IR 05000295/1982016

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SALP Repts 50-295/82-16 & 50-304/82-14 for Jul 1980-Dec 1981.Mgt Performance Less than Desired in Radiological Controls & Handling of Plant Mods
ML20028A746
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 05/31/1982
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20028A747 List:
References
50-295-82-16, 50-304-82-14, NUDOCS 8211240362
Download: ML20028A746 (39)


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U.S. NUCLEAR REGULATORY C051311SSION

REGION III

SYSTE!!ATIC ASSESS!!ENT OF LICENSEE PERFORS!ANCE i

Commonwealth Edison Company ZION NUCLEAR POWER STATION Docket Nos. 50-295; 50-304 Report No. 50-295/82-16; 50-304/82-14 Assessment Period July 1, 1980 through December 31, 1981 Blay 1982 8211240362 821118 PDR ADOCK 05000295 g

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ERRATA SHEET

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Facility: Zion Nuclear Power Station SALP Report Nos. 50-295/82-16; 50-304/82-14 Page Lino Now Reads Should Read

39 The ready acceptance of a Delete generator as operable even though one cylinder was inoperable.

39 also inspected in this area.

also inspected in this area.

Four noncompliances.

Three noncompliances.

42-44 improper pump line up during Delete a liquid radwaste discharge (Severity Level V)

25 50-304/81-23 reported Delete

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inability to perform required boron sample tests because a sample system modification was being done simultaneously with

" outage" of the alternate sample point

34 F-inadvertent safety Three inadvertent safety injec-injections were reported with tions were reported with two two occuring during inverter occurring during inverter failures and one due to failures and one due to transients experienced during transients experienced during a feedwater line waterhammer a feedwater line water hammer.

and one due to operator un-familiarity with a startup procedure change.

4 Appraisal Section (PAS) on Appraisal Section (PAS) during April 10 through May 11-15, 1981.

April and May 1961.

10 The inspection did determine, The inspection did determine that several areas of weakness that several areas of weakness

15 Esca11ated Enforcement Actions Escalated Enforcement Actions 21&22 11 2.

Radiological Controls 2.

Radiological Controls (1) 121 (1)

(1) (1) (1)

21&22 21 Totals (1) (1) 1+191 (3)

Totals (1) (1) 1+(81 (3)

SUMMARY LER EVALUATION An evaluation of LER's indicates that the personnel error report rate at Zion is as high an any plant in Region III. Also, the rate at Zion increased by 50% from SALP period 1 to SALP period 2.

Twenty-seven personnel errors were reported over the eighteen month

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period for both units.

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Examples include:

l 1.

Pipe modification without adequate review.

j 2.

Wrong voltage rating heat trace installed.

3.

Heat tracing damaged by maintenance.

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4.

Inadequately monitored or inadvertent releases.

5.

Violations of environmental technical specifications.

6.

Boric acid concentration exceeded technical specification limit (14 previous events).

7.

Hydrogen purge fan improperly disabled.

8.

Hispositioned valve.

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Mispositioned electrical breaker (same breaker, twice).

I Personnel errors were also involved to one extent or another in

.three auxiliary feedwater related LER's reported. Together they

resulted in common-mode failures within the auxiliary feedwater system on 9/14, 11/26 and 12/11. These problems are discussed

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elsewhere in this report. An additional inadvertent pump trip resulted in a multiple pump outage because a second pump was out

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for maintenance (12/6).

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The equipment failure rate was also high, even though it was reduced by 27% over the previous SALP period. A big factor in the failure rate was radiation monitor failures which are discussed in Item 2 of Section IV.

Repetitive events occurring indicate the need for a more assertive program for timely identification and correction of root causes.

A portion of the repetitive events include:

1.

Vital inventer failures (four at Zion in two years),

2.

Standby instrument air failure (twice this SALP period),

3.

RHR miniflos valve micro-switch failure (four in two years),

4.

Frequent radiation monitor failures, and 5.

Pressurizer level instrument channels drifting low (six in two years).

Emergency power appears to have a lower than desired reliability due to seemingly unrelated problems such as an oil cooler leak, control power breaker failure, broken tachometer wire, rocker arm broken, etc. - including one diesel malfunction event simultaneous with maintenance on another.

(However, this is improved over SALP period 1 when two diesels were reported unavailable for emergency use on three occasions.)

" Equipment failure" appears overly used as the " proximate cause code."

It appears, for instance, that Zion (as do others) often cause codes design problems resulting in equipment failures as

" equipment failures." The associated corrective action is often replacement by " equipment in kind" and the event, without the design problem corrected, is a candidate for early repetition.

This also results in a misleading statistical distribution of event causes.

Another cause, although not generally identified, may be in environ-mental control. Unit 2 LER 81-12, for instance, reports a failed radiation monitor because of failure of all of the Unit 2 auxiliary building exhaust fans.

If this caused failure of the monitor, it may have resulted in other failures or equipment degradations for which the causal connections need to be identified.

Four inadvertent safety injections were reported with two occurring during inverter failures, one due to transients experienced during a feedwater line water hammer, and one due to operator unfamiliarity with a startup procedure change.

(Other events of significance not mentioned here are discussed elsewhere in the report.)

C.

Licensee Activities During the evaluation period, the following licensee activities i

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occurred:

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(1) On July 26, 1980, Unit 2 ended an 85 day refueling outage.

Power was limited to 93% for most of the period due to isolation of leaking feedwater heater string.

i (2)

Installation of the high density spent fuel racks was completed.

(3) On January 15, 1981, Unit 1 commenced a refueling outage that lasted 91 days.

(4) Tube leakage was discovered in Unit 1 shortly before start of the outage. Examination and plugging of steam generator tubes

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reduced but did not eliminate the leakage.

j (5)

In response to clad cracking problems, both Unit 1 charging pumps were replaced with all stainless steel pumps. Unit 2 pumps are yet to be replaced.

(6)

Inverter failures resulted in reactor trips and safety injec-tions on both Unit 1 and Unit 2.

The licensee has instituted a surveillance program to preclude such failures.

(7) Both Unit 1 and Unit 2 boron injection tanks were replaced with all stainless vessels after a leak developed in the Unit 1 tank due to cladding failure.

L (8) TVo of the three major TMI modifications (reactor vessel head vent and reactor vessel level indicator) have been completed.

The third (post-accident sampling system) is underway and should be completed well ahead of the required date.

(9) The licensee conducted an emergency preparedness drill on July 29, 1981, involving Federal, State, and local authorities.

(10) On September 11, 1981, Unit 2 commenced a refueling outage that lasted until November 24, 1981.

(11) In September 1981 a series of problems with auxiliary feed-water pumps began. Three basic malfunctions were identified:

(a) a sneak path from the W-2 switch modification resulted in the inability to start an auxiliary feedwater pump under

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certain conditions, (b) the low pump suction pressure pump trip setpoint was inappropriately modified, resulting in i

I defeat of the pumps on pump start; and c) a new alignment of the motor-driven pump discharge piping during maintenance of the turbine-driven pump resulted in an increased pump suction transient and inadvertent pump trip on start up.

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(12) Three fuel assemblies were damaged during the Unit 2 fuel shuffle. The damage was caused by an unretracted incore thimble which has been partically modified to accommodate the reactor vessel level installation.

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(13) Unit 2 experienced a high reactor trip frequency with six trips occurring in December 1981.

D.

Inspection Activities 1.

A management inspection was performed by the Performance Appraisal Section (PAS) on April 10 through May 11-15, 1981.

The inspection involved 515 inspector-hours onsite and at the corporate office. The results of the inspection were as follows:

Committee Activities - Average

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Quality Assurance Audits - Average Design Changes and Modifications - Average

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Maintenance - Average

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Plant Operations - Average Corrective Action Systems - Above Average

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Licensed and Non Licensed Training - Average

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Procurement - Average Physical Protection - Average

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One item of noncompliance resulted from the PAS inspection.

2.

During the period of June 29 through Jul. 10, 1981, and July 14, 1981, the NRC conducted a special appraisal of the emergency preparedness program at Zion.

Although no items of noncompliance were identified, several deficiencies were found.

These are being addressed by the licensee.

3.

The Institue of Nuclear Power Operations (INPO) conducted its first evaluation of the Zion Nuclear Power Station during the weeks of November 30 and December 7, 1981. Their overall determination was that the plant is being operated in a safe manner by qualified personnel. The findings and recommenda-tions of the INPO team are being addressed by the licensee.

E.

Invest!gations and Allegations Review 1.

On December 23, 1981, Region III based inspectors commenced i

an investigation in response to allegations of onsite drug and alcohol use.

The investigation is still open.

2.

A former licensee employee alleged that the Commonwealth Edison Company's operation of the Dresden, Quad-Cities and Zion stations creates a substantial safety hazard and there-fore is reportable per 10 CFR Part 21.

The allegation was based on the conclusion that licensee management was promulgating operating directives and philosophies which were unsafe in that they authorized departure from the

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Technical Specifications and that the licensee's corrective action's were incomplete or ineffective.

These allegations resulted in an extensive evaluation of the plant events, corrective action, and corporate management policies and l

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l procedures specifically addressed by the alleger. The

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special inspection conducted relative to this matter determined that none of the plant events cited by the alleger or others randomly selected for review created a safety hazard such that a significant threat existed to the health and safety of the public. Further, no instance was identified during the review where NRC reporting requirements had not been met, including those required by 10 CFR Part 21 or where NRC enforcement action was warranted but not taken.

The inspection did determine, that several areas of weakness do exist related directly or indirectly to some of the con-cerns expressed by the alleger where additional corrective measures are needed. These are documented in a separate report and were discussed with licensee management on May 3, 1982.

F.

Esca11ated Enforcement Actions 1.

Civil penaltias None.

2.

Orders None.

3.

Confirmation of Action Letters: On December 11, 1981, Region III issued a Confirmation of Action letter to Zion Station. The letter documented the licensees actions to ensure the reliability of the auxiliary feed pumps prior j

to the resumption of Unit 2 operation.

G.

Management Conferences October 31, 1980: SALP Cycle 1 Conference May 15, 1981: Petformance Appraisal Conference

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