IR 05000295/1988001

SALP Repts 50-295/88-01 & 50-304/88-01 for Dec 1986 to May 1988.Overall Improvement in Performance Noted

ML20207J233
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/23/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207J222	List: IR 05000295/1988001 ML20207J218
References
50-295-88-01, 50-295-88-1, 50-304-88-01, 50-304-88-1, NUDOCS 8808300317
Download: ML20207J233 (46)

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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-295/88001:-50-304/88001'

Inspection Report N l 1  !

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Commonwealth Edison Company l Name of Licensee  :

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Zion Station

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l December 1, 1986 through May 31, 1988 Assesse.ent Period I l

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8800300317 880G23 PDR l

O ADOCK 05000295 I PDC ,

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TABLE OF CONTENTS Page N INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 I I I . S UMMARY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . . . 5 IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . 6 Plant Operations ... ................. 6 Radiological Controls . . . . . . . . . . . . . . . . . . . 9 Maintenance . . . . . . . . . . . . . . . . . . . . . . . . 'll Surveillance ....................... 14 Fire Protection . . . . . . ................ 17 Emergency Preparedness .................. 19 Security ......................... 21 Outages . . . . . . . . . . . . . . . . . . . . . . . . . . .

23 Quality Programs and Administrative Controls Affecting Quality . . . . . . . . . . . . . . . . . . . . 24 Licensing Activities. . . . . . . . . . . . . . . . . . . . 28 Training and Qualification Effectiveness. . . . . . . . . . 30 Engineering / Technical Support . .............. 32 SUPPORTING DATA AND SUMMARIES ................. 36 , Licensee Activities . . . , . . . . . . . . . . . . . . . 36 Inspection Activitias . . . . . . . . . . . . . . . . . . . 38 Investigations and Allegations Review . . . . . . . . . . . 40 Escalated Enforcement Actions . . . . . . . . . . . . . . . 40 Licensee Conferences Held During Assessment Period. . . . . 40 l

' Confirmatory Actien Letters (CALs) ............ 41 Review of 10 CFR Part 21 Reports and Licensee Event Reports Submitted by the Licensee . . . . . . . . . 42 NRR Activities ...,.................. 43 ,

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I. INTRODUCTION The Systematic Assessment of Licansee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. The SALP program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on July 27,1988, to review the collection of performance observations and dath to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II o' this repor This report is the SALP Board's assessment of the licensee's safet)

performance at the Zion Station for the period December 1, 1986 tbyough May 31, 198 SALP Board for Zion Station SALP 7 assessment:

Name Title

• C. E. Norelius SALP Board Chairman, Director, Division of Radiation Safety and Safeguards (DRSS)

• E. G. Greenman Direc*or, Division of Reactor Projects (DRP) ,

• H. J. Miller Directt.r, Division of Reactor Safety (DRS)

• D. R. Muller Project Director, Office of Nuclear Reactor Regulation (NRR)

• W. L. Forney Chief, Reactor Projects Branch 1, DRP ,

• J. A. Norris Zion Project Manager, NRR

• M. M. Holzmer Senior Resident Inspector

• • W. D. Shafer Chief, Emergency Preparedness and  !

Padiological Protection Branch, DRSS

"M. A. Ring Chief, Reactor Projects Section IB, DRP i l

J. M. Hinds, J Chief, Reactor Projects Section 1A, DRP 1 J. W. Clifford Region III Coordinator for the Deputy Executive Director for Regional Op9 rations

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Name Title ,

L. R. Greger Chief, Facilities Radiation Protection Section, DRSS W. J. Slawinski Radiation Specialist, DRSS J. E. House Radiation Specialist, DRSS G. C. Wright Chief, Operations Branch,-DRS M. P. Phillips Chief, 1perational Programs Section, DRS J. R. Creed Chief, Safeguards Section, DRSS J. Holmes Fire Protection Specialist, DRS T. J. Plo4ki Emergency Preparedness Specialist, DRSS P. L. Eng Resident Inspector-

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G. A. Van Sickle Project Engineer, Reactor Projects Section IA, DRP A. Dunlop, J Reactor Engineer, Technical Sup> ort Staff

• Voting member of the SALP Boar ,

• • Voting member for Fire Protection area only, b

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II. CRITERIA The licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, preoperational, or operating phase. Each functional area represents an area significant to nuclear safety and the environment and corresponds to a normal programmatic area. Some functional areas may not be assessed because of little or no licensee retivities or lack of meaningful observations in that area. Special areas may be added to highlight significant observation The following evaluation criteria were used in assessing each fenctional area: Management involvement in ensuring qualit Approach to resolution of technical issues from a safety standpoin Responsiveness to NRC initiative Enforcement histor Operational and construction events (including response to, analysis of, and corrective actions for). Staffing (including management).

However, the SALP Board 12 not limited to these c,iteria, and others may have been used where appropriat Based upon the SALp Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of .

these performance categories are: '

Category 1: Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear '

safety; licensee resources are ample and effectively used so that a high l 1evel of performance with respect to operational safety and/or construction quai My is being achieve Category 2: NRC attention should be maintained at normal level '

Licensee management attention and involvement are evident and are l concerned with nuclear safety; licensee resources are adequate and are I reasonably effective so that satisfactory performance with respect to operational safety and/or construction quality is being achieved, j Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers

> nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used, so that minimally satisfactory performance with respect to operational safety or construction is being l achieve l

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. Trend: The.SALP Board may choose to include'an assessment of the performance trend of a functional area. Normally, this performance trend is only used where Soth a definite trend of performance is discernible to the Board and the Bcstd believes that continuation of the trend may result in a change of performance leve P The trend, if used, is defined as:

Improving Licensee performance was determined to be improving near the close of the assessment perio Declining Licensee performance was determined to be declining near tne close of the assessment perio :

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III. SUMMARY OF RESULTS The regulatory performance of Zion Station is acceptable. The rating in the Emergency Preparedness area has improved, while the rating in the Training and Qualification area has declined. Although the ratings for the areas of Plant Operations, Radiological Controls, and Maintenance are unchanged from the previous assessment period, station performance has improved in_these arsas. Although the fire protection area is rated as Category 2, the performance assessment of this area highlights the licensee's lack of aggressive resolution of 10 CFR 50, Appendix R issues. The Category 3 rating in Engineering / Technical Support reflects weaknesses in dealing with several technical issue Rating Last Rating This Functional Area Period (SALP 6) Period (SALP 7) Plant Operations 2 2 Radiological Controls 2 2 Maintenance 2 2 Surveillance 2 2 Fire Protectica 2 2 Emergency Pre; aredness 2 1 Security 1 1 Outages 1 1 Quality Progr ams and 2 2 Administrative Controls Affecting Quality Licensing Activities 1 1 Training and Qualification 1 2 Effectiveness Engineering / Technical Support 'NR 3

• NR = Not rated (new functional area for SALP 7)

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IV. PERFORMANCE ANALYSIS Plant Operations Analysis Evaluation of this functional area was based on the results of 18 routine and special inspections conducted by resident inspector During the assessment period, the equivalent availability

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factors were 63.4% for Unit I and 74.3% for Unit 2, which are close to the lifetime availabilities of 67.4% and 71.5%,

respectively. During this time, the forced outage rates were 0.1% for Unit I and 1.3% for Unit 2, which are fractions of their lifetime forced outage rates of 12.7% and 13.9%,

respectively. Unit i recorded continuous runs of 35, 5 and 284 days during the. assessment period, and ended the period on day 38 of another run. Unit 2 started the period in the middle of a 131-day run, later recorded 50- and 55-day runs, and ended the period on day 238 of another run of continuous operatio Seven violations during the assessment period were attributable to plant operations; six were Severity Level IV and one was Severity Level V. This represents a decline from the previous assessment period, in which five Severity Level IV violations were identified. All the violations involved personnel errors, such as failure to follow procedures (5), failure to declare failed equipment inoperable (1), and valve mispositioning (1).

Two of these violations were associated with a safety system '

actuation (SSA) in which all four Unit 1 main steam isolation <

valves (MSIVs) failed open while the reactor was in het shutdaw Had nonsafety-related portions of the main steam system not remained intact, a severe cooldown transient could have resulte The resulting transient caused one of the safety injections that occurred during this assessment perio The licensee made noteworthy progress in the reduction of reactor trips from criticality. During the assessment period, Unit I tripped twice from power levels of 55% cand 6% and once with neutron flux low in the intermediate range during a shutdown. Unit 2 had no trips from criticality. All three -

trips were caused by equipment malfunctions; one involved the feedwater control system, one involved a trip of the generator excitation breaker, and the intermediate-range trip resulted from source range nuclear instrument noise. On four other occasions the reactor trip breakers automatically opened, but the reactors were shutdown at the time, and no rod motion occurred. Seven reactor trips from criticality occurred i durir g the previous perio i

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There were seven engineered safety feature (ESF) actuations associated with Unit 1 and six ESF actuations associeted with Unit 2. The total of 13 is much lower than the 24 ESF actuations reported during the previous period. .Six of the actuations occurred during surveillance testing activitie Eight of the ESF actuations involved personnel errors, two involved procedural inadequacies, and three resulted from ,

equipment failure Fifteen licensee event reports (LERs) issued this assessment period were attributed to the operations area. Ten were-attributable to personnel errors. Additionally, nine LERs involved a lack of knowledge on the part of operations personnel regarding technical information about the plant or regarding regulatory requirement The number of personnel errors attributed to operations, as measured by plant deviation reports, >

has decreased in comparison with the last assessment period, but operations personnel errors accounted for a larger percentage of the total number of LERs. Twenty-four LERs issued during the previous assessment period were attributed to the operations area; the percentage of operations LERs has remained about the sam Management involvement in ensuring quality improved during the assessment period. Management involvement, combined with improved performance by operators, has reduced the numbers of reactor trips, safety injections and ESF actuations, reduced the forced outage rate, and increased unit availabilit Specific management initiatives included reactor trip reduction and error-free operation committees, establishment of a plant labelling program and staff, improving nonlicensed operator log sheets, updating and correcting the Annunciator Response

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Manual, and updating Abnormal Operating Procedures and placing them in the Emergency Operating Procedure forma The safety significance of operator personnel errors declined, !

and the number of reactor trips due to personnel errors has been reduced. Additional management attention is needed to continue to reduce the number of operator personnel errors (as recorded in deviation reports). Additional attention is also needed to improve documentation of operating activities 4 in logs and procedures. Operator and shift supervicor logs seemed to record only the bare essentials of operating activities and were not complete in some cases. In addition, ,

for operating procedures which take days or weeks to complete, ,

steps were recorded as complete by use of chech marks; thus it i was difficult to determine when and by whom a step was performe '

Communication procedures have improved since the safety injection in May 1987 with the addition of administrative requirements for repeat-back communication practices. However, implementation of these new requirements has been sporadi l

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The licensee's approach to resolution of technical issues from a safety standpoint was generally adequate. Control room annunciators in the alarm condition and inoperable control room instruments were tracked, and efforts were made to make necessary repairs, although the total numbers of alarming annunciators and inoperable instruments appear to be increasing. Plant work requests were prioritized on the basis of safety as well as reduction of safety system down tim Most operating decisions were made in a conservative manne On the negative side, in cases involving imprecise regulatory requirements, the licensee sometimes made nonconservative decisions without sufficient technical justification based on liberal interpretations of regulatory requirements. For example, when one of two trip solenoid valves for the 20 MSIV was isolated due to a leak in February 1987 and the Technical Specification requirements were unclear, the licensee chose to continue operating until prompted by the NRC to take the conservative approach and to continue shutting down. In another example, aftcr the IB diesel generator tripped for unknown reasons, it was not declared inoperable; this resulted in a violation for failure to immediately test the remaining diesel generator Similarly, the licensee has exhibited a tendency to quickly bring the unit to operational status with a lesser concern for meeting requirements which are perceived as administrative or bureaucratic in natur One significant improvement was made in control room access and professionalism by modifying the control room center desk area to place the control room supervisor and center desk operator on a raised platform and to provide proper work surfaces and storage space to support control room activities. Control room access has now been exclusively routed past the control room supervisor, reducing congestion in the control roo Control room conduct and professionalism were generally adequat L Corporate and plant procedures specifically prohibit sleeping, chronic lack of attentiveness, alcohol or drug use, practical :

jokes, and other distractions under penalty of disciplinary '

action, including discharge. Radios, televisions, and nonprofessional reading materials are prohibited. Operators adhered to these procedures. Operator knowledge of plant status was generally good, but lack of knowledge of plant status, maintenance in progress, or regulatory requirements has resulted in several events and violation Staffing was generally adequate, with a five-shift rotation for operator Shift Control Room Engineer turnover, a concern expressed in the previous SAlp report, has been reduce Contractors augmented the plant staff in order to further .

efforts to improve operating procedures. Overtime was routinely )

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,' used during outages for licensed and nonlicensed operator To reduce operator overtime during the most recent outage, operators from a nearby fossil station were employed at t-Zion to perform general duties not requiring specialized ,

trainin . Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 2 in the previous assessmen !

perio ! Board Recommendations j

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Non j B. Radiological Controls l Analysis Evaluation of this functional area was based on the results of seven routine inspecsions performed by region-based inspectors and routine observations by resident inspector The enforcement history during this assessment period has declined from the previous period; four violations (two Severity Level IV violations and two violations awaiting severity level classification) were identified this period, compared with one Severity Level IV violation during the previous period. The two violations awaiting classification involved an unmonitored liquid releas Staffing levels and qualifications were adequate to implement the routine chemistry and radiation protection program While chemistry management was essentially unchanged, several radiation protection and ALARA professio1al/ technical and supervisory personnel changes occurred auring the assessment period. These changes included the RrJiation Protection Manager, Rad / Chem Supervisor, ALARA '.oordinator, and several professional health physics staff members. While all replacements appeared to be qualified for their new positions, the continued instability of radiation protection management personnel is potentially detrimental to program performanc The breakdown of RCTs into separate radiation protection and chemistry groups, expected to occur in early 1989, should improve performance in these areas due to increased specializatio Management involvement.in ensuring quality was generally goo The laboratories are well equipped, functional, and of sufficient size for proper operatio The licensee's secondary water chemistry control program conforms to the Electric Power

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Research Institute Owners' Group Guidelines, and chemical 4 parameters are well-controlled. The water quality control  :-

y program was upgraded with the installation of new monitoring i c panels with state-of-the-art in-line monitor Licensee

[ management dedication to strengthening the auxiliary building [

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contamination control program was evidenced by increased '

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staffing devoted to this area and by additional and improved 4 decontamination equipment. The radiation protection program was i also enhanced by the acquisition of additional state-of-the-art '%

external / internal contamination and exposure monitoring and '

i detection equipment. On the other hand, several problems '

identified during the 1988 Unit I refueling outage indicate '

the need to improve oversight and control of contractor outage

, activitie s 2 f Responsiveness to NRC initiatives was generally goo $

? The licensee has made improvements that affect both radiological .

and nonradiological measurement programs. The quality assurance / [

.. quality control (QA/QC) and RCT proficiency testing programs are, i

.- however, relatively new and still under development; additional i

! work is necessary in these areas. Several previously identified NRC concerns have been addressed in that training for stationmen

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4 has been formalized and upgraded to include topics devoted to y radiation protection and laundry operations, facility improvements

.; have been made in the dry active waste compaction area, and the 4 7 laundry facility has been improved and its operation better ..

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j The licensee's approach to the resolution of technical issues

[ has generally been sound and timely, with some exception Emphasis on reducing contaminated areas has continued, with

? significant improvements noted in auxiliary building cubicle .

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However, improvements are still needed to reduce the number i of personnel contamination events during outages. The total i station dose was about 650 person-rem for 1987 and about i{ 475 person-rem for 1986. These collective doses reflect .

5 generally good ALARA performance. The 1988 station dose is T expected to be significantly higher, primarily because of

unexpected work during the Unit 1 maintenance / refueling outag Although the station is making strong efforts to keep exposures  !

i as low as reasonably achievable, and has reduced station doses 2 F significantly over the previous five to ten years, there has

been a lack of consistent continuing decreases over the most

? recent few year ~

The results of radiological confirmatory measurements have i i improved and are generally good, with 73 agreements in j 77 comparisons. Three of the disagreements appear to have "

L been anomalies, and the fourth was related to calibration F- and nuclide deposition. The results of the nonradiological i confirmatory measurements program were good. The initial L

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results of 28 agreements in 33 comparisons (85%) were increased to 100% agreement upon reanalysis of the samples that were in disagreement. The disagreements were attributable to equipment difficulties that were corrected during the inspection and ti:

a possibly inaccurate calibratio Radioactive gaseous effluent releases were considerably re ,

during the assessment period, reflecting the absence of any '

significant fuel cladding problems and primary-to-secondary leakage,andapparentlyalsoresultingfromlimitedunit availability in 1987 and the licensee s continued monitoring of waste gas inventory to identify system leakage. Liquid effluents continued a generally decreasing trend that began approximately six years ago. One unmonitored liquid release resulted from failures to perform procedurally required valve line-up and discharg', monitor flow verification . Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 2 in the previous essessment perio . Board Recommendations Non Maintenance Analysis Evaluation of this functional area was based on the results of routine and special inspections conducted by the resident inspectors and four inspections conducted by region-based i inspector Two Severity Level IV violations and one Severity Level V violation were issued in this functional area during the assessment period. This enforcement history is comparable to ,

that of the previous shorter assessment period, when two Severity '

Level IV violations were identified. The violations involved i inadequate work instructions that resulted in a major diesel generator failure (evaluated in the previous SALP report),

incorrect equipment locations on work requests resulting in plant flooding, and uncontrolled vendor technical manual .

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Five LERs were directly at+ributable to maintenance activities, and 10 additional LERs at least partially involved maintenance '

activities or equipment failures. Of the 15 LERs, 6 involved procedure deficiencies, and 8 involved equipment failures, 2 of which caused the only reactor trips from power during the t

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assessment period. The remaining causes of personnel errors, poor communications and lack of craft training and knowledg contributed to about 4 LERs each. Thirty-four LERs were related to maintenance activities during the previous period.

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Eighteen of those were due to equipment failure Management involvement in assuring quality was adequat Management involvement was reflected in the reduced number of reactor trips and increased unit availability, compared to the previous assessment period. Other improvements included reduced safety system failures, low unit forced outage rates, and a reduction in the number of equipment forced outages per 1000 critical hours.

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Maintenance planning has iniprove A recently established l Planning Department provides better preparation of work packages, coordination between maintenance and operations departments, daily planning meetings, and support for about one i fourth of the daily nonoutage work. Maintenance priorities are established by the Operating Engineers, who are involved in the daily planning meeting The licensee has made progress _in the reduction of the work ;

request (WR) backlog. From a peak of over 4000, the total l WR backlog was reduced to around 2700. The licensee began j the assessment period with over 1500 nonoutage WRs, and by :

the end of the period had reduced the nonoutage WR backlog l to about 100 l

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l The licemee has also improved the plant material conditio The plant condition had degraded over the years, and many items

were in need of repair, such as fluid leaks, missing valve handwheels, broken doors, loose components, missing bolts,

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bent electrical conduits and panels, and broken and burned out lights. For many of these items, WRs had not been written to i initiate repair. To improve the overall plant condition, the :

licensee directed operators to write WRs for any items in need of repair. The influx of new work requests contributed to the WR total described above. The licensee established a Material [

i Condition Coordinator position in April 1987, and through his d

efforts material condition items have been more rapidly and !

efficiently addressed. In addition, a painting contract of 5

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over $1.5 million was let, and most of the turbine building ;

I and cribhouse structures and components have been painte As a result, the plant appearance and material condition have

! steadily improve l Management has shown an active interest in developing programs to deal with balance of plant (BOP) problems. These efforts

include the "reliability related" program, the trip reduction i

committee, and increased emphasis on root cause analysis +

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- for identified problems. Management has developed well-stated, understandable policies and has effectively reduced BOP-related reactor trip The licensee has demonstrated viable, generally sound and thorough approaches to BOP-related issues. Zion handles BOP modifications as if they are safety-related; that is, with the same level of management review. Preventive maintenance has also contributed to plant safety by reducing the potential for safety system challenges due to BOP equipment failure Several events indicate the need for additional management attention. Among these were unit shutdowns for a packing leak on one of two 20 MSIV trip solenoid valves and for packing leaks on both Unit 2 pressurizer spray valves, and unit trips due to equipment failures. Most of the equipment problems that led to shutdowns or trips were repetitive. In addition, foreign material in fluid or air systems led to a failure of the generator seal oil system, delaying a startup, and caused a dissel generator trip. Safety injection hasder pressurization due to check valve leakage also went uncorrected because replacement parts were not ordered in time to repair the valves during a refueling outage. Repetitive failures of instrument air compressors and radiation monitors were reduced during the period, and additional efforts are in progres Documentation of maintenance activities has sometimes been incomplete or lacking in detail, and tren6fng of equipment '

failures to identify repeat or generic component failures has been sporadi In addition, the resident inspectors identified two examples of post-maintenance testing which was not sufficient to verify that all potential contributors to equipment failures had been addresse Management weakness was evident in the control of vendor technical information. This weakness was identified h two corporate QA management audits and in third party aud: ts, which illustrate the weaknesses or disregard of the licensee's corrective action programs. Also, equipment classification procedures have nut beer, fully implemented. Only instrumentation components were classified according to the licensee's procedural requirements for a safety-related component lis The licensee's management has implemented a Total Job Management system for planning and organizing maintenance activities and to ensure that work is done effectively and efficiently and in compliance with all requirements. Appropriate management attention addressed inspectors' findings and concern Maintenance policies were adequately stated and understood for most of the period. In March 1988, the licensee completed a

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. corporate "Conduct of Maintenance" policy that standardizes maintenance organization and policy throughout the company, and establishes performance goals and policies; however, implementation procedures have not yet been developed at the station leve The site maintenance organization changed considerably, which has resulted in additional personnel being available_to improve work package preparation, to trend data, and to make long-term program improvements. Staffing levels have improved. Training was generally iffective, and adherence to maintenance procedures was good. A new preventive maintenance (PM) coordinator has

been named, and many PM activities are performed; however, a coherent overall program of PM and a systematic, comprehensive evaluation of PM needs await full implementation of the conduct of maintenance policy.

l Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 2 in the previous assessment j perio I Board Recommendations .

I None, j D. Surveillance , Analysis .

The evaluation of this functional area was based on the results

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of routine and special inspections by the resident inspectors, i five inspections conducted by region-based inspectors, and a '

J special inspection conducted by the Vendor Inspection Branc Specific areas inspected included in-service inspection (ISI); ,

resolution of IE Bulletin 82-02, "Degradation of Threaded l Fasteners in the Reactor Coolant Pressure Boundary .f PWR '

Plants"; containment integrated leak rate testing (cILRT);

and snubber functional testing.

Four Severity Level IV violations attributable to surveillance y activities were identified during the assessment period. This

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represents a slight decline from the previous assessment period, when two Severity Level IV violations were identified. Of these ,

violations, one involved failure to perform surveillance tests 1 I required by the Technical Specifications, one involved inadequate l

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evaluation of snubber surveillance testing requirements, and two involved use of inapnropriate acceptance criteria ih surveillance

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! Twelve LERs issued during the period were attributed to the

surveillance area. LER data identified 12 instances of missed i 14 l

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surveillances (in an 18-month assessment period), as opposed to 7 missed surveillances during the previous period (in a 14-month assessment period). In addition, 6 of 13 ESF actuations occurred during surveillance testing, compared with 6 of 24 during the previous period. Two of these were caused by personnel error, two by procedure deficiencies, and two by component failures. Of the seven instances in which reactor trip breakers opened during the period, two were due to inadequate surveillance test procedure Neither of these was a reactor trip from powe Management involvement to assure quality was evident during the period in the establishment of a computerized master surveillance schedule and the designation of an independent full-time surveillance coordinator. Surveillance coordinators have also been designated for each department that conducts surveillance testing. These coordinators contributed to effective management of the surveillance program; half of the missed surveillances were identified during reviews of surveillance test documentation by the surveillance coordinator Management involvement, including corporate office assistance, was also evident during the performance of containment integrated leak rate testin The licensee has made major improvements in test equipment and overall test personnel performance since 1984. Performance of the Unit 1 CILRT during the 1988 refueling outage was excellen Management controls in the area of ISI procedure and program reviews were generally effective; however, controls associated with snubber surveillances and associated test data evaluations were deficient, as demonstrated by the three violations related to snubber testing. Although minor, the number of violations in this area is indicative of weaknesses regarding management of the snubber surveillance program. Deficiencies included inadequate reviews of snubber service life requirements, inadequate evaluation of snubber test data, and lack of familiarity with pertinent Technical Specification surveillance requirement The licensee was generally aggressive in initiating procedure revisions to enhance or clarify procedure requirements; however, controls regarding procedure issuance need improvement with regard to both timeliness and procedure review. For example, large numbers of permanent and temporary procedure changes were processed during startup activities following both the Unit 2 summer 1987 and the Unit I spring 1988 outages. This practice resulted in confusion on the part of operators as to which procedures should have been used. The licensee also exhibited ,

a tendency to use excerpts of existing procedures in temporary l procedures without evaluating and resolving differences between original procedure assumptions and existing plant condition i This practice was particularly evident during performance of I l

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complex tests and when the licensee was trying to meet production schedules. Some of these procedure changes actually caused greater confusion and required additional procedure changes to ensure procedure compatibility with plant statu Observations regarding the technical adequacy of procedure reviews are addressed further in the Engineering / Technical Support section. The licensee has included operators in the procedure. review process in an effort to improve procedure content and ease of performanc In the specific areas inspected, technically sound methods were used to resolve technical issues. The licensee's response to IE Bulletin 82-02 adequately resolved identified issue Preparations for and the conduct of the Unit 1 CILRT were thorough and well thought out. Effective CILRT test planning was demonstrated by the determinatinn of a slow leak rate from a large PWR containment, using the coi*ervative BN-TOP-1 method, in a relatively short tim With regard to snubber surveillances, weaknesses in the interface between test activities and engineering were evident in the licensee's inconclusive root cause analysis for failures of 4 of the 16 Unit I steam generator snubbers during functional testing. Also, several instances were noted where members of the technical staff were unfamiliar with surveillance test requirement Several weaknesses in the surveillance testing of check valves were identified by the Vendor Inspection Branch special inspection. The most significant finding dealt with deficient testing of pressure isolation valves; this issue is discussed elsewhere in this repor Adequate staffing was applied to the surveillance are Contractors were used for ISI inspections and snubber functional '

testing. Corporate support for CILRT performance was evident during the test, and associated personnel performance was noted to have significantly improved. Observations of ISI and snubber !

surveillance activities indicated that technicians performing I the work were familiar with the appropriate procedures and l with the associated equipment, l

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2. Conclusion The licensee's performance is rated Category 2 in this area. The licensee was rated Category 2 in the previous !

assessment period, i

! Board Recommendations Non .

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E. Fire Protection Analysis Evaluation of this functional area was based on one special inspection conducted by NRC headquarters, a region-based inspector, and consultants to determine the adequacy of the facility's post-fire safe shutdown methods and to conduct a review of the licensee's rot. tine fire protection progra In addition, one routine region-based inspection was conducted to review licensee actions associated with LERs on aircraft fire dampers, and routine inspections were conducted by the resident inspector The licensee's fire protection program activities as observed by the resident inspectors were acceptable. Plant policies and procedures exist to control organization, responsibilities, drills and training of fire-fighting force In addition, other procedures govern housekeeping, fire protection tests and inspections, control of combustibles, use of lumber, and chemical receipt, storage, and control. Based on routine plant tours, combustibles have been well-controlled or stored in approved containers or lockers. Hot work, such as welding or grinding, is controlled by the approval of the operating shift, and hot work permits have been properly posted. Fire watch supervision and management have improved during the inspection period, and hourly rounds for degraded fire protection equipment, which had occasionally been missed in the past, are now properly performed and recorded. Fire watch '

standers have demonstrated that they generally understand their duties and responsibilitie Fire alarms are required to be manually initiated after verification of a fire. Some shifts sound the fire alarm upon receipt of a report of fire or smoke in an effort to provide a more conservative respons Fire brigades respond immediately upon the sounding of fire alarms. Fire brigade training has been a priority at the station, as indicated by the construction of a smoke house for self-contained breathing apparatus practice and a fire tower for practice in extinguishing fires, and by other fire brigade training. There have been few actual fires in the plant during the assessment period, and observed fire '

brigade responses have been acceptabl Fire protection ,

activities have been effectively audited by members of the ;

quality assurance organization with fire protection experienc Enforcement history in this area indicated a decline in performance. During the previous assessment period, one violation (Severity Level IV) was identified. During this {

assessment period, five violations (all Severity Level IV) I were identified. These violations were not of major safety l l

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significance; however, the amount and type of violations did indicate potential weaknesses which, if not corrected, might lead to an ineffective progra Management involvement to assure quality in this functional area was mixed. Management involvement was evident in housekeeping, the control of combustibles, fire watch performance and supervision, and fire brigade training and responses, as discussed above. Management provided support to the fire protection staff and to the development of the safe shutdown analysis. However, several concerns were raised during the two fire protection inspections regarding numerous LERs on aircraft fire dampers, incomplete installation of emergency lights, the fact that approved operating procedures implemented to achieve hot shutdown following a fire did not encompass fires in the inner or outer cable spreading room, and the fact that surveillance procedures were not revised to include all the fire walls identified by the July 1984 safe shutdown capability reassessment analysi As discussed in the SALP 5 report, an NRC letter in response to a schedule exemption request for certain 10 CFR 50, Appendix R requirements indicated that both Zion units would be in violation of the 10 CFR 50.48(c) schedule for the period of time extending from the expiration of the existing deadlines until NRC approval of a revised schedule. The NRC expected that all possible interim measures would be taken by Commonwealth Edison (Ceco) to compensate for the lack of compliance with Appendix R during this perio For some issues, such as revising the fire barrier surveillance procedure to maintain all the fire barriers as stipulated by the safe shutdown capability reassessment analysis, the licensee took a nonconservative approach by delaying revision of the fire wall surveillance procedure pending issuance of a safety evaluation. The licensee did not take sufficient interim measures or aggressively pursue implementation and maintenance <

of the appropriate procedures, systems, and programs required to validate the safe shutdown capability reassessment analysi ;

Management involvement has not been adequate to ensure the l timely resolution of these issue l

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The licensee's responsiveness to NRC initiatives was generally I adequate, based on timely resolutions of concerns identified )

during the safe shutdown inspection. For example, the licensee I has committed to the installation of additional smoke detectors I and to the protection of heating, ventilation, and air I conditioning system cabling with fire wraps. However, the l licensee has not aggressively pursued resolution of some NRC- l identified concerns, such as incomplete emergency lighting and 1 inadequate fire barrier surveillance procedures, which led to violations. The licensee has been particularly slow to revise fire barrier surveillance procedures. In January 1988, the l l

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licensee indicated that the procedures would be revised by December 1988. During a meeting conducted in February 1988, the licensee agreed to improve the dates for completion of corrective actions. Despite this commitment, in May 1988, the licensee indicated that resolution of this issue would be dependent upon the issuance of the safety evaluation report (SER) which will address several exemptions from Appendix R requirements. However, revision of these surveillance procedures does not involve an exemption'to Appendit R requirements; receipt of the SER is thus unnecessary to resolve this concern. In June 1988, the licensee indicated that only a draf t of the proposed Technical- Specification changes (which include fire barrier surveillances) would be available by December 1988. Subsequent to the assessment period (August 2, 1988), after repeated attention by the NRC, the licensee committed to full compliance with Appendix R requirements for fire barrier surveillance procedures by December 31, 198 . Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 2 in the previous assessment perio . Board Recommendations Non F. Emergency preparedness Analysis Evaluation of this functional area was based on three inspections conducted by region-based inspectors, including two routine inspections and an evaluation of the first day of the Federal Field Exercise (FFE).

The enforcement history was unchanged. No violations were identified during this or the previous assessment perio Management involvement in ensuring quality was excellent regarding efforts associated with the FFE. Corporate and station management committed ample resources to planning and training efforts, plus the conduct of the Tabletop Drill, the Dry Run Exercise, and the FFE. The station's emergency response facilities were upgraded to varying degrees. Internal preparations and considerable involvement by all five work groups planning for the FFE increased from efforts begun during the previous assessment period. During the first day of the FFE, corrective actions were satisfactorily demonstrated on both items identified during the 1986 exercise. No significant i

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problemswerenotedregardingtheinterfacebetweenthe licensee's and the NRC s emergency response organization However, five items related to the performance of in-plant and field survey teams were identified on the first day of the three-day exercise. Remedial training was to be part of the annual RCT training program scheduled after the early 1988 outage. This remedial training effort has not yet been evaluate Management involvement in ensuring quality was good concerning activities not directly associated with the FF Station and corporate staffs initiated corrective actions for self-identified problems with the Emergency Operations Facility's emergency ventilation and radiation detection equipment. Corrective actions were continuing at the end of this assessment perio Periodic communications tests and supply inventories were completed as scheduled. All required drills were conducted and critiqued. Administrative systems were more effectively used to track corrective actions in progress. However, the critique of the 1987 medical drill was ineffective, in that a number of significant concerns were dismissed as being acceptable for a drill, rather than being actW upon to improve performance before a future real emergency ar drill situation. The licensee was advised to reevaluate this frill critiqu Independent audits and surveillances of the program were sufficient in depth, more frequent than internally required, and improved in quality during the assessment perio .

The licensee's approach to resolution of issues from a safety standpoint was technically sound and thorough, NRC concerns with the station's proposed Emergency Action Levels (EALs) were resolved in a timely manner. The revised EAls have been  ;

significantly upgraded to eliminate a number of NRC and self-identified concerns. During FFE preparations, it became  ;

obvious that the evacuation time estimates for the ten-mile 1 Emergency Planning Zone were unrealistically hig The licensee ;

updated the input to the old technical study's methodology to '

generate more reasonable time estimates for use in the FFE. The j licensee is fulfilling a commitment to repeat the study using an up-to-date methodology to confirm the revised estimates. The new study will be formally submitted for evaluation after approval by state and local official The licensee has been responsive to NRC initiatives. Work space and communications equipment provisions were added to several emergency response facilities to meet the needs of the expanded site team. The licensee has expressed the willingness to provide similar accommodations for site team personnel in the new Technical Support Center under development. A number of emergency plan implementing procedures have been refined in response to NRC suggestions; however, several of these I

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refinements ihould have been identified during the licensee's internal review process, since they involved cross-referencing of procedures or procedural guidance on implementing emergency plan commitm(nts.

l Through mid-January 1988, the licensee had correctly classified and adequately reported to NRC and state officials all situations that were classifiable emergencies. Internal evaluations of records associated with each activation improved in quality during the assessment perio The licensee has improved the onsite emergency organization's rtaffing in several respects. At least three qualified persons have been identified for each key position. Additional staff personnel have been trained as communicators in the control room and Technical Support Center. Semiannual off-hours drills have successfully demonstrated augmentation capabilitie . Conclusion The licensee's performance is rated Category 1 in this are The licensee was rated Category 2 in the previous assessment period. The improved rating reflects effective management involvement, particularly in efforts related to the FFE, a sound approach to the resolution of issues from a safety '

standpoint, and improvements in the emergency organization

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staf . Board Recommendations Non G. Security Analysi5 Evaluation of this functional area was based on three security inspections (two routine and one special) by region-based inspectors and on routine observations of security force activities by the resident inspectors. Three allegations involving personnel access control were received during the assessment period. All safety and security concerns were determined to be unsubstantiate The licensee's enforcement history was good. One Severity Level :

IV violation was cited this period for the improper search of ,

trash. The violation was due to personnel error, and there was !

no safety significance. The licenne took timely and thorough j corrective action in response to the violation. The number of '

violations was the same as in the preceding perio )

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Management's role in assu ing quality was good. Corporate and .

plant management was supportive of the security program, as evidenced by the allocated personnel and material resource The site security administrator analyzes security data to determine program performance trends. The analysis has resulted !

in the early identification of potential problems and a pro-active security program. When requested, the licensee provided timely and comprehensive assistance in the review of allegation ,

I The licensee's approach to the resolution of technical issues-was good. The licensee improved compensatory measures for .;

failed closed-circuit television cameras; this action addressed

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a concern raised during the previous assessment period. The !

shore protection project prevented serious ice damage to the protected area intrusion detection system and reduced the number of nuisance alarms in the affected are With one exception the licensee's responsiveness to NRC ,

initiatives was good. The licensee did not address NRC concerns i of improper security badge display by personnel in the control room in a timely manner. The matter was resolved during this i I

evaluation perio Security event reporting was good. Only one event (unsubstantiated threat against the site) was reported thih period, due in part to the effectiveness of the security program and in part to the Itcensee's narrow interpretation of the revised NRC security event reporting rule. The licensee i continues to provide the NRC with timely and pertinent j information. The information provided by the licensee was essential to the resolution of one of the tilegations this perio Licensee security staffing was good. Tht licensee's action on NRC concerns regarding extended shift nours for central and :

secondary alarm station operators during the last evaluation l period resulted in significant reductions in forced operator overtime this period. The security training and qualification i program was good. Security personnel were knowledgeable and !

competent in the execution of their duties. Training was not th: root cause of the violation cited this period. The NRC recommended that security contingency drills integrate all contingency equipment and plant management personnel when i appropriate to enhance drill effective:.es !

Conclusion .

The licensee's performance is rated Category 1 in this are ,

The licensee was rated Category 1 in the previous assessment perio !

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H. Outages

_ Analysis Evaluation of this functional area was based on the results of

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inspections by the resident inspectors during two Unit 1 outages and one Unit 2 outage. These inspections included reviews of maintenance activities, surveillance testing, startup '

activities, and event follow-up. Region-based inspectors reviewed containment integrated leak rate and in-service testing activitie The enforcement history in this area indicated improved pe rf o r.ia nce. No violations were identified during the assessment period. One Severity Level IV violation and one

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Severity Level V violation were identified during the previous period. Fourteen LERs dealt with events during refueling

, outages. The most significant of these concerned the discovery l that more than 1% of the-tubes in the 10 steam generator (SG)

1 were defective, tLe identification of an inoperable snubber '

on an operating residual heat removal train, and the failure

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of large-bore SG snubbers due to contaminated flui .

With regard to core performance testing, responsiveness to NRC

. initiatives was good. NRC concerns were addressed in a timely manner by providing documents and ansaers to an inspector's questions and revising procedures when necessary. Corrective ( actions to previously identified inspection findings were thorough and included training conducted by the nuclear group l 1eader for all personnel in the nuclear group on the results of d

a previous inspection in the area of core physics testin However, an inspector identified two concerns which may

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demonstrate an attitude of complacency among the staff. A calculational error was made in a startup test procedure, but

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was not discovered by the nuclear 2ngineers in their review of the results. Also, no member of the staff knew the basis for the error f actor used in a startup procedure, j Managenent involvement improved during the assessment period,

, with the expansion of the Planning Department's duties and responsibilities. Experienced personnel were transferred from the operating, radiation protection, and maintenance departments to increase the Planning Department staff to 10 people. After

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J two refueling outages, which together lasted nearly 11 months, a 10 week outage goal was established for the spring 1988 Unit 1 outage. The outage was well-organized, and contract services

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from many vendors were used to supplement the site work force

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. as well as the outage planning personnel. Major events were well-briefed and planned. Unforeseen equipment problems were factorcd_into the outage plan as they occurred, and updated

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schedules were. frequently provided. Planning meetings were ;

effective in helping to resolve interface. problems between H departments. Housekeeping during this outage was acceptable

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and improved compared to previous outage A corporate Conduct of Planning policy was issued ~at the end of the assessment period. The policy was written to conform to INP0 guidelines. Some problems that need additional attention ;

are deficiencies with outage-related procedures, such as '

Maintenance Instructions (mis), and development of implementing procedures for tne Conduct of Maintenance polic )

The Unit 1 CILRT was well-controlled and efficiently ru 5e licensee performed a short duration test using the BN-TOP-1 irmulas and acceptance criteria, and completed the test and the

/erification in about 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> Site and corporate management involvement in the test was very effective, j Staffing was appropriate. Members of the plant nuclear engineering staff and corporate nuclear fuels section appeared- 1

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to be adequately trained and to have a good understanding of technical issue l

' Conclusion The licensee's performance is rated Category 1 in this are The licensee was rated Category 1 in the previous assessment perio l Board Recommendations Non I. Quality Programs and Administrative Controls Affecting Quality Analysis lhe evaluation of this area addresses two related but separate functions. First, it assesses the licensee's management activities to achieve quality in overall plant activitie This assessment in great measure reflects the quality of licensee activities in the individual functional areas that are addressed in other sections of this repor Secondly, it addresses the licensee's internal, independent quality oversight activities, such as those performed by the QC and QA organization Management's efforts to achieve quality in overall plant activities have resu ,ed in a substantial reduction in

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reactor trips and ESF actuations, with corresponding improved

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availability.for both units, as described in the Plant Operations section of this repor In addition, the backlog of nonoutage-work requests has been reduced somewhat, while the plant material condition has improved,substantiall Management initiatives included committees and task forces for specific plant problems, improved tracking of station commitments to regulatory and other oversight groups, and goal setting and review for the station, departments and work group Although reportable events have been reduced by nearly half in comparison with the previous assessment period, a review of these events and NRC enforcement indicate the need for additional management attention. Of the 46 LERs issued, 21 involved procedural or program deficiencies. Procesaral or program deficiencies also contributed to 16 of the 39 vitlations issued during the period. In addition, rewrites of operating department procedures (General Operating Procedures and Periodic'iests) initiated during the last assessment period have not been promptly issued. This problem was due in'part to tha large number of other procedure enanges that have tended to overtax the station review capabilitie Nevertheless, many prc adure improvements have been noted in annunciator response procedures, maintenance department procedures, and abnormal operating procedure The licensee's response to NRC initiatives was mixed. For example, improvements have been noted in the control of design documents, some of which were inaccurate or dif ficult to retrieve. Control room drawings are now better controlled, as are piping and instrumentation drawings. Drawing verification initiatives have improved security and other station drawings as well. The licensee has also normally been responsive to requests for data or information needed by inspectors in the line of their duties, and event reporting was conservative. The licensee was slow to respond to testing program deficiencies and concents early in the assessment period, and considerable NRC involvement was needed to correct problems concerning. pressure isolation valve testin Licensee actions to correct deficiencies were generally good, and technically sound improvements have contributed to abnormal event reduction and to improved safety system availability, especially diesel generctor availabilit Procurement problems identified earlier in the assessment period were also correcte Correction of some problems has lagged, however, as indicated by the fact that 12 LERs involved the failure ta meet surveillance test requirements, a concern identified during the previous assessment period. To the licensee's credit, about half of these 12 LERs were self-identified. In addition, Technical

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Specification review and implementation efforts, also a previous I concern, have progressed slowly, as have needed improvements in radiation monitor and instrument air compressor performanc Plant staffing has increased to meet the needs of performance improvement while continuing to suoport n:rmal operation Additional performance improvement is needed, however, especially in compliance with regulatory requirements, and some departments will have difficulty meeting the demands of increased workloads without the continued use of contrcctors. Lack of knowledge of plant technical information or of regulatory requirements on the part of personnel at the working or first-line supervisor level was identified in about one third of the LERs and violation Licensee management has expressed greater commitment to achieving excellent performance, but this philosophy has not been fully communicated to all levels of the plant and corporate organization. Evidence of increased management commitment to excellence includes more frequent plant tours by site managers, development of a professionalism course for plant personnel, establishment of committees focusing on specific improvements, such as the reduction of reactor trips, and initiation of a Human Performance Evaluation Syste Incret:ed corporate involvement was evident in the issuance of policies for the conduct of outages and maintenance. Site overview visits by the corporate office have also increase i With respect to the evaluation of the licensee's internal and l independent quality oversight activities, results of three  !

routins inspections and one special inspection conducted by l region-based inspectors, as well as observations by the resident 1 inspectors, were considered. The routine inspections dealt with  !

quality assurance program activities related to codits; receipt, '

stcrage, and handling of materials and equipment; procuremerit; surveillances; and maintenance. The special inspection dealt with quality assurance and quality control support of maintenance  ;

work on the 1B emergency diesel generator, which failed during i post-maintenance testing in late 1986, prior to the beginning of this assessment perio ;

The enforcement history declined relative to the previous  !

t sessment perio Six Severity Level IV violations and two l Severity Level V violations were issued this period, compared with two Severity Level IV violations during the previous perio The two Severity Level V violations included one for inadequate storage of material and one for failure to correct licensee- l identified storage deficiencies. Among the Severity Level IV violations, two involved inaccurate inforn:ation provided to the NRC, one was for record-keeping deficiencies, ora was for failure to correct previously identified deficiencies regarding

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the calibration os stop watches, and one involved the failure to incorporate design basis information into the Technical Specifications. The last violation concerned missed QC hold points following maintenance on the IB emergency diesel generato ~

An example of insufficient management involvement to assure quality was evident in the diesel generator maintenance activities reviewed during tnis inspectio Ineffective controls and directions provided by both maintenance and QC supervision resulted in numerous incidents of bypassed _ hold points, as well as possible omissions of work steps in the diesel generator nuclear work requests (NWRs) and associated procedures. The missed hold points raised the' question as to whether QC and maintenance personnel had been appropriatlly trainea in tie concepts and methods to be used to assure compliance with QC hold point The SSOMI conducted at Zion found many of the same deficiencies that were icKntified during a similar inspection at Dresde The restits of the inspection indicated that the lic asee's corr'ective action program in response to the NRC's findings at Dresden had not been adequate or effective despite the development of the new modification program. Many of these deficiencies involved a lack of attention to detail in complying with stetion procedures or the regulations. Further examples of this concern were the numerous instances in which nonconforming conditions were inspected and accepted by QC personnel ar.d the work completion packages accepted by c11 levels of managemen After the nonconformances were found by the NRC inspectors, work requests were issued to correct the In the area of procurement, receipt, storage, and handling, management involvement in ensuring quality was mixed. The QA organization was particularly effective in the identification and communication of weaknesses to line managemen However, line management efforts to implement corrective actions wero generally poor until problems were also identified by NRC inspectors. Prior to the NRC inspections, the correctiv actions were not timely or effective in this are Sub>equently, the response by management to implement corrective actions was outstanding. All the specific problems were corrected within a few days, and actions were taken to preclude a repetition of the problem The technical content of QA audits has remained good, and the QA staff usually includes at least one person qualified as a Senior Reactor Operato I i

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- Conclusion j The licensee's performance is rated Category 2 in this are The licensee was rated Category 2 in the previous assessment perio ')

' Board Recommendations Non )

J. Licensing Activities Analysis Evaluation of this functional area was based on the licensee's performance in support of licensing actions. Items evaluated were plant-specific amendments to the Technical Specifications and responses to Multi plant Actions (MPAs). These activities are reflected by the large number of amendments processed and MPAs closed during the evaluation period. The submittals consistently reflected adequate planning and assignment of-appropriate prioritie Corporate management's involvement was frequent and at a sufficient level to ensure adequate revie The engineering evaluations submitted in support of the licensing activities were technically sound and clearly presented, with only an infrequent need for additional information. All submittals for amendments were routinely reviewed for adequacy and correctness by onsite and offsite groups. The corporate licensing administrator for Zion maintained daily contact witn the NRC to make sure that matters were running smoothly and that any problems were resolved promptly and satisfactoril The licensee's staff has usually demonstrated clear understanding of the issues involved and presented. technically sound proposals for resolution, but one longstanding issue involving copper content in reactor vessel beltline welds remains unresolve In addition, the resolution of IE Bulletin 85-03 for motor-operated valve testing involved several requests for additional informatio Timely resolutions in almost all cases reflected a conservative approach, although resolutions of Appendix R and inservice testing issues have taken too lon The licensee has consistently been responsive to NRC concerns and initiatives. The resolutions proposed were timely, and deadlines were met. One exception was noted in that FSAR revisions have sometimes lagged far behind plant changes. For example, auxiliary feedwater flow rates of 105 gpm per steam gererator have been used since 1984, but the FSAR has not been updated to reflect this change. The implementation of NRC initiatives and policies was effective and met with NRC

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expectations. Where deviations occurred, they were well explained and documented. If additional response time was necessary, it was requested in advance and for valid reason During this evaluation period the licensee changed the Zion Nuclear Licensing Admini trator (NLA). The vacancy was filled promptl The changeover was smooth and did not affect the licensee's responses to the NRC. Both the previous and the current NLA hold valid Senior Reactor Operator (SRO) license Both men spent several years at Zion Station in various responsible positions prior to their NLA tours of duty. The technical support for the licenisng staff was sufficient to support adequate licensing submittal The licensing personnel maintain their skills in frequent training course The LERs adequately described the major aspects of events,

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including component or system failures that contributed to the events and the significant corrective actions taken or planned to prevent recurrence. The narrative sections typically included specific details of events, such as systems involved, dates of completion of repairs, etc., to provide good understanding of the events. The root causes of events were clearly identified in most cases. Many LERs presented the event information in an organized pattern with separate headings and specific information in each section that led to a clear understanding of the event information. The reports were thorough, detailed, and generally well-written and easy to understan The licensee staff has not always been effective in anticipating and identifying potential problems related to Technical Specification For example, Technical Specification definitions were changed in 1986, but the engineered safety l feature tables in the Technical specifications continue to  !

include the old terms. This contributed to confusion during ,

the February 1987 reactor shutdown (see the Plant Operations '

Section). However, the licensee staff did identify regulatory requirements that may require licensing actions by the NRC, and notified the NRC promptly so that resolution could be obtained on other than an emergency basis. The fact that the licensee has been able to avoid the need for any emergency Technical l Specification changes during this rating period is, at least l

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- Board Recommendations l Non K. Training and Qualification Effectiveness Analysis Evaluation of this functional area was based on routine inspections conducted by resident and regional inspectors that evaluated the effectiveness of training and qualification through inspections of specific program areas and through operator licensing examination The enforcement history shows no violations in this are No violations were identified during the previous assessment perio A review of LERs issued during the period revealed that 23 of the 46 LERs were the result of personnel errors. The majority of these errors appeared to be isolated incidents that were not indicative of generic training weaknesses, except that the number of LERs involving a lack of knowledge on the part of !

operations and technical staff personnel regarding technical information and regulatory requirements indicates a training concer Management involvement to assure quality was generally adequate. Positive involvement was evidenced by the improved operator licensing examination results. The pass rate for this assessment period was 100% (4 of 4), as compared to 70% (7 of 10)

for the previous perio Positive .nonagement involvement was also evidenced by the use of qualified contract instructors during the spring 1988 Unit 1 outage to augment the training staff as training needs increased. As a result, training quality was maintained, and few incidents due to deficient training occurred; however, several instances in which training should have been provided in a more timely manner were identified during normal operations. For example, surveillance procedures that shifted the responsibility for taking pump vibration data from an "A" man to a "B" man were issued before "B" men were trained in operation of the vibration meter, and the completely revised Annunciator Response Manual was issued before training was provided to operators. The former instance was identified by the resident inspector prior to performance of the task by any "B" men, and the latter resulted in a missed Technical Specification surveillanc The operator required reading program was effective 'n keeping operating personnel informed about balance of plant equipment /

plant modifications and operatiens. This training contributed to an adequate overall understanding of plant operation ,

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Review of the training records for members of the licensee's technical staff revealed that although an effort to send members

• :he technical staff to venders or other outside training activities was made, there was limited emphasis on the requirements for system operability and system interaction Aside from the basic indoctrination training.given to all licensee employees upon hiring, no formal training regarding station administrative procedures, applicable rules and regulations, or the requirements of the licensee's quality assurance program was give The licensee's training program for members of the technical staff did not include a job task analysis, as did the programs for other training groups. All technical staff personnel in place before September'1, 1985, were considered to be certified without additional training and will be subject to retraining on a three year basis. Currently-individual group leaders are responsible for developing and implementing lesson plans for members of their group. However, no lesson plan has been developed.for recertification of individual group leader The licensee obtained INPO accreditation for all 10 trC ning programs on November 24, 198 The licensee's responsiveness to NRC identified concerns varied in timeliness. For example, in response to the concern related to.taking vibration data, all "B" men, except those on vacation, were appropriately trained within ten days; however, lesson plans for. training on the applicable limiting conditions for operation related to pressure isolation valve (PIV) leakage had not been developed at 'he end of the assessment period. The content of training lesan plans was generally comprehensive and adequately addressed the subject materia Staffing appears to be adequate; however, significant resources have been devoted to training program revision in response to changes in the operator requalification process. This has affected continuing training for operations personne . Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 1 in the previous assessment period. The decline in the rating reflects the lack of knowledge of technical information and regulatory requirements ,

involved in many LERs and violations, and weaknesses in l

. technical staff trainin . Board Recommendations None, l

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L. Engineering / Technical Support Analysis This is a new functional area that was not rated during previous SALP assessment periods. Evaluation of this functional area was based on the results of four inspections conducted by region-based inspectors, routine inspections conducted by the resident inspectors, and a safety system outage modification inspection (S50MI).

The enforcement history during the current assessment period was poor. Nine violations e.ttributed to engineering and-technical support activities were issued, including two Severity Level III violations with associated Civil Penalties, six Severity Level IV vie!ations, and one Severity Level V violation. Since this area was not rated during the! last assessnent period, no enforcement history is available for comptison. In addition, while engineering and technical issues related to the SS0MI are discussed in this report, any potential enforcement actions related to these issues are still under review and consequently are not included in this repor Of the Severity '_evel IV and V violations issued, two involved inappropriate application of the environmental qualificacion requirements, three involved performance of modification activities without application of the appropriate canage ant and administrative controls, one involved failure to prescribe evaluations of snubber failures, and one involved inadaquate correlation of Technical Specification surveillance requirements with surveillance procedures. Of the Severity Level III violations, one involved inadequacies in the design, installation, and documentation associated with control room heating, ventilation, and air-conditioning (HVAC) systems and resulted in a $50,000 Civil Penalt This violation was related to performance during the previous assessment, period. The second Severity Level III violation involved significant programmatic testing deficiencies associated with the testing of pressure ;

isolation valves. These deficiencies were largely due to l inadequate technical reviews and misunderstanding of test j requirements, and resulted in a Civil Penalty of $100,00 Deficiencies in engineering and technical support activities contributed to 20 of the LERs issued during the assessment period. Of these, 1 LER was due to untimely review of test i data, 4 LERs were partially due to the use of inappropriate l test assumptions or acceptance criteria during test activities, '

and 12 LERs involved inadequate surveillance test procedure Seven LERs were partly due to failure to translate Technical Specification requirements into surveillance test-procedure l Of these seven, two were due to missed Radiological Effluent

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Technical Specification (RETS) surveillances. Two of the remaining LERs addressed-the failure to test safeguards logic circuitry, and one was due to the use of acceptance' criteria for main steam safety valve (MSSV) setpoints that were less conservative than those in the Technical Specification The events associated with testing the safeguards logic circuitry and MSSVs resulted in three violations, two of which had existed for over tan year Management involvement to ensure quality'in this area was largely deficient, as evidenced by the number, type, and severity level of the violations and LERs identified during the assessment period. A number of longstanding Technical Specifications test oversights were identified, including use of incorrect MSSV lift setpoints, repetitive RETS violations, and deficient safeguards logic circuitry testing. The foregoing problems were all identified by the licensee, indicating improved oversight of these activities. However, there was ample opportunity for previous identification during several reviews of the Technical Specification test requirements and correlations with plant procedures. Also, numerous instances of deficient procedures were identified; the most notable were associated with PIV testing, which would not have provided meaningful operability data as issue Procedure writing and reviews were not of sufficient technical depth or quality to ensure consistent successful performance or to avoid NRC violation Management guidance in the area of modifications and temporary l alterations controls was lacking, as evidenced by the three !

violations in that area and by the findings of the SSOMI. The SSOMI identified several areas in which the PWR Engineering Department involvement in managing the design and technical efforts of the Architect-Engineers ( A-Es) was weak. Examples of weak involvement include the lack of detailed review, at least on a selective basis, of calculations and analyses conducted by the A-Es on the various plant design modifications; deficiencies in the interface between design organizations and site staff in establishing required testing; faults in the licensee's 10 CFR 50.59 safety evaluation program, which covered only safety-related systems in lieu of all systems prescribed in the FSAR, and which was improperly implemented for temporary and permanent moJifications; insufficient technical evaluations for wiring discrepancies documented in Speed Letters; inadequate design control for instrument setpoint calculations on setpoint drift evaluations; and inadequate corrective actions taken to evaluate and control cable separation deficiencie The licensee's approach to the resolution of technical issues from a safety standpoint was mixed. The content of the licensee's technical solutions to identified problems was generally acceptable; however, they were not always provided

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in a timely manner and sometimes resulted in operational difficulties. Although the control room ventilation problem initially surfaced in September 1986, the licensee did not initiate a comprehensive evaluation of the noble gas intrusion problem until mid-Decembe Lack-of a well-stated policy toward operability evaluations resulted in the undetermined operability of the hydrogen monitoring piping. PIV leakage was identified during the spring 1986 Unit 2 outage; however, because replacement parts were not ordered in time,.after the outage Unit 2 operated with the safety injection pump discharge header-unnecessarily pressurized. In response to containment purge isolation problems identified in 1985 (LER 304/85029), .the licensee took two years to identify the root cause, but has no yet pursued a final resolution of the problem. Root causes and associated corrective actions have yet to be determined for several recurring problems at the plant, as in the case of frequent radiation monitor failures. On the positive side, resolutions of the piping-related problems and environmental qualification issues involved technically sound and mostly thorough approaches. The content of the licensee's LERs improved throughout the assessment period, and, in general, the threshold for reporting was conservativ With regard to responsiveness to NRC-identified initiatives, the licensee generally was cooperative; however, the licensee l occasionally tended to present reasons why an initiative was not applicable to the given situation rather than evaluating the technical merits of the initiative. Considerable NRC effort was needed to obtain acceptable resolution of the control room HVAC problems. Responses were frequently not timely and were lacking in thoroughness and depth. The regulatory issues were not addressed in a timely manner. Another example of resistance to NRC initiatives was the licensee's assertion that PIVs could not be tested on an individual basis due to the system configuratio As a result of the Severity Level III violation related to PIV testing, all but six PIVs are currently tested individuall In l addition, significant NRC involvement was necessary to ensure  !

that the PIVs were tested appropriately. The licensee was also I slow to investigate certain NRC concerns, such as Valcor valve

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Members of the licensee's engineering and technical support staff did not understand and implement all the quality j requirements imposed on the activities they perform. In addition, many members of the technical staff were inexperienced, with the average time of assignment being approximately three year This relative lack of experience and familiarity with both federal regulations and the quality assurance manual contributed to the deficiencies identified during the assessment perio i _

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2. Conclusion The licensee's performance is rated Category 3 in this are This rating reflects the _large number of violations and events, including two_ Severity Level III violations, attributable to this. functional area, insufficient management attention to several technical issues, and untimely resolutions of identified problems. Because this is a new area, no rating.is available for.the previous assessment perio . Board Recommendations The licensee should increase management attention to this area to ensere technical rigor, _ attention to detail, timely resolution of_ problems, and attention to regulatory requirement .

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V. SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 1 At the beginning of the assessment period, Zion Unit I was in its scheduled Cycle 9-10 refueling / maintenance outage that began on September 4,1986, and remained in this mode-throughout the first quarter of 1987. . Unit 1 engaced in routine operation at power levels up to 95% (limited by main generator vibrations), and experienced no significant outages or power reductions during the remainder of 1987 and early 198 During the first quarter of 1988, Unit 1 began its scheduled Cycle 10-11 refueling / maintenance outage and completed the outage in early May 1988. Unit 1 ended this assessment period in routine power operatio Significant outages and major events which occurred during the assessment period are summarized below:

Significant Outages / Major Events On March 23, 1987, Unit 1 completed the Cycle 9-10 refueling / maintenance outage. Significant activities included the replacement of seals on the main generator, repairs of the problems causing low lubc oil pressure on the main turbine, eddy current testing, control rod guide tube split pin replacement, and replacement of three 125-volt station batteries. The outage was delayed about nine weeks due to repairs on the diesel generator following ejection of the four lef t connecting rods in October 1986 and due to additional problems in the secondary plan April 25-30, 1987 - Unit I scrammed on April 25, 1987, due ,

to the failure of the 13N1 source range instrument. The l unit remained shutdown to repair generator frame vibrations i and a hydrogen leak into the stator water cooling syste l 1 May 10, 1987 - Unit I was taken off-line for maintenan:e and testing of the turbine generator in response to high vibrations, l February 24 - May 7,1988 - On February 24, 1988, Unit 1 I experienced a turbine trip and subsequent reactor scram on high-high level in the IC steam generator, because of a l feedwater regulating valve malfunction. The unit was shut l down, and the licensee elected to begin its scheduled Cycle 10-11 refueling outage for Unit 1 one day earl Major activities during the outage included 100% steam generator eddy current testing, sleeving and plugging of

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steam generator tubes, replacement of the main generator rotor, repairs to the reactor vessel head penetrations, overhaul of the 1A and 1B diesel generators, repair of two moisture separator reheater bundles, and the CILR Unit 1 experienced seven ESF actuations, including one safety injection, and five reactor scrams (one scram at greater than or equal to 15% power, two scrams at less than 15% power, and two scrams without rod motion). Two of the reactor scrams were the result of personnel error . Unit 2 Zion Unit 2 began the assessment period operating routinely, with no significant outages or power reductions reported until February 1987. Unit 2 began its scheduled Cycle 9-10 refueling /

maintenance outage on March 25, 1987. The outage icsted until early August 1987. For the remainder of the assessment period, Unit 2 operated routinely and was shut down only once for repair of pressurizer spray valve packing leakage. Unit 2 ended the asses: ment period operating normally at power levels up to 100%.

Significant outages and major events which occurred during the assessment period are summarized below:

Significant Outages / Major Events On February 3, 1987, Unit 2 was manually shut down when a hydraulic fluid leak was discovered in the trip valve for the 20 main steam isolation valve. It remained shutdown to repair the 'B' train solenoid 0-rin March 25 - August 10, 1987 - Unit 2 was shut down for-its scheduled refueling / maintenance outage; major work activities included steam generator eddy current testing; replacement of a steam generator U-tube anti-vibration bar, station battery, moisture separator tube bunale, and control rod guide tube split pin; steam generator snubber modifications; rebuilding of the 2B and 2C reactor coolant pump motors; and maintenance and refueling surveillances of the 0, 2A, and 2B diesel generator October 2-6, 1987 - Unit 2 was shutdown for repair of packing leaks on both pressurizer spray valve Unit 2 experienced six ESF actuations, including one safety injection, and two reactor scrams without rod motio Each scram resulted from a procedure deficienc ( ;- -.-

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• Inspection Activities-Fifty-six inspection reports are addressed in this SALP report, as listed.in Paragraph 1 of this section, Inspection Dat Significant inspection activities are' listed in Paragraph 2 of this section, Special Inspection Summar . Inspection Data Facility Name: Zion Unit: 1 Docket No: 50-295 Inspection Report Nos: . 86020, 86025, 86026, 86028, 86030 through 86032, 87002 through 87038,-and 88002 through 8801 Facility Name: Zion Unit: 2 Docket No: 50-304 Inspection Report Nos: 86021, 86025, 86026, 86028, 86030 through 86032, 87002 through 87005, 87007 through 87039, 88003, and 88005 through 8801 p '

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Table I Number of Violations in Each Severity Level UNIT 1 UNIT 2 COMMON Functional Areas III IV V III IV V III IV V A. Plant Operations ~ 31 2 1 B. Radiological Controls * 2 C. Maintenance .1 1 1 D. Surveillance 1 3 E. Fire Protection 5 F. Emergency Preparedness G. Security 1 H. Outages I. Quality Program and 1 5 2 Administrative Controls Affecting Quality J. Licensing Activities K. Training and Qualification Effectiveness L. Engineering / Technical 1 2+ 5**1 Support UNIT 1 UNIT 2 COMMON TOTALS III IV V III IV V III IV V 0 51 0 ~5 0 2 22 4

• Two additional violations were identified, but their severity level has ...it to be determined (Inspection Report No. 295/87008; No. 304/87010).

• • 0ne violation was identified during the SALP 6 assessment period, but not issued until the SALP 7 assessment period (Violation No. 295/86016-01; No. 304/86015-01).

+0ne violation was identified during the SALP 6 assessment period, but not issued until the SALP 7 assessment period (Violation No. 295/87005-01; No. 304/87005-01).

2. Special Inspection Summary An emergency preparedness exercise was held during June 22-26, 1987 (Inspection Reports No. 295/87007; No. 304/87009). A special team inspection was conducted during September 14-18, 1987, relating to check valve testing and maintenance (Inspection Reports No. 295/87024; No. 304/87025).

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' A special team inspection of the feedwater system (in accordance with the "Balance of Plant. Trial Inspection Program") was conducted during October 19-23, 198 During the period March 29 through June 2,1988, a SSOMI team inspection was conducted (Inspection Report.No. 295/88003). Investigation and Allegations Review Fifteen allegations were reported during this assessment perio Nine of the fifteen allegations and three previously reported allegations were closed; seven allegations remained open at the end of the assessment perio Escalated Enforcement Actions A Severity Level III violation and proposed imposition of a Civil Penalty in the amount of $50,000 were issued to the licensee on October 2, 198 This action was based on the control room ventilation system not being installed as designed and described in the FSAR. As a result, several significant air in-leakage paths existed. The licensee paid the Civil Penalty on November 3, 1987. (REF: Enforcement Notice No. 87-04, Enforcement Action No.87-105, Inspection Reports No. 295/87005; No. 304/87005) A Severity level III violation and proposed imposition of Civil Penalty in the amount of $100,000 were issued to the licensee :

on January 4, 1988. This action was based on inadequacies in the l licensee's GA program and management controls to ensure adequate testing of pressure isolation valves. The base Civil Penalty amount was increased by 100*4 because of the numerous instances of deficiencies in the licensee's testing procedures and the duration for which the violations existed. In a letter dated February 3, 1988, the licensee partially contested the violation 4 and requested mitigation of the penalty. An order imposing the !

Civil Penalty was issued on May 26, 1988, and the licensee paid the Civil Penalty on June 27, 198 (REF: Enforcement Notice No.87-108, Enforcement Action No.87-211, Inspection Reports i No. 295/87032; No. 304/87033) Licensee Conferences Held During Assessment period On March 13, 1987, a management meeting was held with licensee l representatives in the Region III office to discuss the problems with Zion's control room ventilation syste . On April 1, 1987, a meeting was held with licensee representatives and the public in Zion, Illinois to discuss the Systematic Assessment of the Licensee Performance (SALP) for October 30, 1985 through November 30, 198 L -

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' On July 15, 1987, an enforcement conference was held with licensee representatives in the Region III office to discuss the NRC's findings concerning the release of airborne radioactivity into the control room and the implications of the release on the operability of the control room ventilation syste . On August 18, 1987, a management meeting was held with licensee representatives in the Region III office to discuss the guidance the licensee was preparing to issue to its nuclear stations regarding the proper interpretation of Technical Specification 3.0. A (3.0.3 for Zion Station). On September 30, 1987, a management meeting was held with licensee representatives in the Region III office to review the status of the licensee performance improvement program for Zion Nuclear Power Statio . On October 19, 1987, a management meeting was held with licensee representatives in the Region III office to discuss the result of the safety system functional _ inspections performed by the licensee and its proposal to verify modifications performed prior to the programs upgrade at the licensee's operating site . On October 30, 1987, an enforcement conference was_ held with licensee representatives in the Region III office to discuss concerns and corrective actions associated with reactor coolant system pressure isolation valve testing deficiencie . On January 26, 1988, a management meeting was held with licensee representatives to discuss the role of the licensee's QA department in improving perforiaance at its nuclear stations, to discuss various licensee initiatives in this area, and to communicate to the licensee the NRC's expectations regarding ouality m:ersight of nuclear activitie . On February 17, 1988, a tour of the Zion facility and a management meeting were held with licensee representatives !

at the site to discus i Zion's goals for calendar year 1987 I and its 1988 prioritit . On March 8, 1988, Deputy Executive Director for Regional Operations J. M. Taylor toured the facility and met with ;

station management to discuss the status of Zion operation . On May 6,1988, a management meeting was held with licensee l representatives in the Region III office to discuss the licensee's response to IE Bulletin 85-003, "Motor Operated Valves."

F. Confirmatory Action Letters (CALs)

No Confirmatory Action Letters were issued during the assessment i perio i I

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• A Review of 10 07R Part 21 Reports and Licensee Event Reports (LERs) Submitted by the Licensee CFR Part 21 Reports No 10 CFR Part 21 reports were submitted by the licensee during this assessment perio . Licensee Event Reports (LERs)

Collectively, 46 LERs were issued for Zion during this assessment perio Unit 1 - Docket No. 50-295 LER Nos: 86041 through 86044, 87001 through 87017, and 88001 through 8801 Unit 2 - Docket No. 50-374 LER Nos: 860023 and 86024, 87001 through 87009, and 88001 through 8800 A unit comparison table of cause evaluations for the Zion SALP 7 LERs is shown below:

Cause - Unit 1 Unit 2 Personnel Errors 45.2% (14) 60.0% ( 9)

Procedure Deficiency 25.8% ( 8) 26.7% ( 4)

Design Inadequacies 0% ( 0) 0% ( 0)

Component Failures 22.6% ( 7) 13.3% ( 2)

External Cause 3.2% ( 1) 0% ( 0)

Other/Unkr.own 3.2% ( 1) 0% 0 TOTALS 100% (31) 10n% 1 A comparison table of cause evaluations for Zion's SALP 6 and !

SALP 7 LERs is shown below:

(14 mo) (18 mo)

Cause SALP 6 SALP 7 Personnel Error 41.1% (30) 50.0% (23)

Procedure Deficiency 30.1% (22) 26.1% (12) l Design Inadequacies 5.5% ( 4) 0% ( 0) l Component Failures 9.6% ( 7) 19.6% ( 9) i External Cause 1.4% ( 1) 2.2% ( 1) l

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Other/ Unknown 12.3% ( 9) 2.2% ( 1)

TOTAL 3 100*4 (73) 100 % (46)

Frequency of Issuance 5.21/m .56/m I l

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NOTE: The above information was derived from reviews of Licensee Event Reports performed by the NRC staff and may not completely coincide with the unit or cause assignments that the licensee would mak In addition, these tables are based on asc gning one cause for each LER and do not necessarily correspond to the identification of LERs in the Pert'ormance Analysis Section (Section IV), in which multiple causes may be assigned to each even H. NRR Activities NRR/ LICENSEE MEETINGS DATE DCRDR 12/11/86 SALP management meeting 02/10/87 - 02/12/87 ISAP presentation 01/05/88 VISITS TO THE SITE Routine periodic 04/01/87 - 04/02/87 Routine periodic 06/01/87 - 06/02/8 Inservice Testing 07/28/87 - 07/29/87 Vendor Inspection Branch 08/10/87 - 08/14/87 Appendix R Audit 11/16/87 SSOMI exit 04/29/88 COMMISSION BRIEFINGS Non . SCHEDULER EXTENSIONS GRANTFD Non . RELIEFS GRANTED Non . EXEMPTIONS GRANTED Non . LICENSE AMENDMENTS ISSUED Amendments 99/89 Battery Charger 12/08/87 i

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Amendments 100/90 Hot Channel Factor 02/26/87 ,

Amendments 101/91 Heatup and Cooldown Curves 03/13/87

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Amendments 102/92 Number.of.RCPs in Mode 3 03/20/37 Amendments 103/93 Generic. Letter 85-19 03/26/87 Amendments 104/94

"0". diesel generator outage time 05/08/87 Amendments 105/95 Containment Isolation Valves 06/23/87 Amendments 106/96 Capsule Withdrawal Schedule- 07/20/87 Amendments 107/97 Containment Fan Coolers 08/17/87 Amendment 108 Snubbers 02/05/88 Amendments 109/98 Battery Upgrade 03/28/88 Amendments 110/99 Low Temperature Overpressure 04/04/88 I Protection Amendments 111/100 '

Westinghouse Sleeving Methodology 04/16/88 I Amendments 112/101 .!

PIV Testing 04/15/88 l

8. EMERGENCY TECHNICAL SPECIFICATIONS ISSUED l l

Non j 9. ORDERS ISSUED Non I l

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