ML20129F076
ML20129F076 | |
Person / Time | |
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Site: | Zion File:ZionSolutions icon.png |
Issue date: | 09/16/1996 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20129F027 | List: |
References | |
50-295-96-08, 50-295-96-8, 50-304-96-08, 50-304-96-8, NUDOCS 9610010244 | |
Download: ML20129F076 (33) | |
See also: IR 05000295/1996008
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli
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Docket Nos: 50-295, 50-304
Report No: 50-295/96008, 50-304/96008
) Licensee: Commonwealth Edison Company
, Facility: Zion Nuclear Plant, Units I and 2
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Location: Opus West III l
1400 Opus West III
Downers Grove, IL 60515 ,
Dates: June 8 through July 26, 1996 1
- Inspectors
- R. A. Westberg, Senior Resident Inspector ,
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D. R. Calhoun, Resident Inspector 1
D. M. Chyu, Resident Inspector I
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D. E. Jones, Reactor Engineer, RIII l
S. Orth, Health Physics Specialist '
T. Kobetz, Senior Resident Inspector,
Point Beach Nuclear Plant
K. Stoedter, Resident Inspector, Clinton
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Nuclear Plant
- J. Adams, Reactor Engineer, RIII
J. Lennartz, Reactor Safety Inspector
j H. Peterson, Reactor Safety Inspector
J. Yesinowski, Illinois Department of
Nuclear Safety (IDNS) Inspector
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Approved by: Lewis F. Miller, Jr., Chief I
Reactor Projects Branch 4 l
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9610010244 960916
PDR ADOCK 05000295
G PDR u
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EXECUTIVE SUMMARY
Zion Nuclear Plant, Units 1 and 2 1
NRC Inspection Report 50-295/96008; 50-304/96008
This integrated inspection included aspects of licensee operations,
engineering, maintenance, and plant support. The report covers a five-week
period of resident inspection. In addition, it included the results of
announced inspections of chemistry, operator licensing, and operational
performance.
Operations
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. The Operating Engineer's decision not to perform a service water valve ;
lineup verification and a root cause analysis as part of the plant 4
restart on May 19 was considered a weakness in the self-checking program i
(section 01.3). j
. A fuel handler demonstrated inattention to detail by allowing an
unqualified person to perform rigging which resulted in the drop of a
portable filtration unit in the fuel transfer canal (Section 01.4). The
subsequent recovery effort was good and showed teamwork (Section 01.5), i
. A non-cited violation was identified for failure to perform all the I
administrative requirements, such as, quality control review, operating
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engineer review, and drawing review by design engineering prior to
returning a steam flow instrument channel to service (Section 03.1)
. A violation was identified when a licensed operator inadvertently placed
an excessive load on the 2B emergency diesel generator (EDG) during
performance of a monthly Technical Specification (TS) surveillance.
This is a no response violation (Section 04.1).
. The Unit I reactor coolant drain tank pumps were operated deadheaded for
two hours due to an out-of-service error and inattention to detail
(Section 04.3)
. The Unit Supervisor's command and control during the dynamic simulator
examinations was considered a weakness. Additionally, inattention to
detail, self checking, and use of annunciator response procedures
contributed to Job Performance Measure (JPM) failures (Section 04.4).
. The continuing training program was considered satisfactory with
examination overlap a strength (Section 05.1).
. A licensed operator's questionable medical qualifications were not
resolved in a timely manner. Tracking and resolution of questionable
medical qualifications was considered a weakness (Section 05.2).
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. A violation was identified for crediting watchstanding time for
individuals in positions that did not require a license as defined in
the facility's technical specifications and subsequently designating
them as on-shift Unit Supervisors without prior completion of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
in the Unit Supervisor position under the direction of a senior operator
(Section 05.3).
. Some control room administrative processes, such as, newly implemented
computer systems for electronic work control. and out-of-services,
appeared to be an additional burden on the ' operators (Section 06.2).
Maintenance
. The system engineer (SE) performed well by identifying a scaffolding
interference problem around the Unit I high pressure turbine. However,
the contractors demonstrated poor maintenance practices in erecting the
scaffolding. In addition, the scaffolding procedure did not require
sufficient management review (Section M1.2). ,
Enaineerina ;
. A violation was identified for the untimely response of system
engineering in documenting and addressing a bypass flow condition around ,
the charcoal filters (Section E2.1).
. A violation was identified by the inspectors for the failure to document
the spent fuel pool rerack analysis in the FSAR (Section E3.1).
Plant Suonort
. A violation was identified for the failure to incorporate the rerack
analysis in the FSAR.
. The licensee's water chemistry control program was considered strong l
(Section R1.1). <
. Although the post accident sampling system and routine sample line flow
instruments were unreliable, the chemistry staff ensured that sample
line purge times were adequate (Section R1.2).
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. Chemistry technicians demonstrated good analytical techniques, with the l
exception of some weaknesses concerning attention to detail. Improperly .i
labeled chemistry standards were identified in the chemistry laboratory. 1
. A violation, a non-cited violation, and an unresolved item were
identified concerning inadequate adherence to radiological control
procedures (Sections R4.1, R4.2, and R4.3).
. Site quality verification (SQV) audits of the radiological environmental
monitoring program were thorough, with some minor exceptions. The
inspectors identified weaknesses in radiological practices that were
similar to previous SQV findings (Section R7.1).
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. The inspectors identified two examples of a violation where the licensee
failed to initiate a fire protection impairment permit for the 1A EDG
carbon dioxide fire suppression system while replacing a discharge timer
and to generate a station deficiency report (Section F1.1).
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Report Details
SLmmarY Q L d]RMt S1Atus
L_0cerations
01 Conduct of Operat' ions
01.1 Sfqneral Commqats GML_lR07 and 71715) !
Using Inspection Pro:edures 71/07 and 71715, the inspectors conducted
frequent rey!ew of ongoing plant operations. A special inspection of
operations activities was conducted from May 20 to 24 using Inspection
Procedu.aes 71707 and 71715. The focus of the inspection was to observe
and assen both day-to-day activities and actions during non-routine
activities; such as startup operations and recovery from transients. In
addition., an operating licensing Requalification Examination
Administration Inspection was conducted in accordance with Inspection
Module 71001.
01.2 Shift Turnover Observations
a. Inspection Scope (71707)
- On May 21, the inspectors observed the shift engineer's turnover and the
following shift meeting.
b. Observations and Findinas
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The shift engineer's turnover was conducted in a professional and
systematic manner. Interruptions were minimized by good access control
to the control room complex area. The shift engineers complied with
Zion's new Station Operating Standards in the performance of their
turnover.
The shift engineer conducted the shift meeting in a professional manner.
The meeting was attended by all members of the operational staff, plant
support personnel (radiation protection and chemistry), nuclear
engineering, site quality verification, and plant management. Following
normal discussion of the plant status, the plant manager discussed
recent configuration control errors. The inspectors observed two way
communications between operators and the plant manager concerning the
contributing factors to recent human performance errors.
c. Conclusion
The recently implemented Station Operating Standards were being used by
all control room personnel. The inspectors observed that the nuclear
station operators (NS0s) attention to the control room panels was
excellent even during periods of potential distraction.
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01.3 Unit 2 Reactor Startuo Observation
a. Inspection Scope (71707)
On May 21 and 22, the inspectors observed the Unit 2 startup,following a
May 19, shutdown initiated due to the inoperability of two emergency
diesel generators.
b. Observations and Findinas
The licensed shift supervisor (LSS) overseeing the startup received
several distracting telephone calls. Some of these calls were not
directly related to the startup and probably would have been better
managed by someone not directly involved in the startup.
The operators had to respond to numerous rod deviation alarms while
pulling the control bank rods. The rod deviation alarms were due to the
rod position indication (RPI) system and the control rod step counters
being out-of-tolerance greater than 12 steps. The licensee stated that
a lag time between the process computer's calculations and the RPI
system's position indication contributed to the numerous alarms.
Although this problem did not directly impact safety, it distracted the
operators from other ongoing startup activities.
The inspectors noted good nuclear engineering (NE) support to the
operators during the startup activities. This was particularly evident
when the operators received a rod bottom drop alarm. The operators
entered the appropriate Abnormal Operating Procedure to recover from the
alarm and with the assistance of NE, successfully adjusted the position
indication for the affected rod.
During a review of the licensee's preparations for startup, the
inspectors observed that the trip analysis section in GOP-0, " Plant
Startup," had not been completed by the OE. The plant shutdown was not ,
a result of a trip; therefore the trip analysis section was not '
required. The inspectors noticed that listed items, such as, root cause
of the manual trip and proposed corrective action, were equally
applicable to startups following unplanned shutdowns. The trip analysis
section would have provided an additional check to ensure activities
required for startup were completed.
c. Conclusion
The inspectors also considered the OE's decision not to perform a root
cause analysis as part of the trip analysis was another example of
weaknesses in the licensee's self-checking program.
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- 01.4 Imoroner Riaaina of a Portable Filtration Unit
l a. Insoection Scone (71707)
i On June 12, a portable filtration unit fell approximately seven feet l
i onto the transfer canal island due to a radiation protection technician !
! (RPT) improperly rigging the unit. The inspectors interviewed the '
i individuals involved with the rigging of the filtration unit, reviewed
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the station's recently developed rigging procedure, and attended
i training on the new procedure.
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i b. Observations and Findinas
The 1480 pound filtration unit which measured 46":long, 29.5 wide, and
51" high. It developed an air leak while in the transfer canal;
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therefore, the unit needed to be lifted out of the canal for a
inspection using the fuel building crane. A fuel handler (FH), who had
, been trained in rigging operations, was assigned to perform the rigging
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! The FH attempted to use a rope to guide two slings, which were attached
! to the filtration' unit, onto the hook. However, the FH, due to his
{ physical location, was not able to connect the slings unto the hook.
l mistakenly connected the rope onto the hook instead of the two slings.
. The FH did not notice that the rigging was improper as the unit was
! lifted from the transfer canal. While the unit was being lifted, the
i rope broke and the unit dropped approximately seven feet onto the
i transfer canal island.
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l The licensee suspended all transfer canal activities. The licensee
- conducted an investigation which revealed the following root causes
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- a shackle should have been used for connecting the two slings onto the 4
- hook; 2) an unqualified RP technician was allowed to connect unit; and
j 3) management oversight was lacking.
c. Conclusion
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j The inspectors reviewed the licensee's root causes for this event and i'
- concluded that the FH demonstrated inattention to detail when he allowed
an unqualified person to perform the rigging activity.
01'.5 Good Teamwork and Communication Durina Portable Filtration Unit i
i Retrieval
a. Inspection Scone (71707)
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On June 21, the FHs successfully rigged and retrieved the portable
.! filtration unit from the transfer canal. The inspectors observed the
i rigging and lifting of the unit, attended the as low as reasonable
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achievable (ALARA) meetings, and verified personnel respirator
i certifications and instrument calibration dates were current.
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b. Observations and Findinas
The ALARA coordinator conducted two briefings for the retrieval
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evolution. One briefing was for a RPT to enter into the canal to obtain
smears and a survey; the other briefing was for a FH to enter into the
canal to connect the slings to the hook on the fuel building crane.
- Both the FH and the RPT had to don respirators to enter the transfer
canal. The inspectors verified that their respirator certifications
j were current and that the RPT's instrumentation was within its
calibration period.
- Prior to the lift, the inspectors verified that the FH had completed the
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plant's required rigging training and that the portable filtration unit
had been properly rigged.
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c. Conclusion
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The inspectors concluded that the retrieval of the unit was conducted in
a very controlled manner. In support of the retrieval effort, the
inspectors considered that the ALARA coordinator demonstrated good
leadership and provided clear directions and expectations during the
i ALARA briefings. The inspectors also observed good communication and
- coordination among fuel handling, radiation protection, and
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decontamination personnel during retrieval of the portable filtration !
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unit. l
l 03 Operations Procedures and Documentation
03.1 Steam Flow Channel Imoronerly Returned to Service
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! a. Inspection Scope (71707)
i' On June 12, operations personnel identified that a steam flow channel
had been improperly returned to service by instrumentation mechanics !
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(IMs) personnel. The inspectors attended the investigation meeting.
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! b. Observations and Findinas
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!. As part of a design change, IMs replaced steam flow transmitter, IFT- !
- 512. After the transmitter was replaced, the IMs incorrectly returned
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the transmitter's associated bistable to service upon successfully
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completing the calibration. The transmitter replacement work was
governed by ZAP 510-02C, " Exempt Change Program," Revision 5.
This procedure required the completion of certain administrative
i requirements prior to closing and declaring the work package
operational. However, these administrative requirements, which included
a quality control review and release, operating engineer review, and
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drawing review by design engineering 3 had not been completed prior to
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returning the steam flow channel to service. ;
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A contributing factor to the occurrence of this error was that the work
package did not have a PT-14, " Inoperable Equipment Surveillance Test," i
Revision 6 (used to track inoperable safety related equipment) or an
out-of-service (005) as described by ZAP 300-06, "Out of Service i
Process," Revision 8 associated with the work package. The use of j
either an 00S or a PT-14 would have assured the steam flow channel was -
returned to service only after verifying that all administrative I
requirements had been met. !
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The licensee initiated timely and effective corrective actions which 1
included administrative closeout of the work package and properly j
restoring the channel to service. Concurrently, the licensee conducted
a meeting with all the involved departments to determine the root causes
and long-term corrective actions for the event. The licensee determined
that the work package was incorrectly considered closed. A. standing
order was issued to assure that all design change work packt.ges had
either an 00S or an PT-14 associated with each work package.
c. Conclusion ,
Although the channel was returned to service incorrectly, the channel
was technically operable because the IMs had successfully performed the l
required calibration. The failure to perform all the administrative '
requirements as required by ZAP 510-02C, prior to returning the steam )
flow channel to service, is a violation of 10 CFR 50, Appendix B, 1
Criterion V, " Instruction, Procedures, and Drawings." However, this
violation was identified by the licensee and could not have been s
reasonably prevented by the licensee's corrective action for a previous ,
violation or a previous licensee finding that occurred within the past
two years. Therefore, this licensee-identified and corrected violation
is being treated as a Non-cited Violation, consistent with Section
VII.B.1 of the NRC Enforcement Policy (50-295/304-96008-01(DRP)).
04 Operator Knowledge and Performance
04.1 Diesel Generator 2B Excessive load Event
a. Inspection Scope (71707)
On July 15, a licensed operator inadvertently placed an excessive load
on the 2B EDG during performance of a required TS surveillance test.
The inspectors interviewed the nuclear station operator (NS0) and the
unit supervisor involved in this event. The inspectors also reviewed
the EDG's design in the UFSAR and inspected the control room snitches
involved in the event,
b. Observations and Findinas
At 5:20 p.m., while testing the 2B EDG using PT-11-DG28, "2B Diesel
Generator Loading Test," Revision 6, the NSO attempted to manipulate the
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voltage adjust rheostat to raise KVARs from 700 to 750. However, he
- inadvertently manipulated the speed control rheostat (governor). ' The
NSO realized his error, returned the speed control rheostat to its
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original position, and notified the unit supervisor. The operator's
error resulted in loading the EDG to 4.606 megawatts (MWs) for -
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approximately 5 seconds. The load was greater than the 4 MW required by
the surveillance; however, the licensee determined that this error had
not invalidated the surveillance. The inspectors verified that the EDG
had not exceeded its rated capacity of 5 MW. ;
Due to these two events involving misoperation of EDGs, the licensee
implemented a standing order (S0) on July 17 for4 diesel generator ;
testing oversight. The 50 stated that a higher level of attention and :
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oversight was required and that a complex evolution briefing would be
held prior to all EDG performance testing. It also stated that shift
supervision would monitor all EDG testing and submit a completed
Management Monitoring Report.
c. Conclusion
The inspectors concluded that although the 2B EDG had not been
overloaded, this event was identical to a previous misoperation of the i
2A EDG which occurred on May 19 (see NRC Inspection Report 50-295/304- l
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96007).
PT-11-DG2B, Paragraph 5.0, "2A Diesel Operability Test," Step 18.a.1.
states " increase load in 200 kilowatt steps per minute until desired
load is reached on 2JI-AP57, " Output KW" while following the guidelines
of attachment 1, 2B D/G START /STOP AND LOADING / UNLOADING RECORD." Step
22 states " decrease load in 200 kilowatt steps per minute until desired
load is reachod on 2JI-AP57, " Output KW" while following the guidelines
of attachment 1, 2B D/G START /STOP AND LOADING / UNLOADING RECORD."
Attachment I requires the EDG to be held at full load for 210 minutes
and defines full load as a 4 MW.
Failure to accomplish steps 18.a.1.and 22 of the 2B DG operability test
in accordance with PT-11-DG2B by increasing and decreasing the load on
the 2B E0G by approximately 600 KW in 5 seconds is a violation of 10 CFR
Part 50, Criterion V. However, no notice of violation was identified in
this case due to the escalated actions taken on August 23, 1996, in
response to Inspection Report 50-295/304-96007(DRP) and because the
criteria in NUREG-1600, the " General Statement of Policy and Procedures
for NRC Enforcement Action, "Section VII.B.4 were met.
04.2 Non-Licensed Operator Rounds
a. Inspection Scone (71715)
During the special inspection of operational performance conducted from
May 20 to 24, the inspectors toured the plant with equipment operators
and attendants to assess their knowledge and the quality of their
rounds.
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b. Observations and Findinas
The inspectors accompanied two non-licensed operators during their plant
rounds. In both cases, the individuals were well trained and had a
strong knowledge of the plant. However, instances were noted which
demonstrated the lack of a questioning attitude. The most significant
was that an operator did not question a door that was propped open to
allow an air hose to be routed to a work area. The control room had not
been notified of the condition, and it was not until the inspectors
identified the condition to the operator that.the appropriate actions
.were taken. The inspectors were concerned that the door that had been
propped open was a fire door; however, subsequent inspection determined
that it was not.
c. Conclusion -
The inspectors concluded that the equipment operators had strong
knowledge. However, the lack of a questioning attitude was observed for
a potential fire protection concern.
' 04.3 Unit 1 Reactor Coolant Drain Tank Pumos Run Without a Discharae Path
a. Insnection Scone (71707)
On June 24, the licensee identified that both Unit I reactor coolant-
drain tank (RCDT) pumps were deadheaded due to failure to realign the
RCOT flow path- following a placement of an 00S for a holdup tank (HUT)
maintenance activity. The inspectors interviewed the shift engineers
and the radwaste supervisor, reviewed the DOS checklist and ZAP 300-06,
"Out of Service process," Revision 8, and discussed the pump operability
with the SE.
b. Observation and Findinas
On June 23, the HUT was taken DOS for maintenance activities on the
HUT's recirculation pump and valve. The operations work group prepared
the DOS checklist and special instructions informing the oncoming
licensed shift supervisor (LSS) that the normal flow path from RCDT to
the HUT would be isolated because of the 00S. However, the LSS did not
see the special instructions and failed to verify the effect the 00S
would have on the plant in accordance with ZAP 300-06. Therefore, the !
need to realign the RCDT pump discharge path was not recognized and was
not communicated to the incoming crew.
The RCDT pumps started, as required, when they reached their respective
RCDT level setpoints of 46 and 82 percent. The equipment operator noted
that the level was not decreasing and identified the problem. The
licensee found that the normal discharge flow path from the RCDT tank to
the HUT was isolated because of the 00S. The 1A pump was deadheaded
about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the B pump for several minutes. Subsequent testing
showed that the pumps were not damaged.
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c. Conclusion
On August 8, 1995, a similar event occurred where the Unit 1 RCDT pumps
were started and run without a discharge path due to improper valve
alignment. The inspectors considered that this operational error was
another example of inattention to detail.
04.4 Licensed Ooerator Evaluations (71001)
a. Inspection Scone (71001)
The inspectors observed and evaluated operator performance during a
requalification examination administration June 12 through 14, 1996, for
two crews' dynamic simulator examinations and a sample of Job
Performance Measures (JPMs).
b. Observations and Findinas
During the dynamic simulator examinations the Unit Supervisors (US) !
demonstrated weaknesses regarding command and control. This was also
identified by the facility evaluators as a generic issue. One licensed
individual failed two JPMs which resulted in an unsatisfactory
evaluation while four other licensed individuals failed only a single i
JPM which resulted in a satisfactory evaluation overall. The JPM's t
failed were " Lineup the Feedwater System for Automatic Operation," and
" Respond to Main Generator High Stator Water Conductivity."
c. Conclusion
The inspectors concluded the crew's and individual operator's
performance during the dynamic simulator examination was satisfactory.
However, the US's command and control during the dynamic simulator
examinations was considered a weakness. Additionally, the inspectors
concluded that inattention to detail, lack of self checking, and failure
to use Annunciator Response procedures contributed to the JPM failures.
05 Operator Training and Qualification
05.1 Licensed Ooerator Reaualification Proaram Review
a. Inspection Scone (71001)
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The inspectors reviewed examination materials, records, and procedures
pertaining to the licensed operator requalification training program on
, June 10 to 14. In addition, the inspectors observed the
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requalification examination administration.
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b. Observations and Findinas
No written examination questions, dynamic scenarios, or JPMs
administered during the annual examinations were repeated from week to
week or from the previous year for the current examination cycle. The
inspectors consider the lack of examination overlap a strength. !
The licensee evaluator's abilities to identify weaknesses, effectively
use followup questioning, and evaluate operator performance were
considered good. The use of competencies in addition to identified. :
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critical tasks as evaluation criteria during JPM performance was also ;
considered good. '
The following were recent program changes:
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1. The licensee evaluators identified and evaluated generic training
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issues during the annual examinations which are then incorporated !
into the training program and assigned to specific crews, specific !
individuals or all licensed personnel as appropriate. !
2. . The crews conducted facilitated self critiques following simulator
training sessions and the training staff debriefed with the shift
engineer following the training week.
c. Conclusion
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The inspectors concluded that the licensee's continuing training program l
was satisfactory. The program was revised based on operational
performance and industry events, and satisfactorily evaluated operator
skills. The inspectors considered the lack of examination overlap a
strength. The recent program changes described above were considered +
good.
05.2 Conformance With Ooerator License Conditions. Medical Oualifications
a. Inspection Scone (71001)
The inspectors reviewed the licensee's medical program for licensed '
operators on Juna 10 to 14 and assessed compliance with 10 CFR 55.53
requirements.
b. Observations and Fir, ding
The licensee had commit';ed to develop and initiate a medical program
procedure following the 1395 NRC requalification inspection (Inspection
Report 50-295/304-95013(DRS), section 2.2, page 3). On July 16, 1995,
the licensee revised IAP 200-09A, " Control of 10 CFR 55 Requirements for
Licensed Individuals," Revision 2, section G.3.b, page 4, to require the
Training Department to enter an individual's last NRC physical ,
examination date into the biennial Medical History computer database for
tracking.
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The inspectors identified that an operator's biennial NRC physical had
not been updated as required by ZAP 200-9A. The medical examination was
due by May 23, 1996, but appeared to be a month overdue based on the
database information. The inspectors determined that the medical
examination was performed during April; however, certain medical
conditions identified required resolution. Notification to the NRC of
the situation appeared adequate but the issue was not resolved in a- i
timely manner. As of June 14, the licensee was still waiting for i
information from the operator's personal physician regarding the medical I
condition and therefore had not resolved the issue.
The inspectors questioned the licensee regarding tne operator's '
availability and license status. The licensee assumed that the medical
qualifications were satisfactory. Therefore, the operator was still on
the Active License List and allowed to be on shift. However, the
individual was on vacation.
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The licensee could not resolve the questionable medical qualifications
prior to the individual's return from vacation and removed the .
individual from licensed duties on June 18 pending resolution.
. Additionally, the operations department issued a memorandum regarding
this issue to licensed individuals on June 21 as a corrective measure.
The memorandum expectations included training department scheduling of
all required physicals three months prior to the due date and the
individual license holders were to personally resolve any matters thirty .
days following notification of any discrepancies.
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c. Conclusion
The inspectors determined the licensed operator medical program
procedures did not detail program limitations, expectations, and -
responsibilities to preclude an individual from standing watch with
questionable medical qualific1tions. The procedures in place could have '
allowed the medical condition to continue for an indeterminate amount of
time. The licensee did not expedite the medical qualifications' !
resolution until after the NRC inspectors questioned the operator's
status. The inspectors considered the licensee's tracking and
resolution of questionable medical qualifications a weakness.
05.3 Conformance with Goerator License Conditions. Maintainina Active Status
a. Inspection Scene (71001) '
The inspectors reviewed the licensee's program for maintaining active
operator licenses on June 10 to 14 and assessed the licensee's
compliance with 10 CFR 55.53 requirements.
b. Observations and Findina
The inspectors identified that the licensee allowed two licensed senior -
operators to take credit for. active license duty watchstanding in the
work control organization, specifically the Outage 00S Team, which was
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not a required licensed shift crew position defined in the facility's
technical specifications. This practice occurred during three calendar
quarters of 1994 (first, second, and fourth). Subsequently, the
operators were designated as on-shift Unit Supervisors, responsible for
directing licensed activities of licensed operators, without completing
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift funt.tions in the Unit Supervisor position under the
direction of a senior operator.
The inspectors questioned the licensee regarding whether active licensed
duty credit for watchstanding in support positions was still being
practiced. A licensee representative stated that Zion had performed a
detailed review and confirmed that this practice only occurred in 1994.
In addition, the inspectors identified that the computer database which
tracked licensed duty watchstanding time had no controls to preclude
giving credit for a full 12-hour watch when an individual stood only a
partial watch. For example, the computer database took information
regarding shift position manning from the logs at the start of each
shift and automatically credited the Updated Active Licensee Log with a
12-hour shift. However, if an operator left the watch position a few
hours after logging in, for any reason, the computer database system did
not have the capability to properly credit the individual for only a
partial watch. Therefore an operator could be incorrectly credited for
a full 12-hour watch.
c. Conclusion
The inspectors concluded that the licensee's practice for crediting
watchstanding time for senior operators in positions that did not
require the individual to be licensed as defined in the facility's
technical specifications and subsequently designating them as on-shift
Unit Supervisors without prior completion of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in the Unit
Supervisor position under the direction of a senior operator were
contrary to NRC requirements and a violation of 10 CFR 50.54(1), "
Conditions of License," 55.53, " Conditions of Licenses," and 55.4,
" Definitions" (50-295/304-96008-02(DRS)). The inspectors also concluded
that the computer database that tracked licensed duty watchstanding time
to maintain active operator's licenses was a weakness.
05.4 Reaualification Trainina Records
a. Inspection Scope (71001)
i
1
The inspectors reviewed training records to ensure compliance with 10
CFR 55.59(c)(5), "Requalification Program Requirements - Records," on
June 10 to 14.
b. Observations and Findinas
The inspectors determined that the licensee satisfactorily maintained
the required training records in the program notebooks. Also, the
licensee implemented crew notebooks in May 1996 which maintained
requalification records with more emphasis on self assessment. The
15
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,
inspectors noted that the crew notebooks kept post training briefs,
'
l summary of crew's self assessments, simulator training student feedback
forms, and simulator trainee critiques.
3
'
c. Conclusion
i
The inspectors considered that the crew notebooks had the potential for
i
being a good self assessment and feedback tool. The crew notebook was
still too new to fully assess its effectiveness.
l .06 Operations Organization and Administration
a. Insnection Scone (71707)
e
i
i During the special inspection of operational performance conducted from
May 20 to 24, the inspectors reviewed the licensee's Operator Workaround
List, implementation of computer systems, and control room logs.
-
b. Observations and Findinas
- The licensee implemented an Operator Workaround List to track items that
would inhibit operator response to normal and off-normal events. The
inspectors noted the following weaknesses with the implementation and
j use of this list:
'
- .
The list was not routinely reviewed by licensed operators to
!
ensure awareness of all plant conditions. The operators only
reviewed the list during periodic training. The list was not
treated by the operations department as a living document to
,'
maintain operator awareness of 00S equipment and its subsequent
effects on the plant.
.
.
The list contained between 70 and 80 items. A review of these
,
items showed that the threshold for adding an item to the list was
'
low. The number of items on the list diluted the importance of
each item in lieu of focusing on equipment deficiencies which
- impacted operator response in accordance with station procedures.
'
4
.-
The inspectors interviewed several levels of the plant management
and staff to determine their understanding of the definition of an
- operator workaround. The inspectors did not receive consistent
j answers from those interviewed.
The inspectors noted that the operations staff received insufficient
! training on newly implemented computer systems for administrative
j
control of work activities, such as the electronic work control system,
the PT-14 system used for tracking 00S equipment, and the workaround
4
list. The inspectors observed that, between crews, there was some
disagreement as to when to use the new computer systems and the old hand
written systems.
4
j 16
.
There appeared to be excessive redundancy in keeping control room logs.
Each unit operator maintained a log, as did their supervisor. In
addition, the shift engineer also maintained a station log. During i
interviews with shift engineers, they stated that their logs consist of !
their logs and entries from both the operator and supervisor logs.
Keeping three redundant logs added to the overall administrative burden
of operations supervision and distracted personnel from the other shift
duties and their ability to make plant tours.
c. Conclusion
The inspectors concluded that the implementation of new computer
processes has introduced additional administrative burdens on operations
supervisors. These, with existing burdensome administrative tasks such
as answering telephone calls to the control room and maintaining j
redundant operator logs, had made it difficult for operations
supervisors to perform routine plant tours to observe material condition
and ongoing work activities, according to the supervisors.
II. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
a. Insoection Scone (62703)
The inspectors observed all or portions of the following work
activities: 1A SI pump recirculation line modification; 1A EDG CO, ;
discharge timer replacement; 2A EDG lube oil cooler, jacket water cooler !
and intercooler cleaning and inspection; and the IC SG atmospheric
relief valve replacement
b. Observations and Findinas
The inspectors observed that the craft personnel performing the work
were knowledgeable of their assigned task. Work packages were available
at the work location and were used by the craft. The inspectors
reviewed the work packages and considered them acceptable. ,
1
l
c. Conclusion
The inspectors concluded that the maintenance activities observed were
performed well with the except of the 1A EDG CO, discharge timer j
replacement (see Section F1.1).
I
M1.2 Imoronerly Erected Scaffoldina
a. Inspection Scope (62703)
l
l On June 18, the turbine / generator system engineer (SE) identified that !
l scaffolding in the Unit I high pressure turbine area could potentially
17
l I
l
,
interfere with the operation of two governor control valves. The
inspectors interviewed the SE, the scaffolding foreman, the shift
engineer, and the root cause investigator.
b. Observations and Findinas
!
I
On June 13, contractors erected scaffolding to inspect a steam leak from
an expansion joint located between the high pressure turbine and the "B"
moisture separator reheater. The scaffolding was approved by the
'
!
scaffolding foreman on June 14. However, a need to investigate j
additional steam leaks from different areas of the high pressure turbine
required modification of the scaffolding. i
l
On June 17, the scaffolding was modified and the scaffolding handrail
poles were routed through two governor control valve actuator arms and
pivot points. Subsequent to the scaffolding modification, a walkdown
was not performed by the scaffolding foreman. The scaffolding remained
in place until June 18, when the turbine / generator SE noted the i
,
interference. The SE took immediate actions to restore the scaffolding
to an acceptable condition and initiated a station deficiency report on
the incident.
The licensee performed a Level 3 root cause investigation. Planned
corrective actions include a revision to ZAP 920-01, "Use of Scaffolding :
and Ladders," Revision 4, to require operations personnel to perform a
walkdown of modified scaffolding.
,
I
i
c. Conclusion
The inspectors considered that the licensee demonstrated poor attention
to detail by failure to recognize the interference of the scaffolding
.
!
with the actuator arms. Zap 920-01 was also inadequate, in that, it did
not require an additional walkdown by the foreman following
modifications. However, the SE performed well in walking down his
system and discovering the interference with the turbine / generator's
governor control valves.
III. Enaineerina
E2 Engineering Support of Facility and Equipment
E2.1 Unknown Bvoass Flow Around Charcoal Bed
a. Insoection Scope (37551)
On June 21, the inspectors observed that there were several holes in two
ventilation ducts in the fuel handling building. On July 1, the
inspectors walked down the duct with the SE and reviewed the associated
ventilation piping and instrument diagrams.
18
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l
l \
l
I
b. Observations and Findinas
!
On June 21, the inspectors informed the Fuel Handling (FH) Supervisor
that several in-line manufactured (drilled) holes were found in one duct
and that a puncture hole was found in another duct in the fuel building. i
The inspectors were concerned that the puncture created a potential i
inleakage point that was not routed through charcoal filters. The FH
supervisor stopped all transfer canal work and contacted the control
room (CR). The CR dispatched an operations supervisor and requested 3
assistance from the SE.
I
'
When the SE arrived at the fuel building, he misinterpreted which duct
the inspectors had referenced with the punctured hole, because there i
were four ducts in the general area. The SE concluded that the holes i
i were not a concern because the holes were in the supply ventilation
duct; therefore, the inleakage from the fuel building into the supply j
ventilation duct could not occur. Plugs were subsequently installed in
l
the holes. 4
'
' On July 1, the inspectors and the SE walked down the ventilation systems
and identified that the duct containing the punctured hole was actually
the exhaust ventilation duct from the HUT room. The air flow in the
exhaust duct was routed through HEPA filters but not charcoal filters.
Therefore, this inleakage point created a unfiltered bypass flow around
the charcoal filters which needed to be evaluated.
l On July 8, after prompting by the inspectors, the SE took actions to
i formally evaluate the issue and initiate a PIF. The SE obtained flow
l measurements in the exhaust duct which indicated a bypass flow of 2
l
'
standard cubic feet per minute (scfm). This bypass flow rate was
bounded by the bypass flow rate leakage limit, of 11 scfm, for the
charcoal filter efficiency test. Therefore, the SE concluded the bypass
l flow from the hole was not significant.
i
In addition, the SE considered the installation of a plug into the
l
punctured hole was an acceptable permanent repair. After the inspectors
expressed a concern about the repair being temporary, in that the plug
l
could be removed and the deficient condition returned, the SE stated he
l would write an action request to properly repair the hole with a metal
patch.
!
C. Conclusion
l
l Although the bypass flow around the charcoal bed was not significant,
i the failure of the system engineer to take prompt corrective actions to
l document and address this condition adverse to quality until prompted by
the NRC inspectors is a violation of 10 CFR 50, Appendix B, Criterion
XVI (50-295/304-96008-03(DRP)).
19
e
E2.2 Good Discovery and Followuo of Missina Parts Evaluation
a. Inspection Scope (37551)
' On May 17, in preparation for replacement of blocking latch relay, BR5-
1A, in the safeguards test cabinet, the system engineer discovered that
a parts evaluation was required by ZAP 510-08," Evaluation Guidelines for
new and replacement parts components and material," Revision 1(G). The
evaluation was needed to determine the suitability of the replacement
'
latch relay that was not an ider.tical replacement to the original latch
relay. The SE also identified that one had not been completed for a
previous latch relay, BR2-A, replacement in March 1996. This inspectors
interviewed the system and design engineers and reviewed the work
packages.
b. Observations and Findinas
The latch relays are used so that safeguards testing can be performed
without component actuations. In addition, the blocking latch relays do
not perform a safety function. However, these relays were installed in
a panel where they could affect other safety related components. The
replacement was not a like-for-like replacement because the old and new
latch relays were different and were mounted differently than before.
Therefore, ZAP 510-08 required that an suitability evaluation, which
would also require a separate seismic mounting evaluation, be performed.
After identifying that a parts evaluation was required, the SE initiated
the appropriate actions to request a parts evaluation for the May 17
latch relay replacement. The evaluation concluded that new latch relays
were an acceptable replacement and that seismic mounting of the new
latch relay was not a concern. Therefore, the evaluation also supported
the acceptability of the March 1996 latch relay replacee. ant.
The SE also generated a PIF for the earlier latch relay work. For the
earlier replacement, a procurement parts evaluation was mistakenly used
for the suitability parts evaluation which would have addressed the
seismic aspect of the latch relay. This error was an oversight on the
part of electricians and the SE involved in the March 1996 work. In
addition, the inspectors requested the system engineer to perform a
review of all latch relay replacements to determine if there were any
latch relays had been installed without having a parts evaluation
completed. The system engineer's review concluded that the new latch
relays had been installed only during the March and May 1996 latch relay
replacement work activities,
c. Conclusion
The inspectors considered that the SE demonstrated good engineering
involvement for the May 17 latch relay work as well as in the discovery
and followup to the missing parts evaluation for the March latch relay
'
replacement. Failure to perform a parts evaluation for the March 1996
relay replacement is a violation of 10 CFR 50, Appendix B, Criterion
20
1
l
i
'
III, " Design Control." However, this violation was identified by the
licensee and could not have been reasonably prevented by the licensee's
corrective action for a previous violation or a previous licensee a
finding that occurred within the past tuo years. In addition, a parts
evaluation was performed and the violation was corrected by the end of
the inspection. Therefore, this licensee identified and corrected
violation is being treated as a Non-cited Violation, consistent with
,
i
Section VII.B.1 of the NRC Enforcement Policy (50-295/304-96008- '
04(DRP)).
E3. Engineering Procedure and Documentation
E3.1 Review of UFSAR Commitments )
l
A recent discovery of a licensee operating its facility in a manner
contrary to the Updated Final Safety Analysis Report (UFSAR) description
l
'
highlighted the need for a special focused review that compares plant
practices, procedures and/or parameters to the UFSAR descriptions. The
inspectors reviewed the applicable portions of UFSAR that related to the
'
I
areas inspected. The following inconsistency was noted between the l
wording of the UFSAR and the plant practices, procedures and/or j
i parameters observed by the inspectors. !
a. Inspection Scone (71707)
While investigating the hole in the exhaust ventilation duct from the
Unit 1 HUT tank room, the inspectors identified that UFSAR, Section
15.7.4.1, " Fuel Handling Accident in the Fuel Building," had not been
updated to reflect the reracking analysis for the spent fuel pool. The
inspectors interviewed a nuclear system engineer and a regulatory
assurance engineer,
b. Observations and Findinas
The licensee changed the spent fuel pool arrangement (reracking)
described in Section 15.7.4.1 of the UFSAR in August 1993, and had not
incorporated this change into the UFSAR as of August 30, 1996.
On July 10, the system engineer informed the inspectors that the UFSAR
section 15.7.4.1 should have been updated along with the last UFSAR
update in 1995. The inspectors noted that the reracking change should
have been completed no later than twenty four months after the change.
While preparing the UFSAR change to incorporate the rerack analysis done
HOLTEC, the SE identified that the analysis did not use an organic
filter efficiency of 70% as specified in Regulatory Guide 1.25,
" Assumptions Used For Evaluating the Potential Radiological Consequences
of a Fuel handling Accident-in the Fuel Handling and Storage Facility
for Boiling and Pressurized Water Reactors." Therefore, as a
conservative measure, the SE recalculated the HOLTEC results using RG
1.25 and determined that the total iodine dose received to the thyroid
increased from 27.2 REM to 40.8 REM.
21
i
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,
The SE submitted an engineering request to determine if the HOLTEC
analysis should have included the assumptions in RG 1.25. The SE also
stated he would initiate a change to the UFSAR to include the HOLTEC
analysis using RG 1.25.
The SE documented the subject UFSAR discrepancy in a letter. dated July
29, 1996. This-letter is included as Attachment 2 to this report.
c. Conclusion
The inspectors considered the failure to properly update the UFSAR and
use the correct analysis demonstrated a lack of attention to detail and
is a violation (295/304-96008-05(DRP)) of 10CFR E0.71(e)(4).
IV. Plant Suncort -
R1 Radiological Protection and Chemistry Controls
R1.1 Plant Water Chemistry and Chemistry Ouality Control
a. Inspection Scone (84750)
The inspectors reviewed the licensee's water chemistry control program
including the level of' chemical contaminants in primary and secondary
systems and staff review of the data. The inspectors also reviewed the
laboratory and in-line instrument quality control program including
calibrations, performance testing, and interlaboratory analysis
programs.
b. Observations and findinas
The licensee's water chemistry control program was considered a
strength. The chemistry department's monthly and cycle reviews
contained good evaluations of the water quality for both units.
Overall, water quality for both units was good. The licensee's water
quality program was consistent with industry guidelines, and primary
water quality was very good. However, circulating water inleakage was a
problem for Unit 2 throughout the current operating cycle. Frequently,
the licensee diverted steam generator (SG) blowdown from Unit I to Unit
2 to aid in the removal of contaminants from Unit 2. Coasequently, both
Unit I and Unit 2 SG sodium, chloride, and dissolved oxygen
concentrations were slightly elevated for periods of time. The licensee
took appropriate actions to reduce the level of contaminants and return
the systems to normal chemistry levels.
The quality control (QC) program for laboratory and in-line instruments
was well implemented. The chemistry staff properly identified and
.
evaluated QC data trends. However, the inspectors noted some weaknesses
in the documentation of QC data reviews for analytical instrumentation.
The licensee's performance in interlaboratory comparison programs
22
__. _ _ . _ ._-__ _ _ _ _ _. _
_ . _ _ - _.. . .. ,
'
i
indicated excellent analytical accuracy. The inspector noted a minor
non-conservative bias'in the licensee's high purity germanium gas i
geometry, which the licensee planned to evaluate. '
c. Conclusion i
The licensee's water chemistry control program was considered a l
strength, with good review of operational data.. Periods of Unit 2 ;
circulating water inleakage resulted in slightly ' elevated concentrations !
of. chemical impurities in. steam generator chemistry. Quality control of 1
laboratory and in-line instruments was effectively implemented. ;
RI.2 Post Accident Samnlina System (PASS) Operability and Quality Control '
a. Inspection Scone (84750)
The inspectors reviewed the post accident sampling system (PASS), which
'
was used to obtain reactor coolant samples under both accident and ,
routine conditions. The inspectors reviewed PASS operability, QC
results, and maintenance history. The inspectors also verified the !
adequacy of the licensee's sample line purge times. ,
i
b. Observations and Findinas ,
l
Historically, the licensee has had difficulties in maintaining PASS i
operability. Several in-line instruments have required continual
corrective maintenance, resulting in low availability. Based on an ,
evaluation of its NRC commitments for the PASS, the licensee performed a
'
safety analysis and reduced its in-line monitoring commitments. The
licensee's evaluation demonstrated that several in-line monitors could
be eliminated without losing the ability to monitor significant
parameters. As a result of this evaluation, the licensee was in the
process of abandoning all of its PASS in-line monitoring
instrumentation, with the exception of the gas chromatograph. The
licensee expected that the reduction in instrumentation would focus
efforts in maintaining the remaining instrumentation and would improve
the overall operability of the system. The inspectors reviewed the
licensee's PASS QC results, which indicated that samples obtained from
the PASS were representative of primary coolant and that the PASS 1
dilution factor was accurate.
The inspectors also reviewed the status of the licensee's replacement of
sample line flow orifices in the PASS. The licensee had previously
identified problems concerning several sample line pressure indications.
In 1993, the chemistry staff initiated an action request to replace the i
instrumentation. Subsequently, the licensee had performed an initial ,
engineering evaluation and had obtained replacement parts, but the new i
equipment design could not be installed into the available space. At ;
the time of this inspection, system engineering representatives i
l indicated that current PASS sample line pressure indications did not
l accurately correlate to sample line flow rates. The inability to- _
accurately determine sample line flow impacted the licensee's ability to l
.
23
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_ _ _ _ _ _ _ _ _ . _ .
_ _ _ _ ._,
i
ensure that sample lines were adequately purged prior to obtaining .
required samples. However, chemistry and system engintering personnel '
indicated that resolving the design concerns and completing the repairs
was of low priority.
The inspectors reviewed the licensee's chemistry sample purge times. ' At
a fixed pressure indication in the sample lines, the chemistry staff had
evaluated PASS and normal sample flow to ensure adequate purges of
sample lines. Based on this analysis, the sample purge times for PASS
and routine sample points were adequate. If the evaluated sample line
pressure could not be obtained, additional guidance would be provided by-
chemistry management.
c. Conclusion
Although post accident sampling system and routine sample line flow
instrumentation were unreliable, the chemistry staff ensured that sample
line purge times were adequate to obtain representative samples.
R.1.3 Imolementation of the Radioloaical Environmental Monitorina Proaram
(REMP)
a. Insoection Scone (84750)
The inspectors toured the environmental air sampling stations and
reviewed the 1995 annual report and environmental sample results.
b. Observations and Findinas
The environmental air sampling stations were in good material condition.
Air sampler flow meters were calibrated as required. The inspectors
identified that the ~ text of the offsite dose calculation manual (ODCM)
contained minor inconsistencies and that the 1995 Annual Report
contained sample results for indicator milk samples when only control
milk locations existed. These inconsistencies indicated minor
weaknesses in the review of the program.
c. Conclusion
i
The licensee effectively implerr.ented the REMP and no measurable !
radiological impact on the environment from plant operations was I
identified. '
R4 Staff Knowledge and Performance in RP&C
R4.1 Chemistry Sample Collection and Laboratory Practices
a. Inspection Scope (84750)
1
The inspectors observed the analytical technique and radiation 1
protection practices demonstrated by chemistry technicians (cts).
Observations included cts obtaining primary coolant and secondary system 4
!
24 l
l
l
samples and performing analyses in the chemistry laboratory. The
inspectors also reviewed the preparation and control of laboratory
standards and reagents.
b. Observations and Findinas
The inspectors identified two iron standards in the chemistry laboratory
which had been incorrectly labeled with respect to shelf life. The CT,
who had prepared the 4 part per million iron standards, labeled the
standards as expiring after six months instead of the three months
directed by chemistry procedures. The chemistry superintendent
indicated that the standards had been used in an optional analysis.
Since the standards were not used in an analysis required by Technical
Specifications or by other requirements, no violation was identified.
The inspectors also identified some inconsistencies in the method in l
which reused sample containers were pre-rinsed with sample to reduce l
cross chemical contamination of samples. The licensee planned to review
the practices and ensure that proper analytical practices were J
implemented. j
On July 9,1996, the inspectors identified that CT contamination control l
practices were inconsistent with Zion administrative procedure. ZAP 620- l
03, " Transportation, Conditional, and Unconditional Release of
Radioactive Materials," revision 2. After collecting primary coolant
samples, the CT rinsed the outside of the containers with deionized !
water to reduce the potential for contamination and performed a l
radiation survey of the sample with an ion chamber. Subsequently, the
cts removed the samples and instruments from the primary sampling room l
(a posted, contaminated area). However, the CT did not perform a
surface contamination survey of the materials nor did the CT re-package
the materials to prevent the spread of contamination, as required by ZAP
620-03. Chemistry and radiation protection (RP) management indicated
that it was a longstanding practice to transport chemistry samples via
an elevator between the primary sampling room and the chemistry
laboratory, which was not a posted contaminated area, without surveying
the materials for surface contamination. The lack of assurance that
instruments and sample containers were free of contamination introduced
a potential for the spread of contamination within the Auxiliary
Building. Although the licensee's historical data did not indicate a
significant contamination problem, the licensee suspended the practice
and implemented more stringent radiological controls.
c. Conclusion
The chemistry technicians demonstrated good analytical chemistry
techniques, with the exception of some weaknesses concerning attention
to detail relative to laboratory standards.
25
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TS 6.2.2 requires, in part, that radiation control procedures be ,
prepared and implemented. The failure to properly remove items from the
primary sample room (a posted, contaminated area) in accordance with
1 procedure ZAP 620-03 is a violation of TS 6.2.2 (50-295/304-96008-
, 05(DRS)). !
!
R.4.2 Decontamination of the Fuel Transfer Canal
a. Inspection Scone (83750)
! The inspectors reviewed personnel performance during the decontamination
j of the Fuel Building transfer canal.
b. Observations and Findinas
} On June 10, 1996, the licensee identified that a contractor failed to
, follow station procedures 'after alarming a personal contamination
!
monitor (PCM). Instead of obtaining RP assistance, the individual
i performed a survey and identified the contamination on his clothing. i
- ' The individual disposed of the contaminated section of clothing and
successfully passed through the PCM. After the individual informed his
supervision of his actions, RP personnel escorted the individual to the i
.
decontamination area of the AB, surveyed the individual, and retrieved a 1
1
contaminated piece of clothing from a garbage receptacle. The licensee
i documented the event in a problem identification form (PIF). This item
, is unresolved pending further NRC review (50-295/304-96008-06(DRS)). j
] On June 7, 1996, the licensee identified that contrary to ZAP 600-3,
l " Radiation Work Permit Program," Revision 3, a fuel handler failed to
follow the applicable radiation work permit and removed equipment froa
! the fuel transfer canal without a RPT present. Under the circumstances, .
the individual believed that he was authorized to remove tools from the
'
$
-
fuel transfer canal. The inspectors discussed the event with the
- in an unlabeled bag. The RPT took control of the equipment and measured i
i
a dose rate of 50 mrem /hr on contact with the tools. The individual was ;
wearing the required dosimetry (i.e. thermoluminescent dosimeter and 1
. electronic dosimeter), which would have alarmed if the dose rate from i
j the tools had been significantly greater. The licensee took immediate
corrective actions including a halt in the fuel transfer canal
l activities and additional instructions to the work groups.
1
I Failure to follow the radiation work permit procedure is a violation of
i 10 CFR Appendix B, Criterion V, " Instructions, Procedure, and Drawings."
l However, this violation was identified by the licensee and could not
j have been reasonably prevented by the licensee's corrective action for a
- previous violation or a previous licensee finding that occurred within
'
the past two years. Therefore, this licensee-identified and corrected
'
violation is being treated as a Non-cited Violation, consistent with
j Section VII.B.1 of the NRC Enforcement Policy (50-295/304-96008-
,
2
07(DRS)). !
!
!
l 26
,
3
c. Conclusion
The inspectors concluded that personnel performance issues, both l
radiological and maintenance, have had negative effects on the progress
of the fuel transfer canal decontamination project.
R4.3 Conclusions l
Chemistry technicians demonstrated good analytical techniques, with the
exception of some weaknesses concerning attention to detail. Improperly
labeled chemistry standards were identified in the chemistry laboratory.
In addition, a violation, a non-cited violation, and an unresolved item
were identified concerning inadequate adherence to radiological control
procedures.
1
R7 Quality Assurance in RP&C Activities
R7.1 Ouality Assurance Assessments (84750)
a. Inspection Scooe (84750)
4
The inspectors reviewed audits performed by the licensee's site quality l
verification (SQV) staff of radiation protection and chemistry program
implementation,
b. Observations and Findinal
The SQV staff performed annual reviews of the REMP implementation. The l
SQV staff reviewed the performance of the environmental sample l
collector, REMP sample results, land use census, and annual report.
SQV's audit of sample collector activities and land use census data were
comprehensive. Findings concerning the land use census were well
documented and resolved.
Based on positive performance indicators, the SQV department had reduced
its auditing schedule of the chemistry program. Chemistry performance
was assessed via field monitoring reports and selected review of ,
chemistry activities. The SQV oversight of chemistry activities t
appeared acceptable; however,1994 chemistry findings concerning
adherence to RP procedures were not fully resolved,
c. Conclusion i
Based on NRC observations of minor inconsistencies in the ODCM and l
annual report (See Section R.1.3), the inspectors concluded that the '
review of the annual report data and ODCM was not as comprehensive as ,
the review of REMP. The inspectors identified weaknesses in j
radiological practices (See Section R4.1) that were similar to SQV
findings in 1994.
I
1
27
F1 Control of Fire Protection Activities
F1.1 Inonerability of the 1A Diesel Generator CO, System Not Recoanized
Durina C03 Discharaer Timer Replacement
1
a. Insoection Scope (71750)
On July 2, the inspectors identified that replacement of the 1A EDG CO,
discharge timer on July I had rendered the automatic function of the CO,
system inoperable. The inspectors reviewed the work package and
interviewed fire protection, electrical maintenance, and operations
personnel.
b. Observations and Findinas
On July 1, the onshift operations crew informed the electricians that
the timer could be replaced without taking the CO, system out of
service. But, with the discharge timer removed, the automatic function
of the CO, system was rendered inoperable.- This inoperable status was
not recognized by fire protection, operations, nd electrical
maintenance personnel during the work. The inspectors were informed, by
the electrician, that all the individuals involved were focused on
preventing the inadvertent operation of the C0 system; therefore, the
fact that the CO, system would not automaticalfy operate was not
identified.
Prior to approving the work, the onshift crew conferred with the fire
protection SE. A decision was made to issue the CO, lockout key to the
electricians to re-enable and disable the CO, system at their
discretion. Whenever the CO, lockout key was used, the automatic
function of the C0 system was impaired. However, the electricians
proceeded with replacing the timer without using the CO, lockout key
because they felt the key would not prevent actuation. The inspectors
subsequently reviewed the electrical prints with an electrician and
determined that the use of the CO2 lockout key does prevent actuation.
Although the key was not used, the CO, system was impaired due to the
timer being replaced.
This timer replacement work impaired the automatic function of the CO,
system. ZAP 900-02, " Fire Protection System Impairments," Revision 2,
required the initiation of an impairment permit and establishment of a
continuous fire watch. However, FP and operations personnel did not
perform these required actions because operations )ersonnel considered
issuance of the CO2 lockout key had not impaired tie automatic actuation
of the system. However, the continuous fire watch requirement was
coincidentally, accomplished due to another impairment requirement
already in place.
The practice of rendering the C0 system inoperable and not initiating a
fire impairment permit because tbe CO, lockout key has been issued has
been longstanding. This practice has not been in compliance with fire
protection program requirements of ZAP 900-02 which required that an
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impairment be initiated when impairing the fire protection system. This
practice demonstrated a lack of understanding of the fire protection
system and its requirements.
i The licensee implemented the following corrective actions: 1) revising
the fire impairment procedure to require the initiation of a fire
impairment permit when rendering the CO, system inoperable; 2) adding
lockout key to assure an impairment was
additional labelling
initiated prior to issuingonthe
the CO, key; 3) adding a placard adjacent to
local lockout key switch to assure an impairment was generated prior to
using the key; and 4) issuing a standing order informing operations
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personnel of the requirement to assure an impairment was issued prior to
l using the key.
c. Conclusion
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ZAP 900-02, " Fire Protection System Impairments," Revision 2, states
that a barrier impairment permit was required for fire protection
equipment that was impaired. Failure to initiate a barrier impairment
permit is a violation of 10 CFR 50, Appendix B, Criterion V, (50-
295/304-96008-08a(DRP)). The inspectors considered that the fire
!
protection, operations, and electrical maintenance personnel
demonstrated a lack of understanding of the operation of the CO, system
and requirements in ZAP 900-02. The station's implemented corrective
actions should be appropriate to prevent recurrence. However, there was
a deficient knowledge level that appeared to exist among numerous
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departments with respect to the fire protection system.
Although the licensee' implemented corrective actions to address the
problem, the station was untimely in documenting the inoperability of
the 1A Diesel Generator CO
generated for approximately, 23System; a station
days after July 1.deficiency report
ZAP 700-08, was not
" Problem
Identification Process," Revision 10, required that a PIF be generated
within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovering an issue. Failure to document this issue
' on a P1F, as required by ZAP 700-08, is a violation of 10 CFR 50, i
Appendix B, Criterion V (50-295/304-960008-08b(DRP).
V. Manaaement Meetinos
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X1 Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee
! management at the conclusion of the inspection on July 26, 1996. The
licensee acknowledged the findings presented.
l The inspectors asked the licensee whether any materials examined during l
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the inspection should be considered proprietary. No proprietary
information was identified.
.
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. _ _ . . _ _ . _ _ _ . . . _ _ _ . _ _
+
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Tuetken, Vice President, Zion Station
G. Schwartz, Station Manager
B. Giffin, Engineer Manager
B. Fitzpatrick, Operations Manager
L. Simon, Maintenance Superintendent
R. Cascarano, Assistant Operations Manager
W. Stone, Regulatory Assurance Supervisor
D. Hatton, Site Construction Superintendent
T. Hill, Mechanical Maintenance Master
R. Lane, Maintenance Engineering Supervisor
K. Depperschmidt, Instrument Mechanic Master
M. Rode, Fuel Handling Supervisor
J. LaFontaine, Work Control Supervisor
W. Demo, Assistant Superintendent to Operations
G. Ponce, Electrical Maintenance Master
M. Weis, Services Director
B. Schramer, Chemistry Supervisor
G. Kassner, Radiation Protection Supervisor
E
G. Grant, Director, Division of Reactor Safety
L. Miller, Chief, Reactor Projects Branch 4
IDM
J. Yesinowski !
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INSPECTION PROCEDURES USED
IP 37551: Engineering
IP 62703: Maintenance Observation
IP 71001: Licensed Operator Requalification Program Evaluation
IP 71707: Plant Operations
IP 71715: Sustained Control Room and Plant Observation i
IP 71750: Plant Support Activities l
IP 83750: Occupational Radiation Exposure
IP 84750: Radioactive Waste Treatment and Effluent and Environmental
Monitoring
Items Opened. Closed. and Discussed
Opened
50-295/304-96008-01 NCV improper return to service of a steam flow channel
50-295/304-96008-02a VIO personnel error and misoperation of EDG switch
50-295/304-96008-02b VIO failure to initiate a barrier impairment permit !
for the inoperability of EDG CO, system.
50-295/304-96008-02c )
VIO failure to initiate a PIF when the automatic '
function of the CO, system was rendered inoperable.
50-295/304-96008-03 VIO failure of the system engineer to take prompt
corrective actions for puncture in exhaust duct from
the HUT room
50-295/304-96008-04 VIO improper crediting of standwatch hours for
maintenance operator licenses
,
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50-295/304-96008-05 NCV failure to perform parts evaluation
50-295/304-96008-06 URI failure to properly update the FSAR
50-295/304-96008-07 VIO failure to perform survey prior to removing
material from contaminated area.
50-295/304-96008-08 URI contractor decontaminated himself after alarming
monitor
50-295/304-96008-09 NCV personnel removed equipment from the fuel transfer
canal with RPT present
Closed
None
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- - - = - .- . ._. - - - - . . - - .. ..
1
DEFINITIONS
Violations For Which a " Notice of Violation" Will Not Be Issued
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The NRC uses the Notice of Violation as a standard method for formalizing the
existence of a violation of a legally binding requirement. However, because
i
!
the NRC wants to encourage and support licensee's initiatives for self-
identification and correction of problems, the NRC will not generally issue a
Notice of Violation for a violation that meets the tests of 10 CFR 2,
Appendix C,Section V.A. These tests are: 1) the violation was identified by
the licensee; 2) the violation would be categorized as Severity Level IV or V;
3) the violation will be corrected, including measures to prevent recurrence,
within a reasonable time period; and 4) it was not a violation that could
,
reasonably be expected to have been prevented by the licensee's corrective
l
action for a previous violation. A Violation of regulatory requirements
l
identified during this inspection for which a Notice of Violation will not be
issued is discussed in Paragraphs 03.1, E2.2, and R.4.2.
Unresolved Items
'
Unresolved Items are matters about which more information is required in order
to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs
04.1 and R4.2.
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LIST OF ACRONYMS USED
AB Auxiliary building
ALARA As Low As Reasonably Achievable
CT Chemistry Technician
EDG Emergency Diesel Generator
EWCS Electronic Work Control System
FH Fuel Handler
FP Fire Protection
FSAR Final Safety Analysis Report
HUT Holdup Tank
IDNS Illinois Department of Nuclear Safety
IFI Inspection followup item
IM Instrument Mechanic
LSS Licensed Shift Supervisor
MM Mechanical Maintenance
NCV Non-cited Violation
NE Nuclear Engineer
NLO Non-licensed Operator
NSO Nuclear Station Operator
ODCM Offsite Dose Calculation Manual
OE Operating Engineer
00S Out-of-service
PASS Post Accident Sampling System
PCM Personal Contamination Monitor
PDR Public Document Room
PIF Problem Identification Form
PORV Power Operated Relief Valve
QC Quality Control
RCDT Reactor Coolant Drain tank
REMP Radiological Environmental Monitoring Program
RP Radiation Protection
RP&C Radiological Protection and Chemistry
RWP Radiation Work Permit
RPT Radiation Protection Technician
SALP Systemic
SE System Engineer
SI Safety Injection
SQV Site Quality Verification
Technical Specification
.
TS
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URI Unresolved Item
US Unit Supervisor
VIO Violation
,
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