IR 05000254/1998008
| ML20247E671 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247E589 | List: |
| References | |
| 50-254-98-08, 50-254-98-8, 50-265-98-08, 50-265-98-8, NUDOCS 9805180414 | |
| Download: ML20247E671 (23) | |
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d U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30 Report Nos.: 50-254/98008(DRS); 50-265/98008(DRS)
Licensee: Commonwealth Edison Company Facility: Quad Cities Nuclear Power Station
. Units 1 and 2 Location: 22710 206th Avenue North Cordova,IL 61242 Dates: April 7 - 9,1998 April 14 - 17,1998 inspector: Martin J. Farber, Reactor Engineer, Rlll Peter A. Balmain, Operations Engineer, NRR Stephen A. Eide,INEEL Approved by: James A. Gavuta, Chief Engineering Specialists Branch 1 Division of Reactor Safety 9005100414 980511 PDR G ADOCK 05000254 pg
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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station NRC Inspection Reports 50 254/98008(DRS); 50-265/98008(DRS)
This inspection included a review of the licensee's implementation of 10 CFR 50.65,
" Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The report covers a three-day in-office inspection, and a four-day on-site inspection by a Region til inspector, an Office of Nuclear Reactor Regulation inspector, and a contractor from the Idaho National Engineering & Environmental Laborator Maintenance
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Scoping of structures, systems, and components (SSCs) was considered acceptable. A complete rescoping effort properly identified structures, systems, and components, and functions required to be in the maintenance rule program scope; no omissions were identifie .
Based on reviews of the licensee's risk ranking methodology and results, the inspectors concluded that the licensee's approach to establishing the risk ranking for SSCs within the scope of the maintenance rule was good. Two functions, identified during the baseline inspection as improperly classified as low safety significance, were naw correctly classifie .
Performance criteria established to demonstrate the effectiveness of preventive maintenance of (a)(2) systems and functions had been extensively revised, were appropriate, and were properly justifie .
The process for evaluating events and problems for functional failures and maintenance preventable functional failures had been revised and strengthened. Guidance for assessing events and problems was strengthened and a monthly requirement to evaluate maintenance rule system performance was institute .
Implementation of goals and monitoring for systems and functions classified (a)(1) was improved. Inappropriate goals, identified during the September 1997 baseline inspection, had been corrected. Adequate goals had been developed for those functions noted in the baseline report as having goals and corrective action plans under development. Goals and corrective action plans for all SSCs and functions classified as (a)(1) were considered acceptabl .
The inspectors noted many SSCs and functions were classified as (a)(1) and observed that a significant portion of SSCs and functions modeled in the Individual Plant Examination had exceeded performance criteria. This led the inspectors to question whether the current baseline core damage frequency estimate was valid and whether the licensee understood the underlying cause for so many systems not performing up to station expectations.
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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station NRC Inspection Reports 50-254/98008(DRS); 50-265/98008(DRS)
This inspection included a review of the licensee's implementation of 10 CFR 50.65,
" Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The report covers a three-day in-office inspection, and a four-day on-site inspection by a Region lil inspector, an Office of Nuclear Reactor Regulation inspector, and a contractor from the Idaho National Engineering & Environmental Laborator Maintenance i
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Scoping of structures, systems, and components (SSCs) was considered acceptable. A complete rescoping effort properly identified structures, systems, and components, and functions required to be in the maintenance rule program scope; no omissions were identifie .
Based on reviews of the licensee's risk ranking methodology and results, the inspectors concluded that the licensee's approach to establishing the risk ranking for SSCs within the scope of the maintenance rule was good. Two functions, identified during the baseline inspection as improperly classified as low safety significance, were now correctly classifie . Performance criteria established to demonstrate the effectiveness of preventia maintenance of (a)(2) systems and functions had been extensively revised, were appropriate, and were properly justifie . The process for evaluating events and problems for functional failures and maintenance preventable functional failures had been revised and strengthened. Guidance for assessing events and problems was strengthened and a monthly requirement to evaluate maintenance rule system performance was institute . Implementation of goals and monitoring for systems and functions classified (a)(1) was improved. Inappropriate goals, identified during the September 1997 baseline inspection, had been corrected. Adequate goals had been developed for those functions noted in the baseline report as having goals and corrective action plans under development. Goals and corrective action plans for all SSCs and functions classified as (a)(1) were considered acceptabl . The inspectors noted many SSCs and functions were classified as (a)(1) and observed l that a significant portion of SSCs and functions modeled in the Individual Plant
, Examination had exceeded performance criteria. This led the inspectors to question j whether the current baseline core damage frequency estimate was valid and whether the licensee understood the underlying cause for so many systems not performing up to station expectation *
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Quality Assurance
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Two 1998 corporate self-assessments of the Quad Citie3 maintenance rule program j implementation were thorough and provided good infon 1ation for the station's maintenance rule staff. In turn, the maintenance rule s iff adequately responded to the i issues raised in a timely manne l Engineering
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System engineers were experienced and displayed a good knowledge of their assigned i systems. The inspectors determined that the maintenance rule staff's efforts to improve system engineers' knowledge and opinion of the maintenance rule program were cffectiv l l
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Report Details Summarv of Plant Status Units 1 and 2 were both shut down before the inspection and remrWd in that condition during the inspectio ]
l Introduction This inspection included a review of the licensee's implementation of 10 CFR 50.65,
" Requirements for Monitoring the Effectiveness of Maintenance at Nuclear <>ower Plants." The l report covers a three-day in-office inspection, and a four-day on-site inspection by a Region til inspector and an Office of Nuclear Reactor Regulation inspector, and a contractor from the Idaho National Engineering and Environmental Laborator II. Maintenance l
M1 Conduct of Maintenance (62706)
M1.1 Scooe of Structures. Systems. and Comoonents included Within the Rule insoection Scoce The inspectors reviewed scoping documentation to determine if the appropriate SSCs and functions wme included within the maintenance rule program in accordance with '
10 CFR 50.65(b). The inspectors used NRC inspection' Procedure 62706, Nuclear Management Resource Council (NUMARC) 93-01, Regulatory Guide 1.160, the Quad Cities Station Final Safety Analysis Report, Emergency Operating Procedures, and other information as references. The inspectors conducted a complete review of the station's scoping report to determine if all necessary functions had been correctly identified during the rescoping effort. To evaluate scoping decisions, the inspectors examined all SSCs and functions that could have been included within the scope of the i rule, but were not.
( Observations and Findinos The inspectors noted that many functions had been combined with others to substantially reduce the overall number of functions being tracked. The inspectors verified that this was done correctly by examining combined functions for the eight systems examined in detail as part of this inspection. Other systems were evaluated on a sample basis. No cases were identified where combining functions resulted in improperly omitting a function from the program scope. The inspectors did not identify any system functions that should have been included within the scope but were not.
' This included a complete review of the bases for all functions considered out of scop l
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. Conclusions
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The inspectors concluded that because of the licensee's rescoping effort, SSCs and !
functions were correctly scoped into the maintenance rule progra l M1.2 Safety Determination and Risk Rankina Insoection Scoce Paragraph (a)(1) of the maintenance rule required that goals be commensurate with !
safety. Iniplementation of the rule using the guidance contained in NUMARC93-01 also j required that safety be taken into account when setting performance criteria and j monitoring under (a)(2) of the rule. This safety consideration would then be used to !
determine if the SSCs and functions should be monitored at the plant, system, or train j level. The inspectors reviewed the methods that the licensee established for making l these required safety determinations. The inspectors also reviewed the safety l determinations for all systems and function Observations and Findinas on Risk Determinations l
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l The licensee's process for establishing the safety significance of SSCs within the scope ;
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of the Maintenance Rule was documented in Quad Cities procedure QCAP 0400-18,
" Station Compliance with the Maintenance Rule," Revision 2 (March 27,1998). This j document was reviewed and found to adequately describe the process of determining safety significanc For SSCs modeled in the licensee's individual Plant Examination, three importance measures were evaluated (core damage frequency contribution, risk achievement worth, and risk reduction worth), as recommended in NUMARC 93-01. If a basic event's importance measure met one or more of the criteria, then the SSC associated with that basic event was judged to have potentially high safety significance. Because the NUMARC 93-01 guidance considers that a basic event has potentially high safety significance if any of the three importance measure criteria are met, the approach used by the licensee was adequate. The expert panel then made the final determinations with respect to safety significance. The inspectors verified that the two functions, identified during the September 1997 baseline inspection as inappropriately classified as low safety significance, had been correctly reclassified. The complete review of safety significance determinations showed that no SSCs indicated to have high safety significance from the Individual Plant Examination importance measums were i downgraded to low safety significance. This issue was an inspectior:' flow up in the i baseline inspection and is considered closed.
I For SSCs not modeled in the Individual Plant Examination, the expert panel determined the risk significance by using the Weighted Average Decision Process, which is an y expert judgment, Delphi approach. This approach considered how important each SSC was with respect to four accident response functions and six normal operation function Results for each function were weighted and summed to obtain a single importance
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l number (ranging from 112.8 to 1128) for each SSC function. SSCs with importance
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numbers greater than or equal to 300 were considered to have high safety significance.
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' Conclusions on Risk Determinations Based on the reviews discussed above, the team concluded that the licensee's approach to establishing the risk ranking for SSCs within the scope of the Maintenance Rule was goo M1.3 (a)(1) Goal Settino and Monitorina and (a)(2) Preventive Maintenance a, insoection Scooe The inspectors reviewed program documents to evaluate the process established to set goals and monitor under (a)(1) and to venfy that preventive maintenance was effective under (a)(2) of the maintenance rule. The inspectors also discussed the program with appropriate plant personnel and reviewed the following systems in depth:
(a)(1) systems (a)(2) syster.ns High Pressurn Coolant injection Condensate Feedwater Standby Gac Treatment Feedwater Control Condensate Booster 4160 Volt Switchgear Standby Liquid Control The inspectors reviewed each of these systems to verify that goals or performance criteria were estab'ished commensurate with safety, that industry wide operating experience was taken into consideration, where practical, that appropriate monitoring j and trending were being performed, and that corrective actions were taken when an SSC failed to meet its goal or performance criteria or experienced a maintenance preventible functional failur b.1 Reliability and Unavailability Performance Criteria
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The team reviewed performance criteria to determine if the licensee had adequately set performance criteria under (a)(2) of the maintenance rule consistent with the assumptions used to establish the safety significance. Section 9.3.2 of '
NUMARC 93-01 recommended that high safety significance performance criteria be i set to assure that the availability and reliability assumptions used in the probabilistic i safety assessment (PSA) were maintaine The licensee's approach to establishing performance criteria was outlined in Quad Cities procedure QCAP 0400-18, Revision 2, and a memorandum from M. A. Melnicoff to C. l Sibley," Comed Guidelines for the Establishment of a PSA Basis for Setting l Maintenance Rule Reliability F 'rformance Criteria Per 10CFR50.65 Requirements,"
Revision 1 (September 16,1957).
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The team reviewed all of the SSC and function performance criteria for appropriatenes An in-depth review of performance criteria was conducted for those functions that were specific violation examples in the Notice of Violation. For all SSCs and functions i reviewed, the appropriate types of performance criteria had been used. For example, all I
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high safety significance functions had system or train level unavailability and reliability performance criteria. Also, low safety significance, standby SSCs had system or train level unavailability or reliability performance criteria. Finally, plant-level performance criteria, where used, were appropriate indicators of SSC performanc .
The team also reviewed the Individual Plant Examination basis for unavailability and reliability performance criteria. In general, the unavailability performance criteria were .
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not based on values used in the Individual Plant Examination. Therefore, the licensee performed a sensitivity calculation to determine the impact on core damage frequency of the unavailability performance criteria. The calculation was documented in Calculation Number QDC-0201-N-0469, Revision 1 (April 2,1998). The core damage frequency changed from 2.2E-6/ year to 3.6E-6/ year, or a 61% increase. This was considered acceptabl I For reliability performance criteria, the licensee used the Electric Power Research Institute methodology outlined in Technical Bulletins 96-11-01, " Monitoring Reliability for the Maintenance Rule" (November 1996) and 97-3-01," Monitoring Reliability for the Maintenance Rule - Failures to Run" (March 1997). However, for 14 system functions, the licensee chose reliability performance criteria that allowed more failures than indicated by that methodology. Therefore, the licensee did an Individual Plant Examination sensitivity calculation to evaluate the impact on core damage frequenc The calcu* bn included all unavailability performance criteria and the 14 reliability performance criteria that exceeded the analysis results. The sensitivity calculation was documented in Calculation Number QDC-0201-N-0496, Revision 1 (April 3,1998).
Results showed an increase in core damage frequency from 2.2E-6/ year to 8.0E-6/ year, or a 264% increase. The licensee noted that the PSA Applications Guide allowed this potential core damage frequency increase for permanent plant changes. The inspectors noted that while the increase appeared large, the magnitude of the new core damage frequency remained within the limits recommended by the guide. This was considered acceptabl b.2 Plant Level Performance Criteria for Low Safety Significance Normally Ooeratina SSCs The inspectors reviewed the plant level performance criteria assigned to low safety significance normally operating SSCs. The inspectors also examined SSCs and functions assigned plant level criteria to determine if these were appropriate and examined the functions identified during the September 1997 baseline inspection as having inappropriately assigned plant level criteri b.3 Goals Established for (a)(1) SSCs The inspectors examined the goals and corrective action plans for all SSCs and functions classified as (a)(1). This amounted to approximately 70 sets of goals and
corrective action plans. Goals and corrective action plans for vertical slice systems l classified as (a)(1) received an in-depth review. The inspectors also examined goals and action plans for SSCs and functions identified during the baseline inspection as having goals and action plans under development. Goals selected for these SSCs and functions were commensurate with safety, tailored to the problem, and appropriate; corrective action plans were generally comprehensive, consistent with the safety significance of the function. This specific issue was an Inspection Follow-up Item in the baseline inspection report and now considered closed. Goals and action plans for all of l the currently listed (a)(1) SSCs and functions were considered acceptable. The baseline inspection findings related to acceptability of goals and monitoring is close The inspection team observed that approximately 13 of 46 system functions modeled in i the Individual Plant Examination had exceeded their reliability performance criteria and l were in (a)(1) status. Because the reliability performance criteria established using the l Electric Power Research Institute methodology generally allowed higher numbers of failures than assumed in the Individual Plant Examination, statistically one would not l expect such a high percentage of the system functions to have exceeded their reliability performance criteria. Two questions arose because of this apparent statistical anomaly:
was the Individual Plant Examination baseline core damage frequency estimate still l representative of the plant, and was there an underlying reason so many system functions appeared not to be performing up to expectations? The licensee agreed that these questions would be addressed in the upcoming periodic assessment. A baseline inspection unresolved. item related to the completion of the periodic assessment will remain open pending the evaluation of the team's questions.
l c. Conclusions
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Performance criteria established to demonstrate the effectiveness of preventive maintenance of (a)(2) systems and functions had been extensively revised, were appropriate, and were properly justifie Implementation of goals and monitoring for systems and functions classified (a)(1) was improved. Inappropriate goals, identified during the September 1997 baseline inspection, had been corrected. Adequate goals had been developed for those functions noted in the baseline report as having goals and corrective action plans under development. Goals and corrective action plans for all SSCs and function classified as (a)(1) were considered acceptabl The inspectors noted a large number of SSCs and functions classified as (a)(1) and observed that a significant portion of SSCs and functions modeled in the Individual Plant Examination had exceeded performance criteria. The inspectors questioned whether the current baseline core damage frequency estimate was valid and whether the
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M2 Maintenance and Material Condition of Facilities and Equipment (62706,71707)
M2.1 General System Review Insoection Scoce The inspectors conducted a detailed examination of eight systems from a maintenance rule perspective to assess the effectiveness of the program when it was applied to individual system Observations and Findings for the Hiah Pressure Coolant inlection Svstem The high pressure coolant injection system had risk significant functions monitored with reliability and availability performance criteria. Functions of this system that were low safety significance were monitored with reliability criteria. The performance criteria >
established for this system were appropriate. One function of this system was being monitored under (a)(1) based on exceeding reliability criteria. Corrective actions, established goals, (a)(1) monitoring and use of industry experience were acceptabl The inspectors found that functions returned to (a)(2) status had appropriate justificatio Observations and Findings for the Feedwater System ;
The feedwater system was a high safety significance system currently classified as category (a)(1) because of exceeding unavailability criteria with reliability at, but at exceeding, the criterion. Most of the unavailability was incurred as a result of disassembly of the 1-A reactor feed pump and a series of seal and seal cooling problems with the pumps. A corrective action plan was in place that addressed changes in seal operating procedures, improved seal maintenance, and reduction of pump vibration through closer alignment and new pump impellers. A review of problem
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identification forms, work requests, and action requests did not revea: any unidentified functional or maintenance preventable functional failures. The inspectors concluded that the system was being properly monitored under the station's maintenance rule program. A walkdown of the feedwater system was done in company with the system engineer. While the inspector concluded that materiel condition of the system was adequate, the inspector identified a number of issues with the potential to cause future problems. Among these were rust and verdigris on a number of valve stems and yokes that were indicative of leakage, inconsistent application of live-load packing on valves and live-loading of flanges between identical compone.M.s on the three feedwater pump skids, and oil films thick with dirt on surfaces that was indicative of leakag Observations and Findings for the Feedwater Control System The feedwater control system was a high safety significance system classified as category (a)(1) because of reliability problems with the feedwater control valves, associated operators, and the control logic. The recently completed historical review revealed that six maintenance preventable functional failures had occurred during the
i past 36-month period. Four of the six occurrences involved feedwater control valve lockups; the causes did not appear to be directly related to each other. Among the causes listed were excessive packing friction, an improper output signal from logic, degraded power supply, and excessive actuation coupling friction. An extensive
- corrective action plan was in place with actions focused on eliminating the causes; new actuators were being installed, instruments necessary for three-element control were being refurbished, the master controller was being upgraded, and troubleshooting and evaluating power supply problems. The goals established for the feedwater control system were appropriate. A walkdown of the feedwater control system revealed that the system was in good condition. The hydraulic actuators installed on the control valves appeared to be an improvement over the original actuators. A review of problem identification forms, work requests, and action requests did not reveal any unidentified functional or maintenance preventable functional failures. The inspectors concluded that the system was being properly monitored under the station's maintenance rule progra b.4 Observations and Findings for the Condensate System The condensate system was a high safety significance system with reliability and availability performance criteria and was monitored under (a)(2). The system was appropriately classified and the inspector had no concerns with the licensee's monitoring activitie b.5 Observations and Findings for the Condensate Booster System The condensate booster system was a high safety significance system and was monitored with reliability and availability performance criteria. The function of the condensate booster system to provide a back up to the emergency core cooling systern keep-fill function of the condensate transfer system was being monitored under (a)(1)
because it was recently added to the maintenance rule scope and there were no surveillance or test activities in place that verified the system's ability to perform this function. The inspector found the licensee's actions appropriate to develop and perform the necessary testing procedures to confirm that the function would perform as intended. The inspectors concluded that the system was being properly monitored under the station's maintenance rule progra b.6 Observations and Findings for the Standbv Gas Treatment Svstem The standby gas treatment system was classified (a)(2). The plant staff had established appropriate performance criteria for the system and was monitoring performance monthly as required by station's rnaintenance rule procedure. A review of problem identification forms, work requests, and action requests did not reveal any unidentified functional or maintenance preventable functional failure The review of problem identification forms revealed a potential operability question with the system because of a 1988 wiring error in the logic for the inlet dampers. In 1997, during a revised surveillance, a 10-amp fuse in the logic for the automatic transfer
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function blew. Investigation showed the cause in be a logic wiring error that was subsequently tracked to werk done in 1988. Pending review of the licensee's evaluation regarding past operability, this is considered an Unresolved Item (50-254/98003-01; 50-265/98998-01).
A walkdown of the system showed that it was in good condition. One discrepancy was identified with the fasteners used to bolt the filter housings to the mountings. In several places, the holes in the mounting plate welded to the housing did not line up with the holes in the mounting plate on the support. Instead of properly aligning the holes and using the correct size stud and now, a smaller bolt was dropped through the area where the holes overlapped. The head of the bolt did not cover the entire hole. Consequently, there was some loss of clamping force. After the inspector identified this discrepancy, the licensee's engineering staff evaluated the bolting arrangement and concluded that seismic qualification was still maintained. The inspectors concluded that the system was being properly monitored under the station's maintenance rule progra b.7 Observations and Findings for the Standbyliauid Control Systen)
The standby liquid control system was a risk significant system with reliability and availability performance criteria. The system was being monitored under (a)(1) for exceeding reliability criteria associated with its function to shut the reactor down from full power. Failures were associated with pump breaker thermal overloads, discharge piping relief valves, and explosive ialve manual actuation circuitry. The corrective actions and goals established to return the system to (a)(2) were acceptable. The irispectors concluded that the system was being properly monitored under the station's maintenance rule progra b.8 Observations a_rgl Findings for the 4160 Volt Switchgear System
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The 4160 Volt switchgear system was a high safety significance system currently classified as (a)(1) due to performance uncertainties relating to the station's historical philosophy on allowing deferral of preventive maintenance activities. An extensive corrective action plan was in place; much of it focused on implementing an effective preventive maintenance program. Additionally the licensee was replacing General Electric Magnablast horizontal draw-out circuit breakers with Merlin Guerin SF, circuit breakers. These breakers were simpler, lighter, and the licensee expected that they would be easier to maintain. The licensee said that most of the problems with the Magnablast breakers were the result of deterioration caused by failure to do regular preventive maintenance tasks. The inspector walked down the system with the system engineer and noted that the equipment was clean and generally free of dust and dir Switchboards were clean and adequately labeled; several cubicles examined were also clean and appeared well-maintained. A detailed review of problem identification forms, action requests, and work requests did not reveal any functional of maintenance l preventable functional failures that the system engineer had not already identified. The l majority of the problems identified were with General Electric Magnablast horizontal draw-out circuit breakers and with difficulties encountered in implementing the Merlin Guerin breaker modification. The licensee stated that problems with the vertical style
l breakers were fcr fewer. The inspectors concluded that the system was being properly monitored under the station's maintenance rule progra i . Observations and Findings on Functional and MaintenarLqefreventable Far1GilfJlal I Eajlure Assessments
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Besides examining the events and problems for each of the above eight systems (as l identified in problems identification forms, work requests, and action requests), the !
inspectors specifically examined the corrective actions. reevaluations, and '
classifications for those SSCs and functions specifically stated in the Notice of Violatio These functions involved the emergency diesel generators, controi rod dnve, scram )
discharge vo!ume, station blackout diesels, containment atmospheric monitoring, and I nuclear instrumentation. Each of these functions was properly classified either as (a)(1)
with acceptable goals and corrective action plans, or as (a)(2) with acceptable justification. One potentialissue relating to the standby gas treatment system was j identified and was being eveluated by the licensee at the close of the inspection. No other potential examples of incorrectly evaluated proolems and events were identifie Conclusions for General System Review The inspectors concluded that the licensee had properly classified each SSC and j function as category (a)(1) or (a)(2). The corrective actions, both in progress and i planned, for SSCs and functions in (a)(1) appeared adequate. The inspectors did not
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identify, in the GSCs and functions reviewed, any functional failures not previously l identified by the system engineers, i M2.2 Material Condition Insoection Scoce in verifying the implementation of the maintenance rule, the inspectors did walkdowns using Inspection Procedure 71707, Plant Operations, to examine the material condition of the systems listed in Section M Observations and Findings Material condition of the Gght systems examined ranged from acceptable to goo Since both units were shut down, the inspectors could not evaluate leak tightness of the systems. Attributes examined by the inspectors included supports, bolting and fasteners, thread engagement, rust and verdigris, and general cleanliness (especially for electrical components), Conclusions The material condition of the systems examined appeared acceptabl u
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M7 Quality Assurance in Maintenance Activities (40500)
M7.1 Licensee Self-Assessments of the Maintenance Rule Proaram , Insoection Scoce The inspectors reviewed the following seif-assessment and Quality Assurance audit i reports of the licensee's implementation of the maintenance rule:
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. Nuclear Oversight corporate Assessment Report No. NODCA 98-008GM, '
" Corporate Assessment of Quad Cities Maintenance Rule Implementation,"
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February 24,1998
. Nuclear Oversight corporate Assessment Report No. NODCA 98-081-CWC,
" Quad Cities Maintenance Rule implementation Assessment," April 8,1998 The inspectors discussed the self-assessment findings and their resolution with the Maintenance Rule Coordinator.
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Both self-assessments were thorough and provided opportunities to improve the station's maintenance rule program. Use of independent personnel strengthened these assessments. The maintenance rule staff provided information that showed that all of the findings and recommendations from these assessments had been addressed and that correction action was either complete or in progress. The maintenance rule staff had established a separate data base to track findings and recommendations on weaknesses generated by the June 1997 self-assessment, the NRC maintenance rule baseline inspection, and both 1998 corporate assessments. The data base contained a description of the issue, corrective action, long term enhancements, and objective evidence of completion for 281 findings and recommendations. The inspectors directly reviewed a large sample of corrective actions listed in the data base and concluded that those actions were appropriate and properly implemente _Conclu?IDng Two 1998 corporate self-assessments of the Quad Cities maintenance rule program implementation were thorough and provided good information for the station's maintenance rule staff. In turn, the maintenance rule staff adequately responded to the issued raised in a timely manne M Miscellaneous Maintenance issues (92902)
M 8.1 General Comments The maintenance rule baseline inspection, completed on September 12,1997, identified that the licensee had not adequately implemented the maintenance rule program. A
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predecisional enforcement conference was held with the NRC and licensee on November 26,1997. Subsequently on March 3,1997, a Notice of Violation was issued ,
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with five apparent violations that collectively represented a programmatic breakdown in the development and implementation to the licensee's program to ensure compliance with the requirements of the maintenance rule. The inspectors reviewed the licensee's response to the Notice of Violation, dated April 2,1998, and did a detailed review of the licensee's corrective actions that addressed the root causes of the programmatic i aspects of the failure to adequately implement the maintenance rule. The inspectors l also reviewed the specific corrective actions for the violation examples referenced in the Notice of Violation. In addition, the inspectors did vertical slice reviews of historical i performance data associated with eight systems and interviewed responsible system ,
engineers to determine if the licensee currently had adequate measures in place to !
monitor the results of maintenance to assure plant SSCs and functions remained capable of performing their intended function '
M8.2 Programmatic Corrective Actions l
The licensee's response stated that the cause of the inadequate maintenance rule program implementation was failure to allocate appropriate priority and resources to establish the program and maintain it in compliance with 10 CFR 50.65. The licensee also failed to aggressively pursue corrective actions following a June 1997 self-assessment performed before the NRC baseline inspection. The licensee stated that inadequate internal communications resulted in the failure of station management to fully recognize significance of the findings of the self-assessment. To correct these problems the licensee instituted a broad maintenance rule program recovery plan. A program manager was established to coordinate the recovery effort; an industry expert and several industry personnel were contracted to implement the improvements. The licensee reconvened a standing expert panel with appropriate personnel and representation to provide program oversight. In conjunction, a complete rescoping was done, performance criteria were revised, the 36-month historical review was
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reperformed, and revised goals and monitoring were established for (a)(1) SSC ]
Station management involvement in the maintenance rule program was heightene The recovery effort was included in the station's Top 10 issues List and recovery status was reported to senior management weekly. The licensee also provided additional maintenance rule training to appropriate organizations. Two separate self-assessments were also done following implementation of the program improvement M8.3 LQcsed) eel 50-254/97017-01(DRS): 50-265/97017-01(DRS): Scoping euoa This issue was a violation that involved the failure to properly include SSCs and
! functions within the scope of the maintenance rule program. Three examples were specified (the licencee had identified others before the inspection that were not cited).
The inspectors verified that the licensee had revised scoping for the specific examples referenced in the Notice of Violation. The inspectors also confirmed through vertical slice reviews of a sample of eight systems that SSCs and functions were appropriately scoped in the maintenance rule (refer to section M1.1.) This item is close l
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M8.4 (Closed) IFl 50-254/97017-02(DRS): 50-265/97017-02(DRS):
Misclassification of safety significance for two function In direct response to the issue, these functions were reclassified as high safety ,
significance. The licensee's overall risk ranking and safety significance determination '
process and results were discussed in Section M1.2. This item is close I M8.5 (Ocen) URI 50-254/97017-03(DRS): 50-265/97017-03(DRS): Acceptability of reliability-availability balanc l
'Pending the completion of the licensee's periodic assessment with respect to the baseline core damage frequency still being representative and the underlying cause of l so many functions not meting expectations, this item will remain open. See l section M1.3.b.3, above, for additional discussio l M8.6 (Closed) EEI 50-254/97017-04a(DRS): 50-265/97017-04a(DRS): ,
Unjustified reliability criteria l
l (Closed) eel 50-254/97017-04b(DRS): 50-265/97017-04b(DRS): l Inappropriate availability criteria (Closed) eel 50-254/97017-04c(DRS): 50-265/97017-04c(DRS):
Inadequate availability criteria
(Closed) eel 50-254/97017-04d(DRS): 50-265/97017-04d(DRS):
Insufficient performance criteria (Closed) eel 50-254/97017-04e(DRS): 50-265/97017-04e(DRS):
No performance criteria l (Closed) eel 50-254/97017-04f(DRS): 50-265/97017-04f(DRS):
Inappropriate plant level criteria (Closed) eel 50-254/97017-04g(DRS): 50-265/97017-04g(DRS):
Inability to monitor criteria These issues comprised a violation with multiple examplos of the licensee failing to establish appropriate performance measures in a variety of circumstances.
i The licensee took programmatic corrective actions to do an expert panel review and revision of all performance criteria. The license also reperformed a historical data review for 36 months to classify SSCs appropriately. The inspectors verified that the licensee had revised the performance criteria for the specific examples referenced in the Notice of Violation. The inspectors reviewed all of the performance criteria for their bases and appropriateness (refer to section M1.3). These items are close I k _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ . - _ _ . _ _ _ . _ _ - - _ _ _ _ _ _ _ . _ _ _ _ _ _ . -
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M8.7 (Closed) eel 50-254/97017-05a(DRSh 50-265/97017-05a(DRSh Containment Atmosphere Monitoring system functional failures (Closed) eel 50-254/97017-05b(DRSk 50-265/97017-05b(DRSk Control Rod Drive functional failures (Closed) eel 50-254/97017-05c(DRSk 50-265/97017-05c(DESL Emergency Diesel Generator functional failures (Closed) eel 50-254/97017-05d(DRSh 50-265/97017-05d(DRS);
Station Blackout Diesel maintenance history (Closed) eel 50-254/97017-05e(DRSk 50-265/97017-05e(DRSk Neutron Monitoring maintenance history These issues comprised two violations with several examples where the licensee failed to properly monitor SSCs and functions against established goals or performance measures. Ti;c cause of this violation was an inadequate understanding by system engineers of the maintenance rule requirements, an inadequate historical review of SSC performance data, and a lack of timely (a)(1) determination The inspectors verified that the licensee implemented corrective actions to revise maintenance rule program procedures to require timely (a)(1) determinations, provide appropriate training to system engineers, and reperform a 36-month historical review of SSC performance data. The inspectors verified that corrective actions were effective by reviewing problem identification forms, work requests, and action requests during eight vertical slice system reviews. Vertical slice reviews were discussed in section M These items are closed.
M8.8 (Closed) eel 50-254/97017-06a(DRSk 50-265/97017-06a(DRSE No goals for Containment Atmosphere Monitoring (Closed) eel 50-254/97017-06b(DRSk 50-265/97017-06b(DRSt Station Blackout Diesel Inadequate Goal (Closed) eel 50-254/97017-06c(DRSh 50-265/97017-06c (DRS);
No goals or monitoring for Residual Heat Removal These three issues comprised a violation for failure to establish adequate goals for (a)(1) systems and addressed three examples of inadequate goals and monitoring established for the containment atmospheric monitoring system, the station blackout diesel, and the residual heat removal / residual heat removal service water syste The inspectors verified that the licensee had revised the goals and monitoring action plans for the specific examples referenced in the Notice of Violation. The inspectors confirmed through vertical slice reviews of six (a)(1) systems that goals and monitoring were appropriate. The inspectors examined the goals and action plans for all of the
(a)(1) systems and functions and concluded that they were satisfactory. This was discussed in section M1.3. These items are closed.
M8.9 (Closed) IFl 50-254/97017-07(DRS): 50-265/97017-07(DRSh l Action plans and goals for recent (a)(1) syster.'s and functions l During the baseline inspection the licensee provided the inspectors with a list of SSCs ,
and functions that had recently been classified as (a)(1) and stated that goals and action l plans were in development. During this inspection, the specific goals and action plans l for each of these SSCs and functions were examined and determined to be acceptabl l This was discussed in Section M1.3. This item is close Ill. Engineering E Engineering Staff Knowledge and Performance (62706)
l E Enaineer's Knowledge of the Maintenance Rule Insoection Scoce (62706)
The inspectors interviewed engineers and managers to assess their understanding of probabilistic risk assessment, the maintenance rule, and associated responsibilitie Observations and Findings The inspectors interviewed system engineers assigned responsibility for the eight selected vertical slice systems and did walkdowns with them. The system engineers were experienced and knowledgeable about their assigned systems. The inspectors found that the engineers had a good knowledge of the maintenance rule and their responsibilities for implementing the maintenance rule program. The inspectors reviewed a sample of approximately one year of historical performance data for each of the eight systems. This data included problem identification forms, action requests, and l'
work requests. The inspectors did not identify any examples where the system engineers failed to properly evaluate maintenance preventable functional failure During the baseline inspection the team determined that system engineers had not been adequately prepared for implementing the maintenance rule program and that system engineers viewed the program as merely an additional task that provided no real value added. The maintenance rule staff discussed improvement efforts focused on training, familiarization, and usefulness with the inspectors. These involved additional training, better evaluation guidance, and system visibility. Interviews with the system engineers during walkdowns and subsequent discussions confirmed that system engineers'
knowledge and opinion of the maintenance rule program had improve _ _ _ _ _ - _ _ _ - _ _ _ _ - _ _ _ _ - - _ _ _ - ._ - _ _ _ _ - - _ _ -_ _ _.______
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. Conclusions System engineers were experienced and displayed a good knowledge of their assigned systems. The inspectors determined that the maintenance rule staff's efforts to Imorove system engineers' knowledge and opinion of the maintenance rule program were effective.
- V. Management Meetings X1 Exit Meeting Summary The inspectors discussed the progress of the inspection with licensee representatives on a daily basis and presented the inspection results to members of licensee management at the conclusion of the inspection on April 17,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary; none was identifie ..
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PARTIAL LIST OF PERSONS CONTACTED Licensee i A. Chemick, Regulatory Assurance l D. Craddick, System Engineering Supervisor i P. Cretans, Corporate PRA Engineer l R. Detwiler, Cycle Manager !
R. Eizenga, Senior Reactor Operator R. Fairbank, Deputy Site Engineering Manager F. Famulari, Quality and Safety Assurance Manager R. Gayley, Site Maintenance Rule Owner L. Hamilton, Regulatory Assurance J. Hutchinson, Site Engineering Manager l P. Knoespel, Site PRA Engineer l T. Kolb, Shift Engineer l J. Kudalis, Business Manager M. Nelnicoff, Corporate PRA Engineer E. Pannel, Senior Reactor Operator W. Pearce, Site Vice President C. Peterson, Regulatory Assurance T. Peterson, Regulatory Assurance J. Purkis, Work Control Supervisor T. Rieck, Nuclear Engineering Services J. Robinson, Senior Reactor Operator j C. Sibley, Corporate Maintenance Rule Owner S. Specht, Unit Supervisor M. Strait, Corporate Engineering D. Swartz, Corporate PRA Engineer R. Tubbs, Outage Engineer j R. Venci, Unit Supervisor M. Wayland, Maintenance Manager
! NflC C. Miller, Senior Resident Inspector, Rll!
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LIST OF INSPECTION PROCEDURES USED IP 62706: Maintenance Rule IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 71707: Plant Operations IP 92902 Maintenance Follow-up I
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LIST OF ITEMS OPENED, CLOSED AND DISCUSSED '
Ooened 50-254/98008-01(DRP); 50-265/98008-01(DRP) URI Operability of Standby Gas l Treatment from Wiring Error i Closed 50-254/97017-01(DRS); 50-265/97017-01(DRS) eel Scoping errors 50-254/97017-02(DRS); 50-265/97017-02(DRS) IFl Correct misclassification of two functions l 50-254/97017-04a(DRS); 50-265/97017-04a(DRS) eel Unjustified reliability criteria ,
l 50-254/97017-04b(DRS); 50-265/97017-04b(DRS) eel Inappropriate availability criteria l
50-254/97017-04c(DRS); 50-265/97017-04c(DRS) eel Inadequate availability l criteria j l
50-254/97017-04d(DRS); 50-265/97017-04d(DRS) eel Insufficient performance ,
criteria !
50-254/97017-04e(DRS); 50-265/97017-04e(DRS) eel No performance criteria l
50-254/97017-04f(DRS); 50-265/97017-04f(DRS) eel inappropriate plant level criteria 50-254/97017-04g(DRS); 50-265/97017-04g(DRS) eel Inability to monitor criteria l 50-254/97017-05a(DRS); 50-265/97017-05a(DRS) eel Containment Atmosphere
, Monitoring system functional failures 50-254/97017-05b(DRS); 50-265/97017-05b(DRS) eel Control Rod Drive functional l failures l
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50-254/97017-05c(DRS); 50-265/97017-05c(DRS) eel Emergency Diesel Generator
! functional failures 50-254/97017-05d(DRS); 50-265/97017-05d(DRS) eel Station Blackout Diesel maintenance history 50-254/97017-05e(DRS); 50-265/97017-05e(DRS) eel Neutron Monitoring maintenance history
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50-254/97017-06a(DRS); 50-265/97017-06a(DRS) eel No goals for Containment Atmosphere Monitoring 50-254/97017-06b(DRS); 50-265/97017-06b(DRS) eel Station Blackout Diesel Inadequate Goal 50-254/97017-06c(DRS); 50-265/97017-06c(DRS) eel No goals or monitoring for Residual Heat Removal 50-254/97017-07(DRS; 50-265/97017-07(DRS) IFl Action plans and goals for recent (a)(1) systems Discuss /97017-03(DRS); 50-265/97017-03(DRS) URI Acceptability of reliability-availability balance l l
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LIST OF ACRONYMS USED CFR Code of Federal Regulations DRS Division of Reactor Safety !
eel Escalated Enforcement item l l
IFl Inspection Follow-up Item NOV Notice of Violation NRC Nuclear Regulatory Commission PDR Public Document Room PSA Probablistic Safety Assessment !
SSC Structure, System, or Component j URI Unresolved item j
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, LIST OF DOCUMENTS REVIEWED
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. Quad Cities Maintenance Rule Procedure and Maintenance Rule implementation Instructions l l
t QCAP 0400-18, Revision 2 i
' l MRIN-A1, Revision 2 MRIN-MRFF, Revision 2 MRIN-PE, Revision 1 I
. Maintenance Rule Scoping Results
. List of Maintenance Rule Systems Showing (a)(1) and (a)(2) Status
. Justifications for Non-Maintenance Rule Systems
. Maintenance Rule (a)(1) Systems Cause Determinations and Goals
. (a)(1) to (a)(2) Dispositions
. List of Known Functional Failures, MPFFs, and RMPFFs for the period February 28, 1997 to February 28,1998
. Functional Failures /MPFF Evaluations for the period February 28,1997 to February 28,
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1998
. Nuclear Oversight corporate Assessment Report No. NODCA 98-008GM, " Corporate l Assessment of Quad Cities Maintenance Rulo implementation," February 24,1998
. Nuclear Oversight corporate Assessment Report No. NODCA 98-081-CWC," Quad ,
Cities Maintenance Rule implementation Assessment," April 8,1998
. QDC-0201-N-0469 Revision 1,"PSA Basis for Maintenance Rule Performance Criteria,"
l April 2,1998
( . QDC-0201-N-0496, Revision 1, " Maintenance Rule Performance Criteria Sensitivity Case Runs," April 3,1998
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. Quad Cities Nuclear Power Station Units 1 and 2 ladividual Plant Examination Submittal Report, December 1993, Commonwealth Edison Cornpany
. Quad Cities Station Units 1 and 2 Response to NRC Review of Individual Plant Examination Submittal-Intemal Events, August 30,1996 i
. Quad Cities Nuclear Power Station Probabilistic Safety Assessment Update 1996 Summary Document, December 1996
-. Maintenance Rule Program Corrective Action Summary [ issue tracking data base)
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