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SALP Repts 50-254/96-01 & 50-265/96-01 for 950723-961026
ML20132A409
Person / Time
Site: Quad Cities Exelon icon.png
Issue date: 12/04/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20132A404 List:
References
Download: ML20132A409 (6)


See also: IR 05000265/1996001

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Quad Cities Station - SALP 13

(Report Nos. 50-254:265/96001)

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I. INTRODUCTION

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The Systematic Assessment of Licensee Performance (SALP) process is used to

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develop the Nuclear Regulatory Commission's (NRC) conclusions regarding a

licensee's safety performance. Four functional areas are assessed: Plant

Operations, Maintenance, Engineering, and Plant Support. The SALP report

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documents the NRC's observations and insights on a licensee's performance and

communicates the results to the licensee and the public. It provides a

vehicle for clear communication with licensee management that focuses on plant

performance relative to safety risk perspectives. The NRC utilizes SALP

results when allocating NRC inspection resources at licensee facilities.

This report is the NRC's assessment of the safety performance at the Quad ,

Cities Station for the period from July 23, 1995, through October 26, 1996. j

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An NRC SALP Board, composed of the individuals listed below, met on

October 30, 1996, to assess performance in accordance with the guidance in NRC

Management Directive 8.6, " Systematic Assessment of Licensee Performance."

Board Chairoerson

J. L. Caldwell, Acting Director, Division of Reactor Projects, Region III

Board Members

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R. A. Capra, Director, Project Directorate III-2, NRR i

H. B. Clayton, Acting Deputy Director, Division of Reactor Safety, Region III l

R. J. Caniano, Deputy Director, Division of Nuclear Material and Safety,

Region III

II. PERFORMANCE ANALYSIS

Plant Operations

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Overall operations performance remained good this period and major plant

evolutions were conducted in a careful manner. Improvements noted since the

last assessment included better implementation of performance standards by

both licensed and non-licensed operators, improved procedural adherence, .

better implementation of out-of-service (005) tagouts, and improved trending I

and investigation of operations performance problems. However, some personnel

errors and out-of-service (00S) tagging problems still occurred, and some

examples indicating a weak understanding and application of Technical l

Specifications (TS) and design information were identified. A few examples of

operator knowledge deficiencies and procedure problems were also identified.

Continued implementation of station performance standards resulted in improved

performance of routine activities, especially in control room panel monitoring

and communications. Major plant evolutions such as core reload and plant

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PDR ADOCK 05000254

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startups were conducted in a careful manner without significant operator

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performance problems. Operations assessment of damage, declaration of an

Alert, and initiation of a Unit 2 shutdown in response to the May 10, 1996,

severe storm was good.

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i The persistent reenforcement of management expectations and standards coupled

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with good oversight resulted in a decrease in the number and significance of

errors; however, some personnel errors and 00S tagging problems were noted

throughout the period. Inattention to detail during operator rounds and

subsequent reviews resulted in a standby diesel generator and the control room

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ventilation system remaining inoperable for longer periods than necessary. 1

Poor 00S preparation caused a 125 volt battery to fail and become inoperable

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and caused the shared standby diesel generator to be inoperable to one unit.

Recent problems with verification of 00S valve positions demonstrated a lack

of sensitivity to management expectations and lack of attention to detail by

operators to the 00S process.

Prioritization and control of risk significant activities improved from the

last period. An example of good performance included the use of a computer

program in the control room to assess risk of inoperable equipment. Weak

performance was seen in some cases such as the low priority given Unit I

standby diesel generator work during the QlR14 refueling outage.

The process for Operations to prioritize the repair of important plant

equipment improved over the assessment period and resulted in a noticeable

decrease in the number of open control room corrective maintenance items.

However, a large number of operator work-around issues, temporary alterations,

caution cards, and alarming annunciators still exist. Repeat balance of plant

issues challenged plant operations. For example, problems with the turbine

control and combined intermediate valves, feedwater pumps, and feedwater

> heater level control valves resulted in significant power reductions or taking

the units off-line.

Operator understanding and application of TS and design information was a

weakness evident this period which was not specifically noted in the previous

period. In one case operators inappropriately entered TS 3.0.A voluntarily

for leak rate testing at power in order to reduce outage time. In another

instance, operators made changes to a control rod drive test procedure which

changed the intent of the procedure without the proper procedure review

required by TS. Some additional knowledge deficiencies were noted such as a

reactor trip when the turbine bypass valves opened unexpectedly. Corrective ,

actions to improve procedures have resulted in a number of procedure changes '

and some improvements in overall quality. l

The self assessment and root cause programs have generally improved.

Operations established a low threshold for reporting problems and improved the

trending and assessment of performance. Dedicated root cause evaluators

assessed trends found in operators' performance and initiated corrective

actions as needed.

The Plant Operations area is rated category 2.

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Maintenance l

Overall performance in the maintenance area resulted in an acceptable level of ;

safety. Significant improvements were made in material condition and a major i

effort was focused on improving the work control processes. Nevertheless,

throughout the assessment period overall plant performance was challenged with !

continuing problems stemming from weaknesses in material condition, work i

control, supervisory oversight, and the quality of maintenance activities. !

These same areas were noted weaknesses in the last assessment period. !

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The work control process was a major focus area in the station's Management

Plan. Several iterations were made over the assessment period to develop the '

work control process. This effort included a maintenance standdown during

October and November of 1995 to overhaul the process. Many work control i

process changes were implemented including the electronic work control system :

to track and control work issues, implementation of the 13-week rolling

schedule, and the formation of the Fix-it-Now and interdisciplinary work teams

to more efficiently cc plete

, plant work. However, the work control process

remained cumbersome with problems evident in the ability to plan, schedule,

and execute work and to meet the station's backlog reduction goals. In

addition, some weaknessos were evident in the quality of work packages, the

use of the problem identification system, and implementation of the 00S

program in support of maintenance.

Programs for the conduct of surveillance testing and inservice testing of

pumps and valves were adequate. However, some programmatic weaknesses in

preventive maintenance at the station were observed as indicated by recurring

refueling bridge repairs, control room emergency ventilation (CREV) system

failures, broken reactor building blowout panel bolts, and zebra mussel growth

at the inlet to the diesel-driven fire water pumps.

Supervisory development and training were emphasized during 1996 to strengthen

performance and accountability. While good supervisory oversight was observed

in some activities, inadequate supervisory involvement and oversight

l contributed to problems experienced during several other maintenance l

activities, such as electro-hydraulic control (EHC) system adjustments, l

residual heat removal service water (RHRSW) impeller maintenance, and overhaul i

of the shared standby diesel generator.

While several complex maintenance activities were performed well, such as the i

recent QlR14 feedwater regulating valve repair, significant problems were

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still evident in the quality of maintenance work. Weaknesses were identified

in training, procedures, and work practices. This lack of quality resulted in

plant events, increased safety equipment outage time, and unnecessary rework.

Although increased emphasis was placed on training to improve craft skill !

levels and work analyst performance, training weaknesses led to rework on the

air header compression fittings for the control rod drive hydraulic control

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units and the failure of a standby liquid control system squib valve to

i operate during surveillance testing.

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Problems associated with work practices and procedures included misalignment

of the reactor pressure vessel head, reassembly of a standby diesel generator

room cooler in a degraded condition, and removal of the wrong source range

monitor reactor protective system shorting links. These same problems also :

1ed to rework on the EHC system and ventilation system fans; miswiring of a j

drywell fan cooler and a low pressure coolant injection (LPCI) valve breaker;

and wrong component work on an intermediate range monitor and standby diesel ,

generator cooling water pump.

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Although weaknesses in self assessment activities such as an ineffective wcrk ;

week critique report and the lack of a fomal self assessment process within

the Material Controls Division were noted, some positive initiatives were '

started. These initiatives included improved tracking and trending of (1)

work control and maintenance activities and (2) management or supervisory

observations and critiques of work activities. Significant performance

improvement from these initiatives has yet to be demonstrated.

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The Maintenance area is rated Category 3.

Engineerina

Engineering performance was adequate and some improvements were noted from the

previous assessment period, particularly during the last few months. However,

improvement initiatives started at the end of the last assessment period were

not successful in assuring consistently good engineering performance. The

significant exceptions included poor corrective actions for identified !

structural steel deficiencies and poor engineering assessment of the severe

storm structural damage impact on plant design. These exceptions demonstrated

that continued management attention is warranted.

Increased engineering involvement contributed to numerous material condition

improvements during this period. Some of the more significant included

upgrading the control rod drive, feedwater control, EHC, and reactor

recirculation systems. In addition, some older engineering design issues were

resolved in the latter part of the assessment period such as cable ampacity

and degraded voltage issues. Engineering provided support in correcting a

number of operator work-arounds and control room deficiencies. However, plant

material condition issues requiring engineering resolution remained a

challenge to operators throughout the assessment period. Equipment

performance for some important plant systems, such as high pressure coolant

injection (HPCI), RHRSW, and the CREV system remained poor. Equipment

failures also led to several forced shutdowns and plant transients.

Problem identification improved as evidenced by a number of safety system

deficiencies and deviations from the updated final safety analysis report

found by engineering during this period. Items that were identified and

corrected included improperly canceled or unimplemented modifications to

gallery steel and HPCI pump nozzle supports; non-safety related power supplies

to the control room ventilation toxic gas analyzer and chiller crankcase

heater; and a single failure susceptibility in the reactor protection logic

for the scram discharge volume level instrumentation.

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Poor quality root cause evaluations and corrective actions were evident on

several occasions. Inadequate corrective action for deficient structural

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supports in the LPCI corner rooms resulted in escalated enforcement action.

Narrow root cause evaluations contributed to repeated failures of the high

pressure coolant injection system and the Unit 2 standby diesel generator. ,

Engineering was slow to evaluate leakage test data from a residual heat

removal service water vault, and failed to identify and correct the root cause

of the loss of audible alarms in the control room until multiple failures 4

occurred. Engineering was also not fully successful in correcting

longstanding problems with reactor building closed cooling water system

temperature control valves and reactor recirculation motor-generator set speed

control circuitry.

Some engineering evaluations demonstrated a weak understanding of the plant

design and design bases. The poor safety evaluation of missing reactor

building siding following the May 10, 1996, severe storm event would have

allowed plant restart with conditions outside the design basis had the NRC not

intervened. Poor understanding of design and design bases also contributed to

an inadequate initial submittal addressing a potential reactor water cleanup ;

system line break outside the drywell and an evaluation which incorrectly

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concluded that the high pressure coolant injection system was operable with

associated vacuum breaker valves closed. i

Self assessments performed by site quality verification and the independent !

safety engineering group were performance based and identified good issues.

Use of auditors from other licensees was considered a good practice. Choosing

not to implement an engineering department self assessment program as planned

since 1994, and choosing to postpone a safety system functional inspection

scheduled for 1996 were missed opportunities to identify additional design and

engineering program weaknesses.

The Engineering een is rated Category 3.

Plant Suonort

Overall performance in the area of plant support was good; however, challenges

remain in all areas. Radiation protection and chemistry performance exhibited

continued improvement in ALARA planning, good plant water chemistry and

increased availability of hydrogen water chemistry; however, station dose

remained high. Security program performance was good, but some decline was

noted in procedural adherence. The emergency preparedness program was good;

however, there were some problems with the Alert declaration on May 10, 1996,

and with the 1996 exercise. Fire protection performance remained adequate

with some weaknesses noted with the maintenance and operability of the fire

pumps. j

Radiation protection performance was good, but continued to be challenged by ,

emergent and long-standing engineering issues and a cumbersome station work l

control process. Although total station dose was high, there was improvement

in ALARA planning and source term reduction initiatives which resulted in a

reasonable dose expenditure for the work accomplished. Improvements in the

control of radioactive materials was noted as the number of items identified

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outside of the radiologically protected area significantly declined. However,

numerous minor radworker performance problems continued to be observed largely

due to an increased number of on-site contractors and poor oversight of

contractor personnel. For example, inadequate oversight of the radiological

waste vendor contributed to a resin spill in the radiological waste truck bay.

The chemistry and radiological environmental monitoring programs were good,

with excellent staff analytical (radiochemical and chemical) performance and

several station improvements to maintain good water quality and keep

radioactivity in effluent releases low. Previous problems associated with

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completion of system modifications and cycling of hydrogen water chemistry

were resolved, but maintenance of some chemistry sampling equipment continued

to be a concern.

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Security program performance was good, but some decline was noted regarding

procedural adherence. This resulted in problems with implementing the vehicle

control and psychological testing programs. A contributing factor was weak

management oversight of personnel performance. However, the overall security

program was fundamentally sound. The licensee effectively implemented a

tactical response drill program.

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Overall, the emergency preparedness program was good. Emergency response

facilities were maintained with recent facility and equipment enhancements

made. The licensee successfully performed the 1996 biennial exercise; however,

i there were some minor problems related to classification of the Unusual Event,

slow initial NRC notifications, and slow correction of simulator problems.

Overall performance during the Alert declaration on May 10, 1996, was good.

However, minimum staffing of the interim corporate emergency operations

facility was not achieved in a timely manner. ,

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Fire protection program performance was adequate. Fire protection !

vulnerabilities existed due to inadequate corrective action which led to

problems such as low suction pressure for the fire pumps, and inadequate

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preventive maintenance which led to challenges such as a zebra mussel

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infestation degrading fire system performance. In addition, there were

continued problems with fire protection equipment failing to meet flow

requirements which necessitated compensatory measures. The fire protection

improvement program identified deficiencies in combustible loadings in certain

safety related rooms.

The Plant Support area is rated Category 2.

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