ML20034A343

Responds to Violations Noted in Insp Repts 50-295/89-40 & 50-304/89-36.Corrective Actions:Importance of Adhering to Requirements of 10CFR55.53 Discussed W/Personnel Involved & Refueling Procedures Revised

ML20034A343
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/12/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
EA-89-255, NUDOCS 9004230094
Download: ML20034A343 (7)

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.1 Comm3nwealth Edison-l

-k it'., Opus Placo Downers Grove, Illinois 60515 -

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April 12, 1990 Director

-Office of-Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Zion Station Units 1.and 2-

-Reply to a Notice of Violation Inspection Report 50-295/89040 and 50-304/89036-NRC Docket Nos. 50-295 anL50-304

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Reference:

March 14, 1990, letter from A.'B. Davisito Cordell Reed-Gentlemen:-

Connu wealth Edison was notified of the proposed: imposition of a Civil Penalty at Zion Station;in the above referenced'1etter. The Notice of.

Violation identified two. violations that cumulatively have been classified as a Severity Level III Problem. The two' violations were pertaining to-1) ~the failure to assure that a senior-licensed oper*, tor (limited)'with an. inactive-license stood a required one shift refresher watch before resumption; oft duties, and 2) the failure to revise'the Zion licensed operator requalification program following.the 1987 revision of 10 CFR Part 55..-to-include requirements that operators attend preplannedflectures and to establish controls that ensure any missed' sessions are made up.-

A civil penalty of fifty thousand' dollars ($50,000)-was proposed..

Commonwealth Edison admits to' Violation A:and" admits-to the program, woakness regarding Violation B.

.In both cases, the violations were self identified. With regard to Violation B,~ Commonwealth Edison-has reviewed 10 CFR 55 and compared the previous: regulation.'with.Part 55.

In'either case, the regulations-are silent regarding mandatory attendance at_all lectures.

Therefore, a clear regulatory mandeh.regarding attendance has not been expressed. However, Commonwealth Edison views attendance at lectures as a very important part of the.requalification. program and consequently attendance of all licensed Reactor and Senior Reactor Operators is now required. 'In the event scheduled training.cannot be attended ~, makeup material will be' provided to the trainee and completed by the'end of the following' quarter.

The response to the specific Notice.of Violation items is! contained in Attachment A.

The attachment describes the management controls: program that has been established to ensure that licensed' individuals properly reactivate their-licerme prior to' performing licensed duties. Additionally, the attachment contains a review of the, actions taken-to enhance the Zion ~

Requalification Program including mandatory attendance or remediation of.the missed material.

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PDR ADOCK 05000295 o

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Dirpetorl0ffice of Enforecment

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' April 12,-1990 Commonwealth Edison identified the problem of the SROL performing the duties of'the refueling SR0 with an inactive license and provided the necessary Licensee Event. Report dated November 15,'1989. _A Commonwealth Edison Assessment led by the Manager of Production Training was performed to assess Zion Station's Licensed Training Program.

This assessment was started

- on September 28, 1989r with report issuance November;2, 1989.

The

- self-assessment concluded that lecture attendance was a training program-performance weakness.. The corrective actions 7to resolve the weakness, Giati included the implementation of_the Company Nuclear Operations Directive, were scheduled to start with the initiation of the 1990 Zion Requalification Program.

The Directive requires an increase in the amount of training to 180:

j hours per year and also requires attendance.at lectures or permits remediation j

of missed material. The requalification program had already been suspended in September 1989, and no further lectures were scheduled in lieu of the 1990 Requalification Program implementation.

The Notice of Violation.did not fully.

reflect the Commonwealth Edison self-assesments and corrective actions taken.

To address the NRC concern about Quality Assurance personnel not identifying the violations,_a review of the:1987, 1988, and 1989 " Staffing and J

f Training" Audits performed by Zion Quality Assurance was conducted.- It was noted that the Licensed Operator Training Program was addressed as a portion of each of these audits..The specific audits verified that the items-discussed in Attachment B to this letter were acceptable.. Althou6h each. audit identified deficiencies, none were noted in the specific area of Licensed-Operator Training. This may be partially attributable to the f act that the,

Licensed herator Training Program elements were audited in a random sample basis.

To establish comprehensive audit coverage, standard audit checklists were developed for major functional areas.like training as part of-the.1990 Nuclear-Division audit program review. The checklist for' training will assure'that 4

all significant elements of a Station training program are examined.- Further,-

1 a source document is under development that will identify and prioritize requirements to be audited and specify audit frequencies and depth of.-audits t

based on past results. As new requirements are identified, they will be factored into the source document, and consequently the audit program.

L Although QA audits currently have a " performance based" emphasis, l

additional training has been scheduled for all Quality Programs personnel to further stress the performance based audit concept. The consultant utilized i

for this effort is the same one used to develop the NRC performance based training program.

In addition to the Quality Programs department, the Performance Assessment-l Department provides performance based assessments as part of the Commonwealth Edison Quality Programs effort. Training has been e recent addition to the developing Performance Assessment Department scope.

I The combination of Quality Programs activities provides a comprehensive performance based look at a wide variety of Station and Corporate areas including Licensed Operator Training.

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-. '. Dirgetorf0ffica of Enfcrcement 3=

April 12, 1990-

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Commonwealth Edison believes that the implementation of the icorrective actions described in Attachment'A, including the implementation of

-the Nuclear. Operations Directive, will preclude the recurrence of this event.-

Enclosed please' find a check for $50,000 in payment of the fine.

Please address questions regarding this matter to this office.

Very truly yours,.

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Kovach Nuclear censing Manager 1-Enclosure cc:

A. B. Davis - Regiona1' Administrator.- RIII C. P. Patel ~ NRR Zion Resident Inspector

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ATTACHMENT A CORRECTIVE ACTIONS TAKEN FOR VIOLATION At l

The immediate corrective actions taken were to notify the Assistant L

Superintendent of Operations who subsequently discussed the importance of i

adhering to all requirements of 10 CFR 55.53(e).with the individual involved in this event..

CQRRECTIVE LCTIONS TAKEN TO PREVENT RECURRENCE 4

The root cause for this violation is the apparent lack'of necessaryL administrative controls to verify. personnel q:alifications prior to'the start of fuel moves. The actions taken to administistively' control SROL' proficiency.

requirements included the revision of two refuel procedures.. Specifically-FHI-00, " Administrative Controls During Refueling", was revised December 5.-

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1989. This procedure-was revised to require a verification that'the SROL a t

the requirements of 10 CFR 55.53.

I Another procedure, FHI-38,." Fuel Shuffle", was revised' December 30',-

1989.

The initial conditions section of this' procedure was changed to require-a signoff by the Assistant Superintendent.of Operations-(AS0). The ASO verifies that the SROL requirements of 10 CFR-55 have been' met or the required watchstanding with.a qualified SRO has beenicompleted.;

The actions taken to cusure the remainder of the Reactor and Senior Reactor Operator Licenses are properly ~ activated are described in. Violation B.

DATES _.QI_ IMP.LEMMIAIIDR_0f_CQRRECTIVE ACIlQNS.

The Station'is in full compliance-at this time.

3 CORRECTIVE ACTION TAKEN ASSOCIAIED WITH VlQlAll0N_B Corrective actions for this violation are addressed in two broad

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areas: Requalification Program Attendance and Management Controls and Quality Oversight.

Requalification Program AttendanCA Zion Station has defined ihe.1990 Requalification Program to include 1

180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of classroom training and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> simulator. training.

In addition, j

it is the Station's policy that classroom and simulator training attendance is mandatory for all R0/SRO licenses.

In the event scheduled training'cannot-be attended, make-up material will be provided-to the trainee,and; completed by1 the end of the following quarter.

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M CHMENT A (cont'd)

MANAGEMENT CONTROLS AND OUALITY OVERSIGHT

A matrix was. completed on April 1,.1990, that quantified:the status of compliance with the licensed operator qualification requirements delineated in 10 CFR 55.

This computer generated matrix ~ tracks'medicol examination

-periodicity, the number _of hours attended in both the classroom and simulator

-and finally the utnber of hours -spent on-shif t during a quarter. - = The system compiles the above information and identifies both valid and invalid licenses 3

and defines the deficient qualification requirements'.

This matrix will be updated at least once per-quarter and will be utilized to ensure that only individuals with valid licenses are assigned licensed shif t duties.

The formal procedure to describe the use of the matrix is under

-development..The: procedure is scheduled for completion during July,;1990.-

Quality Programs performed an audit of the management ~ system implemented to control-operator requalification.

Included-in this review were:

l training attendance, the' assignment by line management of: personnel duty and-the system to control-licensee qualification' status. The audit'was completedi on 4/01/90.. The Audit concluded with one observation and two open, items.

Overall, Zion Station was found to be 'ef Netively implementing the commitments-l regarding the-Licensed Operator Retraining Program upgradas and control'of j

licensee qualifications and status.

l Commonwealth Edison's Performance Assessm%i. Department performed a review of the actions taken le response to the Zion Training Task Force.

1 recommenaations in February. 1990. The Assessment conclusion'was that all' i

Zion Station action plan items were tracked as part of the Zion Performance Improvement Plan and that the items were either completed or on-schedule.

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There were four Task Force recommendations that'will be reviewed and j

dispositioned by July 1, 1990.

CORRECTIVE ACTIONS TAEEN TO PREVENT BECURRENCE Eg. qualification Program Attendance l

1 An essential element of the' estab1Lished controls regarding the.

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requalification attendance is the monitoring and reporting of deficiencies in

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l attendance to senior station management, including the Station Manager.

l Beginning April 2, 1990, the results are being reported on a weekly bases ta

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assure prompt review and correction of significant, weaknesses..The final corrective action is the formalization of these commitments in the Conduct of Training Procedure scheduled to be completed by June 1,-1990.

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1 tianagement Controls and Ouality Oversight

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-4 The corrective-actions taken and planned will be further re":ed 1 y the Performance Assessment Department's 199? review of both the licem # and-non-licensed training programs at Zion.

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ATTACHMENT A (cont'd) a

-Quality' Programs'will review' corrective action progress during the fourth quarter:1990., The scope will include a review of the status of -

J operator qualifications and the controls for-monitoring the training program.

i Other management controis taken.to assure continuation of corrective'

' actions include the strenttbening of the Requalification Program:into three distinct act. ion plans as part of the Zion Performance Improvement Plan that are reviewed monthly at the Superintendent lovel and bi-monthly with the Station Manager.-

DATES OF IMPLEMENTATION OF CORRECTIVE ACTIONS-The four open Task Force recommendations will be reviewed and dierositioned by J

July 1. 1990.

The Conduct of Training Procedure will be revised by June 1, 1990.

The-Quality Programs review will be completed by December 31, 1990.

The Performance Assessment progress review will be completed by

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October 1, 1991.

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'ATTACllMENT B

The.QualityProgramsDepartment?AuditsLverifiedthat-thefollowing actions were,taking place

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-Licensed-Operators 1(i.e. R0's) manipulated plant. controls and-senior' operators.(i.e. - SRO's) manipulated plant controls or directed the activities:of' licensed operators during their respective license terms; License requal. lectures were given ont plant modifications:and: that these lectures'provided current information regarding changes'to plantEequipment, and instrumentation; Oral examinations were given to licensed personnel;1and job specific training was completed by various-Station: personnel $1ncluding-licensed Operating personnel; Operating personnel.(i.e. Shift Foreman and SCRE's) who direct-operations on'the Load Dispatcher's electrical equipment were properly qualified; Level l' and 2LTraining Instructors (including those that -teach initini and'requal license classes) vere properly qualified per-NOD-TQ.7; and

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Periodic evaluation was performed by theLZion Training. Depart' ment' for purchased training services that included Simulator' courses andsother-subjects applicable to initial'and requal license' classes.

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