ML20207H346

Forwards NRR Draft Input to SALP Review for Period Oct 1985 - Nov 1986,for Review & Comments.Comments Received by 870108 Will Be Considered in Final Rept

ML20207H346
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/05/1987
From:	Norris J Office of Nuclear Reactor Regulation
To:	Bernero R, Miraglia F, Novak T Office of Nuclear Reactor Regulation
References
NUDOCS 8701070511
Download: ML20207H346 (10)

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January 5, 1987 3 .

Docket Nos. 50-?95 DISTRIBUTION and 50-304 Docket File PD#3 RDg.

C. Vogan MEMORANDUM FOR: Thomas M. Novak, Director J. Norris Division of PWR Licensing-A S. Varga l Frank J. Miraglia, Director Division of PWR Licensing-B b hk Pobert Bernero, Director Division of BWR Licensing William T. Russell, Director Division of Human Factors Technology Themis Speis, Director Division of Safety Review and Oversight THPU: Steven A. Varga, Director Project Directorate #3 Division of PWR Licensing-A FROM: Jan A. Norris, Project Manager Project Directorate #3 Division of PWR Licensing-A

SUBJECT:

DRAFT OF THE NRR INPUT FOR THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) FOR COMMONWEALTH EDIS0N j COMPANY, ZION NUCLEAR POWER STATION, UNITS 1 AND 2 -

1 OCTORER 1, 1985 TO NOVEMBER 30, 1986 Enclosed is a draft of the NRR input to the SALP review for the Zion Puclear Power Station Units 1 and 2. This draft report is based partly upon input solicited from selected staff personnel who have had substantial contact and involvement with Zion licensing material. Please review the draft evaluation and provide any comments you feel appropriate. All comments received by January 8, 1987 will be considered in the final report. Your comments may be provided verbally due to the short turnaround time.

The Senior Executive Service member is Steve Varga.

h Oh$d jgjos Jan A. Norris, Project Manager pg5 Project Directorate #3 Division of PWR Licensing-A

Enclosure:

As stated cc: H. Denton Pdf3 * ^

PD#3 m CVogand IJNprr .:mak SV a 1/5 /87 \1/ Q 87

cf jg UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION g E WASHINGTON, D. C. 20555

\...../

Docket Nos. 50-295 and 50-304 FACILITY: Zion huclear Power Station, Units 1 and 2 LICENSEE: Commonwealth Edison Company EVALUATION PERIOD: October 1, 1985 to November 30, 1986 PROJECT MANAGER: Jan A. Norris I. INTRODUCTION This report contains NRP's input to the SALP review for the Zion Nuclear Power Station, Units 1 and 2. The assessment of the licensee's performance was ,,

conducted according to NRR Office letter No. 44, "NRR Inputs to SALP Process,"

dated January 3, 1984. This Office letter incorporates NRC Manual Chapter 0516,

" Systematic Assessment of Licensee Performance."

II.

SUMMARY

NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 31 based on a composite of a number of attributes. The single final rating should be tempered with

.iudgment as to the significance of the individual elements.

Based on this approach, the performance of Comonwealth Edison Company in the functional area - Licensing Activities - is rated Category 1.

III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.

IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Proiect Manaaer (ORPM) and those technical reviewers who expended significant amounts of effort on the Zion Nuclear Power Station, Units 1 and 2 licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2 or 3) to each attribute.

The reviewers included this information as part of each Safety Evaluation input transmitted to the Division of Licensing. The ORPM, after reviewing the SALP inputs of the technical reviewers, combined this information with his own

. assessment of licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee. This rating also reflected the comments, if any, of the NPP Senior Executive assigned to the Zion Nuclear Power Station SALP assessment. A written evaluation was then prepared by the ORPM and circulated to NRR management for comments which, if provided, were incorporated in the final draft.

The basis of this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the rating period. These actions, consistino of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, include the following specific items:

Multiplant Action Items (MPAs)

Completed or having a significant level of review action completed include:

Technical Specifications covered by Generic Letter 83-36 and 83-37 for NUPEG-0737, MPA B-83 Pressurized Thermal Shock - Phase I, MPA A-?1 Diesel Generator Reliability Technical Specifications, Generic Letter 84-15, MPA D-19 litility Responses to Staff Recommendations Concerning Steam Generators, Generic Letter 85-02, MPA C-16 Inadequate Core Cooling Instrumentation, MPA F-26 Masonry Valls, MPA B-59 NUPEG-0737 Item I.A.1.1, Shift Technical Adviser Plant Specific Action Items Completed or have a significant level of review include:

Amendment, Items Al and A2 of the February 29, 1980 Confirmatorv Order Amendment, Materials irradiation specimen schedules Amendment, Mechanical Snubbers Amendment, Hydraulic Snubbers Topical Report, Revised licensed operators requalification Inservice Inspection and Inservice Testing Propram, Second 10 Year Interval Amendment, Enrichment limits on new and spent fuel storage

O Amendment, NIS Flux rate setpoints Amendment, Radiological Effluents Technical Specifications Amendment, Degraded grid voltage protection system Revision 5 to the first 10 Year Inservice Inspection Program Amendment, Steam Generator Sleeving Methodology V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of nine attributes. These are:

- Management Involvement and Control in Assuring Quality

- Approach to Resolution of Technical Issues from a Safety Standpoint

- Responsiveness to NRC Initiatives

- Enforcement History

- Reporting and Analysis of Reportable Events

- Staffing (including Management)

- Trainina and Qualification Effectiveness

- Housekeeping

- Control Room Atmosphere Manaaement Involvement and Control in Assuring Quality Overall rating for this attribute is Category 1.

During the present rating period, Comorwealth Edison Company manaaement actively participated in licensing resolution of the various licensing issues and kept abreast of current and anticipated licensing actions. Only one request for emergency action during the rating pariod vividly demonstrates foresight and advance management attention to important safety issues.

Voluntary maintenance of a strong Regulatory Performance Improvement Program (RPIP) additionally shows Comonwealth management's appreciates and dedication to vigilance over quality necessary to assure safety. That program requires frequent site visits by corporate managers. The Regulatory Performance Improvement Program has been instrumental in maintaining high morale of station employees, increasing pride in individual workmanship, and increasino the desire for professional excellence, all of which are elements of paramount importance to ensure quality necessary for safe operation of the plants.

Management involvement was particularly evident in closure of several nultiplant actions and attention given to important issues. CECO mid-management personnel frequently visited 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.

Approach to Resolution of Technical Issues from a Safety Standpoint Overall rating for this attribute is Category 1.

Within the rating period, the licensee demonstrated thorough understanding and appreciated of the technical issues involved. CECO consistently exhibited conservatism in analyses and proposed resolutions. Rarely has there been a need for requests for additional information, and when such were sent, the response was timely and technically sound. The licensee maintains a significant technical capability in all 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 utilize new and proven techniques that will enhance the operation and safety of the Plant.

The completed multiplant actions listed in Section IV. demonstrate the licensee's sound technical resolution of complex problems involving plant safety and plant operation, with appropriate attention given to regulatory Concerns.

Responsiveness to NRC Initiatives Overall rating for this attribute is Category 1.

CECO has been responsive to NRC initiatives in almost all instances.

Routinely, technically sound and workable resolutions are proposed. Priority safety reviews and responses are give prompt attention. The responses have been thorough and sufficiently detailed to permit complete review with little need for further interaction with the licensee.

CECO maintains open and effective communications between NRC and its own licensing staffs. Almost daily telephone contacts resulted in close cooperation between CECO 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, Zion Licensing Administrator has 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.

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The licensee has been particularly responsive to NPC's requests to assist or participate in special studies and surveys, including visits to the station by NRC staff and contractors. On such occasions, CECO consistently made available their most knowledgeable individuals to assist NRC visitors.

Enforcement History Overall rating for this attribute is Category 2.

The Project Manager had the opportunity to participate in exit meeting for one inspection and audit at the site during the rating period. The licensee was responsive to concerns voiced by the staff and has taken actions to resolve deficiencies, deviations and open items in a satisfactory manner. The licensee's contact with the resident, regional, and headouarters inspectors appeared open, frank and professional.

Reporting and Analysis of Reportable Events Overall rating for this attribute is Category 2.

During the reporting period each unit had one refueling outage. The followina are reporting statistics for Units 1 and 2.

Description Unit 1 Unit 2 Licensee Event Reports 45 27 Availability Factor (%) 77.8 67.4 Capacity Factor - DEP (%) 68.1 63.8 Forced Outage Rate (%) 7.5 8.1 Net Electrical Gen. Factor (%) 77.8 67.4 Refueling Outage Factor (%) 15.9 26.1

. Scheduled Maint./ Repair Factor (%) 0.0 0.5 Forced Maint./ Repair Factor (%) 6.3 6.0 Trips 3 4 With regard to the 72 Licensee Event Reports, 14 were not dated within the time requirements of 10 CFR 50.73; 10 were late by only one day. The LER analyses were carefully done and thorough. During the SALP period, 3 events were significant enough to be brought to the attention of OR briefings. One had to do with two simultaneously inoperable emergency diesel generators, another with degraded voltage relays actuating a diesel start and ESF bus load shed, and the third with degradation of a main steam line check valve.

For the most part, both the Immediate Notifications and the Licensee Event Reports suggest that the Licensee took appropriate action with regard to the reported events. It should be noted, however, that between November 11, 1985 and March 10, 1986 the instrument and/or penetration pressurization air compressor systems failed to function properly on 10 occasions.

The large number of late reports lead us to conclude that the Licensee's licensing activities need more management attention.

e During the reporting period, Units 1 and 2 experienced 3 and 4 trips respectively. The 1985 industry-wide average is 6.0 per year. The average for Westinghouse plants is 6.8 per year. With regard to the Unit Availability Factor, the Unit Capacity Factor - DER, and the Forced Outage Rate, industry averages for 1985 are 68.5%, 61.7%, and 11.3%, respectively. All four indicators suggest that Zion performed better than the industry average; the Zion trip rates were particularly low.

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Comparino time spent on forced maintenance / repairs and that spent on scheduled maintenance / repair, there is very little scheduled maintenance compared to forced maintenance. This suggests that the Licensee spends much less time >

with preventative maintenance that with forced repair. However, this has not resulted in a high trip rate.

Staffing Overall rating for this attribute is Category 1.

Zion licensing and engineering staffing is ample and any vacancies are promptly filled with qualified individuals. This has resulted in no backlog of overdue licensing actions and in prompt, timely processing of current actions.

Ceco maintains a most competent licensing and engineering staff to ensure technically sound and timely responses to NRC requests. For example, in addition to the engineering staff at the Zion station, CECO maintains 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 excellent staffinq level of the licensee is further demonstrated by another department of Nuclear Fuel Services, which is currently preparing to assume the responsibility for performing the reload safety analysis for Zion Station.

Traininc and Oualification Effectiveness Overall rating for this attribute is Category 1.

CECO licensing staff consists of highly trained, qualified and experienced individuals. This is demonstrated, for example, by both the Zion Licensing Administrator and the head of the Station Nuclear Engineering Department who 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 in the first place CECO assures their continuing qualification by providing additional training.

CECO has access to and routinely uses the Westinghouse simulator that is located next to Zion station. CECO also maintains an extensive active training prooram in a separate, specially constructed training facility. The annual training budoet at Zion averages $5.5 million. The Zion training program is well defined and implemented. All Zion station staff participates yearly in some form of training.

s s A uniaue feature of the training facility is a specially constructed " smoke house," including a maze where members of the fire brigade, using breathing apparatus, receive training under simulated smoke conditions.

Housekeeping Overall rating for this attribute is Cateoory 2.

During several walk-through visits to various parts of the Zion station, acceptable claanliness and housekeeping practices were observed. The disorder associated with work in progress was consistently contained within clearly marked perimeters and construction trash was placed in appropriate containers.

Fresh paint was evident in various areas, indicating continuing maintenance efforts.

No hazardous condition was observed during the visit and no uncontrolled flammable materials were found.

Control Room Atmosphere s Overall rating for this attribute is Category 2.

During several walk-through visits to the Control Room, an atmosphere of quiet alterness prevailed. No disruptive activity or behavior was observed, nor was evidence of such activities present. The unit operators and their supervisors went about their duties with confidence.

At the times of visits, no unusual events took place at Zion and no annunciators were triggered. Consequently, only routine activities were observed.

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VI. CONCLUSIONS An overall performance rating of Category 1 has been assigned in the licensing area.

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INFORMATION TO BE ADDED TO SECITON V 0F THE SALP REPORT i

" SUPPORTING DATA AND

SUMMARY

1. NRR/ Licensee Meetings Inadequate Core Cooling 1/21/86 Core Reload Methodology 1/31/86 Appendix R, Fire Protection 9/30/86 Pressurized Thermal Shock 10/3/86

2. NRR Site Visits / Meetings Site Visit 05/12-16/86

3. Commission Meetings None 4 Extensions Granted None

5. Reliefs Granted ASME Code, Rev. 5 to ISI Program 03/27/86

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6. Exemption Granted None

7. License Amendments Issued Amendment Number Title Date 91/81 Items A.1 and A.2 of 1980 12/31/85 Confirmatory Order 92/82 Capsule withdrawal schedule 01/16/86 93/83 Mechanical and hydraulic sr.ubbers 01/22/86 94/84 Enrichment limits for new and spent 02/19/86 fuel pools

5 Amendment Number Title Date 95/85 Neoative rate trip setpoints 03/10/86 96/86 RETS 03/24/86 97/87 Deoraded grid voltage protection 03/27/86 system 98/88 S.G. tube sleeving methodology 11/18/86

8. Emergency Technical Specifications Issued Amendments 95 and 85 - Negative rate trip setpoints - issued 3/10/86

9. Orders Issued None

10. NRP/ Licensee Manacement Conference None 9

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