IR 05000295/1990002
| ML19354E707 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/22/1990 |
| From: | Lemnartz J, Shembarger K, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19354E702 | List: |
| References | |
| 50-295-90-02-EC, 50-295-90-2-EC, 50-304-90-02, 50-304-90-2, EA-89-255, NUDOCS 9002010171 | |
| Download: ML19354E707 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-295/90-002; 50-304/90-002 Docket No. 50-295; 50-304 License No. DPR-39; DPR-48 EA 89-255 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
Zion Generating Station - Units 1 & 2 Meeting At:
U.S. NRC Region III office, Glen Ellyn, Illinois Meeting Conducted: January 12, 1990 Type of Meeting: Enforcement Conference
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Date of Previous Inspection:
November 21, 1989, December 13-15, 1989, and
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January 5, 1990
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Inspectors:
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i Approved By:
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i U. C. Wright, Cyft+ >
Date Operations Branth Meeting Summary i
Meeting on January 12, 1990 (Report No. 50-295/90-002; 50-304/90-002(DRS)
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Areas Discussed: f.dditional information presented by the licensee on the
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issues pertaining to programmatic deficiencies involving control and tracking of individual licensed operator license requirements as stated in 10 CFR 55.53-
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which resulted in four apparent violations to 10 CFR 50.54 documented in Inspection Report No. 50-295/89-040; 50-304/89-036(DRS). The evaluation and disposition of the apparent violations will be presented in subsequent communications.
9002010171 900124 gDR ADOCK 05000295 PDC
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DETAILS 1.
Persons Contacted a.
Commonwealth Edison Company (CECO)
T. J. Maiman, Vice President, PWR Operations, CECO L. O. Del George, Assistant Vice President, Quality Programs and Assessment, Ceco K. L. Graesser, General Manager, PWR Operations, CECO T. J. Saksefski, Zion Regulatory Assurance T. P. Joyce, Station Manager, Zion R. J. Budowte, Services Director, Zion P. LeBlond, Assistant Superintendent, Operations, Zion
A. M. Roberts, Production Training Manager, CECO M. S. Turbak, Performance Improvement 11anager, Ceco l
P. F. Manning, Nuclear Quality Programs, Program Specialist, CECO
T. J. Kovach, Manager, Nuclear Licensing, Ceco
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P. L. Barnes, PWR Regulatory Assessment Administrator, CECO K. Brennan, BWR Regulatory Assessment Administrator, Ceco G. Trzyna, Training Supervisor, Zion
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R. S. Chrzanowski, Nuclear Licensing Administrator Zion H. Logaras, 0)erator. Training, Zion i
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S. L. Trubatc1, Sideley and Austin j
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Nuclear Regulatory Commission
C. J. Paperiello, Deputy Regional Administrator, Region III H. J. Miller, Director, Division of Reactor Safety, Region III J. A. Grobe,. Director of Enforcement, Region III T. O. Martin, Deputy Director, Division of Reactor Safety, Region III i
G. C. Wright, Operations Branch Chief, Division of Reactor Safety, Region III W. M. Troskoski, Office of Enforcement B. Clayton, Chief, Projects Section 1A, Region III R. M. Pelton, Training / Assessment Specialist. NRR D. J. Lange, Section Chief, Operator Licensing Branch, NRR T. M. Burdick, Chief, Operator Licensing Section II, Region III M. J. Jordan, Chief, Operator Licensing Section'I, Region III J. D. Smith, Senior Resident Inspector, Zion j
K. M. Shembarger, Operator Licensing Examiner, Region.III
J. A. Lennartz, Operator Licensing Examiner, Region III 2.
Enforcement Conference As a result of apparent violations of HRC requirements, an enforcement conference was held in the NRC Region III office on January 12, 1990.
The preliminary findings which were the bases for these apparent violations of NRC requirements were documented in NRC Inspection Report No. 50-295/89-040; 50-304/89-036(DRS) and were transmitted to the licensee by letter dated January 10, 1990. The attendees of this conference are noted in Section 1 of this report.
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The purpose of the conference was to:
(1) discuss the apparent violations, their causes, and the licensee's corrective actions; (2)
discuss additional concerns noted by the NRC regarding the licensee's control and tracking of individual Part 55 licenses; and (3) obtain additional information which would help determine the appropriate
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enforcement action.
3.
Nuclear Regulatory Commission Presentation
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a.
In opening the conference, the NRC representatives identified the following apparent violations:
1).
10 CFR 50.54m(2)(iv): a senior operator limited to fuel
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handling performed licensed duties during a time when his license failed to meet the requirements as described in 10 CFR 55.53(e) regarding maintaining active status of license.
(Identified by licensee in LER-295/89-16-00).
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the licensee assigned a senior operator the responsibility of directing the licensed activities of licensed operators during a time when his license failed to meet the requirements as described in i0 CFR 55.53(h) regarding
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completion of a requalification progt m.
3).
10 CFR 50.54(i): The licensee permitted manipulaticn of the
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facility controls by operators whose licenses failed to meet the requirements as described in 10 CFR 55.53(h) regarding completion of a requalification program.
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the licensee permitted manipulation of the facility controls by operators whose licenses failed to meet the requirements as described in 10 CFR 55.53(i)_regarding medical examinations.
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b.
The following two issues were also addressed by the NRC l
representatives as concerns:-
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1).
The review conducted by and the corrective action.taken by the l
facility for LER 295/89-16-00 was limited to precluding recurrence of this event for SR0s supervising core alterations.
This action would not prevent similar occurrences in other licensed positions.
2). The lack of formal measures in place at the facility to ensure that licensed operators who are assigned licensed duties meet-
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all the conditions of their licenses as stated in 10 CFR 55.53.
The importance of ensuring that only authorized licensed individuals are allowed to perform licensed duties at the facility was underlined
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to stress the concerns on the part of the NRC.
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4.
Commonwealth Edison Company Presentation a.
The licensee's discussion regarding the' apparent violations as l
identified by the NRC included the following:
1).
In regards to the senior operator limited to fuel handling (SROL) performing licensed duties during a time when his license-was inactive, they stated that:
(1) license holders limited to fuel handling are easily identified because there are only two-
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of them; (2) the SROL was relied on to ensure he received any
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required retraining prior to perforting licensed duties; and (3), the schedulers did not know-that the SROL required reactivation prior to being scheduled for licensed duties.
2).
In regards to the senior operator who was assigned the i
responsibility of directing the licensed activities of licensed operators during a time when his license failed to meet the requirements conce' jing completion of a requalification program, j
the licensee stated that:
(1) the Shift Engineer (SE) knew that
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this individual was not authorized to perform licensed duties; (2) the SE knew that the work the individua1 was performing was I
not licensed duties; (3) the individual knew that he was not l
authorized to perform licensed duties and that the individual stated that he did not perform any licensed duties; and (4), the review of all of the docunented licensed activities that were i
performed during the time the individual was logged on shift..
indicated that none were performed by this individual.
In addition, the licensee stated that' licensed' operators who i
enter remediation training are easily identified due to the l
fact that there have been few licenses in this category in the
past, they are assigned to the Training Department during-this j
period, and the Training Department notifies Operations.
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Management of any individuals who have failed requalification-
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examinations and therefore, cannot perform licensed duties.
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3).
In regards to operators manipulating the facility controls during i
a time when their licenses failed to: meet the requirements con-cerning completion of a requalification program, the licensee stated that:
(1) even though the licensed operators failed to attend all of the scheduled requalification training lectures, the operators satisfied the requirement of their license because they met the requirements of the requalification program in place at the time; and (2) the requalification program in place allowed
" testing out" of requalification lectures.
In addition, the licensee discussed the following changes concerning the requalification training program to be implemented in 1990.
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i Increased amount of required classroom and simulator
training time.
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Required monitoring and reporting of deficiencies in-
training time to the station manager.
Required attendance at scheduled lectures or makeup of
material missed.
Additional scheduled training hours are provided to allow for
general employee training and other_ required miscellaneous.
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training sessions.
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The NRC representatives indicated that when the new Part 55 rule went into effect in May 1987, there were no provisions in the rule which allows licensed individuals from " testing out" of requalification lectures, and that attendance at all of the scheduled requalification lectures is required.
The licensee's program appears to be in violation of this requirement, l
4).
In regards to operators manipulating the-facility controls during a time when their licenses failed to meet the requirements con-cerning medical examinations, the licensee stated that:
(1)
they had reviewed and-verified that all medical examinations.
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were completed per;the CECO program which requires medical examinations.on a two year interval following_the license date; and (2) the CECO program governing medical examinations for licensed operators is consistent at all CECO Nuclear Stations-l and that in their' opinion, it meets the regulation.
I The NRC representatives indicated'that the medical examinations are required on a two year interval following the date that the-medical examination was initially administered'for applications-
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for individual operator licenses, and net from the date that the license was issued. The CECO program appears to be in j
violation of this requirement, b.
The licensee's discussion regarding.the concerns as. identified by
the NRC included the following:
1).
In regards to the-limited review and limited corrective actions, taken by the-licensee for LER 295/89-16-00; the licensee stated that-there is a program in place which would preclude similar.
occurrences in other licensed positions and stated that:
(1);
the program is based'on the personal knowledge-'of-the individual
license holder and operations management; (2) licensed operators with normally inactive licenses are easily identified because-they hold staff positions;'and (3), the schedulers are aware of i
these inactive licenses and therefore do not assign them to
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licensed duties.
2).
In regards to the lack of formal measures for controlling and tracking of individual Part 55 licenses, the licensee concluded that the program needs to be. improved in order to document.
compliance with license requirements.
Information presented by-
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the licensee identified corrective actions that have been
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completed to control and track Pa.'t 55 individual licenses.
The following are examples of completed actions taken on the part of the licensee:
A letter was issued to all CECO Nuclear Stations which was
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to be distributed to all individual license holders
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reminding each individus1 licensee of the Part 55
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requirements for maintaining their license.
A list of active vs. inactive license holders has been-
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prepared, will be updated-quarterly or upon change in status of an individual, and will be used.for scheduling licensed operators.
Additional corrective actions, for control and tracking of
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Part 55 individual licenses that will be taken in the future on t
the part of the licensee include the following:
A matrix will be developed to document the status of compliance with the licensed operator qualification
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requirements as stated in 10 CFR 55.. The matrix will be under the direction of the Assistant Seperintendent of operations and will be implemented at the Zion Generating Station April 1, 1990, and at all other CECO Nuclear Stations by July 1, 1990.
Quality Programs (QA) will review the Zion management systems implemented to control the operator requalification program including:
(1) the system to monitor training
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attendance; (2) the system to control licensee qualification status; and (3) assignment by line management of personnel to licensed duties. Additional followup actions will be dependent upon line management review of the1results on the above mentioned QA reviews.
- Performance Assessment will conduct a review of the acticns taken in response to the Zion training task force recommendations as part of the February 1990 assessment.
Performance Assessment is scheduled to conduct a
reaccreditation training assessment of'the licensed and non-licensed operator training programs at Zion in'1991.
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5.
Enforcement Conference Overview The additional information presented by the licensee indicates that there are programs in place at the facility to track individual Part 55 license
.i requirements in regards to two year medical examinations and completion of a requalification program.
The CECO program governing medical examinations requires medical examinations on a two year interval following the license date. The NRC
indicated that the medical examinations are required on a two year
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interval following the date that the medical examination was previously administered and not from the license date. The CECO program appears to be in violation of this requirement.
The facilities requalification program in place allows licensed operators to " test out" of scheduled requalification lectures.
Htwever, the new Part 55-rule, which went into effect in May 1987, has no provisions which-allows licensed operators from " testing out" of requalification lectures.
The new Part 55 rule allows flexibilit.r in requalifcation program contents, but does not provide any flexibility in requalification program attendance.
All licensed individuals must attend c.11 of the scheduled requalification lectures.
A review of all the information presented during the conference indicates
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that while controls existed to impirment the requalification program, the
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licensee failed to revise its requalification program at the time the new Part 55 rule went into effect, and-therefore, appears to be in violation of this rule.
The evaluation and disposition of the apparent violations will be presented
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in subsequent communications.
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