ML20203H884

Insp Repts 50-295/97-32 & 50-304/97-32 on 971217-980202. Violations Noted.Major Areas Inspected:Operations, Engineering & Plant Support

ML20203H884
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203H822	List: ML20203H817 ML20203H860 ML20203H884
References
50-295-97-32, 50-304-97-32, NUDOCS 9803030349
Download: ML20203H884 (22)

See also: IR 05000295/1997032

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

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l Docket Nos: 50 295; 50 304

License Nos: DPR 39; DPR 48

Report No: 50-295/97032(DRP); 50 304/97032(DRP)

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Licensee: Commonwealth Edison Company l

Facility: Zion Nuclear Plant, Units 1 and 2

Location: 101 Shiloh Boulevard

Zion,IL 60099

Dates: December 17,1997, through February 2,1998

Inspectors: A. Vegel, Senior Resident inspector

D. Calhoun, Resident inspector

E. Cobey, Resident inspector

D. Jones, Reactor Engineer

S. Orth, Senior Radiation Specialist

J. Yesinowski, Illinois Department of

Nuclear Safety inspector

Approved by: Kenneth G. O'Brien, Acting Chief

Reactor Projects Branch 2

9003030349 900225

PDR ADOCK 05000295

G PDR

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EXECUTIVE SUMMARY

Zion Nuclear Plant, Units 1 and 2

NRC Inspection Report No. 50 295/97032(DRP); 50 304/97032(DRP) l

This inspection included aspects of licensee operations, maintenance, engineering, and plant

support. The report covers a seven week period of inspection activities by the resident and

region based inspectors. Performance during this inspection period continued to be

characterized as inconsistent despite a reduction in plant activities.

Operations

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The inspectors concluded that the main steam lines were inadvertently filled with water

due to the poor material condition of two isolation valves and a failure by operations

personnel to adequately monitor plant parameters after removal of the condensate

system from service, in addition, operations personnel did not aggressively investigate

an unexpected decrease in condensate storage tank level, which contributed to the loss

of water inventory not being recognized for over eight days (Section O2.1).

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The inspectors identified several weaknesses in the plant winterization procedure. In

addition, concerns were identified with a lack of timely procedure implementation and a

lack of staif followup o ensure that problems, once identified, were corrected prior to the

onset of cold weather (Section 02.2).

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A violation was identified involving the failure of licensed operators to u.=e the appropriate

system operating instruction when restoring two auxiliary feedwater valves to their proper

positions while clearing an out of service, in addition, although a non licensed operator

demonstrated a strong questioning attitude in identifying the improper valve configuration,

the inspectors were concerned that this deficient condition went undetected by other

non licensed operators for six days (Section O2.3).

Enoineering

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The inspectors concluded that engineering department personnel demonstrated a strong

questioning attitude and an in depth system knowledge in identifying that surveillance

tests had potentially not tested allinterlocks associated with emergency diesel generator

operability. In addition, the inspectors determined that the licensee took effective

immediate corrective actions in promptly testing the emergency diesel generators after

discovery of it.e problem (Section E2.1).

ELant Support

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The inspectors, concluded that radiation protection personnel did not demonstrate sound

radiation protection practices in allowing a 55 gallon drum, labeled as low level

radioactive material, to be used as a door stop in the auxiliary building (Section R4.1).

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ReDor1. Details

Summarv f Plant Status

During this inspection period, the licensee maintained Unit 1 in a defueled condition and Unit 2 in

a cold shutdown, depressurized condition pending completion of restart actions delineated in the

Zion Recovery Plan. In late November 1997, the licensee initiated a slow down of work activities

so that plant personnel enuld focus on resolving work control deficiencies identified during the

second operations demonstration period. On January 15,1998, the licensee announced that the

Zion Nuclear Power Plant would be permanently shut down. The licensee planned to reduce the

plant's staff over the next year and maliitain the plant in a decommissioned status,

l. Operations

02 Operational Status of Facilities and Equipment

O2.1 Inadvertent Fillina of the Unit 2 Main Steam Lines with Water

a. Inspection Scope (71707)

j The inspectors reviewed the circumstances surrounding the licensee's identification of

water in the Unit 2 main steam lines (MSLs). The inspectors interviewed operations and

engineering department personnel, reviewed applicable documentation, and conducted

an inspection of the affected systems.

b. Observations and Findinas

On December 5,1997, the licensee identified water in all four MSLs on Unit 2. The

licensee implemented immediate corrective action by initiating an investigation of the

abnormal condition. In addition, operations and engineering department personnel

walked down the MSLs and supports and did not identify any deficiencies. The licensee

commenced the draining evolution of the MSLs on December 5,1997, and completed the

evolution on December 13,1997,

The licensee removed the condensate system from service on November 21,1997, using

System Operating Instruction (SOI)-32U, " Stopping the Last Condensate / Condensate

Booster Pump," Revision 1. Operations personnel, using a valve bar, closed the

condenser normal overflow level control hi stop valve,2CD0024, and the condenser

emergency overflow level control hi stop valve,2CD0037, as specified by SOI 32U.

These manual valves were located between the condensate booster pump discharge

header and the condensate storage tank (CST) flow path. Although a valve bar was

ur.ed to close the valves, the valves were not fully closed. As a result, water flowed from

the CST, past the valves, filling the main condenser, overflowing into the MSL drain

standpipe, and into the MSLs.

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The onshift operating crew noticed the decreasing trend in CST level on

November 29,1997, although the CST had been draining and showing a decreasing

trend s!nce November 21,1997. The onshift operating crew did not write a problem

identification form (PIF) nor did they notify operations management of this unexpectod

decrease in CST level.

On December 1,1997, the Shift Manager (SM) contacted a system engineer (SE) to

investigate the decrease in Unit 2 CST level. The SE determined that the CST leakage

was relatively small based on the decreasing trend rate and that the leakage was going to

the auxiliary boiler vent as steam. The SE notified the SM of his conclusions. The onshift i

operating crew continued to make up to the CST as the water level continued to drop. i

On December 5,1997 CST leakage caused condenser level to increase untilit spilled

from the motor shroud of the 28 gland steam condenser exhauster. The licensee

subsequently determined that valves 2CD0024 and 2CD0037 were leaking water past

their seats causing the loss of water inventory from the CST. Operators closed 2CD0024

a,. additional 5/8 tum, and 2CD0037 an additional nine tums which stopped the CST level

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decrease.

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l The licensee performed an investigation of this event and determined that the following

items contributed to the event:

(1) The operating shift did not perform an adequate review of plant parameters after

the condensate system was removed from service on November 21,1997.

(2) The manual isolation valves were not independently verified closed.

(3) The ongoing Unit 2 CST level decrease from November 21,1997, to

December 5,1997, was not promptly identified.

(4) Physical binding in 2CD0037 made the valve very difficult to close during the

performance of sol 32U. (material condition problem)

The licensee initiated the following corrective actions:

(1) Lessons learned of the event were placed in the Night Orders.

(2) The licensee planned to revise SOI 32U to require verification of the condenser

level and to require independent verification that valves 2CD0024 and 2CD0037

are closed.

The licensee performed engineering evaluation No. 9708719 to determine the impact of

the event on the MSL piping and supports. The licensee concluded that the MSL piping

and supports were not adversely affected by the water. The inspectors reviewed the

evaluation and agreed with the licensee's conclusion. In addition, the inspectors

performed independent walkdowns of the MSLs on December 12,1998, and January 23,

1998, and did not identify any deficiencies. The safety consequences of the event were

minimal since the CST was not required to be operable in the current operational mode,

and no damage to the MSLs occurred.

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c. Conclusion

The inspectors concluded that operations personnel did not adequately verify plant

parameters after removing the condensate system from service, in addition, the

inspectors determined that between November 21 and December 5,1997, the control

room operators failed to demonstrate a strong questioning attitude in falling to ensure that

the cause for the decreasing CST level was fully understood in a timely manner. As a

result, the decreasing levelin the CST, due to leaking valves in the condensate system,

went undetected over an eight day period and water filled the MSLs which could have

caused damage to the system.

l These deficiencies were not violations of NRC requirements because safety-related

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activities were not involved. The inspectors also concluded that the licensee's

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investigation of the event was thorough and proposed corrective actions appeared i

appropriate. However, this event was of concem to the inspectors because a material '

condition problem, binding of 2CD0037, contnbuted to the occurrence of this event. As

previously documented in NRC Inspection Report No. 50 295/97022; 50-304/97022, a

valve material condition problem contributed to an unexpected decrease in pressurizer

level, The licensee's inability to effectively address plant material condition problems

continued to contribute to the occurrence of water inventory control problems.

02.2 Cold Weather Preparation

a. lnipiction Scope (71714)

The inspectors reviewed the licensee's preparations for placing the plant in winter

operations. The inspectors reviewed applicable procedures, interviewed operations

department personnel, and walked down affected systems,

b. Observations and Findinos

On December 15,1997, the inspectors interviewed the operations work control center

(OWCC) supervisor and the shift manger (SM) regarding the plant's readiness for winter

operations. The OWCC supervisor and SM informed the inspectors that the station used

periodic test (PT) 35W, " Winter Operation Verification," Revision 6 for preparing the plant

for winter operations. As a result of these diseassions and review of the applicable

procedure, the inspectors identified the following:

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The SM was not aware of the plant's status with respect to its readiness for winter

operations when asked by the inspectors.

PT 35W was only partially complete although cold weather conditions had already

occurred. For example, the following actions were not completed by the licensee;

engineering department's review of a procedure change to correct some heater

nomenclature was not completed, and the OB control room heating coils were not

placed in operation.

On January 5,1998, the inspectors again questioned the OWCC supervisor and the SM

on the status of PT 35W and again the status was still unknown. However, OWCC

personnel placed additional emphasis on completing PT 35W, and the licensee

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subsequently completed the proceduro on January 7,1998. The inspectors determined

through review of the completed checklist that since October 6,1997, when the

procedure was initiated,25 operators h3d participated in completing PT 35W. However,

no specific individual or group appeared to have lead responsibility in ensuring that the

procedure was being implemented in a timely and effective manner. In addition, the

inspectors had the following concems with the licensee's implementation of PT 35W:

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The PT did not requi,e verification that work requests (WRs),had been completed

for needed work ider,tified during performance of the PT, were completed prior to i

completion of the PT.

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+ The PT did not verify that cold weather protective measures were re established

on systems on which maintenance was performed during the past year, nor did 11

verif/ that proposed modifications, initiated to correct or enhance freeze

protection, were accomplished. As a result, the inoperable cor,dition of three

heaters, which had been identified on the 1996 PT-35W, were not addressed.

• The PT did not verify that outstanding WRs, on affected systems, were closed

prior to completion of the PT. As a result, the SM signed off the PT as complete

with numerous WRs outstanding.

• The PT did not verify operation of the vent stack sampling line heat tracing. The

system had been included in a NRC guidance as a system to be checked for cold

weather conditions.

• The PT did not include a required start or completion date. As a result, several-

periods of extreme weather conditions occurred before the licensee completed

PT 35W.

. The PT included incorrect heater nomenclatures. As a result, the licensee

submitted Revision 7 of the PT to correct the deficiencies.

The inspectors also performed an inspection of the applicable systems and identified that

no method of control appeared to have been used for the installation and control of heat

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tracing on the Unit 2 ventilation supply room ethylene glycol vent and drain lines. After

tha inspectors informed OWCC personnel of this condition, the licensee initiated PIF

No. Z1997 03332. At the end of this inspection period, the licensee had not determined

the mechanisms that were used to install and track the heat tracing.

c. - Qonclusion

The inspectors concluded that the plant's winterization activities were adequate since no

systems had been adversely affected by the cold weather. However. the inspectors

identified several weaknesses in the proceduie. The inspectors also identified a lack of

procedure implementation timeliness and a lack of rigor by the staff in ensuring that

problems, identified during implementation of the procedure, were corrected prior to the

onset of cold weather.

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O2.3 Mispositioned Valves in the Auxiliary Feedwater (AFW) System

a. Inspection Scope (71707)

The inspectors reviewed the circumstances surrounding the licensee's identification of I

two mispositioned valves in the AFW system. The inspectors reviewed the applicable

documentation and interviewed root cause investigation and operations department

personnel.

b. Observations and Findina

On January 13,1998, a non licensed operator identified that two valves in the AFW

system were not in their require,d positions, in mode 5, the licensee configured the AFW

system in a split header configuration which ensuied that both the turbine-driven and the

motor-driven pump headers had an available pump The configuration required the

2B AFW pump discharge isolation valve,2FWOO38, and the 2B AFW pump discharge

stop valve,2FWOO42, to be locked closed; however, the valves were found in the locked

open position. The licensee's immediate corrective action included re positioning the

valves. The onshift operating crew also commenced an investigation after being

informed of the deficient condition.

The licensee determined that the AFW system was taken out of service (OOS) on

December 19,1998, for scheduled maintenance. Operation personnel cleared OOS

No. 970014102 on January 7,1998. The OOS specified the return to service (RTS)

position of valves 2FWOO42 and 2FWOO38 as locked open. The inspectors noted that the

OOS preparer and reviewer, both senior reactor operators (SROs), used SOI 10,

Appendix A 2, Revision 7, " Auxiliary Feedwater Valve and Electrical Lineup * to define the

RTS position of the valves. SOI 10 specified the AFW system valve lincup for normal

at power operations. The RTS positions should have been based on SOI 10E,' Aligning

Auxiliary Feedwater System For Split Header Lineup,' Revision 9. Sol 10E specified the

position of both valves as locked closed.

Zion Administrative Procedure (ZAP) 300-06,"Out of Service Process," Revision 17,

Appendix B, " Lifting OOS Techniques," specified, in part, that equipment shall be

retumed to service in accordance with the applicable system operating instruction. The

failure of the licensee to return valves 2FWOO38 and 2FWOO42 to service in accordance

with SOI 10E is a violation of Technical Specification (TS) 6.2.1.a (50 304/97032-01), as

described in the attached Notice of Violation.

c. Conclusion

The inspectors concluded that operations department personnel demonstrated a lack of

attention to detail when both the preparer and reviewer of an OOS failed to use the

appropriate sol to specify the proper RTS position for two AFW valves. In addition,

although a non-licensed operator, performing normal rounds, identified this deficient

condition; the inspectors were concerned that this deficient condition was not detected by

other non licensed operators during six 6ays of normal rounds.

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The safety consequence of the valves being out of their required position was minimal

due to feedwater to the steam generators being isolated and decay heat removal being

provided by the residual heat removal system. However, the inspectors were concemed

with this error due to the continued occurrence of equipment configuration control and

out of service program implementation problems, as previously documented in NRC

Inspection Reports Nos. 50 295/97019,50 304/97019; 50 295/97022,50-304/97022; and

50-295/97025, 50 304/97025. Although the violation was licensee identified, it is being j

cited as a repetitive issue. 1

08 Miscellaneous Operations issues

08.1 59 54(f) Performance Indicators

a. [0spection Scope (71707)

The inspectors reviewed the development of selected 50.54(f) performance indicators

and interviewed operations, maintenance, and regulatory assurance department

personnel.

b. Observations and Findinas

The inspectors reviewed the following performance indicators-

C1 Operator Workarounds (OWAs)

The licensee developed performance indicator C1, Operator Workarounds, t.rJed on an

equipment or program deficiency which requires that an operator take non standard

action to comply with procedures, design requirements, or TSs. The licensee had

reduced the number of OWAs from 42 to 30 by the end of 1997. However, the licensee

had not met the projected workdown curve for the months of July and August. The

licensee's failure to meet the July and August goals was due to Unit 2 restart plan

execution problems which prevented the correction and elimination of OWAs and an

increase in OWAS based on the implementation of new standards which resulted in a

higher generation rate. As a result, the licensee submitted a revision to the workdown

curve which had a higher goal of 44 OWAs remaini .g by December. The inspectors

concluded that this indicator accurately reflect",, the number of OWAs at the station.

G Out-of-Service (OOS) Errors

The performance indicator C2, Out of Service Errors, was based on the total number of

OOS errors being classified as a SCAO [Significant Condition Adverse to Quality) or a

Level 1,2, or 3 PIF [ Problem identification Form). Due in part to this high threshold, the

licensee documented only three OCS errors for the year. However, four OOS errors had

actually occurred. The licensee overiooked one OOS error that had occurred in

September 1997; the OOS error had not been originally classified as a SCAQ. The

performance indicator steward who tracks this indicator had planned to update C2 to

reflect this change.

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The inspector considered that this performance indicator was not reflective of the number

of lower tier OOS problems occurring at the station. In addition to the SCAO OOS errors,

many other lower tier OOS errors or events have occurred, and several of these

lower tier OOS problems resulted in violations. On December 19,1997, the licensee

instituted a broader definition of OOS errors in Nuclear Operations Directive 30,

• Performance Indicators for Nuclear Generation Group," Revision 3. The definition was

expanded to include all PlFs written after the master OOS card was placed, or all OOS

configurations discovered which: (1) would have jeopardized personnel safety if the work

had croceeded; (2) had the potential to damage isolated or nearby equipment; and (3) did l

not match the OOS configuration stated on the OOS checklist. The licensee determined

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that two additional OOS errors had occurred in the month of December using the new

definition.

As a result of these lower tier OOS problems continuing, the licensee implemented

severalir"provements and established a Process Director for the OOS process on

October 30,1997. The licensee stated that the ability to maintain configuration control

has been mixed snd that 16 OOS errors had occurred during the year. The licensee

determined that of the 16 OOS errors,14 occurred prior to October 15,1997. The

inspectors noted that the licensee had made improvements in the OOS process, but

problems continued to occur due to personnel errors in implementation of the process as

discussed in Section O2.3 of this report.

08.2 (Closed) Licensee Event Report 50 304/96007: Technical Specification action statement

not performed within allowable timo frame as a result of managemeht deficiency.

The inspectors identified and documented this issue in NRC Inspection Report

No. 50 295/96014; 50-304/96014. The inspectors' assessment of the licensee's

corrective actions will be completed during the closure of bolation 50 304/96014 03.

Consequently, this licensee event report is considered closed.

08.3 (Closed) Licensee Event Reports 50-295/96010-00 and -01: Below freezing conditions

create flow restriction in the safety injection pump recirculation line due to design.

On March 8,1996, a non licensed operator identified that the local suction pressure

gages for the Unit i safety injection (SI) pumps were indicating greater than 60 psig.

The licensee determined that a section of the SI pump's recirculation line piping had

frozen due to the piping havir g been routed where it was exposed to the outside

environment. The licensee determined that this issue was also applicable to Unit 2.

The inspectors determined that the licensee had initiated immediate corructive actions to

install heat tracing on the piping and monitor the piping when the outside temperature

dropped below 35 degrees. The licensee also had planned to reroute the piping. The

inspectors verified that the piping had been rerouted for Unit 2, and the heat tracing was

stillin plEc and was being monitored until the Unit 1 piping could be rerouted. The

inspectors considered the licensee's corrective actions adequate. These licensee event

reports are considered closed.

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08.4 (Closed) Licensee Event Report 50 295/97006 00: Zion Station exceeded a Limiting

Condition for Operation due to inadequate procedure controls.

The circumstances surrounding this event were inspected and documented in NRC

Inspection Report No. 50 295/97007; 50 304/97007. The inspectors' assessment of the

licensee's corrective actions will be completed during the closure of Enforcement

Action 97 223, Violati:n 04014. Consequently, this licensee event report is considered

closed.

08.5 (Closed) Unresolved item 50-295/95020 04: 50 304/96020 04: System engineering

personnel did not notify control room (CR) of their actions to enter the control cabinets.

The inspectors reviewed the licensee's processes for notification of CR personnel of field

activities. The inspectors discussed the issue with plant management and reviewed the

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licensee's current requirements contained in Zion Generating Station Policy Statement

No. 211, * Administrative Configuration Control," dated April 7,1997. At the time of the

incident and at the time of this inspection, the licensee did not have any procedural

I requirements for personnel to notify CR personnel before opening and/or entering control l

l panels. Station personnelinformed the inspectors that the CR notification was a good

I practice and management expectation, but not a requirement. Subsequently, the

l licensee provided training to station personnel on CR notifia.ation responsibilities for

in plant activities. The inspectors considered the licensee's corrective actions adequate.

This unresolved item is considered closed.

08.6 10 CFR 50 54(f) letter Commitment Review

a. injpection

n Scope (71707)

The inspectors reviewed the status of commitments pertaining to Commonwealth

Edison's March 28,1997, responre to the NRC's request for information pursuant to

10 CFR 50.54(f). The commitment numbers correspond to those used by the licensee in

their March 28,1997, response.

b. Observations and Findinos

Commitment $4: CNOO [Ch;ef Nuclear Operating Officer), during his periodic visits

(typically monthly) to the sites, conducts open discussions with groups of 15 20

employees regarding station plans, issues of concern, and steps that can be taken to

improve.

Q_gmmitment 316: Chief Nuclear Operating Officer, during his monthly Management

Review Meetings at the sites, has discussions with groups of 'E 20 employees

regarding station plans, issues of concern, and steps for im0rovement.

c. Conclusion

The inspectors concluded that the licensee was generally conducting the meetings. The

licensee had conducted all meetings except three during the period beginning in February

and ending in December 1997.

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il. Maintenance

M8 Miscellaneous Maintenance lasues

M8.1 (Closed) Violation 50 295/9003102: 50 295/9003102 : The licensee lost several hundred

work requests that were written between 1980 and if r 1

The inspector reviewed the licensee's follow up actions lo the missing work requests and

noted the following:

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+ The licensee identifiod that the actual number of work requests involved was 173.

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The licensee performed a resource review to determine the resources necessary

to maintain an accurate database. As a result of the review, the licensee replaced

the Total Job Management System with the Work Request Tracking System,

which the licensee later replaced with the Electronic Work Control System, the

system currently in use.

+ The licensee performed a review of work requests associated with active

modifications which identified work requests to be canceled and those to remain

active.

+ The licensee performed a records search to identify other documents which were

related to work activities performed under the missing work requests.

+ The licensee performed a corrective action audit to verify the effectiveness of the

current Electronic Work Control System.

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The licensee performed a quarterly review of the work control system using Field

Monitoring Reports.

The inspector verified that no similar events had been documented in the licensee's

corrective action systems. The inspectors considered the licensee's corrective actions

adequate to prevent recurrence. This violation is considered closed.

M82 (Closed) Inspection Followup item 50 295/96005-05: 50-304/96005-05: 28 emergency

diesel generator (EDG) failure to start.

The inspectors reviewed the licensee's followup actions to the 2B EDG failure during

surveillance testing on February 13,1996. The licensee determined that a possible

contributor to the 2B EDG failure was a bent starting air distributor body retaining flange.

The licensee determined that this deficient flange could have distorted the distributor

body causing abnormal wear that could have resulted in seizure of the rotor. The

licensee subsequently replaced the affected flanges with redesigned flanges, on all

five EDGs. The licensee replaced the 2B EDG right bank air start distributor body, rotor,

coupling, retaining flange and gasket, and satisfactorily tested the 2B EDG on

February 10,1996. The inspectors considered the licensee's corrective actions

adequate. This inspection folicwup item is considered closed.

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M8.3 (Closed) Violation 60 295/96013 03: 50 304/96013 03: Failure to take prompt corrective

actions for potentially defective steam generator tubes.

The insper: tors reviewed the licensee's corrective actions for this issue The inspectors

verified that the licensee had implemented all of the specified corrective actions for Unit 2

in September 1996, during the fourteenth refueling outage. In addition, the licensee

submitted a license amendment request to the NRC to reflect the licensee's commitment

to utilize enhanced cleaning and inspection processes. The inspectors considered the

licensee's corrective actions adequate. This violation is considered closed.

MB.4 (Closed) Licensee Event Report 50 304/9100100 Unit 2 instrument bus perturbation

caused by a short occumng during 2C accumulator level transmitter modification

, installation which resulted in an engineered safety feature actuation.

As documented in NRC Inspection Report No. 50 295/9702? 50 304/97022, the

inspectors observed on September 2,1997, that the control room operators identified that

the reactor coolant pump thermal barrier containment isolation valve,2MOV CC685, did

not fail close as expected; however, the LER stated that all systems functioned as

designed and no anomalies were noted during the event. The licensee's investigation

into this apparent discrepancy determined that the operators had concluded that the valve

failed to close as expected based on the information provided in Abnormal Operating

Procedure 8.1, * Loss of Instrument Bus," Revision 21, Appendix B," List of Other Major

Components Lost Due To Loss Of Bus 112(212)." The licensee also determined that

since the valve control circuitry did not have a seal in relay, it should not have failed

closed for a momentary voltage perturbation. Consequently, the licensee concluded that

all systems functioned as designed. The inspectors agreed with the results of the

licensee's investigation and considered their followup actions adequate. This licensee

event report is considered closed.

M8.5 (Closed) Licensee Event Report _50-295/9702100: Set points for power range rate trip

surveillance were left greater than TS limits.

The circumstances surrounding these events were inspected and documented in NRC

Int,pection Report No. 50-295/97022; 50 304/97022. The inspectors' assessment of the

licensee's corrective actions will be completed dunng the closure of

Violations 50 304/97022 03 and 50 304/97022 04. Consequently, this licensee event

repori ls considered closed.

Ill. Enoineerina

E2 Engineering Support of Facilities and Equipment

E2.1 Failure to Test Main Feed and Reserve Feed Breaker Permissive Interlock Contacia,

a. Inspection Scope (37551)

The inspectors monitored and reviewed licensee staff activities surrounding the ciiscovery

of a deficient TS surveillance which rendered all five EDGs inoperable. The insper: tors

interviewed operations, engineering, and regulatory assurance department personnel and

reviewed applicable procedures.

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b. Observations and Findinas

On January 8,1998, the licensee identified that all of the station's EDGs were inoperable

due to the failure to have tested a permissive interlock contact which would have

prevented each EDG output breaker from closing onto its associated bus when the bus

was energized due to either the main er reserve output breakers being closed. The

licensee discovered this deficient condition while reviewing surveillances as part of the  ;

improved TS project. Specifically, a SE was reviewin0 a surveillance procedure that

verified that both the main and reserve feeder breakers had to be open to satisfy the EDG

output breaker's closing contact. The SE realized that the surveillance did not ensure

that not having the interlock satisfied prevented the proper operation of the EDG output

breaker. After operations department personnel discussed the issue with engineering

personnel, the licensee declared all five EDGs inoperable since the permissive interlock

contact, for each EDG, had potentially never been tested. The licensee subsequently

tested the applicable interlock contact for all five EDGs satisfactorily by January 9,1998,

and declared all the EDGs operable. At the end of this inspection period, the licensee's

investigation of this event was stillin progress. Specifically, the licensee vcas in the

process of reviewing whether other surveillance tests had inherently tested these

contacts. This issue is considered an Unresolved llem (50-295/97032 02;

50 304/97032 02) pending the inspectors' review of the licensee's cornpleted

investigation and corrective actions,

c. Conclusion

The inspectors concluded that engineering department personnel demonstrated a strong

questioning attitude and an in depth system knowledge in questioning whether the

surveillance tests had adequately tested all the necessary interlocks associated with the

,

operability of the emergency diesel generators. in addition, the inspectors concluded that

the licensee took effective immediate corrective actions in testing all the EDGs promptly

after discovery of the problem.

E8 Miscellaneous Engineering issues

E8.1 (Closed) Unresolved item 50-295/96010-07: 50 304/96010-07: Degraded shaft driven

lube oil pump for the 1B centrifugal charging pump.

The inspectors reviewed the licensee's followup actions to a potentially degraded pump.

The licensee sent the shaft driven lube oil pump to the v'andor for testing. The testing

indicated that the pump was not degraded; as it was found to develop sufficient lube oil

pressure to meet its support function. Based on these results, the licensoe determined

that the 1B charging pump would have been capable of providing its safe shutdown

function during accident conditions for the period from April to August 1996. The

inspectors considered that the licensee's corrective actions were adequate. This

unresolved item is considered closed.

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E8.2 (Closed) Unresolved item 50 295/9601711: 50 304/9601711: Fuel assembly clearance

discrepancies between the Updated Final Safety Analysis (UFSAR) and actual plant

confQuration during fuel moves.

The inspectors reviewed the licensee's followup actions for addressing the clearance

discrepancies identified on November 24,1996. The licensee's corrective actions

included the replacement of the spent fuel handling tool (SFHT) with a shorter tool. The

4" shorter SFHT provided more physical clearance between the bottom of 4 3 fuel and the

%elt gate, in addition, the licensee completed evaluation No. 22S B 141X 009, for the

use of the shorter SFHT and concluded that adequate shielding would be available with

the use of this lool and that an unreviewed safety question had not been created due to

these discrepancies. The inspectors agreed with the licensee's conclusion. The

inspectors considered the licensee's corrective actions adequate. This unresolved item

is considered closed.

E8.3 (Closed) Licensee Event Report 50 295/97015-00: Unit i emergency diesel generators

and Unit 2 residual heat removal system inoperable and an inadvertent engineered safety

feature actuation while performing TS related surveillances

The circumstances surrounding these events were inspected and documented in NRC

Inspection Report No. 50 205/97019;50 304/97019. The inspectors' assessment of the

licensee's corrective actions will be completed during the closure of Violation

l No. 50 295/97019-03c. Consequently, this licensee event report is considered closed.

!

l E8.4 (Open) Licensee Event Report 50-295/97023-00: Auxiliary building ventilation does not

conform to the UFSAR due to an analysis deficiency

On November 7,1997, the licensee identified that not all the exhaust air flow from the

pipe tunnels would have been filtered during a loss of coolant accident (LOCA). Through

a review of operator actions in the event of a LOCA, the licensee determined that

operators were directed to start the auxiliary building ventilation system and place the

hand switch for the system into " cubicle mode" prior to starting the recirculation phase of

a LOCA. The licensee determined that placement of the switch in this position did not

automatically align the exhaust air flow from the pipe tunnels through the charcoal filters.

As a result, the air flow would have remained unfiltered until the pipe tunnel radiation

monitor ectuated and caused the exhaust air flow to be routed through the charcoal

filters.

e

The licensee determined that this unfiltered air flow had not been accounted for in the

off site dose and the control room habitabihty analyses and reported this degraded

condition in accordance with 10 CFR 50.72 requirements on November 10,1997. The

licensee determined that the safety significance of this issue was minimal based on

engineering judgment and preliminary calculations which indicated that the potential

increase in offsite dose and control room department personnel dose was insignificant.

The licensee had not finalized the calculations by the end of this inspection period.

Therefore, this licensee event report will remain open pending the inspectors' review of

the licensee's completed calculations.

14

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IV. Plant Suncort

R4 Staff Knowledge and Performance in Radiological Protection and Chemistry (RPAC)

R4.1 Improper Usaae of Drum Containina Radioactive Content f71750) I

On January 16,1998, the inspectors noted that a 55 gallon drum was propped against an

access door in the auxiliary building. The inspectors questioned the SM on the purpose of

the drum. The SM informed the inspectors that the door was broken and that the drum

was being used to maintain the door closed until parts were received to repair the door.

The drum, containing a mixture of water and glycol, had a radioactive material tag

indicating the drum's contents had a radioactive dose rate reading of less than

1 mrem /hr. Due to the low radioactive limits of the drum's contents, radiation protection

personnel determined that it was acceptable to use the drum in this manner.

The inspectors informed the radiation protection manager of the observations. Because

this practice was not within the expectations of licensee management, the licensee

removed the barrel. The inspectors concluded that radiation protection personnel did not

demonstrate sound radiation protection practices when they allowed a 55 gallon drum

labeled as containing low radioactive material to be used in this manner.

R8 Miscellaneous RP&C lasues

R8.1 (Closed) Violation 50 295/91003-01: 50 304/91003-01: Inadequate qualification of

Radiation Protection Supervisor (RPS).

On August 13,1990, the licensee promoted an individual to the position of RPS who did

not meet the American National Standards Institute (ANSI) required minimum of four

years experience in the discipline of radiation protection. The inspector noted that the

licensee had completed the following corrective actions:

. The individual was removed from the active position of RPS and retained as a

Radiation Supervisor in Training to gain the required experience.

. An ANSI qualified RPS reviewed a sample of surveillances, radiation work

permits, surveys, and logs, that had been completed by the unqualified RPS to

ensure the adequacy of the individual's supervisory review.

. An ANSI qualification checklist was developed for inclusion into ZAP 200-06,

' Personnel Qualification,' Revision 4(G) to ensure an individual's proper

qualification prior to an assignment to a position.

. An annual staffing and training audit was performed to review personnel

qualifications and experience to verify compliance to ANSI 18.1, " Selection and

Training of Nuclear Power Plant Personnel."

The inspector verified that nc sin liar events had been documen'ed in the licensee's

corrective action system. The inspectors considered the licens ,e's corrective actions

adequate to prevent recurrence. This violation is considered closed.

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R8.2 (Closed) Inspection Followup Item 50 295/95023 01: 50-304/95023 01:

January 20,1996, OB lake discharge tank overflow event.

The incident was subsequently characterized as a violation of NRC requirements as

documented in NRC Inspection Report No. 50 295/96007; 50 304/96007. The inspectors' j

assessment of the licensee's corrective actions will be completed during the closure of

Violation 50 295/960t0 01; 50 304/96010-01 which documented a subsequent

August 15,1996 overflow event. Consequently, this inspection followup item is

considered closed.

R8.3 (Closed) Violations 50 295/96010 01: 50 304/96010-01 and 50-295/96216 01013:

50 304/96216-01013: Failure to follow procedures which resulted in OB lake discharge

overflow.

The inspectors reviewed and verified that the licensee had completed all the initial

corrective actions for this event. However, the licensee's failure to follow sol 36J,

• Discharge Blowdown Monitor Tanks to Lake Discharge Tank OB," Revision 3, resulted in

a subsequent August 16,1996, overflow event of the OB lake discharge tank. The

licensee determined that the additional overflow event of the OB lake discharge tank on

August 16,1996, indicated that corrective actions implemented for the January 1996 tank

overCow event were not effective in preventing the August 16,1996, tank overflow event.

Consequently, the licensee expanded its response to the January 1996 incident to correct

issues that contnbuted to the August 1996 event. The inspectors verified that the

licensee had completed the following corrective actions to prevent recurrence:

.

The assistant superintendent of operations counseled the individuals involved in

the overflow events and issued Operations Policy 96-02, " Verification of Valves in

the Operating Department," dated August 17,1996. The policy required operators

to verify the position of manual valves by a hands on physical check.

.

The licensee revised sol 36J to relocate the steps, which direct personnel to

verify that the OB lake discharge tank inlet valves were properly closed after

completing a transfer of water from a blowdown monitor tank, in the same section

of the procedure as the transfer steps.

+

The operations department changed their philosophy of filling radioactive waste

tanks to above the high level alarm. The licensee implemented this philosophy

change, by revising ZAP 30013A, " Water Inventory Manapment Program,"

Revision 3, to include maximum tank filllevels and to iMude the reqWement that

personnel adhere to these levels.

The inspectors discussed the event and corrective actions with operatiorit %,artment

personnel. These personnel were cognizant of the event and the corrective actions.

Radioactive waste operators were aware of the significance of tank alarms and of the

administrative maximum tank levels. In addition, no additional tank overflows had

occurred since the August 16,1996, tank overflow event. The inspectors considered the

licensee's corrective actions adequate to prevent recurrence. This violtstion is considered

close6.

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R8.4 (Closed) Violation 50-295/96010-03: 50 304/96010-03: Failure to have adequate

procedures for rigging of new fuel containers.

The inspectors reviewed the licensee's corrective actions for this July 30,1996, fuel

container rigging event. The inspectors verified that the licensee had revised Fuel

Handling instruction (FHI) . 02, * Handling of Shipping Containers and Site Removal of

New Fuel Assemblies from Shipping Containers and Inspection of New Fuel," Revision 3,

l to ensure that fuel handling department personnel used the proper tools and followed the

proper rigging practices. Following the July 30,1996, incident, the licensee completed a

l revision to FHl 02, and the remaining fuel containers were moved without incident. In

l addition, the inspectors verified that the licensee had reviewed and revised other fuel

I

handling department surveillances and instructions. Specifically, the licensee had revised

the following procedures to provide improved rigging instructions:

• FHl.04," Receipt and Inspection of New RCC [ rod control clusters) Assemblies,"

Revision 1.

.

FHi 17, "U V. 260 Underwater Filter / Vacuum Units," Revision 1.

.

FHl 18, * FPS-65 Shielded Filter / Pump Assembly," Revision 1.

The inspectors considered the licensee's corrective actions adequate to prevent

recurrence. This violation is considered closed.

R8.5 (Closed) Violation 50 295/96010-09: 50-304/96010-09: A radiation protection procedure

failed to specify the appropriate compensatory actions for an inoperable radiation monitor

(RM).

The inspectors reviewed the licensee's corrective actions for the failure to perform

compensatory measures when RM 2R AR03 was inoperable on July 26,1996. Radiation

protection personnel revised Zion Raoistion Procedure (ZRP) 582012, "Out of Service

Requirements for Radiation Monitors," Revision 4, to specify compensatory measures

when 2R AR03 was inoperable, in addition, the licensee reviewed ZRP 5820-12 to

correct any additional deficiencies. The inspectors determined that this review was

inadequate, in that, the licensee failed to identify that ZRP 582012 had incorrectly stated

that no compensatory actions were required when monitor ORE 0006 was inoperable, As

a result, the licensee did not perform compensatory actions when ORE 0006 was

inuperable on April 6,1997. The licensee's failure to implement compensatory measures

for the inoperability of ORE-0006 was documented as a violation in NRC Inspection

Report No. 50-295/97020; 50-304/97020. The inspectors' assessment of the licensee's

corrective actions will be completed during the closure of Violation 50-295/304 97020-05.

Consequently, this violation is considered closed.

R8.6 (Closed) Unresolved item 50 295/9602102: 50-304/96021-02: Processing of chemical

drain tank (CDT) contents not consistent with UFSAR.

The inspectors reviewed the licensee's follow up actions for addressing the CDT

processing discrepancies. The inspectors reviewed the licensee's completed

10 CFR 50.59 evaluation, No. 97-2302, for the difference in CDT processing.

The licensee concluded that the difference in processing did not create an unreviewed

__

17

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safety question. The inspectors agreed with the licensee's conclusion, since the contents

of CDT were routed to the auxiliary building floor drain analysis tank and either tank's

contents were processed through domineralizers or sampled to confirm that processing

was not needed. The inspectors considered the licensee's actions adequate. This

unresolved item is considered closed,

R8.7 (Open) Unresolved item 50-295/96021-03: 50 304/9602103: The licensee's processes

for sampling, processing and maintaining of radioactive waste tanks and evaporators

differed from the processes described in the UFSAR.

The inspectors rsviewed the licensee's followup actions to addre:s these processing

differences. Tne inspectors reviewed the licensee's completed 10 CFR 50.59 evaluation,

No. 97 2237. The licensee concluded that the manner in which the auxiliary building

equipment drain analysis tank and auxiliary building floor drain analysis tank contents

were sampled and processed did not create an unreviewed safety question. The

inspectors agreed with the licensee's conclusion, since the contents of the tank were

ultimately processed and/or sampled prior to release, and considered the licensee's

corrective actions adequate.

At the time of this inspection, the engineering staff had not completed the evaluation of

the impact of maintaining the radioactive waste evaporator in an inoperable condition.

This unresolved item will remain open pending the inspectors' review of the licensee's

completed evaluation.

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at

the conclusion of the inspection on February 2,1998. The licensee acknowledged the

findings presented. The inspectors asked the licensee whether any materials examined

during the inspection should be considered proprietary. No proprietary information was

identified.

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.[ PARTIAL LIST OF PERSONS CONTACTED

)

Licensee

' J. Brons, Site Vice President

R. Starkey, Plant General Manager ,

,

K. Dickerson, Executive Assistant to Site Vice President

T, Saksefski, Executive Assistant to Site Vice President

1 D. Bump, Restart Manager

R.6/ uck, d Site Quality Verification Manager

E. Katzman, Radiation Protection Manager

!.

R. Landrum, operations Manager

'

L. Schmeling, Training Manager

,

R. Godley, Regulatory Assurance Supervisor >

+

F. Jones, Regulatory Assurance

3

MBQ

K. O' Brien, Acting Chief, Reactor Projects Branch 2

. A. Vegel, Senior Resident inspector

D. Calhoun, Resident inspector

i

.

J. Yesinowski

1

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LIST OF INSPECTION PROCEDURES USED

IP 37551 Engineering l

lP 62707 Maintenance Observation  ;

IP 71707 Plant Operations i

IP 71714 Plant Operation Cold Weather Preparations  ;

IP 71750 Plant Support i

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50 295/97023 00 LER Auxiliary building ventilation does not conform to the

UFSAR due to an analysis deficiency.

50-304/97032 01 VIO Failure to restore AFW system to proper configuration while

clearing OOS.

50-295/304 97032 02 URI Review licensee investigation of potential failure to test

main feed and reserve feed breaker permissive interlock

contacts.

9I219A

50-295/304 90031 02 VIO The licensee lost several hundred work requests that were

written between 1980 and 1990.

50 295/304 91003 01 VIO Inadequate qualification of radiation protection supervisor.

50 295/304 95020-04 URI System engineering personnel did not notify control room of

their actions to enter the control cabinets.

50 295/304 95023 01 IFl January 20,1996, overflow of the OB lake discharge tank.

50-295/304 96005 05 IFl 2B emergency diesel generator failure to start.

50 304/96007-00 LER Technical Specification action statement not performed

'

within allowable time frame as a result of management

deficiency.

50-295/96010-00 and -01 LER Below freezing conditions create flow restriction in the

safety injection pump recirculation line due to design.

50-295/304 96010-01 VIO Failure to follow procedures which resulted in OB lake

discharge overflow.

50-295/304 96010 03 VIO Failure to have adequate procedures for rigging of new fuel

containers.

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50 295/304 96010-07 URI Degraded shaft driven lube oil pump for the 1B charging

pump.

50-295/304 96010-09 VIO A radiation protection procedure failed to specify the

appropriate compensatory actions for an inoperable ,

radiation monitor. )

50 295/304 96013 03 VIO Failure to take prompt corrective actions for potentially

defective steam generator tubes investigation which had

identified four contributors.

50 295/304 96017 11 URI Review the evaluation of spent fuel pool fuel assembly l

clearances during fuel moves.  !

'

50 295/304 96021 02 URI Processing of chemical drain tank contents not consistent

with Updated Final Safety Analysis Report .

50-304/97001 00 LER Unit 2 instrument bus pertuitation caused by a short

occurring during 2C accumulator level transmitter

, modification installation resulted in engineered safely

feature actuation.

50-295/97006-00 LER Zion Station exceeded a Limiting Condition for Operation

due to inadequate procedure controls.

50 295/97015-00 LER Unit 1 emergency diesel generators and Unit 2 residual

heat removal system inoperable and inadvertent ESF

actuation while performing Technical Specification related

surveillances.

50 295/97021 00 LER Setpoints for power range rate trip surveillance were left

greater than Technical Specification limits.

Discussed

50 295/304 96021 03 URI The licensee's processes for sampling, processing and

maintaining of radioactive waste tanks and evaporators

differed fror.i the processes described in the UFSAR.

50 295/97023-00 LER Auxiliary building ventilation does not conform to the

UFSAR due to an analysis deficiency

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List OF ACRONYMS USED -

!

AFW- Auxiliary Feedwater System

ANSI American National Standard Institute

CDT Chemical Drain Tank  ;

CNOO Chief Nuclear Operating Officer 3

CST Condensate Storage Tank  !

CR Control Room .

EDG Emergency Diesel Generator

ESF Engineered Safety Feature ,

FHI Fuel Handling Instruction '

IDNS I Pnois Department of Nuclear Safety .

IP inspection Procedure  ;

LER Licensee Event Report

LOCA Loss of Coolant Accident

MSL- Main Steam Line  ;

NCV Non Cited Violation

'

NRC Nuclear Regulatory Commission .

NRR Nuclear Reactor Regulation '

OOS Out of Service

OWA Operator Workaround

OWCC Operations Work Control Center

'

PDR Public Document Room

PlF _ Problem identification Form ,

PT Periodic Test

RCC Rod Control Clusters

RM- Radiation Monitor .

RPS Radiation Protection Supervisor

RTS Return to service

SE System Engineer ,

SCAQ Significant Condition Adverse to Quality

SFHT Spent Fuel Handling Tool

SI Safety injection

SM Shift Manager ,

sol System Operating Instructions

-TS Technical Specifications  :

UFSAR Updated Final Safety Analysis Report -

URI Unresolved item '

VIO Violation

WR Work Request

ZAP Zion Administrative Procedure

ZRP Zion Radiation Procedure

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