IR 05000295/1981004

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IE Mgt Appraisal Insp Rept 50-295/81-04 on 810420-0501 & 11- 15.Areas Discussed:Mgt Controls Over Licensed Activities
ML20054C567
Person / Time
Site: Zion File:ZionSolutions icon.png
Issue date: 07/27/1981
From: Ang W, Belanger J, Belanger J, Hinckley D, Hinkley D, Napuda G, Oberg C, Partlow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20054C561 List:
References
50-295-81-04, 50-295-81-4, NUDOCS 8204210335
Download: ML20054C567 (29)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT (IE)

DIVISION OF PROGRAM DEVELOPMENT AND APPRAISAL PERFORMANCE APPRAISAL SECTION (PAS)

Report No. 50-295/81-04 (PAS)

Docket No. 50-295 License No. DPR-39 Licensee:

Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Facility Name:

Zion, Unit 1 Inspection At:

Zion Station, Zion, Illinois and Commonwealth Edison Company, Chicago, Illinois 3 pril 20 - May 1, 1981 and May 11-15, 1981 A

Inspection Conducted:

W 7[Df8/

Inspectors:

D. G. Hincirby, Insk)ection Specialist (Team Leader)

Date Signed

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W. P. Ang, J pectioh Specialist Date 91gned

'lfQfN (,

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J.L.Belang

, Insp$ tion Specialist Date Signed h4L 9/u/n G. Napuda, I ectiqh Specialist Date Signed

?fD l

I f C. R. Ot erg, Inspectijn specialist Date Signed i

Accompanying Personnel:

J. G. Partlow, PAB

  • A.

B. Davis, RIII

  • D. W. Hayes, RIII
  • J.

H. Neisler, RIII

  • J. E. Kohler, RIII (Resident)

A. T. Gody, PAS

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J. D. Woessner, PAS 0. P. Allison, OIE g

  • Present only during th_e t. interview on May 15, 1981 Jw

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Approved by: J. G. Partlo'w, Chief, Program Appraisal Branch Date S$gned 8204210335 810811 PDR ADOCK O'JOOO295 PUN

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Insoection Summary Insoection on April 20 - May 1 and May 11-15, 1981 (Recort No. 50-295/81-4 (PAS))

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Areas Insoected:

A special, announced inspection was performed of the licensee's management controls over selected licensed activities.

The inspection (by five NRC inspectors) involved 515 inspector-hours onsite and at the corporate office.

Results:

The licensee's management controls for ten areas were reviewed, and conclusions were drawn in each area based on observations presented in this report.

The conclusions are presented as above average, average, or below average as follows:

Section 2, Committee Activities - Average Section 3, Quality Assurance Audits - average Section 4, Design Changes and Modifications - average Section 5, Maintenance - average Section 6, Plant Operations - average Section 7, Corrective Action Systems - above average Section 8, Licensed Training - average, Non-Licensed Training - average Section 9, Procurement - average Section 10, Physical Protection - average Additionally, a number of observations were presented to the Region III Senior Resident Inspector as potential enforcement findings for followup as appro-priate. These observations were also discussed with the licensee during meetings on May 1 and 15, 1981.

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DETAILS I.

Inspection Scope and Objectives The objective of the inspection was to evaluate the management control systems which have been established in support of licensed activities.

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The results will provide input to the NRC evaluation of licensees from a national perspective.

The inspection effort covered ifcensed activities in selected functional In each of the functional areas the inspectors reviewed writthn policies, procedures, and instructions; interviewed selected personnel; areas.

and reviewed selected. records and documents to determine whether:

The licensee had written policies, procedures, or instructions to a.

provide management controls in the subject areas; The policies, procedures, and instructions of (a) above were b.

adequate to ensure compliance with the regulatory requirements; The licensee personnel who had responsibilities in the subject areas were adequately qualified, trained, and retrained to perform their c.

responsibilities; The individuals assigned responsibilities in the subject area under-d.

' stood their responsibilities; and

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The requirements of the subject area had been implemented to achieve compliance, and activities sampled had been appropriately documente e.

The specific findings in.each area are presented as observations which are inspection findings that the inspectors believe to be of sufficient signi-ficance to be considered in the subsequent evaluation of the l ific management performance.

weaknesses in the licensee's management controls that may not have sp regulatory requirements or guidance.

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the report by a "S" or "W" in parentheses.

The observations provide the basis for drawing conclusions in each inspect The conclusions are presented as Above Average, Average, or Below Average, and represent the team's evaluation of the licensee's mana functional area.

controls in each area.

Some of the observations identified as weaknesses ar The followup of these items will findings.

to the Region III Senior Resident Inspector.

be performed by the IE Regional Office.

2.

Committee Activities The objective of this portion of the inspection wa

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offsite and onsite review activities.

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Observations The following observations include perceived strengths and weak-nesses in the licensee's management controls that may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

The onsite and offsite review and investigative functions, as (1)

described in the Technical Specifications (TS), were accom-plished by individuals selected from the Station Technical Staff and Station Nuclear Engineering Department (SNED),

respectively. The TS descibes the required areas of expertise for participants in these functions, and requires that more The onsite than one participant must review a given item.

review activity was supervised by the Station Superintendent, and the participants for a given review were selected by the The l

Technical Staff Supervisor, who was usually a participant.

Supervisor of Offsite Review provided direction to that function and selected the senior participant, who then selected other participants.

Interviews revealed that meetings were not held between parti-cipants for each review.

When meetings were held, minutes were An offsite review subgroup not required and were not prepared.

had on occasion prepared a summary memo of an important meeting.

Each review was documented in a report containing only the There was no provision for documenting signi-final results.

ficant issues discussed or evaluated during the review process.

Also, there was no provision for identifying minority opininns, if any. (W)

The offsite review function was addressed in the Nuclear Safety Department Organization and Administration Manual (NSOAM) and (2)

described in detail such items as individual responsibilities, methods of evaluating and appointing participants, organization, reporting, content and submittal of reviews, and records. The onsite review function was described in ZAP 2-54-1, Onsite

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However, this proceaure did not Station Review, revision 0.

adequately address such items as methods of evaluating and appointing participants, reporting, content and submittal of reviews, use of committees, and control of review assignments.

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(W)

t The Designation of Participants for Onsite Review, revision 8, and their (3)

listed the qualifications of 30 active participantsThe NSDAM area (s) of expertise.

offsite review participants and their area (s) of expertise.

l Comprehensive evaluation and qualification records were maintain Onsite review activities were scheduled and

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tracked by the use of charts that listed critical path review for both groups.

J items, scheduled reviews, upcoming reviews, and reviews by The status others such as the Nuclear Steam System Supplier.

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and assignment of reviews were tracked by categories such as

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procedures, and Deviation Reports (DVRs).

The pool of available reviewers for both functions and the practice of evenly distributing items for review enhanced the quality of the assigned participant's technical review.

(S)

(4) All TS violations were required to be reviewed by the onsite and offsite review groups.

When an audit identified a TS violation, the auditee or audited organization was required to initiate a DVR which was reviewed by both groups; however, audit reports were not reviewed by either group.

There was no method of verifying that all audit violations resulted in DVRs.

(W)

b.

Conclusions l

Procedures had been prepared describing the offsite and onsite review functions.

The offsite review activities were well defined; however, the onsite review procedures lacked detail in certain aceas.

Both groups were composed of an adequate number of qualified partici-pants, and reviews were being performed as required by Technical Specifications.

There were no provisions for documenting signi-

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ficant issues addressed during the review process or to recognize

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minority opinions.

Management controls associated with the onsite and offsite review functions were considered average.

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3.

Quality Assurance Audits The objective of this portion of the inspection was to evaluate the adequacy of the licensee's management controls associated with quality assurance audit and surveillance activities.

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Observations The following observations include perceived strengths and weak-nesses in the licensee's management controls that may'not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

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All Technical Specifications (TS) audits were specifically (1)

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assigned to the Manager of the Quality Assurance Department This responsibility was delegated to the Director of QA (MQA).

for Operations (0QA0) and the Staff Assistant to the Supervisor of QA-Maintenance (SQAM).

A five person audit staff at the station, reporting to the DQA0 and SQAM, conducted the TS audits and other special audits.

This staff conducted approximately 35 audits and 100 QA surveillances per year (approximately one-third were on backshifts).

The surveil-lances ranged from monitoring of a specific activity to a mini-audit of a quality element.

Three auditors conducted audits of maintenance and modification activities.

Two other

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-5-auditors, one of whom held a current SRO license, conducted audits and surveillances of facility operations.

(S)

(2)

Semiannual audits of station activities had been conducted by offsite teams since 1979.

These teams were composed of cor-porate and other stations' Quality Assurance Department (QAD)

personnel, as well as non-QA offsite personnel.

The DQA0 had developed a cross reference index as guidance to ensure that 10 CFR 50, Appendix B, criteria were addressed over the conduct of five consecutive audits.

TS requirements were addressed con-currently over the course of every three audits.

This offsite audit activity was an independent audit of areas audited by the onsite audit group. (S)

(3) Audits of engineering activites were conducted by QAD and were the responsibility of the Director of Quality Assurance-Engineering and Construction (DQAEC).

Vendor audits were performed by both QAD and Station Nuclear Engineering Department-Quality Control (SNED-QC).

Various engineering groups were soliciti.d for recommendations as to which vendors should be audited.

The DQAEC developed the audit schedule and assigned specific audits to one or the other group.

A QAD auditor, located at the SNED office, conducted audits of SNED engineering and SNED-QC activities.

Review of several audit reports revealed extensive use of engi-neering and technical expertise from within and outside the company.

(S)

(4) The station QC group maintained an audit finding log that contained information such as identified audit deficiencies,.

audit completion dates, and corrective action due dates.

A QC inspector was identified as being responsible for followup of corrective action.

This QC inspector monitored the status of corrective action and issued periodic reports.

Shortly after the due date, station QA conducted a surveillance to verify completion of required corrective action (s).

The timely followup of corrective actions appeared to be a factor in the relatively low backlog of open audit findings (o.ne open item from 1980 and five open items for 1981).

(S)

Auditors were not required to review past audit reports in order to identify any adverse trends.

However, trending of QA audit findings to identify repeat violators and generic aspects of findings was initiated by QC in January 1981.

This trending appeared to be very limited as reflected in the report, since it contained only general information.

(W)

(5) Most audits and associated checklists were detailed with respect to the area examined.

However, minimum or recommended sample sizes were not specified. (W)

(Reference section 4, observa-tion 5, regarding QA checklists.)

The principal independent evaluation of the adequacy and effec-tiveness of the audit program was the biennial management audit by an outside consultant.

The latest such audit was conducted during September 1979.

The report of this audit did not

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-6-specifically address the licensee's audit system; however, a line item on one of the audit's checklists could be interpreted as addressing the adequacy and effectiveness of the licensee's audit program.

Since only the audit report was routinely provided to the licensee, the report should address all elements of the quality assurance program reviewed.

(W)

(6) There were approximately 95 auditors, company-wide, of which 44 I

l were qualified as lead auditors.

Auditors and lead auditors were qualified to ANSI N45.2.12 and N45.2.23, respectively. The licensee maintained a " Matrix of Auditor Qualifications" listing 46 audit elements and the areas in which each auditor was qualified.

After the initial auditor training for certification, however, there was no formal refresher training program.

(W)

Reviews of auditor and QC inspector experience ana qualifications, discussions with those personnel and responsible management, and evidence of reassignmants and promotions revealed that QA or QC experience was considered to enhance career progression.

(S)

(7)

Channels of communication between levels of management had been established.

This was evidenced by the' following reports:

semiannual activity reports from station QC to the DQA0, montnly QAD Activity and Status Reports to the QAM and senior management, and the 1981 Activities and Goals Report. QAD personnel also participated in the 1981 Goals and Executive Assessment Meeting held on February 23, 1981, and an oral presentation was made by the QAM during an executive meeting held in January 1981. (S)

b.

Conclusions

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An audit system to verify compliance with the quality assurance program had been established and implemented.

Functional responsi-bilities were defined in approved procedures for QAD, SNED-QC, and other affected organizations.

Personnel were found to be qualified and understood their responsibilities.

Formal and informal communi-cation channels had been established.

Audits and surveillances had been conducted and documented.

The dual auditing of the same areas by the onsite QA staff and by offsite audit teams was a positive indication of management's com-mitment to the concept of quality assurance.

Attention to, and support for, the audit system was also evident.

The philosophy of QA and QC being an opportunity for career enhancement appeared to be a strong contributor to the positive attitude that prevailed within the QA and QC organizations.

Significant weaknesses were the failure to effectively trend audit findings and to provide a formal retraining program for QA personnel.

Management controls in the area of quality assurance audits were considered average.

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Design Changes and Modifications

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The objective of this portion of the inspection was to evaluate the j

adequacy of management controls associated with design changes and

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modifications, a.

Observation The following observations include the perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

(1) QR 3.0, Design Control, established the basic requirements for control of the plant design and design changes and assigned responsibilities for review of proposed design changes and evaluations of plant modifications to the Station Nuclear Engineering Department (SNED).

Review and authorization control was vested in the Station S verintendent.

QP 3-51, Design Control for Operations - Plant Modifications, provided detailed instructions for the control of plant modifi-cations involving safety related systems. Specific responsibility for controlling the flow of documents was assigned to a Modification Coordinator who maintained the status of all proposed, active and completed modifications. In addition, control of the modification-package within SNED was ensured by the assignment of a Project Group Recorder. The detailed instruc-tions for SNED responsibilities were given in SNED procedure Q6, Modifications Originated by Station Technical Staff.

The individual control of each modification was documented on a

" Modification Approval Sheet" which contained provision for I

the signatures of personnel responsit>1e for the required reviews and approvals.

The overall procedural control of the modifica-tions was verified to be effectively implemented through the review of a current computerized status report, examination of individual modification packages, and discussions with personnel.

(S)

(2) ANSI N45.2.11, Section 5, Interface Control, requires that internal interfaces between organizations perfon..ing work l

l affecting quality of design be identified in writing.

Specific organizational responsibilities, lines of communication, and documentation requirements were to be established.

Sargent and Lundy (S&L), under contract to Coramonwealth Edison, had performed, I

with few exceptions, all modification design work for the Zion Station.

The activities of S&L were periodically audited by the SNED QA Coordinator to ensure conformance to the approved QA Program. Meetings were held between S&L and SNED during the design process; only those meetings called by S&L were docu-mented. A procedure or other document could not be provided by SNED personnel which established the design interface between i

S&L and SNED as required by ANSI N45.2.11. (W)

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This observation was discussed with the licensee and presented to the Senior NRC Rasident Inspector as a potential enforcement

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finding.

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ANSI N45.2.11, Section 9, requires a procedure be established for corrective actions.

Part of this procedure would include the determination of the cause and the implementation of appro-priate changes in the design process for significant or recur-ring deficiencies.

Discussions with SNED personnel, and review of applicable procedures revealed there was no mechanism, as part of a corrective action system, which would ensure upgrading of the design process.

(W)

This observation was discussed with the licensee and presented to the Senior NRC Resident Inspector as a potential enforcement

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finding.

(4) QP 3-51, Design Control for Operations - Plant Modifications, provided instructions and described responsibilities for controlling plant modifications.

QP 3-51, paragraph C, provided specific instructions for code and safety-related modifications and for non-code and nonsafety-related modifications requiring engineering department assistance.

Paragraph C.6.b. required the Station Nuclear Engineering Manager to perform safety evaluations for all such approved modifications and changes thereto.

QP 3-51, paragraph D, provided specific instru:tions for non-code

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and nonsafety-related modifications not requiring engineering department assistance.

However, the procedural content appeared to direct the Technical Staff Supervisor to perfonn safety evaluations, without review by the Station Nuclear Engineering fianager, for safety-related modifications if no engineering department assistance was required.

As an example, the Technical Staff Supervisor was made responsible for the safety evaluation of safety-related modification M22-1/2-80-16 since it did not require engineering department assistance.

This is inconsistent with paragraph C.6.b.

(W)

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(5) QP 3-51, Paragraph C.22, required the Quality Assurance Engineer or Inspector to verify that "... quality requirements and

i desired hold or witness points...." are provided for safety-related modifications.

If acceptable, the modification Work Request, Station Traveler, and Maintenance / Modification pro-

cedure were signed, indicating, "... the papers have been audited." Paragraph C.30 required QA verification that the

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requirements of the work package had been satisfactorily completed.

A signature on the Modification Approval Sheet and Work Request indicated, "... the papers had been audited." In addition to the reviews by QC and then by QA, all WRs were reviewed by responsible supervisors and managers.

ANSI N45.2.12 defines an audit as, "A documented activity per-formed in accordance with written procedures or check-lists

" However, an approved QA checklist for auditing the modi-

...fication packages or work requests was not available.

The site QA personnel indicated that the only governing audit

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document was QP 3-51 for Modifications, and QP 3-52 for Work Requests.

Further, the " audit" was in reality a review primarily ensuring that all blanks were filled with an appropriate signature.

Reviews of selected modification packages revealed that the " audits" required by QP 3-51 were not effective in identifying the quality of the modification packages.

This was due to the lack of an approved audit procedure and checklist.

(W)

b.

Conclusions A program for the control of facility design changes and modifications had been established and implemented.

The functional responsibilities were defined in approved quality procedures for SNED, Zion Station, and other affected organizations.

Personnel were qualified and understood their responsibilities.

Control of instrument setpoint changes and special processes (welding & NDE) were found to be acceptable.

Onsite review and QC monitoring were found to be adequate.

The program prcvided positive control of the status of modifications.

Weaknesses in this area were the lack of design interface control, design system corrective action, clarification of responsibilities for the performance of safety evaluations, and direction and acceptance criteria for QA audits of modification packages.

The management controls associated with safety-related design changes and modifications were considered average.

5.

Maintenance The objective of this portior, of the inspection was to evaluate the adequacy of management controls associated with maintenance activities.

a.

Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

(1)

ANSI N18.7-1976, paragraph 5.2.7.1, requires a preventive maintenance program be established and maintained.

Maintenance Department Administrative Instruction, MDAI 3-51-88, Preplanning and Documentation of Maintenance, defined a Zion Station pre-ventive maintenance program for the Maintenance Department.

This procedure indicated that the " Maintenance Engineer" (Maintenance Assistant Superintendent) would designate work as preventive or corrective in nature.

In addition, he would determine the frequency of preventive maintenance (PM)

performed on station equipment.

Interviews and review of records revealed there was no formalized PM Program; however, PM was being done.

Some PM activities were being done in response to indications from a trial vibration

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.y.3 monitoring program on pumps and motors.

Some equipment received PM as a result of current observations made by the Technical Staff or Operating Department and in conjunction with corrective main-tenance activities.

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PM procedures had been written and used.

These procedures included periodic PM applied to diesel generators and main coolant pumps.

All PM procedures reviewed had received the required onsite review and approval. A lubrication program was conducted and surveillance testing was being performed.

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lines for an overall corporate PM program were being developed.

The proposed guidelines included a formalized vibration analysis program, a lubrication program, a surveillance / inspection program, and a trend analysis program based on equipment experience.

While PM was being conducted, the lack of a written PM program addressing all~PM work was considered a significant weakness.

(W)

(2) The introduction to the QA Program Manual stated that the licensee would comply with the NRC document guidance on

" Quality Assurance Requirements during the Operations Phase at Nuclear Power Plants." This commitment requires compliance to ANSI H45.2.3. (Housekeeping).

Section 2, General Requirements, provides that measures be established and implemented, and that housekeeping operations be documented, verifying conformance to requirements.

Discussions were conducted with station personnel regarding housekeeping requirements.

Although housekeeping area responsibility assignments had been made, no station procedure, based on ANSI N45.2.3, could be provided.

(W)

(3) QP 3-52, Design Control for Operations Plant Maintenance, ZAP 3-51-1, Origination and Routing of Work Requests, and M0AI 3-51-8A, Preplanning and Documentation of Maintenance, described the program for the control of maintenance activities.

All safety-related maintenance work, including modifications, was required to be documented on a " Nuclear Work Request Form." (WR) The system provided for emergency main-tenance, priority of maintenance, and control of maintenance activities by the Shift Engineer. ' The following observations, related to the WR procedure, were identified through review of the procedures, maintenance records, and discussions with

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maintenance and operating personnel.

MDAI 9-51-1B, Welding and Burning Permit, provided for j

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control of welding and burning.

This permit was under the

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control of the maintenance foreman.

The Operating Engineer

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l was required to approve welding and burning performed in the Auxiliary Electric Room, Control Room, and Cable

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Spreading Room.

However, there was no formal mechanism to inform the Shift Engineer of welding or burning activities within the plant.

(W)

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The WR system did not ensure that the Shift Engineer was l

kept apprised of all maintenance activity in the plant. A-

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WR required the permission of the Shift Engineer to start work. However, the work request had to be authorized in order to draw repair parts, if required,'while actual work could start at a later time.

In addition, modifications could be authorized, and after delays, the work could be continued without the Shift Engineer's direct approval or knowledge. This concern was verified by shift personnel.

In most cases the Shift Engineer would have adequate knowledge of the status of work by other means such as discussions with the maintenance foremen, or review of the out of service log.

However,these provisions did not always ensure that the Shift Engineer was aware that work was being done in a given area.

(W)

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Site QC and QA personnel reviewed all WRs prior to and

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after the work had been accomplished.

However, no procedure (. auld be identified which established the criterion for review and acceptance.

(W)

(See Section 4 for a discussion l

of this area as applied to modification packages).

(4)

10 CFR 50, Appendix 8, Criterion VI, requires that documents

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which prescribe activities affecting quality are to be reviewed and approved for adequa'cy by authorized personnel.

QR 6.0,

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Document Control, stated that " documents such as specification, procedures, and drawings are reviewed for adequacy."

TS 6.1.G i

describes the review responsibilities of those performing the onsite review and investigative function. TS 6.2.A describes the requirements for procedural approval.

Zion Station Instrument Department Administrative Procedure, ZIAP 5-51-12, contained instructions'and procedures for calibrc-tion of instrumentation.

This procedure had not been reviewed by the onsite review group or approved by the Assistant Super-

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I intendent of Maintenance.

While this appeared to be an isolated i

occurrence, this was a primary calibration program document.

l (W)

This observation was discussed with the licensee and presented to the Senior NRC Resident Inspector as a potential enforcement item.

(5)

ANSI N18.7, Sections 5.2.15 and 5.3.5.(4), contains the require-ments for ensuring that maintenance procedures and their support-ing documents, such as vendor technical manuals, receive appropriate control, review and approval.

Discussions with site document control personnel, maintenance personnel, and review of procedures, revealed that vendor technical manuals l

were not controlled documents. Maintenance personnel utilized

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copies of vendor manuals maintained in ' departmental files for assigned maintenance activities; however, there was no estab-lished way to determine if these manuals were current prior to

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l their use.

A central file of manuals was maintained by the site document control section; however, no comparison was made between the central file and the departmental file.

Specific audits had not been made in this area.

(W) Portions of vendor manuals which were included in part of a maintenance procedure had received appropriate onsite review.

b.

Conclusions An approved program for the control of maintenance activities had been implemented.

Staffing needs were determined to be appropriate with some growth planned in the near future.

The concept of requir-ing all maintenance to be performed under a work request authori-zation was considered a strength.

Onsite reviews were performed and appeared adequate.

Management attention to maintenance was evident.

The following weaknesses were identified:

failure to control vendor technical manuals, lack of a documented housekeeping program, lack of a formalized PM program, and inadequacies in the work request sy; tem to keep shift personnel apprised of maintenance activities.

The management. controls associated with safety-related maintenance activities were considered average.

6.

Plant Operations The objective of this portion of the inspection was to evaluate the adequacy of the licensee's management controls associated with plant operations.

a.

Observations

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The following observations include the perceived strengths and I

weaknesses in the licensee's management controls which may not have specific regulatory requirements but will provide the basis for subsequent performance evaluations.

(1)

Interviews revealed that corporate management was knowledgeable of activities at the Zion Station.

Areas of concern at the Station were being evaluated and addressed by directives and policy statements issued by corporate managment.

The Zion Station organization was structured similarly to the Nuclear Stations Division at the Corporate Office, resulting in effective communications between the Zion Station and corporate counter I

parts.

(S)

(2) The Commonwealth Edison Company organization was described in the Quality Assurance Manual.

Organization charts depicted the current organization.

However, organization charts in the FSAR and Technical Specifications (TS) were not current.

(W)

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was noted, however, that the FSAR was being updated and a TS change had been submitted.

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(3) ZAP 6-52-2, Zion Station Document Control, revision 1, provided

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instructions for the operation and maintenance of the Zion I

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Central Files.

Interviews and observations revealed that microfilming of records was current and the Central File was well maintained.

ZAP 6-52-2 addressed the use of " active files" maintained by i

the various departments.

A review of the technical staff active file revealed the file was being controlled and an index had been prepared identifying the records to be maintained; however, several problems, as described below, were identified.

(W)

ZAP 6-52-2 specified a one yeai maximum retention period

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for active records in departmental files.

At the begin-

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ning of the insp'ection, 1979 records were being maintained in the technical staff active file.

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When records were transferred from the active file to Central Files, there was no assurance that records required

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to be maintained in the file were actually transferred.

ANSI N45.2.9-1974, Section 5.6, specifies that a single record storage facility should be Class A fire rated with

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a recommended four hour minimum rating.

(ANSI N45.2.9-1979 requires a two hour minimum rating).

The file cabinet being used for active records was a standard, non fire rated, metal cabinet.

These observations were discussed with the licensee and were presented to the Senior NRC Resident Inspector as a potential enforcement finding.

(4) ZAP 6-52-2 addressed the control of drawings at the Zion Station.

Drawings were microfilmed, and a master aperture and drawing

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file of architect / engineer (A/E) and vendor drawings was main-tained as the station's permanent file.

Seven satellite drawing files were also maintained:

one was an exact duplication of the master drawing file, and six duplicated only the A/E portion of the master file.

A/E drawing satellite files ~ were located in the Control Room, Instrument Maintenance Department, Electrical Maintenance Department and the Training Department.

These satellite files did not have duplicating capability and were maintained on a daily basis by central file clerks.

Drawings used in the plant were required to be authorized and issued by designated central file personnel. Drawings pending revisions were maintained in a " Construction Hold File" under the control of designated personnel.

Satellite copies of drawings in the Construction Hold File were stamped " Revision Pending." These drawings were well identified and maintained under tight administrative controls. (S)

(5)

ZAP 3-51-4, Procedure Governing The Use of Temporary Jumper Cables, the Lifting of Terminated Wires, or The Bypassing of Alarms, revision 7, addressed the administrative controls for the use of temporary jumpers, lifting leads, and bypassing of alarms.

. __

_. _ _ _ _

._ _

-

.

..

- 14 -

-

The procedure was inadequate in that the requirements of ANSI N18.7-1972, Section 5.2.6, regarding bypass lines, and indepen-dent verification of temporary modifications were not addressed.

There was no procedure which addressed the use of mechanical blocks. Interviews confirmed that independent verification was not being performed. (W)

Installing 'umpers and lifting wires was controlled by use of The Shift a Jumper Log or Lifted Wire Log, as appropriate.

Foreman and Shift Engineer were required to fill out certain portions of the logs, thus providing a dual review and evaluation.

Contrary to procedure requirements, one individual had signed

for both the Shift Foreman and Shift Engineer on the log sheets identified below. (W)

Date Jumper Log No.

9-072 1/17/80 9-073 1/17/80 9-074 2/4/80

9-081 7/1/80

'

9-082 7/1/80 9-085 1/6/81 Date Lifted Wire Log No.

L-1-008 2/12/81 L-1-009 2/12/81 The above observations were discussed with the licensee and presented to the Senior NRC Resident Inspector as a potential enforcement finding.

(6) ZAP 5-51-3, Procedure Periodic Review, revision 0, established f

the frequency and accepted methods for conducting periodic reviews of station procedures.

A record review revealed that procedures were being reviewed; however, two of.the procedural requirements, as described below, appeared minimal.

(W)

Station procedures were required to be reviewed no less frequently than every four years. (ANSI N18.7-1976 spec-

.

ifies procedure review no less frequent than every two I

years.)

'

Procedures used in conjunction with an approved Work Request were considered reviewed when the Work Request was

.

completed. There was no assurance that the craftperson using the procedure was technically qualified to perform the review.

ZAP 17-51-2, Procedure Change and Distribution, revision 8, (7)

described the system for making changes to existing procedures.

Individual responsibilities were identified and a review flow

- 15 -

path was outlined.

A record review revealed that the procedure had been implemented.

Interviews revealed that a krawledgeable individual with operat-ing experience had full time responsibility for tracking and assisting in making changes to operating procedures.

As a result, temporary changes were well tracked, timely reviewed, and expedited. (S)

(8)

Several Zion Station staff personnel had current Senior Operator Licenses (SRO).

Also, the Technical Staff had Instituted an equivalent SRO certification program for group leaders.

This program was administered by Westinghouse and consisted of seven months of systems and simulator training.

Interviews revealed that management recognized the importance of this type of training. (S)

The licensee had instituted a program to give recognition for quality performance.

The program was called PRO (professional)

and was well accepted and recognized by Zion Station personnel.

Management stated since they were critical of poor performance they also wanted to recognize quality performance.

Interviews revealed the overall morale and attitude of ifcensee personnel to be positive.

Personnel appeared to be enthusiastic and wanted to do a good job.

(S)

b.

Conclusions The licensee had issued written policy statements and utilized management directives and procedures, as required, to clarify existing policy or establish new requirements for p1' ant operations.

Organization and individual responsibilities were clearly defined in written procedures. The operating organization appeared to be adequately staffed, and personnel interviewed were knowledgeable of their job responsibilities.

The licensee had implemented an effective program for.the operation of the Zion Station; however, two significant weaknesses were identified involving inadequacies in the procedure for control of jumpers and lifted leads and control of active record working files.

Strengths were identified in several areas; the most significant being the document control program, the effective interface between Corporate and Zion Station Managers and staff counterparts, and SRO equivalency training given to the Technical Staff Group Leaders.

The management controls in the area of plant operations were consid-ered average.

7.

Corrective Action Systems The objective of this portion of the inspection was to evaluate the adequacy of the licensee's management controls over the corrective action systems.

_ - - _ _

'

- 16 -

-

.

a.

Observations The following observations include the perceived strengths and weaknesses in the licensee's management control which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

l (1) The Commonwealth Edison Company (CECO) policy was to manage by objective. Goals and objectives were established on an annual

,

'

basis.

Oral and written progress reports were made periodically during the year and at year end.

A review of a recent corporate

'

management annual assessment report revealed that some of the more significant corrective action items identified by the licensee had been included as part of the 1981 goals and objec-J tives. (S)

,

The CECO Topical Report, CE-1-A, and the Quality Assurance (2)

Program Manual delineated the QA requirement for the operation of the Zion Station.

The QA manual contained a cross reference listing of the ASME Code (Section III), ANSI N45.2, 10CFR50 (Appendix B), and Ceco quality requirements and procedures.

,

However, there was no comprehensive listing of all commitments to applicable guides and standards.

Also, there was no program

.

established to periodically review and evaluate, for imple-mentation, regulatory guides and standards, particularly revisions, to which no commitments had been made. (W)

(3) The licensee had established a corporate Production Performance i

Policy Committee.

One of this committee's responsibilities was to review and evaluate operating and maintenance personnel errors. As a result of these evaluations, corporate policy statements or directives were issued, if required, to clarify or strengthen company policy to preclude recurrence of the events.

(S)

The following methods were utilized by the licensee to identify (4)

and track problems to assure appropriate corrective actions:

Discrepancy Record (DR) - Used primarily to document and track corrective actions of discrepant items (spares,

.

materials, consumables, parts, and components) identified during receiving inspections; Deviation Report (DVR) - Used to document and track cor-rective actions of departures from accepted equipment per-

.

formance and failures to comply with administrative con-trols; Audit Report - Used to document audit deficiencies.

(Audit deficiencies open over 60 days were reported to

.

management in a monthly report);

Action Item Record (AIR) - Used to track long term deviation, discrepancies, audit deficiencies, and all commitments to

.

the NRC;

-

-

-

..

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--

-

.

_ 17

.

QA Surveillance Report - Used to verify corrective action

.

taken on audit findings; and Work Request (WR) - Used to initiate, track, and control

.

maintenance.

Procedures were established to control the various methods of identifying and tracking corrective actions.

These procedures detailed in a step-by-step sequence the responsibilities of all personnel involved in corrective action identification, tracking, and closecut.

Record reviews and interviews revealed that individuals were knowledgeable of their responsibilities, and the status of outstanding corrective action items was well documented. (S)

(5) The licensee had established a target date of 45 days for close-out of DVRs not considered reportable to the NRC.

A QA surveillance conducted on March 30-31, 1981, identified a number of non-reportable DVRs open in excess of 45 days.

From a review of these open items, it appeared that a large portion of these items could be closed out with little effort, suggesting a lack of followup by responsible individuals. (W)

(6) QA issued a monthly report to the Vice President Nuclear Stations and the Manager of QA.

This report listed the audit deficiencies open over 60 days.

Items identified as needing management attention were hi~ghlighted in a memo.to appropriate corporate management.

Interviews witn corporate management revealed that this report was distributed among senior management.

(S)

(7)

IE Bulletins (IEBs), IE Circulars (IECs), and IE Notices (ins) were distributed and tracked by the Nuclear Licensing Administrator (NLA) at the Corporate Office.

They were also tracked at the Zion Station by a member of the Technical Staff.

There were no detailed procedures outlining the handling of IEBs, IECs and ins.

However, a method for tracking and distributing this NRC correspondence had been implemented and the results were well documented.

The NLA issued an IEB status report twice a month and an IEC l

and IN status report once a month.

A written response was l

required from the Zion Station on all issued IEBs, IECs and ins. (S)

(8)

Interviews and procedure reviews revealed there was no compre-hensive trending program.

Trending was alluded to in various procedures, but no specific trending requirements were identified.

Some trending, however, was identifed as having been performed:

LERs, audit findings, and some general items contained in a Nuclear Division Operating Report.

-

-

_

_

_.

_

,

- 18 -

-

Formalized trending was lacking in the area of equipment failures and malfunctions.

Interviews revealed that equipment failures and malfunctions were evaluated informally by individuals designated as responsible for given equipment or systems; however, no formalized trending was being done. (W)

(9) Although not part of the licensee's corrective action system, the licensee utilized several methods to exchange information with utilities and nuclear suppliers concerning generic issues.

Those methods identified were: NOTEPAD, SEE-IN (Significant Event Evaluation and Information Network),and NOMIS (Nuclear Operating Maintenance Information Systems). (S)

b.

Conclusions The licensee had implemented a corrective action program.

Responsi-bilities were clearly defined for tracking and closeout of identified problems.

Corrective actions, generally, appeared to be completed in a timely manner.

Items needing attention were identified to upper management.

The most significant weaknesses were the lack of a formalized trending program and the lack of a comprehensive listing of standards and guides to which the licensee was committed.

Apparent strengths were the committee review and evaluation of operations and maintenance personnel errors and the extent of corporate management involvement in the Corrective Actions System.

The management controls in the area of corrective actions were considered above average.

8.

TRAINING The objective of this portion of the inspection was to evaluate the adequacy of management controls in the area of training.

a.

Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.

(1)

Licensed Training (a) ZAP 2-52-1, Training Program, revision 2, described in general terms the training and retraining requirements, and established the responsibility for implementation and documentation of the training and retraining program.

However, there were no written and approved implementing procedures which provided instructions and guidance on how activities were to be performed; eg., program change, instructor qualifications, training records, and training.

(W)

.

_

-

_ 19 -

(b) There were no program standards for evaluating present and future training programs.

The Quality Assurance overview of the training program did not review for quality and content, but rather against a list of specific require-ments.

(W)

(c)

Licensed Reactor Operators and Senior Reactor Operators were required to participate in a requalification program as per Appendix A of ZAP 2.52-1, Training Program, revision 3.

The program consisted of lectures, simulator training, and on-the-job-training (0JT).

The referenced procedure stated that a minimum of 80 training hours should be devoted to these areas over a two year requalification cycle.

The actual time over the two year requalification period was approximately four times the minimum amount.

It was noted that the entire requalification lecture program was under the direction of one instructor who, in addition to teach-ing twenty hours each week, was also responsible for lesson plan update, lecture preparation, examination preparation and grading, and other instructor duties.

There were sixty-seven personnel participating in the licensed requali-fication program.

An additional instructor position had been approved for the requalification program but not filled.

The understaffing in the requalific& tion area

..

had decreased the available time for upgrading the program.

(W)

('d) The licensee had a strong replacement training program for Reactor Operators and Senior Reactor Operators.

Each candidate for an NRC operator license received sixteen months of training, four and one half months of which were devoted to OJT.

The material presented during the course went beyond that which wa's required to pass the license Instructors interviewed appeared to be motivated, exam.

knowledgeable, and people oriented.

Six months following course completion, former students were requested by the Training Department to evaluate the overall. effectiveness of the course.

Recent graduates of the replacement training program were interviewed relative to their impressions of the training.

They stated there was less emphasis on preparation for the NRC exam and more practical demonstration on operating the plant safely.

(S)

(2) Non-Licensed Training QP 2-52, Quality Assurance Program for Operations -

(a)

Conduct of Training in the Production Area, provided instructions and described the responsibilities for administration of training programs for operations, maintenance, technical, management, and quality assurance functions.

This procedure required the Maintenance Engineer (among others) to complete periodic training program evaluations as requested by the Station Training Supervisor.

These evaluations were not accomplished;

_

- 20 -

however, an annual report for " Department Head Evaluation of Training Programs" was available.

This report was initiated by the Training Supervisor, completed by the

" Department Head", sent to the Station Superintendent for review, and returned to the Training Supervisor.

This report did not contain the training status and did not evaluate the training program as required by QP 2-52.

(W)

i (b)

ZAP 2-52-1 described the training and retraining require-ments and established the responsibilities for imple-l mentation and documentation of training and retraining.

!

This procedure specified that training in skills required for the efficient performance of duties assigned such as maintenance, should be scheduled and implemented by the cognizant department supervisors.

The Maintenance Department (mechanical, electrical, and instrumentation)

had established training objectives and courses.

Training l

was being performed; however, in most cases the maintenance

'

training was not formalized in a written and approved program and was not effectively evaluated by management for effectiveness.

Also, there was limited QA training given to maintenance personnel. (W)

The instrument shop training program included mock-up training, allowing technicians hands-on experience on similar, if not identical, plant equipment.

(S)

l

!

(c) The Zion Fire Protection Training Program included drills and subsequent critiques.

The fire protection course instructor attended many of the critiques, but copies of the critiques were not always sent to toe Training Depart-ment.

A review of tlie 1980 and 1981 fire drill critiques I

revealed that training effectiveness and training needs, l

if any, were not normally addre'ssed, thereby providing no feedback to the Training Department.

(W)

(d) The licensee was in the process of upgrading the non-licensed training program.

Station management had recently-appointed training coordinators for each department.

These coordinators had the responsibility to establish specific objectives and training needs for their depart-ments.

At the time of the inspection, however, this program had not been fully implemented to the point that the results were visible.

Therefore, training needs had not been fully identified in some departments.

(W)

(e)

The Production Training Department (PTO) at the Corporate Office was responsible for coordinating the training activities at all the licensee's nuclear stations.

This l

department had a staff of 50 members.

By the end of 1981, the staff was expected to increase to 95 members.

The PTD had been actively involved in the following programs. (S)

f Establishing training oriented job classifications to i

permit career path progression within the training

.

'

area.

. - _

.-

-.

-_

.

- 21 -

-

Performing job and task analyses for nuclear station

.

operator positions to provide a basis for estab-lishing training standards, performance standards, training modules, and instructor guides.

Establishing a standardized format and set of guide-

.

lines for requirements and performance standards to provide a manageable system for dev9lopment and implementation of training programs.

Developing a curriculum of instruction and estab-

.

lishing a performance standard for instructors to meet the needs of the PTO and station training personnel.

Developing a computerized training records system.

.

(f) A Production Training Center had been approved and was scheduled

,

for occupancy in November 1982.

This facility, as planned, is to be utilized for conducting standard training programs for nuclear operators, techn_ical personnel, fossil and nuclear station maintenance personnel, and management personnel.

(S)

b.

Conclusions (1)

Licensed Training The licensee had established an adequate written training program to provide replacement training and retraining for reactor operators and senior reactor operators.

The Training Department had not issued implementirig procedures for admin-istrative matters, and standards had not been developed to measure instructor performance and quality of instruction.

Instructors interviewed appeared motivated and understood their responsibilities.

Instructor staffing for initial training was adequate; however, additional instructors were needed in the retraining program.

The management controls in the area of licensed training were l

'

considered average.

'

i (2) Non-Licensed Training l

The licensee had established non-licensed training in the various departments; however, training needs in some areas, particularly maintenance, had not been formalized.

Depart-mental training was under the cognizance of the various department heads.

There was a lack of routine reporting to upper management of the departmental training status; consequently, the effectiveness of non-licensed training received limited evaluations.

Management had recognized the need to upgrade the non-licensed training program and had taken action to identify training needs for individual job task.

-

- 22 -

The management controls in the area of non-licensed training were considered average.

9.

PROCUREMENT The objective of this portion of the inspection was to evaluate the adequacy of management controls associated with procurement.

a.

Observations The following observations include the perceived strengths and weaknesses in the licensee's management controis which may not have specific regulatory requirements but will provide the basis for subsequent performance evaluations.

(1) 10 CFR Part 50, Appendix "B", Criterion V, and Section 5 of CECO Topical Report CE-1-A, revision 16, requires activities affecting quality be prescribed by documented instructions, procedures, or drawings and.be accomplished in accordance with these instructions, procedures, or drawings.

Section 2.2 of Ceco Topical Report CE-1-A committed CECO to comply with NRC Regulatory Guide 1.38 and ANSI N45.2.2.

Section 6.3.3 of ANSI N45.2.2, 1972, requires hazardous chemicals, paints, solvents, and other material of like

.

nature be stored in well ventilated areas which are not in close proximity to important nuclear plant items.

Section 3.5.1 of ANSI N45.2.2, 1972, requires caps and plugs be used to protect threads and weld end preparations.

.

Section 2.6 of ANSI N45.2.2, 1972, requires housekeeping of storage areas be in accordance with ANSI N45.2.3.

.

Paragraph 2.1 which prohibits the use of tocacco or eating in all access cor. trolled cleanliness zones.

l i

The following conditions were observed during an inspection of

-

the onsite safety-related material storage warehouse.

(W)

Eight (8) boxes of flammable dye penetrant were stored in the same area as other safety-related material.

.

l Station batteries were stored and being charged in the safety-related material receiving inspection area where

.

safety-related material awaiting or undergoing inspection was stored.

Weld end preparations for numerous safety-related butt weld fittings were stored without protective caps or

.

plugs.

Smoking and eating in the storage areas were not prohi-

!

bited. Smoking was observed in the Grade "B" storage area.

.

-

- -

.

.

. _ _ _ _ - - _ _ _ - _ -

.

. -.

..

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-.

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- 23 -

This observation was discussed with the licensee and was presented to the Senior NRC Resident Inspector as a potential enforcement finding.

(2) CECO corporate office purchasing procedures and records were l

reviewed.

Requirements for the following activities were noted.

j Bid package preparation, review, and evaluation l

.

QA purchasing activities and interface

.

Identification, processing, evaluation, and reporting of potential 10 CFR Part 21 conditions identified from within

.

Ceco

~

Interviews revealed an apparent lack of direction for the identification, processing, evaluation, and reporting of potential 10 CFR Part 21 conditions identified by vendors or other organizations outside of Ceco.

(W) During the inspection, CECO initiated changes to the QPs to clearly define the processing, evaluating, and reporting of potential 10 CFR Part 21 conditions identified by vendors or other outside organizations.

..

(3) 10 CFR Part 50, Appendix "B", Criterion V, as implemented by Section 5 of Ceco Topical Report CE-1-A, revision 16, required that activities affecting quality be prescribed by documented procedures or drawings and be accomplished in accordance with these instructions, procedures, or drawings. Section 12 of Ceco Topical Report CE-1-A required inspection, measuring, and test

, equipment to be adjusted and calibrated by procedure at scheduled intervals against certified standards.

A major contractor on site provided modification work and

,

design change installation services.

The contractor's purchasing, receiving inspection, and storage procedures and activities were reviewed and appeared to conform with Ceco procedures.

Interviews with licensee representatives revealed that initial major work activities of the contractor on site were for the NRC IE Bulletin 79-02 inspection and repair of pipe support concrete expansion anchors.

Interviews with licensee and contractor representatives revealed that they had used torque wrench multipliers for the IEB 79-02 work.

The following problems were identified.

(W)

A procedure had not been provided for the calibration of torque wrench multipliers used by the licensee and the

.

contractor.

Torque wrench multipliers used on site were not calibrated or checked for accuracy.

A check of a torque wrench

.

multiplier revealed that approximately 12% less than the required torque was provided.

The normal station practice i

.. _. _ _,.. - - _.. _,

._

__

. _ _ _ _ _

.. _.,. _ _. _ _ _ _,.

_ _ _ _, _

m._,,,__._-

.-____-.--.-_,__,__r

_ -, - - _ _

_. _,

.

-

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- 24 -

was to increase the required torque by 10% for the antici-pated error.

A procedure covering this practice was not available.

This observation was discussed with the licensee and was presented to the Senior NRC Resident Inspector as a potential enforcement finding.

b.

Conclusions The licensee had written policies and procedures to provide manage-ment controls in the procurement area.

The procurement program content appeared to ensure compliance with regulatory requirements and commitments to the NRC.

Information flow between management and lower levels of the organization appeared adequate.

Personnel responsible for procurement were aware of, and understood, their assigrea duties.

Guidance was not provided for handling potential 10 CFR Part 21 items identified by vendors or organizations outside of Ceco.

Also, safety-related material storage did not conform with certain ANSI N45.2.2 requirements.

Observations of the licensee's activities and interviews with management personnel revealed a commitment to the QA program in the procurement area.

The licensee's responsiveness to the inspector's observations further emphasized this commitment.

The management controls in the area of procurement were considered average.

10.

Physical Protection

.

t The information in this section is exempt from public disclosure in accordance with 10 CFR 2.790(d).

This section is included as Attachment A to this report.

11.

Management Exit Interviews

,

Exit meetings were conducted with licensee representatives at the CECO Corporate Offices on May 1, 1981, and at the Zion Station on May 15, 1981.

The licensee representatives who attended the May 15 exit meeting are I

identified by title in Attachment B.

The method of handling the Appraisal report and significant observations were discussed.

The Team Leader indicated that the inspection would continue with data review and analyses in the IE Regicnal Offices.

.

- - - - - - -

, -.-

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,,-,.e,,--

--

- - -

--

-

-.

--

,

i

-

.

Attachment B Persons Contacted The following lists (by title) the individuals contacted during this inspec-tion.

The table to the right of the listing indicates the areas (number corresponds to paragraph number in the report) for which that individual provided significant input.

Other individuals were also contacted during the inspection but the extent of their input to the inspection effort was not significant to the findings delineated in this report.

.

Title of Individual Corporate Office

3

5

7

9

Chairman and President x

x x

  • Executive Vice President x

x x

x x

Vice Chairman x

x x

  • Vice President-Nuclear Operations x

x x

Vice President-Engineering x

  • Division Vice President-Nuclear Station x

x

  • Manager of Quality Assurance x

x x

x x

x Manager, Station Nuclear Engineering x

' Manager, Station Construction x

x Manager, Operation Analysis x

x Operations Manager x

x Maintenance Manager x

x x

  • Production Training Manager x

Assistant Manager of Station Nuclear Engineering x

  • 0irector of Nuclear Safety x

x x

x

  • 0irector of QA-Operations x

x x

x x

Director of QA-Engineering and Construction x

x x

Director of Nuclear Licensing x

x

  • Supervisor, Off-Site Review x

x x

x Alternate Supervisor Off-Site Review x-x

~

Senior Participant, Off-Site Review x

Supervisor, Inventory Control x

Supervisor, Safety Engineering Group x

General Supervisor, Production Stores x

Zion Project Engineer x

x x

Station Nuclear Design Engineer x

QA Coordinator, OAD

~ x x

QA Coordinator, SNED x

x QA Engineer x

x QA Auditor QC Engineer, SNED x

x Fire Protection Coordinator x

x Nuclear Fuel Inspector x

  • General Purchasing Agent x

x Purchasing Agents (2)

Assistant Purchasing Agents (2)

x

  • Nuclear Security Administrator

.

_ _ -.

.

-

.

3

S

7

9

Assistant Nuclear Security x

Administrator x

Nuclear Security Staff Assistant Zion Station

  • Plant Superintendent x

x x

x x

x x

  • 0perations Assistant Superintendent x

x x

x x

Maintenance Assistant Supetintendent x

x x

x x

x

  • Administrative and Support Services Assistant Superintendent x

x x

x x

x x

  • Technical Staff Supervisor x

x x

x x

x Assistant Technical Staff Supervisor x

x x

x

  • QC Supervisor x

x x

x x

x x

  • QA Supervisor, Maintenance x

x x

  • Training Supervisor x

x x

  • 0perations Engineers (3)

x x

Chairman-Plant Nuclear Safety Committee x

  • 0ffice Supervisor x

x x

x Central Files Supervisor x

x x

x Technical Staff Group Leaders (3)

x x

x

  • Construction Lead Engineer Technical Staff Modification Coordinator x

x x

x Maintenance Engineer QA Engineer x

x x

QA Inspectors (2)

x x

x QC Specialists (3).

x x

x Shift Engineers (2)

x x

x Shift Foreman (2)

x x

x Station Control Room Engineer x

x x

Nuclear Station Operator (2)

x x

x Station Nuclear Engineer x

Master Electrician x

x

-

x x

x Master Mechanic x

x x

x Master Instrument Mechanic x

x x

Electrical Foreman x

x Electrical Work Analyst x

x x

Mechanical Foreman

,

x Instructors (3)

x x

x Outage Planner x

Station Security Administrator x

Assistant Security Administrator

  • Personnel Administrator x

x Storekeeper x

Senior Stockman B-2

-

-

-.

-

-

~

.

,

3

5

7

9

Phillips Getchow Company x

Field Superintendent x

QA Manager Burns International Security Services, Inc.

x Site Supervisor

,

x Assistant Site Supervisor x

Training Supervisor x

Lieutenant x

Security Officer (5)

  • Attended exit on May 15, 1981 b.

Documents Reviewed The documents listed below were reviewed by the inspection team members to the extent necessary to satisfy the inspection objective stated in Section 1 of the report.

The specific procedures referenced in the report are listed by title and revision number where they first appear.

(1) CECO Quality Assurance Manual, Quality Requirements (QRs)

(2) CECO Quality Assurance Manual, Quality Procedures (QPs)

(3)

Station Quality Assurance Program (4)

CE-1-A, Topical Report, Quality Assurance Program for Nuclear Generating Station, revision 16 (5)

Final Safety Analysis Report (FSAR), Chapter 12, Conduct of Operation, amendment 24 (6) Vice Presidents Instruction (7) Nuclear Stations Division Vice President's Directives (8) Nuclear Safety Department Organization and Administration Manual, revision 11 l

(9) Security Plan for the Zion Nuclear Power Station, revision 8

,

(10) Zion Administrative Procedures (ZAPS)

Station Nuclear Engineering Department Procedure (SNEOPs)

(

!

(11)

(12)

Zion Station Instrument Department Administrative Procedures (ZIAPs)

(13)

Zion Generating Station Maintenance Procedures (MPs)

(14)

Selected Generic Security Procedures (15)

Zion Security Procedures (16) Zion Station General Operating Procedures (GOPs)

'

(17) Periodic Test Procedures (pts)

(18) Zion Station Maintenance Department Administrative Instructions (MDAIs)

Zion Station Operating Instruction (SOIs)

l (19)

(20)

Zion Station Quality Control Department Administrative Instructions (QCAIs)

B-3

.

~

-

- -,. -. _ _.

__

,

-

.

(21)

Zion Nuclear Power Station - Licensed Operator Training Program Syllabus, January 1980 (22)

Station Nuclear Engineering Department Quality Training Program, October 19, 1977 (23) Zion Station Quality Assurance Training Program, July 15, 1978 (24)

License Retraining Review, Topic Outline, March 1, 1976 (25)

Simulator Retraining Course Syllabus, October 1980 (26)

License Retraining Schedule, 1981 (27)

Station Departmental Training Coordinator Appointment, March 19, 1981 (28)

Selected Departmental Memoranda

)

(29)

Selected Modification Packages (30)

Selected Work Requests (WRs)

l (31)

Selected Discrepancy Records (DRs)

(32)

Selected Deviation Reports (DVRs)

l (33) Quality Assurance Department Activities Report, March 1981

,

(34)

Region III Correspondence Follow-up Status Report, April 21, 1981 (35) Nuclear Division Monthly Operating Report, March 1981

,

f (36) Zion Station Audit Schedules (1980 and 1981)

)

(37) Zion Station QA Surveillance Schedules (1980 and 1981)

!

(38)

Selected Corporate General Office Audits (1980 and 1981)

i (39) Selected Onsite QA Audits (1980 and 1981)

(40)

Selected SNED QC Audits (1980 and 1980)

(41)

Independent Management Audit, CECO QA Program for Operating

,

l Nuclear Stations, September 1979 (Energy Inc.)

(42)

Shift Engineer Log (March - April 1981)

(43) Control Room Log - Units 1 and 2 (March - April 1981)

(44)

Zion Station Curve. Book

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i B-4

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