IR 05000295/1985001

Corrected Pages to SALP Repts 50-295/85-01 & 50-304/85-01 for May 1984 - Sept 1985 Re Duties of Radiation Protection Manager

ML20155F666
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/17/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155F661	List: IR 05000295/1985001 ML20155F657 ML20155F684 ML20155F698
References
50-295-85-01, 50-295-85-1, 50-304-85-01, 50-304-85-1, NUDOCS 8604220299
Download: ML20155F666 (11)

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SALP 5 APPENDIX SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

, REGION III l

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l

I 50-295/85001; 50-304/85001 Inspection Reports N Commonwealth Edison Company Name of Licensee Zion Nuclear Power Station Name of Facility May 1, 1984 - September 30, 1985 Assessment Period 8604220299 860417 5 DR ADOCK 0500

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Zion 1 and 2 Facility A. Summary of Meeting with Commonwealth Edison Company on January 10, 1986 The findings and conclusions of the SALP Board documented in Inspection Reports No. 50-295/85001; No. 50-304/85001 were discussed with the licensee on January 10, 1986, at the Region III office in Glen Ellyn, Illinois. The licensee's regulatory performance was presented and found to be acceptable in each functional area rate The licensee was informed that the surveillance area had recorded a declining performance trend and that the overall number of reported personnel errors in several functional areas at Zion was high compared to other facilitie On balance, an overall improving trend in regulatory performance was noted at the facility over the course of the SALP period, with a significant improvement observed in the security are Attendees The following licensee and NRC personnel attended the meeting:

Commonwealth' Edison Company B. Thomas, Executive Vice President Cordell Reed, Vice President - Nuclear Operations D. Galle, Division Vice President and General Manager -

Nuclear Stations D. Farrar, Director of Nuclear Licensing G. Plim1, Station Manager, Zion and Others of the CECO Staff U.S. Nuclear Regulatory Commission J. G. Keppler, Regional Administrator A. B. Davis, Deputy Regional Administrator C. E. Norelius, Director, Division of Reactor Projects N. J. Chrissotimos, Chief, Reactor Projects Branch 2 C. W. Hehl, Chief, Reactor Projects Section 2A S. A. Varga, Director, PWR Project Directorate No. 3 J. A. Norris, Licensing Project Manager M. M. Holzmer, Senior Resident Inspector J. N. Kish, Resident Inspector, Zion L. E. Kanter, Resident Inspector, Zion and Others of the NRC Staff B. Regional Administrator Comments By letters dated February 10 and April 4, 1986, the licensee provided written comments on the SALP report and minor errors contained therei The NRC acknowledges the errors noted and has modified the report as described in the attached errata sheet. The comments provided in the February 10 letter regarding the improvement of the surveillance area and the comments provided in the April 4 letter regarding the plans to reduce the high incidence of personnel errors appear responsive to the Region's concern . __ _ ._ __

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L ERRATA SilEET Facility: Zion Station SALP Report No: 50-295/85001; 50-304/85001 Page Line Now Reads Should Read 10 9 In response to this The RPM, however, does hold concern, the licensee meetings with the Services agreed to schedule routine Senerintendent and the RPM has meetings between the a: ess to upper station management Services Superintendent fc- the resolution of problems on and the RP an as needed basi inadvertent containment event involving leakage past a spray system activatio valve in the radwaste syste ... Master IM, EM and MM... ... Master IM and MM to improve...

31 30 ...of Plant Manager to ...of Station Manager to whom the whom the superintendents superintendents of Production and of Production and Tech- Services now report. The Main-nical Services now tenance Department now reports to repor The Maintenance the Superintendent of Productio Department which was under Technical Services now reports to the Super-intendent of Productio Basis for Change: All of the above changes were required due to factual errors in the SALP repor . _ __ _ _- _. _ _ , _ _ _ _ _ _ . _

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The radiation protection and chemistry staff turnover raty, which has been quite high in the past, has stabilize stability appears to have helped the licensee improve /This performance in the area of radiological controls, although experience levels on the average remain quite low. ,A recent reorganization has added an additional layer of ranagement between the Radiation Protection Manager (RPM) and the Station Manager; this is generally an undesirable change'frora the standpoint of RPM access to top plant managem.en In response to this concern, the licensee agreed to schedule routine meetings between the Services Superintendent and the RP The licensee's management involvement i enerally good, with occasional poor performance. Audi are thorough and timely, with good responsiveness to findi / The licensee has implemented measures to improve ker adherence to station radiation protection procedure better identification of offenders and stronger discip ry actions. The improvements in conjunction with increased,surveillances and program changes are expected to reduce the ber of radiation occurrence report Management con initiatives during this assessment period resulted in: im@vedALARAoutageplanning; reduction of contaminated and r Piratory areas in the auxiliary building; and devel nt of a radiation work permit program, a whole body friskin ' program, and several trending program Several items, h Ver, have remained open for prolonged periods, includ' .~ development of compliance documentation for certain TM ction Plan Items; proper control of high radiation area ccess doors; repair of minor leaks in the auxiliary bu' ding; post accident effluent sample line loss determinati ; certification calibration of the containment high rang radiation monitors; and documenting that the sealants sed in the modification and repair of the control room e rgency air cleaning system possess acceptable prop ie T licensee's responsiveness to NRC initiatives has generally en adequate during this assessment period. As noted above, I several NRC concerns remained open for prolonged periods. On 1 the other hand, improvements were made for a number of NRC l identified weaknesses, including those concerning the use of j half-face respirators, inadequate number of continuous air 1 monitors, radioactive gases entering the counting room, the i need for new lead lined frisking booths at containment access, the need to improve the review method of air sample results, the need to improve and formalize the method for guarding containment access during entries, inadequate alpha counting equipment, the need to revise the MPC-hr procedure to include a method for calculating MPC-hrs from whole body count results, the large number of lost film badges, and an unusually large number of personal contamination incidents associated with the use of the laundry facilitie _ _ _ _ _ _ _

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The radiation protection and chemistry staff turnover rate, which has been quite high in the past, has stabilized. This stability appears to have helped the licensee improve performance in the area of radiological controls, although experience levels on the average remain quite low. A recent ;

reorganization has added an additional layer of management '

between the Radiation Protection Manager (RPM) and the Station Manager; this is generally an undesirable change from the standpoint of RPM access to top plant management. The RPM, however, does hold meetings with the Services Superintendent and the RPM has access to upper station management for the resolution of problems on an as needed basi The licensee's management involvement is generally good, with occasional poor performance. Audits are thorough and timely, with good responsiveness to findings. The licensee has implemented measures to improve worker adherence to station radiation protection procedures by better identification of ,

offenders and stronger disciplinary actions. The improvements in conjunction with increased surveillances and program changes are expected to reduce the number of radiation occurrence reports. Management control initiatives during this assessment period resulted in: improved ALARA outage planning; reduction of contaminated and respiratory areas in the auxiliary building; and development of a radiation work permit program, a whole body frisking program, and several trending program Several items, however, have remained open for prolonged periods, including: development of compliance documentation for certain TMI Action Plan Items; proper control of high radiation area access doors; repair of minor leaks in the auxiliary building; post accident effluent sample line loss determination; certification calibration of the containment high range radiation monitors; and documenting that the sealants used in the modification and repair of the control room emergency air cleaning system possess acceptable propertie The licensee's responsiveness to NRC initiatives has generally been adequate during this assessment period. As noted above, several NRC concerns remained open for prolonged period On the other hand, improvements were made for a number of NRC identified weaknesses, including those concerning the use of half-face respirators, inadequate number of continuous air monitors, radioactive gases entering the counting room, the need for new lead lined frisking booths at containment access, the need to improve the review method of air sample results, the need to improve and formalize the method for guarding containment access during entries, inadequate alpha counting equipment, the need to revise the MPC-hr procedure to include a method for calculating MPC-hrs from whole body count results, the large number of lost film badges, and an unusually large number of personal contamination incidents associated with the use of the laundry facilitie .

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Gaseous and liquid radioactive releases remained within technical sp cification limits during this assessment perio However, during the third quarter of 1984, the licensee exceeded the technical specification quarterly liquid radwaste release design objective. The licensee's liquid releases increased significantly during this assessment period due/j in large part to the cleanup associated with a 1984 inadvertent containment spray system activation. A new crystallizer (evaporator), expected to be in operation by the end'of 1986, is expected to improve the licensee's capability fo'r processing liquid waste and allow reuse of water from source's such as the auxiliary building equipment and floor drains. The solid radioactive waste volumes in 1984 and 1985 wer'e significantly less than in recent years, and the licensee'has recently implemented a volume reduction progra Ind' plans to begin segregation of dry active waste in t ear future to reduce the amount of solid radwaste furthe Other planned improvements include an interim r 'te storage facility, which is nearing completion, an ans for incineration of dry 1ctive waste in a contractor supp ied incinerator. A warning wasissuedinSeptember198Qy#theSouthCarolinaDepartment of Health and Environmenta Control concerning loose radioactive waste in shipping conta' the licensee took appropriate corrective actio No itional transportation problems were identifie The station perfo e[verywellinconfirmatorymeasurements with 75 agreeme in 75 comparisons made in two different inspections dur the period. Licensee calibrations of the gamma spectrome ers used in these comparisons were current and complete /nd the licensee had verified consistency of calibratio between the different detector Minor p blems in the annual report of the radiological envir mental monitoring program (REMP) were again noted during thi period. These problems, which involved discrepancies b een the annual REMP report and the offsite dose calculation nual, errors in nonroutine reporting levels and detection limits, and differences in monitoring locations, were also noted during the two previous assessment periods and are indicative of weak program oversight by the responsible corporate group. Following an April 1985 inspection at the corporate office, the licensee took significant steps to strengthen the program, including reorganization of the responsible group to provide stronger review and oversigh Most of the identified problems have been corrected or are in the process of being correcte .

Gaseous and liquid radioactive releases remained within technical specification limits during this assessment perio However, during the third quarter of 1984, the licensee exceeded the technical specification quarterly liquid radwaste releasedesignobjective. The licensee's liquid releases increased significantly during this assessment period due in large part to the cleanup associated with a 1984 event involving leakage past a valve in the radwaste system. A new crystallizer (evaporator), expected to be in operation by the end of 1986, is expected to improve the licensee's capability for processing liquid waste and allow reuse of water from sources such as the auxiliary building equipment and floor drains. The solid radioactive waste volumes in 1984 and 1985 were significantly less than in recent years, and the licensee has recently implemented a volume reduction program and plans to begin segregation of dry active waste in the near future to reduce the amount of solid radwaste further. Other planned improvements include an interim radwaste storage facility, which is nearing completion, and plans for incineration of dry active waste in a contractor supplied incinerator. A warning was issued in September 1985 by the South Carolina Department of Health and Environmental Control concerning loose radioactive waste in shipping containers; the licensee i.cok appropriate corrective action. No additional transportation problems were identifie The station performed very well in confirmatory measurements with 75 agreements in 75 comparisons made in two different inspections during the period. Licensee calibrations of the gamma spectrometers used in these comparisons were current and complete and the licensee had verified consistency of calibration between the different detector Minor problems in the annual report of the radiological environmental monitoring program (REMP) were again noted during this period. These problems, which involved discrepancies between the annual REMP report and the offsite dose calculation manual, errors in nonroutine reporting levels and detection limits, and differences in monitoring locations, were also noted during the two previous assessment periods and are indicative of weak program oversight by the responsible corporate group. Following an April 1985 inspection at the corporate office, the licensee took significant steps to strengthen the program, including reorganization of the responsiLle group to provide stronger review and oversigh Most of the identified problems have been corrected or are in the process of being correcte . .

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Several personnel changes were implemented in the MM and IM Departments. These changes included a new Master Mechanic and a new Master Instrument Mechanic (who is a former SCRE), as well as new work analysts (planners) in these department An assistant to the head of the Maintenance Department yes also added. These individuals have considerable experiencg/at the station,andthesepersonnelchangesaregenerally/(iewedas favorable. In addition, the licensee has provided ARO license qualification for the Master IM, EM and MM to i ~ ove cross training in the maintenance departmen f-Equipment reliability has been good and is W. proving as indicated by the excellent Unit 2 avail fity (99.5%) during cycle 8 and the relatively event fre rn of Unit 1 to service following the refueling out Efforts to improve equipment reliability reported in previous assessment have continued and have been suppleme by a " Recurring Station Problems List" which highlights a ion plans for the ten most significant problems. Only reactor trips occurred which were directly attributable /quipmentproblemscomparedto thirteen during the last sment period. Two trips were attributable to feedwatp $ stem control problems (feed pump speed variations at fulV/ower and sluggish feed regulating valve response at 2C p er), and one resulted from a capacitor failure in an inst ' t inverter at 1% power. This is a significant impr nt over the previous assessment perio During this asse ment period there were 17 Deviation Reports (DVR's) attrib able to personnel error and 2 DVR's attributable o poor procedures. These DVR's vary in safety significan .

A preve ive maintenance (PM) program was initiated early in the a essment period to help improve equipment reliabilit The ogram includes a computerized list of PMs which is used to roduce a monthly list of PMs for the MM department. The censee has encountered some difficulty integrating this additional work into the existing MM work load. IM and electrical maintenance (EM) PMs are managed separatel Because the program is new and is not fully implemented, its effectiveness to date has been difficult to asses Control of the backlog of outstanding work requests (WR) in the MM department was improved by implementing a Total Job Management (TJM) syste The system helps manage WRs by entering new WRs into a database by a number which uniquely identifies the equipment (EID number). When preparing to take a component or system out of service for maintenance, the work analyst checks the system for related WRs in order to make more effective use of equipment down time. The MM department has used the system for about a year, and because of the improvements in WR management experienced by the mms, the

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'Several personnel changes were implemented in the MM and IM

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Departments. These changes included a new Master Mechanic and a new Master Instrument Mechanic (who is a former SCRE), as well as new work analysts (planners) in these department An assistant to the head of the Maintenance Department was also added. These individuals have considerable experience at the station, and these personnel changes are generally viewed as favorable. In addition, the licensee has provided SR0 license qualification for the Master IM and MM to improve cross training in the maintenance departmen Equipment reliability has been good and is improving as indicated by the excellent Unit 2 availability (99.5%) during cycle 8 and the relatively event free return of Unit 1 to service following the refueling outage. Efforts to improve equipment reliability reported in the previous assessment have continued and have been supplemented by a " Recurring Station Problems List" which highlights action plans for the ten most significant problems. Only three reactor trips occurred which were directly attributable to equipment problems compared to thirteen during the last assessment period. Two trips were attributable to feedwater system control problems (feed pump speed variations at full power and sluggish feed regulating valve response at 20% power), and one resulted from a capacitor failure in an instrument inverter at 1% powe This is a significant improvement over the previous assessment perio During this assessment period there were 17 Deviation Reports (DVR's) attributable to personnel error and 2 DVR's attributable to poor procedures. These DVR's vary in safety significanc A preventive maintenance (PM) program was initiated early in the assessment period to help improve equipment reliabilit The program includes a computerized list of PMs which is used to produce a monthly list of PMs for the MM department. The licensee has encountered some difficulty integrating this additional work into the existing MM work load. IM and electrical maintenance (EM) PMs are managed separatel Because the program is new and is not fully implemented, its effectiveness to date has been difficult to asses Control of the backlog of outstanding work requests (WR) in the MM department was improved by implementing a Total Job Management (TJM) syste The system helps manage WRs by entering new WRs into a database by a number which uniquely identifies the equipment (EID number). When preparing to take a component or system out of service for maintenance, the work analyst checks the system for related WRs in order to make more effective use of equipment down time. The MM department has used the system for about a year, and because of the improvements in WR management experienced by the mms, the

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In May of 1935, the resident inspectors were placed on l distribution for all DVRs at their reques As a result, events which would have ordinarily passed unnoticed were reviewed and if questions arose, NRC followup resulted. As a consequence of these reviews, it appears that NRC became much more aware of the licensee's corrective action processes than had been the case in the past. For this reason, it was difficult te assess whether the apparent increase in ents was due to poorer performance or due to a heightened aw ness of plant events, In any case, the concerns noted ab regarding adequacy of investigations indicate the need fop ore effective determination of root cause and corrective ctio During the assessment period, manageme tiated several steps to improve plant performance in de range of area Forthefirsttime,annualgoalsdevd, ment was conducted using the inputs from each work leader in an effort to obtain more cooperation at the r level toward achievement of the station's overall goalc, date, this approach appears to have been successful in p ing a team effort tuward improvement of station pe hnce. In addition, a recurring station problems list was eloped to focus technical attention on problem eaf. The licensee has also implemented a station commitment t to track all NRC concerns and findings as well a . ernal commitments such as corrective actions developed t 'ough their LER/DVR system. The licensee's Regulatory Improv 'ent Program which was implemented during the last assessment eriod remains in forc The license hanged the site organi7.ation at all their operating ations in June of 1985. The reorganization created the pos* on of Plant Manager to whom the superintendents of Produ on and Technical Services now report. The Maintenance Dep ent which was under Technical Services now reports to t Superintendent of Productio he QA organization onsite is adequately staffed and traine Relations between QA and site personnel are generally business-like and a team attitude is usually evident. QA audits are timely and generally thoroug One inspection of environmental qualification (EQ) activities was conducted by Region III specialists and NRC Headquarters inspectors. This inspection covered the licensee's Unit 2 EQ equipment and the EQ program for both Unit 1 and Unit 2. One violation (with two examples) was identified as follows:

Severity Level IV - (1) qualified Limitorque valve operators were installed with plastic protection shipping caps on the valve operator gear case relief valves; however, these shipping caps were not part of the documented qualification method; (2) junction boxes with top conduit entries were installed in some cases; however, these were not part of the documented qualification method (Inspection Report No. 304/85006).

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In May of 1985, the resident inspectors were placed on distribution for all DVRs at their reques As a result, events which would have ordinarily passed unnoticed were reviewed and if questions arose, NRC followup resulted. As a consequence of these reviews, it appears that NRC became much more aware of the licensee's corrective action processes than had been the case in the past. For this reason, it was difficult to assess whether the apparent increase in events was due to poorer performance or due to a heightened awareness of plant events. In any case, the concerns noted above regarding adequacy of investigations indicate the need for more effective determination of root cause and corrective actio During the assessment period, management initiated several steps to improve plant performance in a wide range of area For the first time, annual goals development was conducted using the inputs from each work group leader in an effort to obtain more cooperation at the worker level toward achievement of the station's overall goals. To date, this approach appears to have been successful in promoting a team effort toward improvement of station performance. In addition, a recurring station problems list was developed to focus technical attention on problem areas. The licensee has also implemented a station commitment list to track all NRC concerns and findings as well as internal commitments such as corrective actions developed through their LER/DVR system. The licensee's Regulatory Improvement Program which was implemented during the last assessment period remains in forc The licensee changed the site organization at all their operating stations in June of 1985. The reorganization created the position of Station Manager to whom the superintendents of Production and Services now report. The Maintenance Department now reports to the Superintendent of Productio The QA organization onsite is adequately staffed and traine Relations between QA and site personnel are generally business-like and a team attitude is usually evident. QA audits are timely and generally thoroug One inspection of environmental qualification (EQ) activities was conducted by Region III specialists and NRC Headquarters inspectors. This inspection covered the licensee's Unit 2 EQ equipment and the EQ program for both Unit 1 and Unit 2. One violation (with two examples) was identified as follows:

Severity Level 'V - (1) qualified Limitorque valve operators were installed with plastic protection shipping caps on the valve operator gear case relief valves; however, these shipping caps were not part of the documented qualification method; (2) junction boxes with top conduit entries were installed in some cases; however, these were not part of the documented qualification method (Inspection Report No. 304/85006).

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