IR 05000254/2016007

NRC Problem Identification and Resolution Inspection Report 05000254/2016007; 05000265/2016007

ML16305A345
Person / Time
Site:	Quad Cities
Issue date:	10/31/2016
From:	Karla Stoedter NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2016007
Download: ML16305A345 (33)

Text

UNITED STATES ber 31, 2016

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000254/2016007; 05000265/2016007

Dear Mr. Hanson:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Quad Cities Nuclear Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed at an exit meeting on September 30, 2016, with Mr. K. Ohr and other members of your staff.

The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Quad Cities Nuclear Power Station, Units 1 and 2, was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP. A risk based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance.

Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Quad Cities Nuclear Power Station.

Licensee staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety. Based on the results of this inspection, no finding of significance was identified.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents 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/

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

Enclosure:

IR 05000254/2016007; 05000265/2016007

REGION III==

Docket Nos: 50-254; 50-265 License Nos: DPR-29; DPR-30 Report No: 05000254/2016007; 05000265/2016007 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Dates: September 12, 2016, through September 30, 2016 Team Leader: R. Ng, Project Engineer Inspectors: R. Murray, Senior Resident Inspector - Quad Cities J. Rutkowski, Project Engineer J. Mancuso, Reactor Engineer L. Rodriguez, Reactor Inspector C. Mathews, Resident Inspector, Illinois Emergency Management Agency (IEMA)

Approved by: K. Stoedter, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000254/2016007; 05000265/2016007; 09/12/2016-09/31/2016; Quad

Cities Nuclear Power Station, Units 1 and 2; Identification and Resolution of Problems.

This inspection was performed by four region-based inspectors, the IEMA resident inspector and the Quad Cities Senior Resident Inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 6, dated February 2016.

Identification and Resolution of Problems On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Quad Cities Nuclear Power Station, Units 1 and 2, was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP. A risk based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance.

Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Quad Cities Nuclear Power Station.

Licensee staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that the licensees performance in each of these areas supported nuclear safety.

Although implementation of the CAP was determined to be effective overall, the inspectors identified several issues that represented potential weakness of the program.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of problem identification and resolution (PI&R) inspection as defined by Inspection Procedure 71152, Problem Identification and Resolution. Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the CAP at Quad Cities Nuclear Power Station to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as the Management Review Committee meeting and the Station Ownership Committee meeting. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the CAP.

The inspectors reviewed selected issue reports (IRs) across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensees CAP. The majority of the risk-informed samples of IRs reviewed were issued since the last NRC biennial PI&R inspection completed in September of 2014. The inspectors also reviewed selected issues that were more than 5 years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, and workgroup evaluations. The inspectors assessed the scope and depth of the licensees evaluations. For issues that were characterized as significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for issues that were less significant, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors performed a 5-year evaluation of safety-related relay failures based on input from the resident staff. These safety-related relay failures encompassed multiple risk significant systems. The primary purpose of this review was to determine whether the licensee was monitoring and addressing performance issues of safety-related relays.

A 5-year review of the aging management program was also performed to assess the licensees efforts in monitoring and correcting age-related performance issues.

Specifically, the inspectors reviewed implementing Aging Management Program procedures, attended CAP meetings to observe how aging management issues were being addressed, reviewed licensee CAP documents related to aging management issues, and performed a walkdown of the high pressure coolant injection rooms to assess the licensees evaluation of some aging management related issues of the system. The CAP documents selected for review were chosen from a list of documents that were either screened by the licensee as being related to aging management, or because they contained aging related keywords such as corrosion and/or aging in their titles. The inspectors performed walkdowns, as needed, to verify the resolution of issues.

The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors also performed walkdowns, as necessary, to verify the resolution of the issues.

b. Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that Quad Cities Nuclear Power Station was generally effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were normally identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution.

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

The inspectors performed a 5-year review of safety-related relay failures. As part of this review, the inspectors interviewed the system engineer and supervisor, reviewed a sample of equipment apparent cause evaluations for relay failures, IRs, operating experience, test calibration data, and Maintenance Rule status. The inspectors reviewed licensees CAP and work management system procedures that provided guidance for trending. The inspectors concluded that safety-related relay concerns were identified and entered into the CAP at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance.

i) Observation CAP Classification Based on Plant Condition On February 6, 2014, the licensee initiated AR 1617892 for a through wall leak on a service water supply line to the 2B residual heat removal service water (RHRSW)cubicle cooler. The issue was assigned a significance level 3 in the CAP because it resulted in an unplanned Limiting Condition for Operation (LCO) entry which could lead to a unit shutdown. The issue was then assigned a B investigation class (Apparent Cause Evaluation) to be evaluated. These assignments were performed in accordance with CAP procedure PI-AA-120, Issue Identification and Screening Process. On September 10, 2015, the licensee initiated AR 2553103 for a similar through wall leak on a similar line, the service water supply line to the 2A RHRSW cubicle cooler. However, that issue was assigned a significance level 4 and a D investigation class (no formal investigation required) because it was discovered during post maintenance testing when the RHRSW pump was already in a LCO due to planned maintenance. Since the leak in AR 2553103 did not cause an unplanned LCO entry due to the plant conditions at the time it was discovered, it was treated as a less significant issue than the leak in AR 1617892, even though both leaks were nearly identical. Therefore, the licensees CAP process allows the significance level, and as a result, the investigation class of identified issues to be influenced by plant conditions at the time of discovery. This could lead to a significant issue being treated and reviewed as less significant simply because it was discovered during a plant condition where entry into an unplanned LCO was not warranted (i.e. during an outage). Although the licensee appropriately dispositioned the issue in AR 2553103, the inspectors identified this as a vulnerability in the licensees CAP. It is important to correctly assign the significance level of an issue because it directly affects the level of review, and ultimately, the corrective actions assigned to address the issue.

ii) Findings No findings were identified.

(2) Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that the station was effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk.

The inspectors determined that the Management Review Committee meetings and the Station Ownership Committee meetings were generally thorough and maintained a high standard for evaluation quality. Members of the Management Review Committee discussed selected issues in sufficient detail and challenged each other regarding their conclusions and recommendations.

The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

i) Observations Insufficient Documentation During the latest refueling outage, Q2R23, the licensee identified that 17 General Electric Type HFA relays were deficient and had not been repaired or replaced. The licensee documented in the CAP that the relays should be repaired or replaced prior to plant startup. These relay deficiencies were reviewed by the Outage Scope Panel for addition into the outage. However the outage panel decided that repair was not necessary and removed the work from the outage. No written justification was provided in the CAP and there was no Outage Scope Panel meeting notes to document why the repair was not necessary. Upon questioning by the inspectors, the licensee was able to provide an engineering evaluation that determined that the relays were not degraded enough to require repair/replacement during the refueling outage. This information was not contained in the IR when the IR was closed.

Similarly, on August 20, 2014, the licensee initiated AR 1694580 due to elevated levels of contamination being discovered near the Unit 2 reactor water clean-up phase separator decant pump. The contamination was believed to be from a leak of the pump due to the discovery of dried resin near the pump. Since the pump had been recently run, the leak was not believed to be an active leak. The corrective action document specified that no work order was required because the pump would be decontaminated and then monitored for an active leak. If an active leak were to be discovered, a separate corrective action document would be generated. When reviewing the actions assigned for the issue, the inspectors noted that although there was an action to decontaminate the pump, there was no action to track the monitoring of the pump for active leakage. From discussions with the licensee, although the monitoring of the pump was not being tracked in the corrective action document, individuals involved were able to confirm that the monitoring had been accomplished and that an active leak had not been identified. The inspectors discussed with the licensee the importance of ensuring the CAP properly tracks and documents actions necessary to resolve identified issues.

Even though the lack on documentation in the CAP was not wide spread, the inspectors did come across a number of these examples and therefore, considered the lack of complete information a weakness in the CAP. This weakness has the potential to lead to degraded or inoperable conditions not being recognized. Therefore, the licensee needs to be more vigilant to ensure that complete information is provided before a CAP item can be closed.

ii) Findings No findings were identified.

(3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Since 2013, outstanding corrective actions had been trending down. As of the beginning of the inspection, the licensee had 29 corrective actions open and only 2 of these were greater than 2 years-old. The inspectors sampled a number of these corrective actions in each significance level and determined that they were being tracked with appropriate level of attention to ensure their completion. The inspectors also sampled other action items and verified that the licensee did not systematically downplay the action items as non-corrective actions.

Problems identified using root or apparent cause methodologies were resolved in accordance with the CAP procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely.

The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

The inspectors also performed a 5-year extensive review of the licensees implementation of their Aging Management Program. In general, the licensee was appropriately implementing their Aging Management Program at the station. The licensee was following their program and identifying aging related issues. Those issues were properly evaluated under the CAP and adequately dispositioned. Identified aging related issues were also being adequately monitored in order to identify further degradation.

i) Observations Corrective Action Not Complete In NRC inspection report 2015004, the NRC issued a licensee-identified non-cited violation for the licensees failure to have an adequate procedure for installing fuse blocks in safety-related breakers. The procedure did not provide the operators guidance to ensure the fuse blocks were fully seated. This resulted in the breaker closing springs not being charged following post-maintenance testing of the 1A residual heat removal pump breaker and the system being declared operable on August 21, 2015, when in fact, the system was inoperable.

In the licensees equipment apparent cause evaluation (EACE), the licensee stated that because not all fuse blocks were fully seated even when they were flush with the fuse block holder, some fuse blocks required additional pressure when being seated, and would actually be slightly recessed into the fuse block holder. Therefore, procedure QCOP 6500-07, Racking in a 4160 Volt Horizontal Type AMHG or G26 Circuit Breaker, contained incomplete guidance for ensuring the fuse blocks were properly installed. The licensees corrective actions were to revise the procedure to include discussion that the installed position for some fuse blocks would be slightly beyond flush and might require additional pressure to fully seat. Direction would also be added to pull on the fuse block after insertion to verify it was snug and fully seated.

During this PI&R inspection, the inspectors reviewed the licensees corrective actions associated with this violation. Although the licensee did add guidance in the discussion section of the procedure to provide direction on how to ensure the fuse blocks were fully inserted, Section F of the procedure that contained the execution steps for inserting fuse blocks still directed the fuse block to be fully inserted and flush with the fuse block holder. The inspectors determined that the licensee failed to fully implement the corrective actions as stated in the EACE.

Given that the licensee had briefed all operations crews on the direction to properly insert fuse blocks into the holders and added this skill to their training curriculum for operations, the inspectors determined the likelihood of this event occurring again was minimal, and therefore determined the inadequate procedure change was a minor corrective action violation. The licensee entered this issue into the CAP as AR 2716518 and is evaluating actions for changing the procedure.

ii) Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed the OE program implementing procedures, attended CAP meetings to observe the use of OE information, and reviewed licensee evaluations of OE issues and events. The objective of the review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were appropriate, whether the licensees 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, were identified and implemented in an effective and timely manner.

b.

Assessment In general, OE was appropriately used at the station. Industry OE was disseminated across the various plant departments. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to Quad Cities Station was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

c.

Observations Preventive Maintenance of Safety-Related Relays Since 2014, the inspectors identified at least three failures of safety-related relays that were attributed to age-related causes. In some of the failure examples, the licensee identified that there were no preventive maintenance tasks (i.e. visual inspection or contact resistance testing) performed on the failed relays. In each of these instances, the licensee corrected the issues and performed extent of condition reviews as appropriate. However, the inspectors questioned the licensee on their plan to perform a more comprehensive review of their safety-related relays, to include identification of component age and associated preventive maintenance tasks. The licensee established the service life of their safety-related relays through their performance centered maintenance (PCM) template. The PCM template was based on Electric Power Research Institute (EPRI) Report 3002000541, Relay Series - Specific Guidance:

Generic Service Life Analysis (GSLA) and Preventive Maintenance (PM) Templates, dated July 2013. The EPRI report states, in part, The service lives in this evaluation assume that all recommended preventive maintenance, inspections, and surveillances are performed as intended. After discussing the service life of safety-related relays with the licensee, the inspectors determined the licensee had identified a list of relays to be reviewed. However, the licensee did not have a well-documented, specific, or systematic plan to identify gaps between the EPRI report and existing assigned preventive maintenance tasks for safety-related relays. The inspectors did not identify any specific instances where the licensee was not meeting their PCM template for service life. The inspectors considered this a gap in the preventive maintenance program that could potentially lead to failures.

d. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments and Nuclear Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues were entered into IRs as required by the CAP procedures. The inspectors also determined that findings from the CAP self-assessment were consistent with the inspectors assessment.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys Employee Concerns Program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2015 safety culture survey and meeting minutes of the Safety Culture Monitoring Panel.

The inspectors held scheduled interviews with approximately 30 non-supervisory individuals and approximately 6 first-line supervisors in various group and individual settings, to assess their willingness to raise nuclear safety issues. Additionally, the inspectors interviewed other personnel informally during plant walkdown to ascertain their views on the effectiveness of the CA program and their willingness and freedom to raise issues.

The individuals in the scheduled interviews were randomly selected to provide a distribution across various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also included discussion on any changes in the plant environment over the last 12 months. Items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• knowledge and understanding of ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator; reviewed program logs from 2014 through 2016; and reviewed selected case files to identify any emergent issues or potential trends.

b. Assessment The inspectors did not identify any issues of concern regarding the licensees SCWE.

Information obtained during the interviews indicated that an environment was established where licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CAP and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.

c. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting On September 30, 2016, the inspectors presented the inspection results to Mr. K. Ohr and other members of the licensee staff. The licensee acknowledged the issues presented. One item had remained open pending licensees evaluation. This open item was discussed and closed during a teleconference on October 6, 2016. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Ohr, Plant Manager

W. Beck, Regulatory Assurance Manager

T. Bell, Engineering Director

R. Craddick, Organization Effectiveness Manager

D. Collins, Radiation Protection Manager

J. Cox, Operations Support Manager

R. Earley, Outage Manager

R. Hight, Maintenance Director

H. Dodd, Operations Manager

T. Wojcik, Engineering Program Manager

J. Wooldridge, Chemistry Manager

NRC

K. Stoedter, Branch Chief

R. Murray, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open None

Closed

None

Discussed

None