was slow to close during operation. The IR was written, troubleshooting was performed, switch contacts were burnished, and retest confirmed that the components were operating properly. The pump was then returned to service. Approximately 1 month later, operators again noticed that the pump was slow to start and IR 1187270 was written. More troubleshooting was performed, and when no specific problem could be identified, the breaker was replaced. The removed breaker was quarantined and the work order remained open to perform troubleshooting on the breaker at a later date.

About 9 months later, Dresden station experienced a slow operating breaker. Troubleshooting determined that Dresden's breaker was slow to operate due to grease hardening (IR 1365523) in the latch roller. The breaker that Quad Cities had quarantined was also tested and found that it also showed signs of grease hardening in that component. The licensee determined that the issue potentially impacted other 4kV breakers. An operability evaluation was performed and an aggressive schedule was developed to clean and lubricate the affected components. Inspectors concluded that had the Quad Cities breaker troubleshooting been performed promptly on the quarantined breaker, the potential common cause failure mechanism could have been identified sooner. Timely identification of the potential common cause failure mechanism at Quad Cities and communication to Dresden could have provided Dresden personnel with the opportunity to implement corrective actions to prevent the 4kV breaker failure at Dresden.

• Findings

Introduction:

A finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion II, "Quality Assurance Program" was identified by the inspectors when they determined that a licensee specified corrective action to prevent recurrence of a significant event was not completed as required by a quality assurance program implementing procedure, LS-AA-125, "CAP Procedure."

Description:

On August 12, 2010, Unit 1 scrammed while operators were performing a planned flow reversal on the main condenser. The licensee determined that although the equipment was not safety related, the equipment performance and plant transient represented a significant condition, and management assigned a root cause investigation. The licensee's investigation determined that some valves did not reposition per the automatic flow reversal sequence due to foreign material inside auxiliary contactors.

Several corrective actions were developed including two CAPRs. One of those CAPRs (CAPR 19) was to develop and perform specific, enhanced testing during the receipt inspection process since the contactors were sealed components, and visual inspection of the internals was not possible to determine if foreign material that could impact contactor performance was present. Enhanced testing of the contactors was developed, and the enhanced testing requirement was added to the equipment identification documentation in the supply program.

The second CAPR (CAPR 48) was written to install new auxiliary contactors into Units 1 and 2 that had undergone this enhanced testing. Corrective action to prevent recurrence 48 stated: "Replace all Unit 1 and Unit 2 auxiliary contacts in the breakers associated with the main condenser reversing valves with auxiliary contacts purchased in accordance with the control implemented per CAPR 1100602-47, and subjected to the PQI testing instituted per CAPR 1100602-19."

While reviewing the CAPRs, inspectors asked for verification that the enhanced testing was performed for the switches installed in the plant. When the licensee's staff searched for documentation of the completed testing, they identified that the auxiliary contactors that were installed in Units 1 and 2 to complete CAPR 48 did not receive the enhanced testing required by CAPR 19. When new contactors were sent to the contract organization for testing, procurement specialists did not explicitly request the enhanced testing, and it was not performed. Therefore, inspectors determined that although the documentation indicated CAPR 48 was completed, the contactors installed in the plant had not been tested as required by the CAPR prior to being installed in the plant and released for service.

Inspectors also identified that the effectiveness review performed by the licensee after the CAPR closure documentation was completed failed to identify that the installed parts had not been properly tested prior to installation. Per procedure LS-AA-125, "CAP Procedure," an effectiveness review is defined as "An evaluation performed to determine whether a CAPR or corrective action has effectively resolved the condition and whether the CAPR(s)/CA(s) has effectively eliminated or reduced recurrence rate to an acceptable level." This represented a missed opportunity for the station to identify and correct inappropriate action.

Inspectors reviewed performance of the auxiliary contactors installed on both units and determined that contactor operation since the installation date essentially performed the same function as the enhanced testing. No problems with the contactor performance had been observed through multiple flow reversal evolutions. Inspectors reviewed the functional evaluation of the installed contactors and had no ongoing concerns regarding the quality of the installed parts.

Analysis:

Inspectors determined that the failure to complete CAPR 48 and install auxiliary contactors that had undergone enhanced testing before installation was a performance deficiency and a finding. The finding was more than minor because it impacted the reactor safety, initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The specific attribute affected was equipment performance to ensure the availability and reliability of equipment. The finding was compared to the work in progress examples provided in Appendix E of IMC 0612 and determined to be similar to example 5.c, installation of a solenoid that did not meet the specification. This finding was more than minor because the CAPR established criteria that should have prevented installation of the parts until testing was performed, but the parts were installed in the plant and the components were returned to service, thus potentially impacting equipment reliability.

Inspectors performed an SDP Phase 1 screening using IMC 06 and IMC 0609 Appendix A Exhibit 1, Initiating Events Screening Questions," and answered all of the questions, "No." Therefore, the finding screened as very low safety significance or Green.

The inspectors identified that this finding has a cross-cutting aspect in the area of Human Performance - Work Practices, in that, personnel work practices support human performance. Specifically, the licensee defines and effectively communicates expectations regarding procedural compliance and procedures (H.4(b)). Inspectors determined that the primary contributor to this finding was that procurement personnel did not follow procedure SM-AC-3019, "Parts Quality Process," which states in Attachment 6 that "the station shall inform the test facility of any unique or special test requirements for the equipment. Otherwise, Exelon PowerLabs will apply standard PQI testing criteria for the item." Procurement personnel did not identify the enhanced testing requirement to PowerLabs when the part was sent for testing.

Enforcement:

Title 10 CFR 50, Appendix B, Criterion II, states that a quality assurance program shall be established, and this program shall be documented by written policies, procedures, and instructions and shall be carried out throughout plant life in accordance with those procedures and instructions.

Station procedure LS-AA-125, "CAP Proc edure," implements requirements of the Quad Cities Quality Assurance Topical Report Chapter 16, "Corrective Action."

LS-AA-125 step 4.8.1.4 states that to complete an assigned CAPR, the proposed action should be completed and implemented.

Contrary to the above, licensee individuals did not follow the quality program procedural requirements when completing CAPR 48 in the corrective action documentation. Specifically the licensee did not verify the actions to perform the enhanced testing prior to placing the auxiliary contactors in the plant were complete or implemented as intended. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as IR 1409378, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000254/2012007-01; 05000265/2012007-01 "CAPR Not Completed"). As corrective action, the licensee performed a functional evaluation of installed components, quarantined remaining spare parts and initiated enhanced testing on all contactors still in inventory.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented. b. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments. No issues were identified during the inspectors' review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staff's ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. b. Assessment The inspectors concluded that self-assessments, NOS audits, and other assessments were typically effective at identifying most issues. The inspectors concluded that these audits and self-assessments were generally completed in a methodical manner by personnel knowledgeable in the subject area. Corrective actions associated with the identified issues were implemented commensurate with their safety significance.

The inspectors also observed that issues identified in self-assessments and audits were captured in the CAP. For example, the NOS organization was effective in identifying a number of issues needing management attention and utilized a low threshold for placing these findings into the CAP. Inspectors identified that the title to a corrective action associated with a previous finding had been changed to a new title that was not related to the IR. Inspectors found that IR 1204785 was titled "Radwaste Valve Lineup Incorrect" in the subject line of the IR when in fact the IR was related to an NRC inspection report non-cited violation about a leak on the Unit 1 emergency diesel generator cooling water pump (EDGCWP) room cooler. The licensee was unable to determine when the IR subject line was changed but stated that as long as the IR was open anyone could change the subject line content since the data base field was not locked and did not record a history of changes. After the inspectors identified this issue the IR title was revised to "U1 EDGCWP Cubicle Cooler Leak". While the subject field is not critical to problem resolution, individuals using the licensee's data base search tool rely heavily on the title or subject line to identify related issues when personnel are searching the CAP program as part of an OE, assessment, extent of condition review or audit. The integrity and validity of the subject line is critical to ensure related issues are easily identified. The significance of this title change is that site IR investigative searches involve word searches and the incorrect title to IR 1204785 could have resulted in this IR not being found. While this was the only example of an incorrect subject line identified by the inspectors, inspectors felt that the specific vulnerability was important enough to document this observation in this report even though the issue did not represent a finding that was more than minor in the Reactor Oversight Process.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensee's safety conscious work environment through the reviews of the facility's employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. In order to assess Quad Cities' safety culture, interviews were conducted with a representative group of station employees over the course of the first and third weeks of the inspection. Additionally, the site's most recent safety culture assessment was reviewed and the Employee Concerns Program (ECP) coordinators were interviewed.

b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong safety conscious work environment and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised or knew of anyone who had failed to raise issues. Additionally, individuals were aware of the different processes available for raising safety concerns, including the stations CAP, raising concerns to supervisors and managers, and the station's ECP. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment.

The inspectors determined that the Employee Concerns Program was being effectively implemented. The inspectors noted that the licensee had appropriately investigated and taken constructive actions to address potential cases of harassment and intimidation for raising issues.

c. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 31, 2012, the inspectors presented the inspection results to Mr. T. Hanley and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Hanley, Site Vice President

K. O'Shea, Operations Director

W. Beck, Regulatory Assurance Manager

J. Garrity, Maintenance Director

R. Larkin, Site Project Management Manager

D. Collins, Radiation Protection Manager

K. Johnson, Site supply Manager

A. Misak, Nuclear Oversight Manager

V. Neels, Chemistry/Environ/Radwaste Manager

K. Ohr, Site Engineering Director

T. Scott, Work Management Director

R. Sieprawski, Training Support Manager

Nuclear Regulatory Commission

Mark

A. Ring, Chief, Reactor Projects Branch 1

Attachment

LIST OF ITEMS

Opened

05000254/2012007-01; NCV CAPR Not Completed

05000265/2012007-01 (Section 4OA2.1b.3)

Closed

05000254/2012007-01; NCV CAPR Not Completed

05000265/2012007-01 (Section 4OA2.1b.3)

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed t