IR 05000295/1991001
| ML20029B618 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/05/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20029B608 | List: |
| References | |
| 50-295-91-01-01, 50-295-91-1-1, 50-304-91-01, 50-304-91-1, NUDOCS 9103130132 | |
| Download: ML20029B618 (3) | |
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Enclosure 1
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SALP 9 i
FINAL SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Reports No. 50-295/91001; 50-304/91001 Commonwealth Edison Company Zion Station, Units I and 2 October 1, 1989 through October 31, 1990 l
9103130132 910305 PDR ADOCK 05000295 l
PDR l
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Zion Units 1 and 2 A.
Summary of Meeting with Commonwealth Edison Company on January 31, 1991 The findings and conclusions of the SALP Board are documented in Reports No. 50-295/91001; 50-304/91001 and were discussed with the licensee on January 31, 1991, at the Illinois Beach Resort in Zion Illinois.
While the meeting was primarily a discussion between the licensee and NBC, it was open to members of the public as observers.
The following licensee and NRC personnel were in attendance, as well as the noted observers.
Commonwealth Edison Company C. Reed, Senior Vice President, Nuclear Operations K. L. Graesser, General Manager, PWR Operations L. O. Del George, Assistant Vice President, Engineering and l'onstruction D. Farrow, General Manager, Nuclear Services R. E. Querio, General Manager, Q.P. & A.
T. Joyce, Plant Manager, Zion Nuclear Regulatory Commission A. B. Davis, Regional Administrator, RIII H. J. Miller, Director, Division of Reactor Projects, RIII R. J. Barrett, Director, Project Directorate III-2, NRR W. L. Forney, Deputy Director, Division of Reactor Projects, RIII
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W. D. Shafer, Chief, Branch 1, Division of Reactor Project, RIII M. J. Farber, Chief, Section 1A, Division of Reactor Projects, RIII C. Patel, Project Manager, Project Directorate III-2, NRR
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J. D. Smith,-Senior Resident Inspector, Zion R. J. Leemon, Resident Inspector, Zion A. M. Bongiovanni, Resident Inspector, Zion Other A. Geo-Karis, Mayor, City of Zion and State Senator for 31st Illinois Legislative District A. J. Mork, Zion Commissioner, City of Zion W. E
'iorris, Director of Planning and Development, City of Zion
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D. l1cnaams, Chief of Fire Department, City of Zion L. DeTienne, Chief of Police, City of Zion e
argent, ESDA Coordinator, City of Zion
. Maples, City Clerk, City of Zion Mallery, Trustee, Village of Winthrop Harbor
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R. Enstad, Staff Writer, Chicago Tribune C. Peterson, Staff Writer, The News Sun A. Alexander, Producer, Fox 32 News D. McKinney, Reporter, Daily Herald J. Hagler, Editor, Zion-Benton News D. Lyons, Nuclear Safety Engineer, Illinois Departn.ent of Nuclear Safety K. E. Mitchell, Steward,.IBEW Union F. J. Angelos, Resident J. A. Drury, Resident J. Bianchi, Resident C. Paxton, Resident B.
Comments Received from Licensee Commonwealth Edison Company's response to the Zion Initial SALP 9 Report dated March 1, 1991, had no comments requiring revision to the specific content of the report.
Because there is no revision, the Initial SALP Report is considered the Final SALP Report.
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Enclosure.2
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Commonwaalth Ediscn
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t cowners Grove, Illinois 60515 March 1,1991 Mr. A. Bert Davis Re lonal Administrator Re ion Ill.
U.. Nuclear Regulatory Commission Glen Ellyn,IL 60137:
i Subject:
Zion Station Units 1 and 2 Res onse to SALP 9 N
_s.cke1Noshand_50-3M Reference:
' January 15,1991, letter from A. Bert Davis to Cordell Reed
- Dear Mr. Davisi
This letter provides Commonwealth Edison's response to the Systematic
.l 1 Assessment of Licensee Performance (SALP 9) report covering the period from
' October 1,1989, through October 31,1990.
Commonwealth Edison recognizes the serbus nature of the identified.
performance weaknesses. Significant resources have been allocated and action plans
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= developed to reverse the trend of declining performance. The acknowledgement by
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NRC that performance improvements have been achieved late in the SALP period Is appreciated, but Commonwealth Edison recognizes the need to strive for accelerated improvement.
Due in part to the intensive NRC inspection activities during the SALP 9 -
nperiod and the results of Commonwealth Edison's self assessmer, programs, the need
- to improve at Zion Station was identified. As a result, an improvcment program has.
. been devcloped to establish higher expectations of performanc >, to clearly
.~ communicate expectations to alllevels of the station, to develop Management Action Plans to focus on priorities, and to aggressively monitor progress. To accomplish these-
_ improvements,._ Commonwealth Edison corporate support was provided in the form of enhanced oversight and resources.
. As a recult of implementation of our improvement program, progress has been accomalishec and noted in NRC reports over the past year. In addition, we believe that ;he rate o' improvement at Zion Station has steadily increased since the close of the SALP 9 ps-iod.
Commonwealte Edison's planned corrective actions to sustain the
' improvement effort are detailed in Enclosures 1 through 5 for the areas of Plant-Operetions, Radiological Controls, Maintenance / Surveillance. Emergency Preparedness, and Engineering / Technical Support, respectively.
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A. Dort Davis 2-March 1,199t As requested in the SALP rewrt coverletter, Enclosuro G providos clarification to the specific sections of t to report. Thoso clarifications are provided to ensure that both Comrnonwealth Edison and the NRC have a sommon understanding of the concerns identified. We recognizo, however, that the clarifications do not affect too performanco rating in those are.
00mmonwealth Ldison l' e mitted to excellonce in all aspects of nuclear operaticns. The Zion Team and th<
3mmonwealth Edison supnort departments understand what noods to be accomplished to chlove that expos.ition. As a result of the improvement efforts, Zion Station is performing bottor now than last year. Wo are confident that performance will continuo to improve with the utilization of the additional resources and implomontation of the improvement action plans Should your staff han any comments regarding this responso, please direct them to the Nuclear Licensing Department.
Very truly yours,
,e av M.. Wallaco
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Vice Presic$f t PWR Operations
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Enclosures 1-6 cc:
C. Pato! - NRR Zion Resident inspector W. Snell-Alli NRC Document Control Desk
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Enckisure 1 Plant Operations The following Management Action Plans (MAPS) have been completed or are in progress to address the weaknesses in the Operations area:
Management Oversight and involvement Zion Station has increased the visibility of upper station management in the plant and in the main control room. The amount of time and the frequency of visits to Mie control room has been increased. Additionally, senior level management personnel are present on weekends to ine ease visibility and remove communication barriers.
Organization and Toamwork The Control Room Reorganization was implemented and has removed some of the paperwork burden from the Unit Supervisors, has dedicated operations management for each unit in the control room to permit supervision of activities and personnel for the unit, and has increased the confidence and accountability of the operators.
MAP 781 is in progress to examine, evaluate, and implement additional value l
added methods of utilizing operators in the plant. The planned completion date is April 4,1991.
A management skills im arovement training program for Operations on-shift management will begin in mid March. This program will provide guidance on improving management skills and on using the Zion Union Contract to improve the effectiveness of the relations between on shift personnel.
Staffing and Ovortimo
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Equilibrium staffing for the Operations Departrnent will be achieved by February 1,1992. Steps have been taken to expedite hiring and training of the necessary additional personnel to accomplish this action. This activlty is on schedule, MAP 809 is in progress to address the overtime isnue both for the Operations Depadment and the entire station. The Operations Department has been following the NRC and Corporate Guidelines with minimal preapproved deviations since September igon. In order to accomplish this task,it was necessary to bypass the Union ontract requirements. Also included in the MAP is the administrative procedure to expand the scope to ali site personnel.
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Enclosure 2
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Ra$ological Controis
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J The following Management Action Plans have been completod or are in progress to address the weaknesses in the Radiological Controls area:
High Radiation Area Controls
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A corporate task force was created to address this area. A MAP has been
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developed to implement the recommendations which were made by the task force in January 1991. Already, the following actions were taken to address this concern:
The R-locks in the plant were changed so that each high rad door now
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has a unique lock.
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The applicable procedures were revised to reflect this change.
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Although the number of high rad area violations for SALP 8 and 9 weie idontical,15 events occurred in 1989, and only 9 events occurred in 1990.
There have not been any high rad area control events since August 1990.
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Radiation Monitors
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To address the missed Radiation.nonitor surveillances, a radiation monitor out of service surveillance procedure ZRP 17201, was created and is being implemented. Management Action Plans are being implemented to improva the teamwork and communications between the Health Physics and Chemistry Departments to prevent funher missed surveillances. There have been no missed radiation monitor surveillances since September 22,1990, increased attention is being provided to the Radiation Monitor Task Force with the addition of representation from the Mechanical Maintenance and Corporate Engineering Departments. In addition, the completion of the DCRDR Radiation Monitor Display System willincrease the system engineer's ability to investigate and resolve long term radiation monitor problems.
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Personnel Contamination Evonts (PCEs)
A Contamination Control Coordinator was assl ned in April 1990. The PCE
rates since that time have continued to trend downward as illustrated in the following statistics:
306 PCE's in the first third of 1990 254 PCE's in the remaining two thirds of the year 30 PCE's in 1991 (through 2/22/91).
These downward trends have been accomplished even though significant forced outage radiation work has been ongoing.
The following actions were taken to improve overall contamination control:
The contamination boundary setup procedure was revised and all
contamination boundaries in the plant were changed. Major changes included locating laundry hampers inside the conlaminated area, using tape on the floor to better delineate the contamination boundary, and using at least two step off pads at the exit of each area.
The procedure for periorming contamination surveys was revised to
include extensive use of large area smears.
The use of tacky mats for contamination control on steam generator
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platforms was implemented.
Contaminated tool monitors for the Auxillary Bullding exit are under inve.atigation to help eliminate the transferral of contaminated rnatorialinto l
clean areas.
To address the worker radiation practices, an advanced radiation worker training program will begin in March,1991. The lesson plans have been develop 9d. The Construction Department has added a full day radiation worker. raining program requirement for contractors. Also, contamination contro' tallgate sessions are being given to work groups performing jobs in areas with high exposure rates and high contamination potential. A positive effee, of these actions was noted during the current forced outage work on the ieactor coolant pump replacement,ob; only two PCE's occurred.
Fir' ally, a Hot Particle Program was placed into effect on October 6,1990, wPt1 the implementation of ZRP 1330 7.
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Porr.on-Rom Exruro Total person rem ex 30sure was high during the SALP period. However, the station's dose was s gnificantly impacted by the amount of timo spent in an outage and the nature of the non routino work performed. Examples of work completed durin outage periods included the ECCS check valvo inspections and the loop sto isolation valve repairs.
Using the " LWR Occupational Dose Data for 1989" (compiled by the NRC and dated June 28,1990), Table 6 shows Zion Station compared to other PWRs older than 15 years. The results show that Zion was below the average person-rem / day for non outage periods and slightly higher than the average for outago periods during 1989. (Addendum 1 contains the Table with the data). Using the lame methodology for 1990, and considering the amount of timo performing outago work. Zion Station would fall below the 1989 average depicted in the table.
To allow a better comparison, a job by job c.omparison was performed with the following highlights:
In 1985, the 1 A reactor coolant loop cold leg valve was toaaired with 82
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3erson rem expended. However, in April,1990, both the lot and cold og valves for t1e 1D reactor coolant loop were repaired with a total of 92 person rom expended. This dose reduction was attributed to the implementation of lessons learned from the 1985 job, extensivo daily planning, continual Radiation Protection field supervislor,, and enhanced technology (e.g. video equipment, shield design).
Beactotlicad R!sassembly/Beassambly
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.1986_Unita 19BB_ Unit 2 1989._Unita 1990_ Unit.2 52 person rem 56 person rem 43 person rom 42 person rom SteanLGeneratotEddy Cutrent and.Manway_Bomoval/Beplacement
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19BBilnlL1 19BB_ Unit.2 1981UnlL1 1990_ Unit.2 43 person-rom 47 person-rom 31 person-rom 29 person-rom EuuLTransieLCanaLWoth
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19.89_UnlL1 3.78 person-rem (exposure only for replacement of the fuel building sido proximity switches)
1991Unil2 2.59 person-rem (exposum for replacement of fuel building and containment switches and fuel handling check outs)
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Enclosure 3 Mainttmance/Surveillaix:o The following actions have been completed or are in progress to address the
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weaknesses in the Mair,tenance/ Surveillance area:
j Planning and Scheduling A team of personnel from the planning and scheduling areas has been drawn to0 ether and has been meeting to identify and implement actions necessary to improve performance in this area and to fully implement the corporate work planning and conduct of maintenance directives. As a result, Zion has implemented a computer based nur.orical weighting system for pending maintenance, surve llances, and othcr oJvities. This system assigns values to pending work requests for such attributes as being a control room work request, an Operating Engineer concern, a preventive maintenance item, a leak, or a radioactive leak. This program provides assurance that the operational needs of the plant are consistently paramount in the prioritization
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of work. The computer provides a listing of the pending work requests with j
numerical vri ues assigned based u 3an the values in the program in order of t
priority and also lists the o"ler penc ing work on the equipment in question.
This list is then used by t',,s planning and maintenance department personnel, who are now meeting da ly, to develop coordinated schedules.
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These schedules are then used to drive the priority of all support activities such as work package development, procurement of parts, performance of technical evaluations, etc.
Additionally, Zion has implemented a program designating pending work activilles as " lead' activilles when they provide an opportunity to do parallel work and then identifying the work that can be done prior to, during, or
.following the lead activity as associate activities. It is it,us a simple matter to determine sil work that needs to be performed on a given component and g
which work may be performed within the same out of service boundaries.
- Also, for most lead activities Zion is developing schedules which show the cec uence, interfaces, timing, responsible organizations, and duration of act vities so that all will know what is planned to be dono, when, and by whom. Thus, Zion will have an easily understood plan of action and this will result in less miscommunication regarding planning and scheduling.
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MAPS in progress in this area include the following activities:
implement the electronic work request system
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develop 4 yr./3 cycle schedule a
implement / enforce the work request tracking system
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improve the man-hour projections for planned work a
improve the updating of electronic data bases such as Total Job
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Management (TJM), Work Request Tracking System (WRTS), Master Operating Tracking System (MOTS), etc.
Open Management Action Plans are: 95,132,133,301, and 483 Work Control To ensure that work mquests are properly controlled WRTS is being closely monitored to ensure program compliance. Non-compliances are reported for follow up with those responsible. Senior management support has been reemphasized in a station memo and added clerical resources have been provided to the TJM group. Continued monitoring and assessment of the program will ensure that work requests are properly controlled.
Maintenanco improvement Programs The Conduct of Maintenance (COM) directive consists of 16 sections which address every major area of station maintenance. This includes work practicos, preventive maintenance, control of maintenance, procedures, material condition, work planning, management involvement, and problem analysis. At the end of the SALP aeriod,4 sections had been implemented; to date an additional 5 sect ons have been implemented. The remaining sections are due by 12/31/91 and are on schedule. To facilitate implementation of this program, a Conduct of Maintenance Coordinator (COMC) has been added as well as a Preventive Maintenance Coordinator. Each of the 16 COM sections has been assigned to a lead person for implementation. MAPS identify the actions remaining to achieve fullimplementation of each section. Progress towards implementation is assessed and reported monthly by the COMC. After a section !s implemented, there will be additional actions required in most cases to assess performance and identify enhancements. These assessments may be performed by INPO, Nuclear Quality Programs (NOP), corporate Performance Assessment, or others. Lessons learned from other stations also provide input to these items. This information is collected by the COMC, published in a monthly report, discussed with the Maintenance Staff and added to the MAPS as deemed appropriate in accordance with the MAP proceduro
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MOV Program To improve the MOV program and address the specific concerns a number of MAPS have been created. The MOV program is addressed in MAP 312, the MOV testing and overhaul activities are addressed in MAPS 739 and 422, and a number of specific MOV concerns are addressed in MAPS 783,741, and 740. In January,1991 Corporate Engineering performed an assessment of the implementation of the MOV Nuclear Operations Directive at Zion. Additionally, an INPO MOV assist visit is being scheduled for the first half of 1991.
Recommendations from these assessments will be added to the MAPS as deemed appropriate. Many of the action plan steas have been completed; this includes the implementation of the is OV setpoint control program and the development of specific schedules for
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diagnostic testing of all Safety Related MOVs.
Emergency Diosol Generator Maintenance A dedicated team of personnel was appointed to address emergency diesel generator (EDG) maintenance. MAPS to f acilitate the diesel maintenance / surveillance improvement effort have been developed and approved. These MAPS include:
implement the lacket water heater modification
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rewrite the maintenance arocedures
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prioritize, budget, and se iedule all EDG related mods
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record base line data and establish alert levels for important EDG
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operating perameters write comprehensive PM procedures
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create EDG dedicated group
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A Zion Station Emergency Diesel Generator (EDG) Reliability Improvement Program has been initiated by Zion and the Nuclear Engineering Department. To date, four action items have been completed for Zion's EDGs: EDG Design Concerns, EDG Walkdowns Against Design Drawings, EDG Surveillance Test Program implementation Review (EDG Technical Specification /FSAR Requirements Review) and EDG Correspondence Review and Creation of EDG System File. These actions have resulted in the cceation of an EDG System Notebook and a report documenting the results of the EDG test review. The EDG Improvement Program will continue throughout 1991 and early 1992 with the following actions: EDG Operating and Annunciator Response Procedure Review, EDG System Design Review, EDG Sub-System Design Review, Cooper Bessemer Vendor Manual Preventive Maintenance Guidance Revision, and Performance Monitoring / Trending Program. The completion of these efforts are expected to substantially improve EDG performance at Zion Station.
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In addition, Nuclear Engineering worked with the six nuclear stations to develop an Emergency Diesel Generator (EDG) Status Report which provides major activity conducted and in progress on each station's EDGs.
The Repor1 contains the scope of EDG maintenance activities in progress at all stations, and includes the following items:
a description of the statiors EDGs
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a description of the station's EDG Ma:ntenance Program,
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current EDG Rel! ability Values
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a list of upcoming EDG Maintenance Outages
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a list of significant open EDG nuclear work requests
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a description of existing EDG temporary alterations
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an update of EDG Special Projects currently underway by Nuclear
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Engineering and station personnel.
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Enclosure 4 Emergency Preparodness The following actions have been completed or are in progress to address the weaknesses identified in the Emergency Preparedness area:
OrDanization To ensure continued management support and oversight of the Emergency Preparedness (EP) Program: the EP Coordinator now reports to the Technical Superintendent. This organizational structure has been standardized at all six of the Commonwealth Edison Stations. Additionally, an EP Trainer / Assistant has been assigned to the EP Coordinator. Two part time consultants were also added to assist with the update and standardization of station emergency procedures. Last!v, a station representative from the Corporate Nuclear Services Emergency Preparedness (NSEP) department has been assigned the res 3onsibility of increasina contact and enhrs, icing communications between h SEP and the Station, the specific corrective actions for the violations identified in the SALP report are on schedule for completion and will improve the attention to detall cited in the SALP report.
EOF Vontitation Equipment in order to improve the reliability of the EOF ventilation eculpment, the frequency of filter changes for the monitoring system has been increased to once per week and a monthly surveillance of this equipment is being performed. The area radiation monitor has been included in the Station j
Surveillance Program and the calibration frequency has been increased from once every 18 months to once every 12 months.
Exorciso Weaknessos To address the concerns that arose during the annual exercise, a prompt re-demonstration mini exercise was conducted within 2 months of the annual exercise. Successful assembly and accountability was demonstrated during this mini exercise. Other corrective actions included: providing additional training and specific lesson plans for non licensed shift supervisors; discussing alternative methods of obtaining information in the event computers are inoperable; improvbg the dispatch of teams from the Operations Support Center (OSC), including status board updates; installing additional telephones in the OSC; and revising the OSC layout.
Radiation Technicians will now foin their Maintenance counterparts and will be included in OSC tabletop driis in order for them to observe and capture the importance of prompt team dispatching. The initial annual exercise
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critique was reviewed with the Zion GSEP Directors and Radiation Technicians. This practice will continue and will also be included during their annual continuing training program.
As a means of ensuring Nuclear Accident Reporting System (NARS) forms are filled out in their entirety, trainir.g was conducted for all operating shift personnel addressing the appropriate method of completing the form.
Additionally, an instruction sheet explaining the required information has been attached as a cover page to each NARS form.
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Enclosuro 5 Engineering /Tectmical_ Support
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The following Action Plans have been completed or are in progress to address
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weaknesses identified in the Engineering / Technical Support area:
Licensed Operator Training Attendance at requalification training has been improved with 100%
attendance of the licensed operators for lectures during the first 5 week training cycle ending earlier this month. Additionally, Station expectations have been issued to all license holders through a memo from the Station
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Manager and a Zion Policy addressing requalificatta attendance.
Increases in the manning levels in the training depai;,nent have occurred.
Authorized personnel levels have been increased from 33 to 41 personnel.
Hiring remains a priority until all vacancies are filled.
Staffing and Resources Technical Staff recognized that management involvement during the early part of the report period was loss than desired. This recognition motivated the addition of staff in several areas to allow Technical Staff management to concentrate and become involved with the emerging technicalissues.
Among the staff additions are:
An Asst. Technical Staff Supervisor was added providing a 25% reduction in the workloads of the existing four assistants. This allows additional time to be spent managing the day-to-day activities of their assigned groups.
Technical Staff is continuing to increase the number of engineers to perform work. For 1991, the Technical Staff budget allows for 76 engineers, an increase of six over 1990. Interviewing and hiring of appropriate personnelIs ongoing.
The Zion Project Engineering Support Group allocated additional engineering resources to the station. This group is solely dedicated to the Zion improvement effort. The group reports to the Zion Project Manager onsite thereby linking the activities of this special project group with the ongoing engineering support activities for Zion Station.
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Resolubon of Technical issues A contributor to the improper evaluation of the RTDs associated with the reactor vessellevel indication system was a misleading note included in the Environmental Qualification (EO) binder. Upon discovery, the note was removed and an EO variation report was issued as required. Zion Station and the Nuclear Engineering Department have undertaken an effort to reformat the Zion ED binders. In parallel, the analyses sup3orting the
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binders are being reviewed and upgraded as appropriate "his effort is underway with completion expected in July,1991. Additionally, the Technical Staff Supervisor discussed the RTD error during a weekly department meeting to ensure all Technical Staff personnel were aware of the concern.
Formal training on the administrative procedure governing EO variations will be given to Technical Staff personnel by April,1991.
To address the general concern about the timeliness of resolving technical issues, the Technical Staff initiated a monthly technicalissues meeting in early 1990, in aut for this meeting is solicited from all departments at the station, as wel as the Nuclear Engineerl.ig Department. The meeting -
provides a convenient forum for the Technical Staff and the Engineering Department to make progress on the resolution of the issues. According to i
the last meeting notes,24 of the originall identified technicalissues have i
been closed and there are approximatel 84 remaining open technical issues. Additionally the Technical Staff 1as 6btained a list of long Ganding equipment problems from the Operating Department. These problems have been added to the list of technical Issues and are being addressed by the Nuclear Engineering Department, the Technical Staff, and the Zion Project Engineering Support Group.
An Operational Problems Review Committee chaired by the Production Superintendent was created to resolve longstanding problems identified by operating crews. The committee is responsible for correcting those deficient conditions which require operating personnel to take compensatory measures to overcome the deficiency. Those deficiencies could include proceduralinadequacles, design deficiencies, and degraded equipment.
Training of engineers in problem analysis and root cause evaluation is continuing.- At present, eleven engineers have received formal training in the Human Performance Enhancement System (HPES) methodology; six engineers in Management Oversight Risk Tree Analysis (MORT) methods, and six in the Problem Solving / Decision Making (PS/DM) course taught by the Production Training Department. By the end of 1991, an additional twenty one engineers are expected to have completed either HPES, MORT, or PS/DM training.
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The development of system engineer notebooks now provides a central location to document problems and corrective actions. As similar problems appear, the system engineer has a base of historicalinformation from which to work to improve responsiveness and accuracy of corrective actions.
Technical Staff is continuing to improve and assemble the notebooks. To date,65 notebooks have been completed and work is in progress on 31 additional notebooks. All of these notebooks are scheduled to be complete by December,1991.
Commercial Grado Procurement Program Zion Station's actions to mitigate procurement program weaknesses were defined in the response to inspection Report 50-295/89200. At that time Zion committed to upgrading the commercial grade program to follow the guidelines of the Electnc Power Research Institute and NRC Generic Letter 89-02.
CECO revised Nuclear Operations Directive (NOD TS.10) ' Procedures for Procurement and Use of items for Repair and Replacement of Safety Related Equipment"in November,1990. CECO's revised dedication program fully meets the NUMARC procurement initiatives and has been in use since late 1990.
A centralized procurement engineering group was established in 1990 to begin implementation the new program. The central group will alleviate duplication of effort in classifying and dedicating the same part at each station. The group is part of the Nuclear Engineering Department and is currently staffed by 16 eng:neers, a Westinghouse parts specialist, a General Electric parts specialist, and a CECO stores and material management representative. These personnel are located in CECO's Central Receipt inspection and Test Facility.
Communications and Teamwork Technical Staff is proceduralizing the Nuclear Operations Directive defining the responsibilities and expectations of a system engineer. Upon completion of this procedure Technical Staff personnel will be tralned as to the requirements of the procedure. A representative of Technical Staff management will meet with the Operating crews during their requalification training week to discuss the procedure and allow for questions / comments.
The clarification of responsibilities and roles between Operating and Technical Staff is expected to improve communications. The discussions with Operators will be completed by September.1991. Additionally. similar meetings will be held between the three maintenanco departmonts and Technical Staff supervision to discuss the system engineer procedure.
These discussions will take place by September,1991.
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-The development and implementation of the System Engineer Program administrat ve procedure will ensure that the Technical Staff will becom9 more involved in routine plant activities including surveillances and startups.
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The administrative procedure governing system engineers is scheduled for implementation on safelv relateu systems by June,1991. Other systems
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designated by the Station Manager will be implemented by December,1991.
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The associated doadlines are found in MAPS 725,726,727, and 728.
Technical Staff has initiated daily tours of the control room to meet with Operations personnel allowing timely response to operatin0 concerns / problems. These tours provide face to f ace communication and are expected to build rapport between the departments.
Members of the Technical Staff meef daily with Operating personnel First, the Technical Staff Planner meets with Operating Engineers to defino and prioritize work expectations for the day as well as planning for the ensuing week. In the plan of the day meeting the Technical Staff Supervisor meets with the Asst. Superintendent of Operating as well as the Operating
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Engineers. Finally, the Technical Staff Planner meets with representatives from the Maintenance and Operating departments to assign priorities on work requests written that day.
Five Zion " System Design Engineers" have been designated in the Nuclear Engineering Department. These System Design Engineers support the station in the resolution of technical issues, provide information on system operetional concerns, and assist in the develo ment of 50.59 Safety Evaluations. The purpose of the System Des n Engineer, which is a program initiated in f/ ay,1990 for Zion, is to d ignate a corporate design counterpart to support the site Technical Staff System Engineer. System Design Engineer Training to support the System Design Engineer Program is currently under development; some Inillal training will be provided in 1991.
Motor Operated Valves With respect to the comment concerning control over Motor Operated Valves (MOVs), our actions are well documented in response to the DET reaort findings. Durin0 the first quarter of 1990, Zion Station assigned a full time MOV Program Coordinator to implement and trend all MOV
"
activities. Additionally, a backup engineer has been identified and is currently being trained to provide additional support. The Electrical Maintenance (BM) and the Mechanical Maintenance (MM) departments have assigned specific personnel to supervise and perform MOV overhauls.
These individuals along with other support members meet biweekly to discuss and resolve on oing MOV issues. MAPS 312,739. 740. 741. and 783 contain specific im lementation dates.
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Referencing Ins aection Report 50 295/90034, the most recent communication aetween the NRC and Zion Station indicates that Zion has
' demonstrated significant improvement in implementation of the program for motor operated valves." This document Indicated that MOVs were being tested and torque switch settings established, recorded, and controlled.
A formal MOV Setpo!nt Control Procedure incorporating applicable corporate guidance was approved for use at Zion Station on August 1,1990. The
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precedure cortains the guidance arovided in the corporate Nuclear Operations Directive for MOV anc setpoint change methodology. The Coraorate Nuclear Engineering Department performed an assessment of the imp ementation of this program and discussed the results with the NRC on February 1,1991. The results of the Byron Station MOV Team inspection conducted by the NRC in January,1991, will also be transferred to Zion as part of the CECO Lessons Leamed Program.
Final Safety Analysis Report (FSAR)
CECO has previously acknowledged the need to upgrade the Zion FSAR.
To reitterate the DET response, CECO has undertaken the activities necessary to rebaseline the FSAR. The effort was planned in 1989 and initiated in July 1990. The scope of this effort is to reassemble the records generated since receipt of the f acility operating license which may affect the content of the UFSAR. The UFSAR will then be completely rewritten. The rebaseline effort for the Zion UFSAR will be completed by March,1992.
A training class was developed to present information on Zion's Technical Specifications, FSAR and Cha examples of CECO 10CFR50.pter 14 Accident Analysis, and included s9 Safety Evaluations. The intent of the class is to acquaint the trainee with Zion's Licensing Bases Documents and the role of these documents in performing 10CFR50.59 Safety Evaluations.
Class participants include Station (Technical Staff, Maintenance, Operations, etc.) and Corporate Engineering personnel. The training has been provided at Zion Station twice in 1991 and is scheduled to be given again four more times in 1991.
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Enclosure 6 Clarit.ications On page 24, in Section IV.A.1.a, to clarify the type of outage and the work performed consider the following changes:
replace
... Unit 1 was in an extended 141 day outage to replace auxiliary feed water check
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valves. "
with
" Unit 1 was in an extended 141 da feedwater motor operated va!ves..." y refueling outage to replace auxiliary
...
On Page 25, in Section IV.A.1.f, to further explain the work performed during the 31 days of mid loop operations consider the following change:
replace
" The repairs to the loop D stop valve required 31 days of mid loop operations."
...
with
" The repairs to the loop D stop valve and the inspection and repair of 7 Anchor
...
Darling check valves required 31 days of mid loop oporation."
On Page 25, in Section IV.A. Unit 2, to clarify the extent of the early entry into the Unit 2 refueling outage consider the following change:
replace
" March 1990 refueling outage, which began a few days earlier than planned..."
...
with
" March 1990 refueling outage, which began 21 days earlier than planned..."
...
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ADDiiNDUM1 (ucorpt 1stm 1WR O*upatonal Don Data for 1900*)
TABL 0 0 coBRELAIJONOEDAltiOOSE.WmiPLANT AGE Daih.Ce!!ntive Dowilutt (percon tem / day)
Q6d PWB (rutostatr)
(tage)
DWF)
(rusustagn)
(mange)
(a 15 years)
f t. Calhoun
.315 1.4n Dig Rock Point
.162 1,00 Ginna 200 10.0 Droodon 2,3
.550 4.73 IAillstone Pt.1 2 60 Haddam iJeck
.064
Kewcunee
.033 4 00 fJine IAlle Pt.1
.312 1.27 Oconee 1,2,3
.143 7.00 Oyster Creek
.075 0.50 Point Deoch 1,2
.100 2.55 Peach Bottom 2,3
.500 1.00 Pilgrim 480
,07 Prairie Island 1,2
.100
-.
San Onofre 1 240 1.19 Quad Cities 1,2
.445 3.45 Surry 12 2 57 1.58 Yankee Rowo
.110 2.91 Zion 1,2
.105 4.16
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Average
.149 4.14 400 3.05 Meistuin (713 years)
Calvert Cliffs 1,2
.144 2.91 Drunswick 1.2
.333 4.00 Crystal River 3
.075 3.00 Hatch 2
.500 8.50
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Davis Desse
.003 0.033 Farley 1,2
.007 3.75 IAcGuire 1,2
.150 720 PAilstone Pt. 2
.140
..
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Avsrage
.113 4.02
.300 5.50
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