ML20204F131
| ML20204F131 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/16/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20204F033 | List: |
| References | |
| 50-295-87-01, 50-295-87-1, 50-304-87-01, 50-304-87-1, NUDOCS 8703260140 | |
| Download: ML20204F131 (36) | |
See also: IR 05000295/1987001
Text
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SALP 6
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-295/87001; 50-304/87001
Inspection Report No.
Commonwealth Edison Company
Name of Licensee
Zion Units 1 and 2
Name of Facility
October 1,1985 through November 30, 1986
Assessment Period
40 87
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TABLE OF CONTENTS
Page No.
I. INTRODUCTION 1
II. CRITERIA 2
III. SUMMARY OF RESULTS 4
IV. PERFORMANCE ANALYSIS 5
A. Plant Operations 5
B. Radiological Controis 8
C. Maintenance 11
D. Surveillance 13
E. Fire Protection 14
F. Emergency Preparedness 16
G. Security 17
H. Outages 19
I. Quality Programs and Administrative Controls 22
Affecting Quality
J. Licensing Activities. 24
K. Training and Qualification Effectiveness 26
V. SUPPORTING DATA AND SUMMARIES 29
A. Licensee Activities 29
B. Inspection Activities 30
C. Investigations and Allegations Review 31
D. Escalated Enforcement Actions 31
E. Licensee Conferences Held During Assessment Period 31
F. Confirmatory Action Letters 31
G. Review of Licensee Event Reports and 10 CFR 21 Reports 32
H. Licensing Actions 33
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
l integrated NRC staff effort to collect available observations and data on
( a periodic basis and to evaluate licensee performance based upon this
l information. SALP is supplemental to normal regulatory processes used to
j ensure compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on
February 10, 1987, to review the collection of performance observations
and data to assess the licensee performance in accordance with the
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Zion Generating Station for the period October 1,
1985, through November 30, 1986.
SALP Board for Zion Generating Station:
Chairman
- J. A. Hind, Director, Division of Radiological Safety and Safeguards
Board
- C. E. Norelius, Director, Division of Reactor Projects
- C. J. Paperiello, Director, Division of Reactor Safety
- J. A. Norris, Licensing Project Manager, NRR
- M. M. Holzmer, Senior Resident Inspector
R. F. Warnick, Chief, Projects Branch 1
- B. L. Burgess, Chief, Reactor Projects Section 2A
P. L. Eng, Resident Inspector
J. W. McCormick-Barger, Reactor Engineer, Technical Support Staff
R. M. Lerch, Project Inspector, Section IA
- Voting members of the Board.
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II. CRITERIA ~ [,c
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5 ThE licinsee s performance is a s ssed in selected functioNN areas '
dependird whether the facilith' inaconstruEtioQere-oMati'enalor ,.
operating phase. Each functienal aree normal 7y reprtcentsp an(area
significant to nuclear safety \nd che environment, and is a normal i
programmatic area, Soms functional areas aay not be,a'ssessed because of '
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little or no licensee activities or lack of mearingfdl observations.
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Special areas may be added to highlight significant observations. is
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One'or more of the following evdation crira-ia' were. used to assess each -
functt g 1 area.
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A. /y sManagement involvement in@ssuring qualf ty. .
Approachtoresolutionoftechnicalissuesfpmasafetystandpoint.\
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C. ' i desponsiveness to NRC init'.Ttives. 1 (
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D. Enfoicede.'t histor'y.
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E. )OperationalandConstructionevents(fnclydingresponseto,analhsis
of, and corrective,hgi,ols for). ,{ )
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F. Staffing (including *mana'gement). '
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However, the SALP Board is not limited,to thhe criteria and others may
have been used where appropriate.' g i.'
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BasedupontheSALPBoa'rdasse'ssmnt,babifunctionalareae'vafuatedis . .
classified into one of three performance \ sate @. ies. The definftfon of ds
these performance categories is: g
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Category 1: Reduced NRC attention may be apropriate. Licensee h
management attention and involvement ar2 aggressive and oriented toward (
nuclear safe'ty; licensee resources are ample and effectivWy used so that
a high level of performance'with respect to operational satAty or 4
monstruction is being achhved. '
"
Category 2: NRCattentionkhouldbemaintainedatnormallevels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adeduate and are g
reasonably effective such that satisfactory performance with '
respect to '
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operatipnal safety or constrb: tion is being achieved.
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Catejoay 3: Both NRC and licensee attention should be Ocreased.
Licensee management attentKr or involvement is acceptable and considers (
nuclear safety, but weaknesses are evident; licensee resources appear to i '
be strained or not effectively used so that minimally satisfactory s
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performance with respect to operational safety or construction is being '
achieved. V i
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Trend: The SALP Board may determine to include an appraisal of the
performance trend of a functional area. Normally, this performance
trend is only used where both a definite trend of performance is
discernible to the Board and the Board believes that continuation of ;
, the trend may result in a change of performance level.
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J'.. The trend, if used, is defined as:
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a. Improving
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Licensee performance was determined to be improving near the close '
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of the assessment period,
b. Declining
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Licensee performance was determined to be declining near the close
of the assessment period.
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III. SUMMARY OF RESULTS s
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/ '0verall, the NRC has found the licensee's performance' acceptable and -
'dir'ected toward safe facility operation. However,ithe Ticensee's 1 <
overall performance remained lat the same . level identifie'd in the last
SALP period. A Category 1 rating was given in the new functional areas
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of Outages and Training and Qualification Effectiveness. Continued e
Category 1 performance was noted in the areas of Security and Licensing
Activities and seven areas remained at a Category 2 rating. The licensee i
should continue to provide aggressive management attention to the SALP
Category 2 functional areas -in order to achieve the level of performance
desired by both the NRC and the licensee. '
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, Ratfag Rating Thisp
Functional' Area i SALP :5 / Period
'
Trend
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A. Plant Operations '
2 2
- B. Radiological Controls 2 2
, C. Maint.enance "
2 2
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d. Fi S Protection 2
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G. Security 1 1 1
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Administrative Controls {
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J. Licensing Activities /
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K. Training and Qualification
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- Not rated (new( functional area for SALP 6)
< For SALP 6.the previous Refueling functional area has been expanded to
encompass al' major outage activities.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
During the assessment period, nine inspections were performed
by the resident inspectors in this functional area. This
assessment was based on direct observation of operating
activities such as startups, shutdowns, routine evolutions and
response to abnormal plant conditions, reviews of logs and
other records, verification of equipment lineup and
operability, and followup on significant cperating events.
Five violations of NRC requirements were identified in this
area during the assessment period, all of which were Severity
Level IV. One of the violations stemming from an auxiliary
feedwater pump being inoperable for 14 days longer than allowed
by Technical Specifications (TS), resulted in an enforcement
conference and a proposed Severity Level III violation. Appeal
of the severity level by the licensee was found acceptable by
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the NRC and the violation was issued as a Severity Level IV
on December 19, 1986. Another violation, consisting of failure
to meet TS requirements. involved the loss of recirculation
flow to the Unit 1 borce .njection tank (BIT) for a time period
in excess of that allowed by the TS.
Three other Level IV violations identified were failures to
meet the requirements of 10 CFR Part 50. One violation
involved the failure to report the closure of containment
purge valves as required by Part 50.72, and occurred early
in the assessment period. Since that time, the licensee has
adhered to the require.ments of both Parts 50.72 and 50.73.
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, Two other violations pertained to 10 CFR Part 50 Appendix B,
Criterion V, one of which resulted from the failure to follow
a procedural caution while attempting to pull fuses to main
steam isolation valve (MSIV) control power. The other, which
was the result of a procedural inadequacy as supported by
three examples, involved the loss of both trains the residual
heat removal system while the reactor coolant system was
partially drained for maintenance.
During the 17 month SALP 5 assessment period, there were six
violations of NRC requirements consisting of eight examples.
Compared with the current SALP period of 14 months and the
cited five violations consisting of seven examples, the rate
at which violations occur appears to be nearly equal. However,
two violations were related to events that represented a
greater safety significance than those that were noted during
the previous assessment period. These were the inadequacy
of Procedure MI-6 and the inoperability of the auxiliary
feedwater pump for 14 days longer than allowed by TS.
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Unit I tripped three times and Unit 2 tripped four times
during this assessment period, with six of the seven trips
occurring while the units were above 15% power and one of
the Unit 1 trips occurring between 0% and 15% power. All
reactor trips were automatic and not manual. Three of the
reactor trips were caused by equipment failures. Of these,
one was related to the turbine electro-hydraulic control
system, one was related to electrical noise in nuclear
instrumentation cabinets during surveillance testing, and one
was caused by instrument drift in a reactor protection system
bistable. Three trips were caused by personnel error or
training deficiency. Two of those were caused by instrument
mechanics and one was caused by a non-licensed operator. The
remaining reactor trip was caused by a lightning strike.
Reactor trips occurred at essentially the same rate as SALP 5,
with similar rates for root cause of personnel error and
equipment failures. There were also two trip signals at 0%
power, one for Unit I and one for Unit 2.
There were 24 Engineered Safety Feature (ESF) actuations during
this assessment period (excluding the reactor trip signals
discussed above). Five of these ESF actuations were due to
containment purge isolation signals, five were actuations of
one or more containment isolation valves, and four were
automatic starts of penetration pressurization air compressors.
In addition, six ESF actuations resulted from test activities,
and were caused by switch malfunctions, operator errors, and
procedural deficiencies. The licensee has complied with the
requirements of 10 CFR 50.72, and has reported conservatively
throughout the period.
Of 24 licensee event reports (LERs) which involved the
operations area, six involved inadequate procedures. The
remainder were evenly split between procedural violations,
technical knowledge deficiencies, communications errors, and
personnel errors.
The licensee routinely exhibited a conservative approach to
safety issues as indicated by their response to the four
unusual events which occurred during the assessment period.
In these cases, operating mode reductions were initiated or
made according to the technical situation, at the expense of
production. In addition, reactor startups following trips
were properly delayed until the licensee had completed a
determination of root cause of reactor trips, actions to
prevent recurrence, and correction of equipment problems.
For example, following the reactor trip that was caused by
a lightning strike, extensive testing was performed to
determine which electrical components had been affected by
the lightning.
Operator response to plant transients and events was generally
good. Detection of subtle changes in plant parameters led to
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the discovery of the failure of the 1B main steam check valve.
In addition, a leaky valve in the Unit 1 pressurizer spray line
was promptly detected by a radwaste operator who had observed
an increase in the frequency of cycles of the containment sump
pump. Several startups and shutdowns were observed by the
resident inspectors. During these evolutions, procedural
adherence, supervision, communications, and operator vigilance
were very good.
Control room behavior and conduct are addressed in detail in
corporate and plant directives and procedures, which
specifically prohibit sleeping, chronic lack of attentiveness,
alcohol or drug use, practical jokes, and other distractions
under penalty of disciplinary action including discharge. In
addition, radios, televisions, and non professional reading
materials are prohibited. Operator adherence to these
procedures is excellent. Operator's knowledge and awareness
of plant status is also very good. Operating units routinely
run with few alarm status lights. During the assessment period,
there were long periods in which fewer than four alarms were
illuminated for operating units. Plant management has also
acted to minimize the amount of traffic and reduce the number
of unnecessary personnel in the control room.
Several management positions changed in September of 1985,
including the Operating Assistant Superintendent, and Operating
Engineers. Since that time, management turnover has stabilized
with the exception of Shift Control Room Engineers (SCRE). Of
9 SCREs, only 2 have been in that position for more than 18
months. While no specific problems were identified, which
were attributed to the low level of SCRE experience, this is
considered an area of potential weakness.
The operations department has initiated several actions to
improve regulatory performance during the assessment period.
These include enhancements to control room professionalism and
appearance. One such action will be the remodeling of the
control room center desk area in 1987, which should provide a
better facility for shift management and control of access.
The licensee also initiated a procedure improvement program.
Aspects of this effort include contracted assistance to reduce
the backlog of procedure changes needed for the near term, and
contracted procedure development and revision assistance to
incorporate human factors principles and INPO guidelines into
all operating procedures. Operator involvement is also planned
to ensure that procedures are " workable". Conduct of opera-
tions improvements have included improved turnover, night
order, and standing order procedures. Reviews are also planned
for operator logs, the locked valve control program, and the
conduct of operations policy. Plant labelling improvements
have been in progress throughout the assessment period to
ensure that valve and component labels are properly provided.
A color coding scheme for the plant is also planned.
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2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last assessment period.
3. Board Recommendations
None
B. Radiological Controls
1. Analysis
Six inspections were performed during this assessment period by
region based inspectors. The resident inspectors also reviewed
portions of this area during routine inspections.
One Severity Level IV violation was identified concerning
failure to collect a reactor coolant sample for iodine analysis
within the required time frame.
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The licensee's management involvement has generally been good
with some exceptions. Audits are thorough and timely with
good responsiveness to findings. The licensee's efforts to
! improve worker adherence to station radiation protection
procedures by increased identification of offenders and
stronger disciplinary actions have been somewhat successful,
although further effort is necessary based on NRC inspector
observation of workers failing to properly frisk themselves
when leaving contaminated areas. Positive management control
initiatives during this assessment period include the formation
of a dry active waste (DAW) volume reduction committee,
periodic meetings between the Radiation Protection Manager
(RPM) and appropriate plant management, the auxiliary building
cubicle contamination reduction program, a corporate directed
secondary water chemistry control program, and various trending
programs. Several items, however, failed to receive timely
and thorough licensee management attention, including
development of compliance documentation for certain TMI
Action Plan Items, resolution of the acceptability of the
1983 modification and repair of the control room emergency
air cleaning system, and laundry operational problems. The
September 11, 1986, incident involving the inadvertent
intrusion of radioactive noble gas into the technical support
center (TSC) and control room gas control envelopes also does
not appear to have received appropriate management attention.
The licensee did not recognize until late November that the
TSC ventilation system apparently could not meet its design
objective. A comprehensive program to investigate the
technical and regulatory ramifications of the September 11,
1986, incident was not initiated until mid-December.
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Licensee staffing performance during this assessment period
has improved in some aspects and declined in others. The
radiation / chemistry technician (RCT) staff has stabilized with
a very low turnover rate; however, the turnover rate for the
professional health physics staff has been high resulting in
60% of the positions either vacant or filled with personnel
who have very little operating plant experience. The staffing
levels appear adequate, however, to perform the necessary
work activities in this functional area. A persistent problem
continues to exist in that the rotation of the RCTs between
health physics and chemistry groups results in long periods
of absence from the laboratory, which is conducive to a loss
of laboratory proficiency, especially in the use of
sophisticated analytical instrumentation.
Licensee responses to NRC initiatives have generally been
adequate. Improvements were made in response to NRC identified
weaknesses concerning radiological environmental monitoring
program (REMP) management, liquid effluent alpha counting,
degraded auxiliary building HVAC exhaust ductwork, in-situ
calibration of containment high range radiation monitors, and
management of 10 CFR 61 implementation. NRC concerns about
inconsistencies between the REMP and the Offsite Dose
Calculation Manual that carried over from the previous
assessment period were largely resolved with implementation of
the new Radiological Effluent Technical Specifications (RETS)
in the fall of 1986. Although, as stated above, certain TMI
Action Plan Items have remained unresolved for an extended
period, significant progress regarding compliance documentation
was made by the licensee near the end of the assessment period.
The licensee's approach to resolution of radiological technical
issues has generally been technically sound, thorough, and
timely. The licensee has realized significant dose savings by
establishing and diligently maintaining an effective ALARA
program. The 1985 personnel exposures were about 550
person-rems per reactor which is about 20% less than the
licensee's average over the previous five years but 35%
higher than the 1985 average for U.S. pressurized water
reactors. The 1985 personnel exposure level was due mostly
to extensive outage work on both units. The 1986 personnel
exposures are expected to total approximately 250 person-rems
per reactor. Noteworthy improvements implemented during this
assessment period include the continual reduction of the
contaminated floor area in the auxiliary building general
access area, initiation of the cubicle contamination reduction
program, and installation of new state-of-the-art whole body
frisking units. Problems identified during this assessment
period include lack of finalization of procedures and plans
for the use of the interim radwaste storage facility,
correction of certain HVAC system design deficiencies, problems
with implementation of dry active waste (DAW) compaction area
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facility modifications, lack of procedures for segregation of
" clean" DAW trash, and repetitive failures to meet technical
specification monitor surveillance requirements.
Radioactive gaseous effluents have remained about the same as
the previous period, about 2000 curies annually per unit,
reflecting the absence of any significant fuel cladding
problems and only minor primary to secondary leakage. Two,
minor, unplanned but monitored, gas releases resulted from a
leaky valve and a faulty computer chip related to a gas
analyzer associated with the water gas compressor. Appropriate
and timely measures were taken to preclude further releases
from these sources. Liquid effluents continued a generally
decreasing trend which began about five years ago. About 2
curies were released in liquid effluents in 1985 and about
0.7 curies were released during the first half of 1986. The
licensee continues to pursue an aggressive and effective solid
radwaste reduction program; solid radwaste generated in 1986
is expected to be about one-half and one-third that generated
in 1985 and 1984, respectively. No licensee radwaste trans-
portation problems were identified during this assessment
period.
Improvements in control of water quality were noted beginning
in the second half of 1985. Trend plots of key chemistry
variables showed that the plant was able to remain within
administrative limits about 99% of the time. The licensee has
adequate sampling capability on both the primary and secondary
systems, but plans to improve on-line monitoring of chemistry
variables in 1987.
Laboratory QA/QC was considerably improved with better use
of control charts for instrument performance data, testing
of technician performance with blind duplicate samples, and
participation in interlaboratory crosscheck programs for
radiological analyses. The station has had problems in
analyzing EPA environmental level radiological samples.
This comparison program will be replaced by vendor supplied
unknowns at concentrations more appropriate for station
analyses. The station achieved 55 agreements in 60
comparisons in the NRC confirmatory measurements program,
a slight decline in performance from the previous assessment
period. The licensee is taking appropriate corrective steps
including recalibration of gas geometries and analyses of a
spiked sample from the NRC reference laboratory.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last assessment period.
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3. Board Recommendations
None
C. Maintenance
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1. Analysis
During the assessment period, eight inspections were performed
by the resident inspectors in this functional area. This
assessment was based on direct observation of plant modifica-
tions, replacements, repairs, equipment overhauls, preventative
maintenance, maintenance organization and administration, and
response to events related to maintenance.
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Two Severity Level IV violations were identified in this area.
One violation resulted when the level in the containment spray
additive (Na0H) tank fell below the minimum required because
calibration procedures did not contain appropriate acceptance
criteria. Procedure revisions corrected the problem. The
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other. violation was cited for two examples where plant workers
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manipulated plant equipment without procedures and thereby
defeated the system design. In one case this resulted in a
reactor trip when a turbine pressure transmitter was isolated.
Eight violations were identified during the previous assessment
period, most of which were related to Instrument Mechanic
3 (IM) or Mechanical Maintenance (MM) procedures or procedure
i adherence. Revisions to all safety related IM pincedures,
begun during the previous assessment period, were completed
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and incorporated more detailed work instructions, cautions,
and independent verifications of return-to-service valve and
switch lineups. These revisions, combined with improved IM
performance have significantly reduced the number of IM related
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events.
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Of 34 LERs related to maintenance activities, 18 were caused
by equipment failures and 7 were caused by personnel errors.
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The remainder were due to instrument drift (4), installation
not meeting the design (3), and inadequate procedures or
- design (2 each).
About 25 new MM procedures were written during the assessment
period, although this effort has been done on a spare time
basis. Late in the assessment period, a contract was prepared
to provide assistance in writing and revising MM procedures.
The need for improved MM procedures was highlighted in
October 1986, when the IB diesel generator (DG) threw a piston
- connecting rod through the crankcase wall during a post
j maintenance run. The maintenance performed involved removal
, of the affected piston and cylinder liner. The procedure used
i was inadequate to prevent improper tcrquing of the connecting
i rod lower bolts, and the DG failure resulted.
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Maintenance staffing levels are generally adequate, however,
additional personnel appear needed to provide planning and
coordination of work activities, and to write procedures and l
work packages. Also, new demands on staff time for performing
more detailed work instructions and requalification training l
may impact the staff's ability to keep pace with work request.
Maintenance personnel, including management, are well trained
and adherence to procedures is generally good.
The backlog of maintenance work requests has varied depending
upon whether an outage is in progress, but was generally large
during the assessment period. This backlog, which includes
safety related and nonsafety-related modification and
preventive maintenance work requests, peaked at about 3250.
Equipment availability for safety related equipment was very
good, as indicated by relatively few entries into the Technical
Specifications (TS) limiting conditions for operation (LCO)
involving plant shutdown. Resolution of equipment operability
issues was typically handled on a technical basis, and
resolution involved appropriate consideration for safety.
Examples included repairs to plant equipment following the
July 1986, reactor trip due to lightning and the actions
taken following the failure of the 18 main steam check valve.
Equipment availability for some non-safety related plant
systems needs considerable improvement. Examples include
radiation monitors and recorders (including SPINGS, which are
the particulate / iodine / noble gas monitors), and instrument
air compressors. About half of the maintenance related LERs
reviewed involved equipment failures as causes or contributors
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to the events.
A formal preventive maintenance program still does not exist;
! however, many preventive maintenance activities do take place.
These include the development of an extensive vibration
monitort,a program, the use of oil samples to determine the
l need for bearing replacement, and inspections and rebuilding
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of many plant components including safety valves, snubbers,
ISI hangers, circuit breakers, and environmentally qualified
(EQ) components. Positive effects of these activities are
exhibited by the few shutdowns / reactor trips due to equipment
failures.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last assessment period.
3. Board Recommendations
None
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D. Surveillance
1. Analysis
During the assessment period, eight inspections were performed
by the resident inspectors in this functional area. This
assessment was based on direct observation of surveillance
activities, and review of surveillance procedures and
surveillance scheduling. Examination of this functional
area also consisted of three inspections by regional based
inspectors to examine activities as they relate to snubber
inservice inspection and the resolution of unresolved items
and IE Bulletins.
One event resulted in two Severity Level IV violations
during the assessment period. In this event, a control
room ventilation system HEPA filter was replaced without
the post-installation efficiency testing as required by the
Technical Specifications. Appropriate corrective actions
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were implemented.
Management of surveillances improved during the period.
LER data indicate that 7 missed surveillances occurred
during the assessment period (14 months) compared to 15
during SALP 5 (17 months). In addition, 6 of 24 ESF
actuations occurred during surveillance testing. Two of
these were caused by personnel error, 2 by procedure
deficiency, and 2 by component failures during tests.
In response to NRC concerns expressed in SALP 5, the licensee
developed an action plan to reduce the number of missed
non periodic surveillances. These actions included:
-
Establishment of a master surveillance plan which would
computerize routine surveillances (monthly or less
frequent). This action is not yet complete.
-
Development of an "Off-normal / Transient Surveillance
Manual" (ZAP 10-52-1A, effective December 23, 1986) as
a guide to operators when changing mode or reactor power,
or when information is needed to supplement the Technical
Specifications.
Two examples of missed surveillances occurred following
implementation of the Radiological Environmental Technical
Specifications (RETS) on September 24, 1986. The RETS involved
numerous changes to surveillances on plant radiological
instrumentation and to sampling requirements. The licensed
received the RETS approximately 6 months prior to the
September 24 implementation date to provide adequate time
for review and development of necessary procedure changes.
Oversights during the review process resulted in missed
13
.
.. _ _ _ _ _ _ __ _
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
.
. ..
surveillances on the TSC portable area monitor discovered
October 5, 1986, and in failure to take containment iodine
samples shiftly during Unit 2 containment vents on October 7,
1986.
Surveillance procedures reviewed during the period were
generally adequate, and technically correct. Individuals
performing surveillances adhered to procedures. At the end
of the assessment period, the licensee contracted for a
major rewrite of operating procedures which was to include
performance tests. This action should provide improved
uniformity in format, and incorporate INPO procedure guidelines.
The inspectors determined that snubber inservice inspection
records were generally complete, well maintained and
available. The licensee's responsiveness to the IE Bulletins
was timely, viable, and generally sound and thorough.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 during the last SALP period.
3. Board Recommendations
None
E. Fire Protection
1. Analysis
Fire protection activities were observed during routine
resident inspections, and during followup of liceasee event
reports (LERS).
l
l One Severity Level IV violation was issued involving
'
inattentive fire watches.
Fourteen LERs were issued regarding fire protection. Eleven
of these were for inoperable or degraded fire barriers and
dampers. Some of the degraded barriers were identified during
quality assurance audits. Several of the inoperable dampers
were the result of inadequate knowledge of the damper design,
which rendered the dampers inoperable when the dampers were
removed from service for maintenance. The number of LERs
involving fire protection is considered too high and warrants
increased management attention.
Management attention to the posting of fire watches needed
improvement. In addition to the violation mentioned above,
there were two instances of fire watches required by Technical
Specifications that were not properly posted. One watch was
14
_--___ - _____- _ -___-__ _ _ __ . _ _ _ _ _
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
secured too early, and another was not posted for two hoa-s
due to a scheduling oversight. Interviews with fire watetes
also indicated the need for better directions and more specific
delineation of the requirements of the watch.
The fire protection staff consists of a Unit 1 operating
engineer assigned responsibility for implementing the fire
protection program, a Fire Marshal, and an additional
operations person assigned to do fire protection surveillances
under the direction of the Fire Marshal. Staffing is generally
adequate with weaknesses as evidenced by the fire damper and
fire watch reportable events.
Fire brigade training and the qualifications of fire brigade
members were good.
As reported in SALP 5, the licensee continues to be in
violation of the scheduler requirements of 10 CFR 50, Appendix
R, regarding fire protection modifications. During SALP 6,
the licensee resubmitted their plan to comply with Appendix
R. The licensee's plan is currently under review by NRR.
Housekeeping improved dramatically over the assessment period.
The auxiliary and fuel building walls were painted, and decks
were repainted. Tools and materials (such as scaffolding
materials and ladders) were inventoried and placed in dedicated
storage areas. Goals for outage and non-outage contaminated
areas were lowered, and the licensee plans to decontaminate
auxiliary building pump cubicles and release them for general
access. Leaks in the auxiliary building were generally
controlled, although some chronic service water leaks still
per.tst.
Painting in the turbine building was in progress by the end of
the assessment period. Painting included components, such as
turbines, pumps and valves, as well as walls, and general
areas. Tb? painting also included switchgear rooms and will
include diesel generators (DG) and DG rooms.
The units will be color coded, as will be certain process
pipes. Felt tip marker component labelling is being replaced
with engraved gravel ply labels. Metal valve identification
tags are also being added or replaced.
Housekeeping improvements have had a high management pricrity
during the assessment period, and as indiceted by the station
goals, this will continue into 1987.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last assessment period.
15
_ _ _ - _ _ _ _ _ _ _ _
.
.
3. Board Recommendations
None
1. Analysis
Two inspections were conducted during the period. These
included the observation of the unannounced, 1986 emergency
preparedness exercise and a routine inspection.
Management involvement and control in assuring quality has
generally been adequate. Independent audits of the program
were adequate in scope, depth, and frequency. Four
surveillances were conducted during the twelve month period
ending in March 1986, which is a greater number than required
by departmental instructions. Surveillance topics included
the annual exercise, a drill, and the licensee's response to
an actual emergency plan activation. However, the auditor
findings regarding the exercise and drill exhibited a lack
of emergency preparedness expertise when compared to the
findings of the licensee's specialists who also observed
those activities. Records of all quality assurance audits
and surveillances were complete and readily available, as
were records of emergency supplies inventories. However,
there were inadequate provisions for promptly replenishing
missing or depleted items identified during these periodic
inventories.
Between July 1985 and March 1986, the licensee activated the
emergency plan on four occasions. All situations were
properly classified. Required offsite notifications were
completed in an acceptable manner. While the station's
emergency planning coordinator independently evaluated the
records associated with each event, these evaluations varied
in quality and did not always identify problems later
identified by the inspectors. In contrast, the coordinator
j
'
maintained adequately detailed records of emergency prepared-
ness drills, including any corrective actions taken.
The licensee's responsiveness to NRC concerns has generally
been acceptable and timely. A notable long-standing
regulatory issue attributable to the licensee has been a
major revision to the Station's Emergency Action Levels
(EALs). The licensee's corrective action approach, was sound
and thorough. However, several time extensions were granted
before the revised EALs were finally submitted for staff
review.
As evidenced by walkthroughs and player performances during
the exercise, the licensee has maintained an adequate training
program for members of the onsite emergency organization.
16
_ -- . _ _ _ _ _ _ _ _ .
O
'
4
However, Training Department staff were unable to produce
documentation that all director-level personnel had been
trained during 1985 on all relevant emergency plan implementing
procedures in addition to the standardized training modules.
Although simulator training had supposedly included emergency
preparedness decisionmaking, no formal records of this aspect
of emergency preparedness training were maintained. The
licensee has committed to resolve both training documentation
omissions.
The licensee has maintained a prioritized roster of qualified
personnel to fill well-defined, key positions in the onsite
emergency organization. The licensee has demonstrated the
capability of augmenting onshift personnel in a timely manner
by conducting semiannual off-hours drills.
Corporate emergency planning staff has interfaced with the
station on the annual exercise, certain drills, and on
revisions to the emergency plan. Corporate staff has taken
the lead role in frequently interfacing with State and Federal
agencies in the ongoing major planning effort associated
with the 1987 Full Field Exercise. During 1986, corporate
management and staff were responsive to a Kenosha County
official's concern regarding issuance of potassium iodide
to the general public. The licensee met with State and local
officials to resolve the concern. The licensee also adequately
interfaced with Illinois State and local officials in resolving
the concerns of the owner of an Emergency Broadcast Station.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last assessment period.
3. Board Recommendations
None
G. Security
1. Analysis
Three security inspections (two routine and one special) were
conducted by regional inspectors during the assessment period.
Reduced inspection effort was the result of the licensee
being rated a Category 1 during the SALP 5 period. Two
allegations were received at the beginning of the period.
The allegations involved personnel access control and security
force performance issues and were determined to be unfounded.
One Severity Level IV violation was identified during the
assessment period. It involved a degradation of a vital area
barrier that did not, however, result in an easily exploited
17
.
.
access path. The licensee took prompt and extensive corrective
action which led to the immediate identification and correction
of an identical second breach. The events were reported within
the required time frame. The expeditious manner in which the
barrier degradation was analyzed and corrected was indicative
of an effective security program.
Licensee management's role in assuring quality was clearly
evident as demonstrated in the following examples. The shore
protection project which should prevent future damage to the
Protected Area (PA) intrusion detection system, involved a
concerted effort among the licensee's corporate security
director, the plant manager and the site security adminis-
trator. Considerable management effort was expended in
researching, planning and designing an appropriate solution.
The licensee's PA intrusion detection system continues to be
one of the more effective systems within Region III.
Additionally, the transition from one site security force
contractor to another during the period was smooth and without
impediments. The transition was clearly indicative of prior
planning.
With one exception, technical security issues were resolved
in a timely manner. The licensee's actions implemented as a
result of the identified Vital Area breach were the result
of a conservative approach in the analysis of the event's
significance. The corrective action taken was expeditious,
technically sound, and very thorough. There was only one
issue that was not resolved in the licensee's usually
consistent manner. Compensatory measures for a failed closed
circuit television camera observing the PA perimeter were not
addressed with a conservative approach; however, the licensee
does satisfy applicable security plan commitments.
Events reported in accordance with 10 CFR 73.71 were properly
identified and analyzed and were reported in a timely manner.
Timely and accurate reporting demonstrated excellent knowledge
of regulatory requirements and security commitments on the
part of the security force and also a comprehensive reporting
policy and comprehensive procedures.
The licensee has identified positions within the security
organization which are well defined and which possess the
appropriate level of responsibility. Key positions are filled
on a priority basis. The recent change of the site security
force contractor demonstrated the licensee's ability to
maintain a high level of performance during transition,
highlighting its dedication to a quality program.
During the most recent inspection, the NRC noted that some
central alarm station and secondary alarm station (CAS/SAS)
operators are sometimes required to work 16-hour shifts because
18
.
O
O i
their relief was not available. Some of the forced overtime
was caused by the unanticipated departure of two supervisory
personnel. The licensee was aware of the problem and had
initiated a cross-training program to ensure that qualified
personnel are available on each shift to perform CAS/SAS duties
in the event of an operator's unplanned absence. The initiative
should significantly reduce the frequency of 16-hour shifts by
CAS/SAS operators.
The training and qualification program is effective. Although
the program was not directly reviewed during the assessment
period, the lack of any significant security force personnel
errors and the sustained superior security force performance
were demonstrative of an effective training program. Training
inadequacies were not identified as the root cause of any
security event and, when questioned, security force personnel
were knowledgeable of security plan commitments and security
procedures.
During the assessment period, the morale of the security
force improved notably due, in part, to licensee management
initiatives to improve communications within the security
organization. Improved morale represents another enhancement
to a quality security program.
2. Conclusion
The licensee is rated Category 1 in this area. The licensee
received a rating of Category 1 in the last assessment period.
3. Board Recommendations
None
H. Outages
1. Analysis
Examination of this functional area consisted of routine
observations by resident inspectors during LER followup and
attendance at station meetings, as well as inspections by
regional based inspectors to examine activities as they
relate to inservice inspection (ISI) of piping system
components, steam generator sludge lancing, diesel generator
repair, and startup refueling testing.
One violation (Severity Level IV) was issued involving the use
of uncontrolled drawings by the Station Electrical Engineering
Department during the development of a modification to the
4160 volt ESF bus breaker interlocks. Another Severity Level
V violation was identified in this functional area concerning
physics testing and is discussed later in this section.
19
. ._ - ____-- -_ -___
.
. . . .
.
.
Another event involving modifications indicated the need to
provide better drawing detail to installers.
Outage planning is coordinated by a central outage planning
group under the direction of the Assistant Station
Superintendent, Outages. This individual is one of the most
experiented personnel at the station, having been in the
operating department since before initial criticality.
Outage schedules are developed using a computer program,
and schedules are updated weekly.
During the assessment period, station meeting routine was
changed to add a 7:00 a.m. morning meeting between repre-
sentatives of working groups to review and coordinate work
activities. The 8:15 a.m. morning management meeting format
was also changed to give greater detail on station work,
emphasizing each group's priorities of the day. In the
afternoon, another meeting is held to plan future work.
These meetings have been very beneficial to the flow of
information at the station.
Outage planning is done continuously using 6 month and 3 month
goals. The basic refueling sequence is " pre-set" in the
computer code and other jobs are added where they fit best
in the schedule. After an outage schedule is developed,
daily meetings described above are used as a means to
coordinate work and adjust the schedule as needed. Near
the end of the outage, lists are generated for certain key
milestones, such as drawing a pressurizer bubble. Onsite
reviews are performed prior to leaving cold shutdown.
Outage management for the July 1986, Unit 2 outage caused by a
lightning strike showed a very good approach to the resolution
of technical issues from a safety standpoint. During that
outage, a thorough review of instrumentation which could have
been affected by the lightning strike was conducted. Testing
to verify instrument operability was also conservative.
Management controls as indicated by outage related procedures
were generally adequate, although some deficiencies in
Maintenance Instructions (MI) and General Operating Procedures
(GOP) were identified. Minor ISI deficencies were also
identified in two LERs, and a defective hydrostatic test
procedure lead to the inoperability of the 18 auxiliary
feedwater pump in December 1985. Procedures for the outage
planning group have not been developed because corporate
guidelines have not been issued.
For the ISI areas examined, the inspectors determined that
the activities had received prior planning and priorities
had been assigned. Activities were controlled through the
use of well stated and defined procedures. Observation of
4
20
_ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ .
l'
.
.
ISI activities, sludge lancing, and repair welding indicate
that personnel have an adequate understanding of work
practices and that procedures were followed. Records were
found to be generally complete, well maintained, and available.
The records also indicate that equipment and material
certifications were current, complete, and that the personnel
performing nondestructive examinations and repair welding
were certified. Discussions with personnel performing
nondestructive examinations indicate that they were knowledge-
able in their work activities.
Refueling activities were performed without incident during
the assessment period. Refueling activities are performed by
a stable, well trained, group of fuel handlers. Replacement
of control rod guide tube, split pins, was also performed
without incident and ahead of schedule.
One inspection of core performance surveillance testing
following startup from a refueling outage was performed by.a
region-based inspector. The inspection included verification
that test results conformed with Technical Specifications and
procedure requirements and that any deficiencies identified
during the testing were properly reviewed and resolved. One
Severity Level V violation was identified concerning physics
testing at zero power, where testing was not performed in
accordance with written test procedures in that certain
4 procedure steps were not signed-off or performed before
proceeding to subsequent procedure steps. This violation had
minimal safety significance. However, similar problems in
'
controlling compliance to procedures and adequately reviewing
completed test results were documented in the SALP 5 assessment.
Although these problems had only minimal safety significance,
. the fact that they were repetitive indicates the need for
t
management attention to ensure that corrections prevent
recurrence.
During this assessment period, nuclear group staffing
adjustments were proposed and implemented; the resulting
level of staff in the nuclear group appears to be adequate.
2. Conclusion
The licensee is rated Category 1 in this are.. The licensee
was rated a Category 1 in Refueling during the last SALP
period.
3. Board Recommendations
None
21
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_
- _ - - - _ . _
,
_ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
I. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
Examination of this functional area consisted of routine
inspections by the resident inspectors, and of one limited
scope inspection by a region based inspector. In addition,
an inspection of implementation of a program for preventing
overpressure transients was performed by a headquarters
inspector.
Two Severity Level IV violations were identified: (1) failure
to take adequate corrective actions following a loss of decay
heat removal event and (2) negative flux rate reactor trip
setpoints set incorrectly. This is a substantial improvement
from the previous assessment period when seven Severity Level
IV violations were identified.
An NRC headquarters inspection regarding overpressure
transients identified two incorrect assumptions in the
licensee's original calculations, however, the licensee
provided corrected data which demonstrated an adequate
design. The approach to resolution of technical issues
from a safety standpoint and responsiveness to NRC
initiatives was found satisfactory. The attitude and
system knowledge of the people encountered during the
inspection were excellent.
Sixteen out of 27 LERs which applied to this functional area
involved deficient procedures (14), lack of a procedure (1),
or drawings not showing sufficient detail (1). The licensee
has contracted for total rewriting of operating department
procedures (pts and GOPs) and has also contracted for
assistance in writing maintenance department procedures.
These actions should reduce the number of events due to
deficient procedures.
The station goals program is well developed, and effectively
run. General goals are formulated by management, and specific
goals are developed by working groups. Quarterly goals reviews
are conducted. Approximately 161 out of 215 goals were
achieved during the assessment period. Safety and regulatory
goals are included in the program.
l
'
At the beginning of the assessment period, Zion had been in a
Regulatory Perfcrmance Improvement Program (RPIP). Because
of improved performance, regular RPIP meetings with Region III
management were terminated on February 20, 1986.
Corrective action system documents, such as LERs and Deviation
Reports (DVRs), have improved during the assessment period.
In the past, root cause evaluations had occasionally lacked
detail, or had missed one or more contributors to events. ,
In addition, corrective act!ons to prevent recurrence were
22
____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
sometimes minimal or not addressed for one or more event
contributors. These concerns were expressed to licensee
management in October 1985. As part of an action plan to
improve LER/DVR quality, administrative procedures for LERs
and DVRs were revised and training was conducted for LER/DVR
writers and reviewers. LER/DVR quality has improved
substantially during the assessment period.
The site quality assurance (QA) department was well staffed by
qualified engineers and auditors. The group is effectively
managed, and has implemented several new audit methods. For
example, the group conducted a safety system functional
inspection of safety related portions of the CVCS system.
The inspection involved four auditors and was effective,
resulting in five findings and three observations. The site
QA group was also trained on aspects of fire protection which
they had not previously audited (fire barriers) and made several
findings of non-functional fire barriers (see section IV.E).
Management involvement in site quality assurrance has been
good. The licensee periodically reviewed the overall
effectiveness of the quality assurance program and assured
that personnel received timely training about changes made
to commitments in Technical Specifications, the QA Topical
Report, and the corporate QA manual. Response to NRC
-
identified issues in the area of Technical Specification
calibration testing was timely and thorough.
Management and corporate involvement needed improvement in
the area of Technical Specifications (TS) review and
implementation:
a. The negative flux rate reactor trip (NFRT) setpoints
were found to have been set nonconservatively for
several years,
b. Figure 3.2-9, the normalized Fq (Z) operating envelope
(K(2) curve) was found to be incorrect.
c. Changes to TSs were not properly translated into
procedures, which led to radiation monitor surveillances
being missed.
1
Items a and b involved old errors which the licensee had an
opportunity to detect and failed to do so, and c involved
inadequate review and implementation of a new TS. In the
past, changes to reactor containment fan coolers (RCFCs),
which made previously required surveillances both unnecessary
and impossible to perform were done without prior NRC approval.
10 CFR 50.59 states that prior NRC approval must be obtained
for plant changes which involve changes to the TS. In other
cases, TSs are difficult to interpret.
23
_ _ _ _ _ _ _ _ _ _ _. , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _
_ _ _ _ _ _ _ _ _ _ _
.
.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rated of Category 2 in the last assessment period.
3. Board Recommendations
None
J. Licensing Activities
1. Analysis
During this assessment period, licensee management actively
participated in resolution of the various licensing issues
and kept abreast of current and anticipated licensing actions.
The submittal of only one request for emergency action during
the assessment period demonstrates foresight and advance
management attention to important safety issues.
The Regulatory Performance Improvement Program (RPIP)
additionally shows licensee management's dedication to
assuring safety. From the licensing perspective, this has
resulted in increasing pride in individual workmanship, and
increasing the desire for professional excellence.
Management involvement was particularly evident in closure of
several multiplant actions and attention given to important
issues. Licensee mid-management personnel frequently visited
the NRR Project Manager to inquire whether NRC licensing needs
were being met, both in substance and schedules.
The licensee maintained close control over licensing action
schedules and either met the originally established dates or
obtained timely acceptance of revisions.
The licensee demonstrated a thorough understanding and
appreciation of the technical issues involved and consistently
exhibited conservatism in analyses and proposed resolutions.
Rarely was there a need for requests for additional informa-
tion, and when such were sent, the response was timely and
technically sound. The licensee maintains a significant
technical capability in all the engineering and scientific
disciplines necessary to resolve items of concern to the NRC
and the licensee. In addition the licensee utilizes the
services of other nuclear support groups to assist in the
resolution of technical problems or to implement new and
proven techniques that will enhance the operation and safety
of the plant.
The completed multiplant actions listed in Section V.H.6
demonstrate the licensee's sound technical resolution of
24
_ _ _ _ _ _ _ __ _ _ __ ___
.
.
complex prom ems involving plant safety and plant operation,
with appropriate attention given to regulatory concerns.
The licensee was responsive to NRC initiatives in almost all
instances. Routinely, technically sound and workable
resolutions were proposed. Priority safety reviews and
responses were given prompt attention. The responses have
been thorough and sufficiently detailed to permit complete
review with little need for further interaction with the
licensee.
The licensee maintains open and effective communications
between NRC and its own licensing staffs. Almost daily
telephone contacts resulted in close cooperation between
licensee and NRR licensing personnel.
The licensee consistently has sent advance copies of submittals
by the overnight express service and, when urgent matters were
involved telecopied them to the Division of Licensing the same
day. Periodically, the Zion Licensing Administrator reported
on the progress of the various commitments to NRC.
To ensure even greater responsiveness to NRC initiatives, the
licensee has a dedicated, full-time coordinator to respond to
and track requirements from Generic Letters.
The licensee has been particularly responsive to NRC's requests
to assist or participate in special studies and surveys,
including visits to the station by NRC staff and contractors.
On such occasions, the licensee consistently made available
their most knowledgeable individuals to assist NRC visitors.
The corporate Zion licensing and engineering staffing is
ample and any vacancies were promptly filled with qualified
individuals. This resulted in no backlog of overdue licensing
actions and in prompt, timely processing of current actions.
The licensee maintains a competent licensing and engineering
staff to ensure technically sound and timely responses to NRC
requests. In addition to the engineering staff at the Zion
station, licensee maintains a Station Nuclear Engineering
Department in its corporate offices where a group of more
than ten engineers, dedicated exclusively to Zion, provides
engineering support to licensing activities and the station.
The corporate engineering support staff is expanding by the
addition of another department of Nuclear Fuel Services,
which is currently preparing to assume the responsibility
for performing the reload safety analysis for Zion Station.
The licensing staff consists of highly trained, qualified and
experienced individuals. For example, both the Zion Licensing
1
25
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, _ . . . . . _ . . . . .
i
.
.
! Administrator and the head of the Station Nuclear Engineerir.)
Department maintain current Senior Reactor Operator licenses.
Both individuals have spent several years at the Zion station
holding various responsible positions. The Licensing
Administrator, before his current assignment, headed the
training department at Zion station. In addition to
appointing highly trained individuals to the licensing
division, the licensee assures their continuing qualification
by providing additional training.
2. Conclusion
The licensee is rated Category 1 in this area. The licensee
received a rating of Category 1 in the last assessment period.
3. Board Recommendations
None
K. Training and Qualification Effectiveness
1. Analysis
Resident and regional inspectors have evaluated training and
qualification effectiveness during inspection of specific
program areas. In addition, an inspection was conducted to
evaluate the effectiveness of the licensee's licensed and
non-licensed personnel training programs. No violations were
identified.
During inspections of licensee activities, personnel were
found knowledgeable and effective in implementing their
duties. Training appeared to be well planned and adequately
presented. In cases where abnormal incidents had occurred
at the plant, the licensee prepared a Deviation Report (DR)
which was subsequently used to evaluate whether personnel
error contributed to the event. In cases where it did,
the licensee also evaluated the cause of the personnel error
including an assessment of whether the training program had
been effective or could have contributed to the cause of the
event. Of seven reactor trips in this assessment period,
three were related to personnel errors and possible training
deficiencies. In all cases, completed DRs were forwarded to
the Training Department for independent evaluation to determine
if the formal training program could be improved to prevent
recurrence of the incident. l
The licensee's formal training program for operations personnel
had been accredited by INP0. Instructors were required to
participate in the Company's Supervisor on Shif t (SOS) program.
There was a good feedback path between operations and training.
Operators were aware of the opportunities to provide suggestions
26
_______-_______ ______
.
.
for future modifications to the training programs. The
training department activities were guided by procedures that
implemented a well defined licensed operator program.
Inadequate training could only rarely be traced as a probable
cause of events occurring during this rating period.
The licensee's training program provided a means of
disseminating information related to operating deficiencies
and events to licensed operators. The Training Department
issued and controlled the required reading program and
incorporated lessons learned from past events into the
classroom training topics.
Required reading was distributed to all Zion licensed
individuals, non-licensed operators, radwaste foremen,
training staff, NRC operator license candidates, and
maintenance training coordinators.
Early in the assessment period, the NRC administered
replacement examinations to seven senior reactor operator
(SRO) candidates. Four passed and three failed. The three
who failed did so because they each failed the simulator
examination. These simulator failures could, in part be
attributed to the plant training department's unfamiliarity
with the new symptomatic emergency procedures which had
recently been introduced at Zion. Because these new emergency
procedures addressed more complex emergencies than the old
emergency procedures, the simulator scenarios used in the
examinations were required to be more complex as well. The
training department trained their candidates to handle
simulator scenarios which were adequate for the old emergency
procedures. The training department acknowledged that the
candidates should have been trained more thoroughly in complex
scenarios which the new emergency procedures are designed to
address.
The number of replacement examinations administered in the
period was too small to make any meaningful comparison with
the national pass rate average. It can be stated that all
candidates did pass an examination within the assessment
period.
Additionally, the NRC administered a requalification
examination to eight SR0's and four reactor operators (RO's)
in October 1986. Of the eight SRO's tested, seven passed
as well as the four R0's tested, resulting in a pass rate of
91.7%, which is above the national average.
The problem noted earlier concerning the inability of many
operators to properly use the new emergency procedures to
handle complex simulator scenarios was not evident during the
requalification exam, which indicates that this problem has
been properly corrected.
27
.
e
The facility has been cooperative with the NRC throughout the
assessment period, except for the licensee's initial reluctance
to supply' the Standing Orders to be used as exam reference
material.
For the maintenance groups, the training program was well
defined and implemented with dedicated resources. Inadequate
training could only rarely be traced as part of the cause of
events occurring during this rating period. The maintenance
on-the-job training (0JT) program was directed toward the
application of previously taught knowledge and skills to
maintain plant equipment. The Maintenance Training Program
will be used to ensure that mechanics who have not received
training or have not previously worked on a system will not
be assigned to jobs on that system unless they are accompanied
by a foreman or mechanic with training on the system. There
was a good feedback path from maintenance to the training
department, with pertinent items being factored into the
training program. Maintenance personnel were aware of their
opportunities to input suggestions for revisions to the
training program. The Training Coordinators understood their
training procedures and were implementing a well defined
maintenance training program.
The licensee has begun a two-week radiation / chemistry
technician annual requalification training program involving
the use of new instrumer,ts as well as discussion on health
physics topics. In addition, the chemistry staff has received
a pilot training program on water chemistry control, in
response to a corporate directive on this subject, to alert
personnel of the significance of maintaining good water
chemistry for long-term plant reliability.
Seven training programs (Shift Technical Advisor, Instrument
Maintenance, Electrical Maintenance, Mechanical Maintenance,
Radiation Protection, Chemistry, and Technical) have been
submitted to INPO for accreditation. Full accreditation is
expected by the Fall of 1987.
In cases where the NRC recommended improvements to the training
program, the licensee was very responsive in addressing the NRC
concerns.
2. Conclusion
The licensee is rated Category 1 in this area. This area was
not rated in the last assessment oeriod, because this is a new
functional area.
3. Board Recommendations
. None
28
l
- - _ _ - . _ . - - . . - - - - . _ _ _ _ _ - _ - _ - - ._ _. . - ___
.
.
o
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
1. Unit 1
Zion Unit 1, began the assessment period in routine power
operation and ended the assessment period in a refueling
outage. This refueling outage is expected to last until
March 3, 1987 (SALP 7). During this assessment period,
Unit 1 experienced two outages.
Unit 1 outages are summarized below:
a. March 10-17, 1986: After receiving a full power reactor
trip, due to a reactor trip breaker not being properly
racked into place, Unit I remained shutdown to repair a
bowed shaft on a RHR pump,
b. September 4, 1986: Unit 1 began it's 17 week, routine
refueling and maintenance outage.
2. Unit 2
During this assessment period, Unit 2 began the assessment
period in an extended refueling outage; this refueling outage
lasted until February 4,1986. Unit 2 experienced seven
outages.
Unit 2 outages are summarized below:
a. December 6, 1985 thru February 4, 1986: Shutdown for
refueling, routine maintenance and 10 year in-service
inspections.
b. February 28 thru March 2, 1986: Unit 2 was taken off
line to perform over-speed trip vibration tests on the
newly installed Brown-Boveri low pressure steam turbine.
c. March 24 thru 25, 1986: After receiving a trip from
full power during reactor protection system testing,
Unit 2 remained shutdown to investigate electrical noise
and radio frequency problems in the nuclear instrumenta-
tion drawers,
d. June 27 thru July 14, 1986: Unit 2 remained shutdown
due to failure of primary system instruments after a
lightning strike caused a reactor trip on high Over-
Temperature Delta-T. Five reactor coolant system
resistance temperature detectors were replaced, one
accumulator transmitter was recalibrated, and maintenance
was performed on an essential service water pump.
29
Mc
'
s, ' ' \
t e
,
, ,
I %,yg -t , s
7 .
'
- t A i ; s. ._
e
f
'
e, '1986: Unit 2 was shutdo*, from mode 2 (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> -
yJuly
LCO act 5,'f an staAament) to repair esstotial service water
a
pumon %ich we're out of servicel ei t
, sc ,
, q f. September 20-22, 1986: Unit 2 was shutdown to repair , .
.
the turbine electro-b3draulic control system. N
N ( " '
..
T B. Inspection Aci.iv'1 ties
p. , (- 'Q,y v. -
There were 33) inspections concucted at Unit 1 and 33 inspections '
o
conducted at'# nit 2 during this, assessment period for October 1,
1985 througti Xavember 30,1986.*? ,
'
'
1. Inspe::tf on Data
Facility Name: Zion '
'3
Unit: 'l ,
Docet No . : 50-295 *
e, i
" Ins'p'edtion Reports No. : 85001, 85032, 85036, 85038 through
'
85043, 86001 through 86019, 86021 t t. cough
j~86024, 86027 and 86029.86005,l86007/through
'
t ', . >
's t,,
'
Facility Name: Zion ,
Unit: 2 c'y
Docket No.: 50-304 -
3
s ',
, Inspection Reports No.: 85001, 85033, 85035, 85038 through , e
85044, 86001 through 86005, 86007 through 26019, 86020, ;, -
86022 through 86024, 86027,'and 86029. j
'
'
Table'1
'
, \. [s
'
e
,
, ; ,s
Number of Violations in Each Severity Level
'
. .. 1- Commontd
i Unit 1 , Unit 2 Both Units
Functional Areas o I II III IV V I II III IV V I II III IV V
r
A. Plant Operations 3 1 1
B. Radiological Controls 1 %
C. Maintenance 2
D. Surveillance . 2
E. Fire Protection 1
G. Security 1'
H. Outages 11
1. Quality Programs and
Adminis. Controls
Affecting Quality 2
J. Licensing Activities '
,
,
K. Training & Qualification
Effectiveness
t.
TOTAL I II III IV V
0 0 0 30
I II III IV V
0 0 0 31 I II III N
0 0 \0 90
t V'
30
s
s
_ _ _ _ _ _ _ _ - - _
-_- - _ - _ _ - _ _ - _ _ _ - _ _ _ -
'
,
4 - , .s <
., 3
l l 2. Special Inspection Summary
. s
4 None
i
C. Investigations and Allegations Review
'> Allegation Review
Seven allegations relating to Zion consisting of eleven concerns
were received in Region III during this assessment period. Four
allegations were of a nature that they were closed following
regional review. Two others dealt with safeguards issues and one
, No safety significance issues
y, l } pertained
or violationsto administrative
were identifiedissues.
from the NRC review of these
,'
/
'
,
'
g allegations.
c 1
-
D. {scalatedEnforcementActions
No civil penalties were issued during this assessment period.
Y During this assessment period one Severity Level III violation,
,
regarding the inoperable IB auxiliary feed water pump, was
initially proposed with a $25,000 civil penalty. However, after
the NRC reevaluated the licensee's response, the severity level
yas reduced to Severity Level IV based on the over 100% of
required capacity remaining even with the one pump inoperable.
E. Licensee Conferences Held During Assessment Period
1. January 10, 1986, (Regional Office) - Management meeting to
discuss the findings of Zion's SALP 5.
'
2. March 14, 1986 (Regional Office) - Enforcement Conference was
held to discuss information regarding the IB auxiliary feed
water pump which were inoperable due to having service water
to the bearing oil cooler valved out.
3. April 9, 1986, (SITE) - A tour and management meeting with
representatives from Zion plant management to discuss
operational safety.
4. April 29, 1987, - Management meeting regarding the history
behind improperly set negative flux rate reactor trip (NFRT)
setpoints, and to discuss corrective actions taken in response
to the December 14, 1985, loss of residual heat removal event
which occurred when Unit 2 was in cold shutdown.
(
5. May 21,1986, (Site) - Management meeting to tour the facility
and meet with station management.
F. Confirmation of Action Letters
October 27, 1986, A Confirmatory Action Letter was issued following
the October 24, 1986, failure of the IB diesel generator during
post-maintenance testing.
31
'
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _
~
,y,q '
'
,
, (
/- ,tt e
' . ,
G. A Review of Licensee Event Reports and 10 CFR 21 Reports Submf tted
by-the Licensee
1. Licensee Event Reports (LERs)
1
'
Unit 1
,. Docket No.: 50-295
4 LERs Nos.: 85040, 85042 thru 85047, and 86001 thru 86040.
i Unit 2
l Docket No.: 50-304
l LERs Nos.: 85026 th;*u 85029 and 86001 thru 86022.
Seventy-three LERs were issued during this assessment period;
30 LERs were the result of personnel errors; 22 LERs resulted
from procedure inadequacies; 7 LERs were due to component /
equipment failures; 4 LERs were related to design problems;
and 10 LERs fell into the other categories (i.e., unknown
human errors, external causes, and other).
1
CAUSE Unit 1 Unit 2
Personnel Errors '
18 12
Procedure Inadequacies 15 7
, Design / Construction 2 2
External Causes 0 1
Component / Equipment 6 1
Other 5 2
Unknown Human Errors 1 1
NOTE: The above information was derived from reviews of
Licensee Event Reports performed by NRC Staff and
may not completely coincide with the unit or cause
assignments which the licensee would make. In
addition, this table is based on assigning one cause
code for each LER and does not necessarily correspond
to the identification of LERs addressed in the
Performance Analysis Section (Section IV) where
multiple cause codes may be assigned to each LER.
The frequency of occurrence of LERs was unchanged since the
previous SALP. During SALP 5 95 LERs were identified over a
17 month assessment period or an average of 5.3 per month
compared to an average of 5.2 LERs per month during this
assessment period. The percentage of LERs which were caused
by personnel error increased during this assessment period
from 32.7% to 41.1%. Although this percentage is not
considered excessively high, the number of LERs issued is
high and improvements in both statistic is warranted.
32
- - - - - - - - - - - - - )
o
~
o
l 2. Analysis and Evaluation of Operational Data (AE00)
'
The results of the AE00 evaluation of Zion Licensee Event
Reports for this assessment period indicated an improvement
in both content and quality. AEOD assessed an average score
of 8.8 out of a possible 10 points; compared to Zion's
previous overall average score of 6.8 and the current reactor
industry average of 8.1. AE00 indicated that information
concerning the identification of failed components needs to
improve. However, strong points of the Zion LERs are that
information concerning mode, mechanisms, and effect of a
failed components is well written.
2. 10 CFR 21 Reports
(a) Inspection Report 304/85018 documented limitorque wires
for which there was inadequate environmental qualification
documentation.
(b) Inspection Report 304/86017 documented leaking Anderson-
Greenwood 5-valve manifolds.
H. Licensing Activities
1. NRR Site Visits / Meetings / Licensee Management Conferences
Inadequate Core Cooling January 21, 1986
Core Reload Methodology January 31, 1986
Appendix R, Fire Protection September 30, 1986
Pressurized Thermal Shock October 3, 1986
Site Visit May 12-16, 1986
2. Commission Meetings
None
3. Schedule Extensions Granted
None
4. Reliefs Granted
ASME Code, Rev. 5 to ISI Program March 27, 1986
5. Exemptions Granted
None I
6. Licensee Amendments Issued
Amendment
Number Title Date
33
__ _
c>
%
4
91/81 Items A.1 and A.2 of 1980
Confirmatory Order December 31, 1985
92/82 Capsule withdrawal schedule January 16, 1986
93/83- Mechanical and hydraulic snubbers January 22, 1986
94/84 Enrichment limits for new and
spent fuel pools February 19, 1986
95/85 Negative rate trip setpoints March 10, 1986
96/86 Radiological Environmental
Technical Specifications March 24, 1986
97/87- Degraded grid voltage protection
system March 27, 1986
98/88 S.G. tube sleeving methodology November 18, 1986
7. Emergency Technical Specifications Issued
Amendments 95 and 85 - Negative rate trip setpoints - issued
March 10, 1986,
8. Orders Issued
None
9. NRR/ Licensee Management Conference
None
.
34