IR 05000295/1987021

Insp Repts 50-295/87-21 & 50-304/87-22 on 870818-28.No Violations or Deviations Noted.Major Areas Inspected: Allegation Re Work Assignments

ML20236G299
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/26/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236G270	List: IR 05000295/1987021 ML20236G267
References
50-295-87-21, 50-304-87-22, NUDOCS 8711020489
Download: ML20236G299 (7)

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/87021(DRP); 50-304/87022(DRP)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, Illinois Inspection Conducted: August 18-28, 1987 Inspectors: R. M. Lerch G. A. VanSickle

- -

Approved By: M nds J . hief 10 2+ . 6 7 Reactor Projects Section 1A Date Inspection Summary Inspection on August 18-28, 1987 (Reports No. 50-295/87021(DRP); 50-304/87022 (DRP))

Areas Inspected: Special, unannounced region-based inspection of allegation Results: No violations or deviations were identifie l

.

O

- _ _ .

,

_

.

..

DETAILS i

l Persons Contacted I i

• Plim1, Station Manager

• E.' Fuerst, Superintendent, Production

• Kurth, Assistant Station Superintendent,' Operations

• Schultz, Regulatory Assurance Administrator L. Holden, Regulatory Assurance D. Dexheimer, Industrial Relations

• J. Ballard,LQuality Control Supervisor

• W. Stone, Quality Assurance Supervisor i J. Rapaport, Quality Assurance ,

• T. Blake, Operations Training Supervisor  :

T. Saksefski, Regulatory Assurance Engineer

• Indicates persons'present at exit intervie . Inspection Results  ! (Closed) Allegation (RIII-87-A-0022): Operator concerns regarding work assignments expressed to the Senior Resident Inspector (SRI). ,

Plant operations personnel expressed concerns in two areas: i (1) Downgrading  ;

Background The licensee has a policy, referred to as downgrading, of reassigning nuclear station operators (NS0s) and equipment  !

operators (EOs) to assignments in the next lower job level ,

when neede This means that on short notice an NSO would be  !

assigned E0. tasks and an E0 assigned equipment attendant (EA)

tasks. This practice also allows for a shift foreman, which is the next job level above an NSO, to assist anyone who feels unfamiliar with his assignment. However, the downgrading reassignment is made considering only the job level of the q individual involved. The concern is that a downgraded person 1 may not have performed the tasks of the next lower job level for long periods of up to several years, and thus is not truly qualified for the assignmen !

Review of Downgrading

'

The inspectors interviewed licensee management and operations personnel, including NS0s, E0s, and EAs, to determine the extent of the concern among personnel, the basic causes for this concern, and management's position regarding downgradin It was determined from interviews that downgrading is allowed I by the labor agreement in effect. In a normal career path, an

<

.

2 i l ._ -_ - _ - _ _ _ - _ _ - _ _ _ _ _ _

.

5-individual starts as an equipment attendant and proceeds to

~

equipment operator and then to nuclear station operator. On any given shift, if a higher position person is available and )

a worker is needed in the next lower position, a temporary !

downgrade is made. This practice saves calling in another

'

employee who would be paid overtime. The inspectors reviewed two memoranda which were issued to shift supervisors to ;

implement this policy. The memoranda were issued for 1 consistency in implementing this policy. In interviews with personnel, it was determined that progression upwards depends on vacancies at the next higher pos One NSO had completed classroom training for E0, but had not performed the duties in the plant as an E0 before being promoted. Other NS0s had not performed E0 duties since their promotion more than two years <

earlie In addition, E0/EA responsibilities are changed in I the course of operations. Each of the six NS0s interviewed had misgivings over being assigned duties with which they are not familia The licensee has a policy of providing a shift foreman, which is a position in management one level above an NSO, to assist anyone not comfortable with an assignment; however, shift foremen are further removed from performing E0 duties, and several NS0s reported that they would seek out an E0 instead l of a shift foreman for assistance. No one stated any hesitancy ,

to request assistanc ]

l Another aspect of operations work which might also cause f dissatisfaction with downgrading is that most of the NSO duties ;

are performed in and around the control room, which is clean !

and quiet and requires less physical exertion. An individual

"

who has earned a promotion might resent being assigned lower job responsibilities in less desirable work condition In order to determine the technical proficiency required to I perform E0 and EA duties, the inspectors accompanied electrical I and mechanical E0s on their normal rounds. The rounds do not I include any special duties that might also be assigned to an E0 during a shift. The training programs established to qualify EAs and E0s were also reviewe The E0 rounds are performed with the use of a checklist, which includes spaces indicating equipment parameters to be recorded and acceptance ranges for the values. The tasks involved require identifying the gage or meter to be read, locating it, and properly reading and recording the gage value. In several u

instances however, the E0 connects meters or manipulates l equipment controls to provide the appropriate readings. The l review of training programs found that for qualification as an E0, 12 weeks of training are specified. Of these, 6 weeks are L

l l

!

2

_m ,g .

t

, ^\ ]

v

{_ 'k r

V a'I -

-. e

-

-

given to orrthe-job training with signoffs for demonstrating specified;tbk are provWd ,Jhe licensee also has a requalificatioq,prdgranFor EA that runst sser.a two year cycl , ,

")y

)). t i

.Conclutlen '

y / ) m,,

As observed during the E0 rounds, the perfeirred function 'o !

require 7somel specialized knowledge. The licensee?s thnuing and requalification programs also demonstrate a requirasant -

for' maintaining a tevel of proficiency. To indiscriminantly: g assign higher leveliamployees who have not kept current to ,

' lower level jobs is to assign safety-related duties to unqualified personnel, an apparent violqtion of 10 CFR 50, x- i Appendix B, Crfterion II. Licensee Eveqt Reports and Deviation Reports from 1987 were reviewed for any impact by this practice, but none was (dentified. This item is unresolved pending further'rdlew of safety significance. (295/87021-01; 340/87022-01) ./

'

'

(2) Partiality I

In a meeting ber seen the SRI and licensee non-unagement operationsperw[nnel,an'op#oionwasexpresset.pyalicensee e employee that NRC inspec Nrs' favor managementlover operator j This concq n was direct @ ht thq m sident inspectors. The inspectors discussed thb opint yn with the 16dividual involved, and asked if he still. Nit that 'NPC inspectars favored management. The individual stated that now he knew the resident inspectors better, and he fe'at thht p cou?

get fair treatment; therefore, he was nolo,d ngertalk to them of the opinion and i that the revident insredtors are biase This allegation is 1 considered close {

,

!

b. (Closed) Allegation (RIII-87-A-013D): Concerns $with operating i e l

!

procedures expressed by an NSO irqa meeting with the 3R y Background  ;

'

( [

'

TheNSOstatedthatsinceaboutYancaryt 1987 the rate at which

I l

operating procedure changes havr '}been 'implemmted /has 3 been excessive. He felt that the pace of procedure changes exceeded 3 his capacity to properlv review tM m,and compelled him to request'

removal from licensed duties in lat(' March 1987. The NS9 r.lso t ;)

expressed concern with the numberior pl" ant modifications with vMch i operators must keep og. He cited an event in which aD four miin )

steam isolation vaives @SIVs) were inadvertently oper.ed; he felt l that the event resulted from confdsion associated trW.) a two year- i old modification to th'e MSIV hydraulic operator sysce l

<

t

\ > ,

'\

r

'

,

4 ,

. . ,

.) I

N a' ,  !

D L -

J

_

hN S y J;

%

The NSO also stated that because he has requested removal from

3 A,;[ licensed-duties, he feared that management may be "after his job."

He stated-that management had attempted to have a member of the yD training staff administer an oral' board which he could not pass; 4' the NSO stated that the staff member had refused to do so, y Review s3

'

With regar.d to the alleged excessive rate of procedure changes, the

'

inspectors reviewed the site practice of issuing procedure changes T to operator Procedure changes are distributed to the NS0s in

%g 4 " Required Reading Packages," which are issued approximately once per

'..

-

month., These-packages also contain summaries of plant modifications qN.P%9/ 3 and other documents relating to plant operation. Interviews with l operators and the training staff revealed that operators are l

,.

required to read each package within a month from the date of issue, l y, ,

'

.and that keeping up with~the packages is constantly emphasized I p' during operator requalification trainin The licensee is in the process ofLimproving plant procedures (begun in late 1986) and therefore is generating more changes than normally. During the preparation of the required reading packages, the training staff makes a determination of the classroom training, if any, that should I be give The inspectors reviewed the number of changes to the following Zion operating procedures in the six reading packages issued during 1987:

!

Annunicator Response Panels (ARPs) l Abnormal Operating Procedures (A0Ps) i Emergency Operating Procedures (EOPs) j Emergency Plan Implementing Procedures (EPIPs) l Fire Operating Procedures (F0Ps)

Function Restoration Procedures (FRs)

General Operating Procedures (GOPs)  !

Maintenance Instructions (mis) l Periodic Tests (pts)  ;

of System Operating Instructions (SOIs)

h Zion Administrative Procedures (ZAPS)

Zion Electrical Distribution (ZED)

l i

l The preceding list accounts for 423 operating procedures. The !

number of changes in the six packages is 127, for an average of 21 l per package. A review of the changes themselves showed that they !

ranged from short, one-step revisions to extensive revampment of I entire procedures. Interviews with five NS0s (other than the )

- alleger) and the training staff revealed that few procedure 1 changes are specifically covered in training sessions prior to l implementation, but that keeping up with the reading packages and l reviewing procedures on shift prior to execution were sufficient '

to keep track of procedure change :

'l  !

}; l,

l

!

I I - -

- - -

_ . . . . _ . __

__ _ _ _ _ -_

,  !

l

\ p'

l The inspectors obtained from the licensee approximately ten percent of the 1987 reading package changes to ascertain their scope and i length and to evaluate the difficulty an operator would face in j

. keeping up with the In-depth reviews of three early-1987 changes 1 characterized as major revisions are summarized as follows: j (1) Surveillance procedure PT-10, " Safeguards Actuation," was revised to incorporate portions of another procedure, PT-6,

!

for alignment of the containment spray system. Previously, l PT-10 simply referenced PT-6 in the appropriate section )

The change resulted in the rewording of several sections and the addition of three sections from the PT-6 procedure. None ] 1 of the revised steps appeared difficult to follow. As PT-10 i is a " mandatory in-hand" procedure, operators would have the i

"new" steps in front of them to follow as they worked through the procedure. Although the total number of pages is large, {

the procedure is to be read and followed in the prescribed i order so that the material doesn't have to be learne i (2) A change to S01-35, " Generator and Generator Auxiliaries,"

added a new section for stator water demineralized resin change-out. The change consisted of four new pages of operating steps consisting mainly of valve manipulations, the format was consistent with the rest of the procedur (3) ZAP 14-51-2, " Inspection, Test and Operating Status - Tagging of Equipment," was almost completely revamped, including the forms for tracking and processing out-of-service tag Through interviews with five NS0s, members of the training staff, and one procedure writer, the inspectors learned that the new procedure resulted in much confusion during the shifts when the new procedure was first in effect. The major effect on plant operation was the slowing of the out-of-service proces Following the initial problems, a training session on this procedure change was subsequently incorporated into the NS0 training progra Of all the procedure changes reviewed, the ZAP 14-51-2 change described above appeared to be the only instance where a procedure change was particularly difficult for operators to assimilate in accordance with the normal station practice. With this one exception, which did not threaten continued plant operation, the inspectors did not identify evidence that procedure changes were outstripping the capacity of operators to keep up with them. Thus, the rate of change to procedures was not found to be excessiv With regard to plant modification changes, 31 plant modification summaries were included in the required reading packages. Inter-views with the training department revealed that modifications are covered during operator training. The inspectors reviewed the Licensee Event Report (LER No. 87-009-00) associated with the MSIV opening and agreed with the licensee's assessment that the event resulted from miscommunication and lack of procedural adherenc _ . _ _ - _ _ _ _ _ _ _ _

.i l l

The 5 vent did not appear to have resulted from operator unfamiliarity with the modification. The inspectors reviewed the remaining 1987 LERs and licensee deviation reports and did not identify events l resulting from a lack of. operator knowledge of plant modifications I or procedure change ;

With regard to the alleger's statements concerning his employment status and management attempts to have the training department create an oral exam that could not be passed, the inspectors learned through interviews with the alleger and with licensee management that the alleger had undergone an extensive examination involving an oral board, simulator examination, and system '

walkdown, each of which he failed. The licensee maintained that this examination (much lengthier than a yearly requalification examination)

was necessary to completely gauge the alleger's qualification, in light of the fact that he had expressed doubt in his ability to continue to perform his licensed dutie Members of the training department denied that they had ever administered an examination with the intent of failing any individual. The inspectors concluded that management actions in this regard were appropriat i Further, during interviews with the inspectors, five additional i NS0s (not including the alleger) stated that they did not feel that i raising operational concerns would affect their occupational statu Conclusion The foregoing information does not substantiate the alleger's concern that the number af procedural changes and plant modifications exceeds the capacity of operators to keep up. In addition, his concern that management was "after his job" does not appear to be substantiated by his treatment after he raised the operations issue This allegation is considered close . Unresolved Items Unresolved items are matters about which more information is required i in order to ascertain whether they are acceptable items, items of noncompliance or deviations. One unresolved item disclosed during this inspection is discussed in paragraph . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection conducted on August 18 through August 28, 1987 to summarize the scope and findings of the inspection activitie The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar _ . _ _ _ _ _ _ _ _ _ _ _ _ _