IR 05000295/1987001

SALP Board Insp Repts 50-295/87-01 & 50-304/87-01 for Oct 1985 - Nov 1986.Category 1 Rating Given in New Functional Areas of Outages & Training & Qualification Effectiveness & Security & Licensing Activities

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: ML20204F027 ML20204F131
References
50-295-87-01, 50-295-87-1, 50-304-87-01, 50-304-87-1, NUDOCS 8703260140
Download: ML20204F131 (36)

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ds 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 N 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 32h0CgOShoh95 ppg G

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'b 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 license '

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, Ratfag Rating Thisp Functional' Area i SALP :5 / Period

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Trend

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' Plant Operations '

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Radiological Controls 2 2

, Maint.enance "

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' Fi S Protection 2

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. Emergency Preparedness

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, Security 1 1 1

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ay , Quality Programs and Administrative Controls {

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O,Affecting Quality 2 2 (

p 3' /, Licensing Activities /

1 1 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 activitie y e i'

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IV. PERFORMANCE ANALYSIS Plant Operations Analysis During the assessment period, nine inspections were performed by the resident inspectors in this functional are 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 event 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 T 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 50.7 , 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 maintenanc During the 17 month SALP 5 assessment period, there were six violations of NRC requirements consisting of eight example 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 equa 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 T +

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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 strik Reactor trips occurred at essentially the same rate as SALP 5, with similar rates for root cause of personnel error and equipment failure There were also two trip signals at 0%

power, one for Unit I and one for Unit 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 compressor 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 perio 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 error 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 perio 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 problem 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 lightnin 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 valv 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 pum Several startups and shutdowns were observed by the resident inspectors. During these evolutions, procedural adherence, supervision, communications, and operator vigilance were very goo 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 excellen 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 roo 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 weaknes The operations department has initiated several actions to improve regulatory performance during the assessment perio 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 acces The licensee also initiated a procedure improvement progra 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 provide A color coding scheme for the plant is also planne _ ._,

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. Conclusion The licensee is rated Category 2 in this area. The licensee received a rating of Category 2 in the last assessment perio . Board Recommendations None B. Radiological Controls Analysis Six inspections were performed during this assessment period by region based inspectors. The resident inspectors also reviewed portions of this area during routine inspection One Severity Level IV violation was identified concerning failure to collect a reactor coolant sample for iodine analysis within the required time frame.

i 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 area 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 program 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 attentio 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-Decembe _ _ _ _ _ _ _ _ _ _ _

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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 instrumentatio Licensee responses to NRC initiatives have generally been adequat 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 perio 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 unit 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 requirement 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 perio 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 198 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 sample 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 laborator . Conclusion The licensee is rated Category 2 in this are The licensee received a rating of Category 2 in the last assessment perio _ - - .. -.

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. Board Recommendations None Maintenance

, 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 are 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 criteri 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 isolate 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 adherenc Revisions to all safety related IM pincedures, begun during the previous assessment period, were completed

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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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 procedure 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 ru 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 reques Maintenance personnel, including management, are well trained and adherence to procedures is generally goo 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 325 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 safet 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 valv Equipment availability for some non-safety related plant systems needs considerable improvemen 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 l

to the event A formal preventive maintenance program still does not exist;

! however, many preventive maintenance activities do take plac 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 i

of many plant components including safety valves, snubbers, ISI hangers, circuit breakers, and environmentally qualified (EQ) component Positive effects of these activities are exhibited by the few shutdowns / reactor trips due to equipment failure . Conclusion The licensee is rated Category 2 in this area. The licensee received a rating of Category 2 in the last assessment perio . Board Recommendations None

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D. Surveillance 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 Bulletin 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 i

were implemente Management of surveillances improved during the perio 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 test 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:

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Establishment of a master surveillance plan which would computerize routine surveillances (monthly or less frequent). This action is not yet complet 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 Specification 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 change Oversights during the review process resulted in missed

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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, 198 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 guideline 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 thoroug . Conclusion The licensee is rated Category 2 in this area. The licensee received a rating of Category 2 during the last SALP perio . Board Recommendations None E. Fire Protection Analysis Fire protection activities were observed during routine resident inspections, and during followup of liceasee event reports (LERS).

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inattentive fire watche 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 attentio 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

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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 watc 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 event Fire brigade training and the qualifications of fire brigade members were goo 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 The licensee's plan is currently under review by NR Housekeeping improved dramatically over the assessment perio 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 acces Leaks in the auxiliary building were generally controlled, although some chronic service water leaks still per.ts Painting in the turbine building was in progress by the end of the assessment perio 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 room 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 replace Housekeeping improvements have had a high management pricrity during the assessment period, and as indiceted by the station goals, this will continue into 198 . Conclusion The licensee is rated Category 2 in this area. The licensee received a rating of Category 2 in the last assessment perio _ _ _ - _ _ _ _ _ _ _ _

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. Board Recommendations None F. Emergency Preparedness Analysis Two inspections were conducted during the period. These included the observation of the unannounced, 1986 emergency preparedness exercise and a routine inspectio 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 activatio 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 inventorie 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 inspector In contrast, the coordinator j

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maintained adequately detailed records of emergency prepared-ness drills, including any corrective actions take 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 revie As evidenced by walkthroughs and player performances during the exercise, the licensee has maintained an adequate training program for members of the onsite emergency organizatio _ -- . _ _ _ _ _ _ _ _ .

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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 module 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 omission 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 drill 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 Statio . Conclusion The licensee is rated Category 2 in this area. The licensee received a rating of Category 2 in the last assessment perio . Board Recommendations None G. Security Analysis Three security inspections (two routine and one special) were conducted by regional inspectors during the assessment perio 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 perio The allegations involved personnel access control and security force performance issues and were determined to be unfounde 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

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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 progra 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-trato Considerable management effort was expended in researching, planning and designing an appropriate solutio The licensee's PA intrusion detection system continues to be one of the more effective systems within Region II 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 plannin 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 commitment Events reported in accordance with 10 CFR 73.71 were properly identified and analyzed and were reported in a timely manne 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 procedure 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 progra 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

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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 operator 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 procedure 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 progra . Conclusion The licensee is rated Category 1 in this area. The licensee received a rating of Category 1 in the last assessment perio . Board Recommendations None H. Outages 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 testin 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 sectio . ._ - ____-- -_ -___

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Another event involving modifications indicated the need to provide better drawing detail to installer Outage planning is coordinated by a central outage planning group under the direction of the Assistant Station Superintendent, Outage This individual is one of the most experiented personnel at the station, having been in the operating department since before initial criticalit Outage schedules are developed using a computer program, and schedules are updated weekl 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 activitie 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 wor These meetings have been very beneficial to the flow of information at the statio 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 shutdow 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 conservativ 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 198 Procedures for the outage planning group have not been developed because corporate guidelines have not been issue 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

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 availabl 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 activitie 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 schedul One inspection of core performance surveillance testing following startup from a refueling outage was performed b 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 assessmen 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 recurrenc During this assessment period, nuclear group staffing adjustments were proposed and implemented; the resulting level of staff in the nuclear group appears to be adequat . Conclusion The licensee is rated Category 1 in this are.. The licensee was rated a Category 1 in Refueling during the last SALP perio . Board Recommendations None

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_

- _ - - - _ . _

,

_ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

I. Quality Programs and Administrative Controls Affecting Quality 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 inspecto 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 identifie 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 excellen 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 procedure These actions should reduce the number of events due to deficient procedure 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

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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, 198 Corrective action system documents, such as LERs and Deviation Reports (DVRs), have improved during the assessment perio In the past, root cause evaluations had occasionally lacked detail, or had missed one or more contributors to event ,

In addition, corrective act!ons to prevent recurrence were

____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

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 perio 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 method For example, the group conducted a safety system functional inspection of safety related portions of the CVCS syste 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 manua Response to NRC

-

identified issues in the area of Technical Specification calibration testing was timely and thoroug Management and corporate involvement needed improvement in the area of Technical Specifications (TS) review and implementation: The negative flux rate reactor trip (NFRT) setpoints were found to have been set nonconservatively for several years, Figure 3.2-9, the normalized Fq (Z) operating envelope (K(2) curve) was found to be incorrec Changes to TSs were not properly translated into procedures, which led to radiation monitor surveillances being missed.

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 approva 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 interpre _ _ _ _ _ _ _ _ _ _ _. , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _

_ _ _ _ _ _ _ _ _ _ _

.

. Conclusion The licensee is rated Category 2 in this area. The licensee received a rated of Category 2 in the last assessment perio . Board Recommendations None Licensing Activities Analysis During this assessment period, licensee management actively participated in resolution of the various licensing issues and kept abreast of current and anticipated licensing action The submittal of only one request for emergency action during the assessment period demonstrates foresight and advance management attention to important safety issue The Regulatory Performance Improvement Program (RPIP)

additionally shows licensee management's dedication to assuring safet From the licensing perspective, this has resulted in increasing pride in individual workmanship, and increasing the desire for professional excellenc 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 schedule The licensee maintained close control over licensing action schedules and either met the originally established dates or obtained timely acceptance of revision The licensee demonstrated a thorough understanding and appreciation of the technical issues involved and consistently exhibited conservatism in analyses and proposed resolution 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 plan The completed multiplant actions listed in Section V. demonstrate the licensee's sound technical resolution of

_ _ _ _ _ _ _ __ _ _ __ ___

.

.

complex prom ems involving plant safety and plant operation, with appropriate attention given to regulatory concern 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 license 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 personne 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 NR To ensure even greater responsiveness to NRC initiatives, the licensee has a dedicated, full-time coordinator to respond to and track requirements from Generic Letter 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 contractor On such occasions, the licensee consistently made available their most knowledgeable individuals to assist NRC visitor 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 action The licensee maintains a competent licensing and engineering staff to ensure technically sound and timely responses to NRC request 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 statio 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 Statio The licensing staff consists of highly trained, qualified and experienced individual For example, both the Zion Licensing

25

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, _ . . . . . _ . . . . .

i

.

.

! Administrator and the head of the Station Nuclear Engineerir.)

Department maintain current Senior Reactor Operator license 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 trainin . Conclusion The licensee is rated Category 1 in this area. The licensee received a rating of Category 1 in the last assessment perio . Board Recommendations None K. Training and Qualification Effectiveness 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 program No violations were identifie During inspections of licensee activities, personnel were found knowledgeable and effective in implementing their duties. Training appeared to be well planned and adequately presente 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 inciden 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) progra There was a good feedback path between operations and trainin Operators were aware of the opportunities to provide suggestions

_______-_______ ______

.

.

for future modifications to the training programs. The training department activities were guided by procedures that implemented a well defined licensed operator progra Inadequate training could only rarely be traced as a probable cause of events occurring during this rating perio 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 topic Required reading was distributed to all Zion licensed individuals, non-licensed operators, radwaste foremen, training staff, NRC operator license candidates, and maintenance training coordinator 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 addres 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 perio Additionally, the NRC administered a requalification examination to eight SR0's and four reactor operators (RO's)

in October 198 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 averag 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 correcte .

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 materia 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 perio 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 progra 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 reliabilit Seven training programs (Shift Technical Advisor, Instrument Maintenance, Electrical Maintenance, Mechanical Maintenance, Radiation Protection, Chemistry, and Technical) have been submitted to INPO for accreditatio Full accreditation is expected by the Fall of 198 In cases where the NRC recommended improvements to the training program, the licensee was very responsive in addressing the NRC concern . 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 are . Board Recommendations

. None

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o V. SUPPORTING DATA AND SUMMARIES Licensee Activities 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 outage Unit 1 outages are summarized below: 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, September 4, 1986: Unit 1 began it's 17 week, routine refueling and maintenance outag . 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 outage Unit 2 outages are summarized below: December 6, 1985 thru February 4, 1986: Shutdown for refueling, routine maintenance and 10 year in-service inspection 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 turbin 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, 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- Five reactor coolant system resistance temperature detectors were replaced, one accumulator transmitter was recalibrated, and maintenance was performed on an essential service water pum Mc

'

s, ' ' \

t e

,

, ,

I %,yg -t , s 7 .

'

- t A i ; ._

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 September 20-22, 1986: Unit 2 was shutdown to repair , .

.

the turbine electro-b3draulic control syste N N ( " '

..

T Inspection Aci.iv'1 ties p. , (- 'Q,y 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.*? ,

'

' 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 -

s ',

, Inspection Reports No.: 85001, 85033, 85035, 85038 through , e 85044, 86001 through 86005, 86007 through 26019, 86020,  ;, -

86022 through 86024, 86027,'and 8602 j

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Table'1

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, \. [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 Plant Operations 3 1 1 Radiological Controls 1  % Maintenance 2 Surveillance . 2 Fire Protection 1 Emergency Preparedness ' Security 1' Outages 11 1. Quality Programs and Adminis. Controls Affecting Quality 2 Licensing Activities '

,

, Training & Qualification Effectiveness 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'

s s

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4 - , .s <

., 3 l l Special Inspection Summary

. s 4 None i 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 identifiedissue from the NRC review of these

,'

/

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,

'

g allegation c 1

- {scalatedEnforcementActions No civil penalties were issued during this assessment perio 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 inoperabl Licensee Conferences Held During Assessment Period January 10, 1986, (Regional Office) - Management meeting to discuss the findings of Zion's SALP ' 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 ou . April 9, 1986, (SITE) - A tour and management meeting with representatives from Zion plant management to discuss operational safet . 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 shutdow ( May 21,1986, (Site) - Management meeting to tour the facility and meet with station managemen 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 testin '

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,y,q '

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, (

/- ,tt e

' . , A Review of Licensee Event Reports and 10 CFR 21 Reports Submf tted by-the Licensee Licensee Event Reports (LERs)

'

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 8602 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).

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 LE 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 warrante )

o

~

o l 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 writte . 10 CFR 21 Reports (a) Inspection Report 304/85018 documented limitorque wires for which there was inadequate environmental qualification documentatio (b) Inspection Report 304/86017 documented leaking Anderson-Greenwood 5-valve manifold H. Licensing Activities 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 Commission Meetings None Schedule Extensions Granted None Reliefs Granted ASME Code, Rev. 5 to ISI Program March 27, 1986 Exemptions Granted None I Licensee Amendments Issued Amendment Number Title Date

__ _

c>

%

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

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34