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| {{Adams | | {{Adams |
| | number = ML20215A819 | | | number = ML20207C168 |
| | issue date = 06/06/1987 | | | issue date = 07/29/1988 |
| | title = Insp Repts 50-295/87-09 & 50-304/87-11 on 870418-0601.No Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Summary of Operations & Unit 2 Diesel Fuel Oil Tank Room Flooding | | | title = Informs of 880811 Enforcement Conference in Region III Ofc to Discuss Violations Noted in Insp Repts 50-295/87-09 & 50-304/887-11.Util Should Be Prepared to Discuss Listed Items |
| | author name = Hinds J | | | author name = Miller H |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| | addressee name = | | | addressee name = Reed C |
| | addressee affiliation = | | | addressee affiliation = COMMONWEALTH EDISON CO. |
| | docket = 05000295, 05000304 | | | docket = 05000295, 05000304 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-295-87-09, 50-295-87-9, 50-304-87-11, NUDOCS 8706170100 | | | document report number = GL-88-07, GL-88-7, NUDOCS 8808050081 |
| | package number = ML20215A789
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 1 |
| | page count = 14 | |
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| | ,, M JUL 2 91988 Docket No. 50-295 Docket No. 50-304 Comonwealth Edison Company ATTN: Mr. Cordell Reed , |
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| | Senior Vice President Post Office Box 767 Chicago, IL 60690 l Gentlemen: . |
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| | l SUBJECT: ENFORCEMENT CONFERENCE |
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| V.S. NUCLEAR REGULATORY COMMISSION !
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| ==REGION III==
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| Report Nos. 50-295/87009(DRP);50-304/87011(DRP)
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| Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 | |
| 'I Licensee: Commonwealth Edison Company !
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| P. O. Box 767 i Chicago, IL 60690 ;
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| Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, IL Inspection Conducted: April 18 through June 1, 1987
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| Inspectors: M. M. Holzmer :
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| P. L. Eng N. Williamsen d
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| Approved B : 93E L=kuer J. M. Hinds,<A(ftincf Chief Gsc/d2 7
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| +7 Reactor Projects Section 1A Date a
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| Inspection Summan i
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| Inspection on A)ril 18 through June 1, 1987 (Report Nos. 50-295/87009(DRP)*
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| 50-304/87011(DR))) J Areas Inspected 1 R'outine, unannounced resident inspection of licensee action l on previous inspection findings; ''nnmary of operations; Unit I reactor trip i at zero power; Unit I safety injection due to all four main steam isolation valves opening; Federal Field Exercise dry run; Unit 2 diesel fuel oil tank room flooding; operational safety verification and engineered safety feature (ESF) system walkdown; surveillance observation; maintenance observation; licensee event reports (LERs); training; Generic Letter followup; and site tour by Branch Chie Results: Of the areas inspected, no violations or deviations were identifie .
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| 8706170100 870609 PDR ADOCK 05000295 O PDR
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| ,,,. .* i DETAILS i Persons Contacted
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| *G. Pliml, Station Manager
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| *E. Fuerst, Superintendent, Production
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| *T. Rieck, Superintendent, Services i
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| * Kurth, Assistant Station Superintendent, Operations R. Johnson, Assistant Station Superintendent, Maintenance J. Gilmore, Assistant Station Superintendent, Planning ;
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| *R. Budowle, Assistant Station Superintendent, Technical Services i L. Pruett, Unit 1 Operating Engineer i N. Valos, Unit 2 Operating Engineer M. Carnahan, Training Supervisor
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| *R. Cascarano, Technical Staff Supervisor C. Schultz, Regulatory Asswance Administrator V. Williams, Station Health Physicist
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| *J. Ballard, Quality Control Supervisor i
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| *W. Stone, Quality Assurance Supervisor
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| *A. Bless, Regulatory Assurance Engineer {
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| * Indicates persons present at exit intervie t 1 Licensee Actions on Previous Inspection Findings (92701)
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| (Closed) Unresolved Items 295/86025-04(DRSS);304/86025-04(DRSS): !
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| Missed surveillances on radiation monitors. These items were I subsequently addressed in inspection report 295/86031(DRP);
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| 304/86031(ORP). Investigation of the associated events resulted l in a violatio These unresolved items are therefore considered close (Closed) Open items (295/86028-06; 304/86028-06): Operator training on demineralized water (DW) system containment isolation valves. Review of the training lesson plans and training records associated with containment isolation valves and their associated support systems revealed that the training administered to operations personnel was sufficient to have prevented the occurrence of the DW event which was discussed in inspection report 295/86032; 304/86032. These items are considered close (Closed) Unresolved Item (304/85032-01(DRP)): -Environmentally qualified (EQ) valve operators found to have unqualified internal wiring. The licensee identified four limitorque motor operated valve (MOV, operators with unqualified wires on September 27, 1985, and reported the condition pursuant to 10 CFR Part 21. This issue was unresolved pending review of the licensee's report, and determination of whether this condition constituted a violatio Non-EQ wiring in EQ limitorque M0V operators has since been found at many U. S. nuclear generating stations, and this matter was reviewed by NRC headquarters staf The NRC has determined-that no enforcement action will be taken for Environmental Qualification violations involving unqualified valve motor internal wiring. This decision is based on the generic nature of the deficiencies, extenuating
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| circumstances, and limited potential safety significance of the violation. This item is considered close (Closed) Violation (295/86013-01(DRP);304/86012-01(DRP)): Failure to adequately calibrate the level instruments for the containment spray H additive tanks, resulting in the tank levels for both units being below Technical Specification limits for more than 8 hour Prior to June of 1986, the "Magnetrol" capacitance-type level instruments, LIS-CS-44 and {
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| -45, were calibrated using a bubbler-type gauge. However, the !
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| calibration procedure was faulty in three ways: (1) the calibration procedure assumed a specific gravity of 1.3 whereas in the previous few !
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| years the specific gravity actually varied between 1.3 and 1.45, (2) i there was an uncompensated two-inch difference between the zero reference points for the bubbler and the Magnetrol, and (3) the procedures did not mandate any type of mixing which should be done prior to sampling and calibration. The corrective action has included (1) using a large diameter, clear, tygon tube as a " sight-glass" whenever calibrating the Magnetrol level instruments, thus eliminating most of the specific-gravity-induced corrections, (2) correcting the calibration procedure to eliminate the two-inch difference in zero reference points, and (3)
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| revising the procedures (2L-CS-44, and 45 and 50I-4 " Containment Spray")
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| to require mixing prior to calibration and sampling. This Open Item is close l No violations or deviations were identifie . Summary Of Operations i
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| i Unit 1 The unit began the inspection period in Mode 1 at 80% power. Power levels were limited due to excessive genwator frame vibrations. On April 25, 1987, the unit was taken off the line in order to reduce generator vibrations and repair a generator hydrogen leak. The unit stayed critical in Mode 2 until April 30, 1987, when the licensee .
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| initiated a reactor shutdown in order to reduce probability of l inadvertent trips. At 3:20 a.m., during the shutdown, the reactor !
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| tripped at 10E+5 counts per second in the source range due to noise on j source range channel IN31 (see paragraph 4). At 11:00 a.m. the same day, a steam flow delta-pressure safety injection occurred when all l four main steam isolation valves inadvertently opened (see paragraph 5). Following repairs to the generator, the unit was made critical on May 3, 1987, and after two days of generator balancing work, the unit was tied to the grid on May 5, 198 On May 10, 1987, the unit was again taken off the grid to further reduce generator frame vibrations. The unit remained critical-in Mode 2 until May 15, 1987, when the unit was tied to the grid. The unit operated at power levels up to 95% for the remainder of the inspection perio During most of this time, the unit was limited to 90% power due to spiking on steam flow instrument channel !
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| Unit 2 The unit remained in the cold shutdown and refueling modes for the entire inspection perio No violations or deviations were identifie ! April 30, 1987 Unit 1 Reactor Trip From Zero Power On April 30, 1987, during a reactor shutdown, Unit 1 tripped from zero power. (5E-11 amps in the intermediate range (IR)) when one of two source
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| range nuclear instruments (SRNI) tripped on a high flux signal. Unit I l had been maintained critical between 0% and 3% power since April 25, j 1987, for main generator balancing work. When it was learned that '
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| additional work would be needed, the unit was shut down for the purpose of reducing the probability of a low power tri Following the trip, all safety systems functioned normall '
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| The trip occurred when reactor power had been decreased.to the point at t which the nuclear station operator (NS0) energized the two SRN1 channels, l 1N31 and 1N32, in accordance with procedure GOP-4, " Plant Shutdown". i SRNIs are normally de-energized during reactor startups when reactor j power is at the high end of their range to prevent damage to the detectors. During shutdowns, when power decreases to the bottom of the I IRNIs, the SRNIs are re-energized. Immediately after the SRNIs were
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| re-energized, an electrical noise spike caused 1N31 to reach the high l flux trip setpoint. When 1N31 tripped, the "one out of two" reactor j protection logic tripped the reacto j
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| The noise spike was attributed to the use of the spare detector for 1N3 (
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| The spare detector was connected to IN31 during the previous Unit 1 !
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| refueling outage after the normal detector failed. This connection l
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| involved the use of an extra 60 feet of cable which acted as an antenna I for electrical nois '
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| The temporary cable for the spare detector was relocated, which reduced the noise on channel IN31 as observed during the reactor startup on l May 3, 1987. As an additional precaution, the SRNI high flux reactor trip for channel 1N31 was bypassed to prevent additional inadvertent reactor trips until the normal detector can be replaced. (Technical Specifications require only one operable SRNI trip channel).
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| No violations or deviations were identified. Additional NRC review of this event will be performed in response to the licensee's LE . April 30, 1987, Unit 1 Safety Injection at Hot Shutdown On April 30, 1987, with Unit 1 in hot shutdown (mode 3), a steam line delta-pressure safety injection occurred when all four main steam isolation valves (MSIV) inadvertently opened. The event occurred due to an equipment operator failing to refer to plant procedures prior to removing MSIV control power fuse In addition poor communications contributed to the even _
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| This event was reviewed in detail in NRC Inspection Report 1 295/87012(DRP). Determination of enforcement action will be done by NRC Region III following an Enforcement Board meeting on June 3, 198 . May 5 and 6,1987 Federal Field Exercise Dry Run On June 23 through 25, 1987, a Federal Field Exercise (FFE) will be !
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| conducted at the Zion Station to test emergency preparedness capabilities of Commonwealth Edison and local state and federal agencies. This exercise will involve over 700 participants who will be simulating response to a severe reactor accident. On May 5 and 6,1987, a dry run of the FFE was conducted. The resident inspectors participated in the FFE dry run in the control room (CR) and technical support center (TSC).
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| The dry run was helpful in that it improved the resident inspectors'
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| knowledge and experience with regard to interfacing with the licensee and with offsite NRC personne Following the dry run, the resident inspectors requested that a controlled copy of the licensee's Emergency Response Guidelines (ERGS)
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| be kept available for NRC site team use in the TSC, and that a telephone set or line be made available to the NRC inspectors in the CR. The
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| licensee agreed to both requests and has already installed the requested e
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| telephone lin n No violations or deviations were identifie . Flooding in Diesel Fuel Oil Storage Tank Rooms (93702)
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| On May 21, 1987, with Unit 2 in a refueling outage and no fuel in the reactor vessel, the control room was notified of a large leak apparently spilling from the Unit 2 diesel fuel oil storage tank rooms nnto the 560 foot elevation floor of the turbine building. Both 2A and 2B diesel generators were out of service for maintenance work at the tim Investigation revealed that roughly 11 feet of service water had accumulated in the 28 fuel oil storage tank room and that approximately 8 feet of water had accumulated in the 2A roo Discussions with members of the licensee's staff revealed that work request Z56525 had been written on April 21, 1987, to open service water (SW) check valve 25W0010, located in the 2A diesel fuel oil tank storage room, for Inservice Inspection (ISI) purposes. Initial attempts to open the valvw were unsuccessful as isolation of the check valve from service water flow was not achieved. Contractor personnel assigned to open the check valve for inspection then returned the work request and out of service paperwork to operations and proceeded under a separate work'
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| request, 259405, to open a parallel check valve 2SW0011, located in the 2B tank room for inspection. As in the case of the 2SW0010 valve, isolation was, not adequate for valve inspection. The contract personnel then returned the work package to operations who performed several valve ,
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| t manipulations to achieve sufficient isolation for valve inspectio Following system adjustments, operations notified the maintenance
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| contract personnel ~that isolation had been achieved, and issued an out j of service package and work request Z60054 for inspection of the 2SW0010 '
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| check valve. The licensee stated that review of the work request package revealed that equipment location was erroneously specified as the 2B storage rcom. Upon receipt of the work request during the midnight I
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| shift, the contract mechanics proceeded to the 2B room and erroneously i opened the bonnet on the 2SWOO11 valve. Field.. inspection revealed.tha the check valves were not labelled. Shift change occurred before actual inspection of the valve began. Members of the day shift received-the work package and correctly went to the 2A tank room where they removed the bonnet of the 2SW0010 check valve and ISI inspection was performed- i satisfactoril Upon completion of the inspection, the 2SWOO10 check '
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| valve bonnet was reinstalled and the completed work request Z60054- )
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| including .the out of service was returned to operations for closur j Operations then aligned service water to provide cooling to the 2A;and j 2B diesel generator intercoolers and initiated flow in preparation for 4 surveillance testing of the 28 diesel. Service water then entered the !
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| header line and spilled out of the open bonnet of the 2SW0011. check valve
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| into the 2B tank room. The water level increased in the tank room until 1 it began to rise above the level of th~e floor jamb of the personnel access door to the turbine building at which point it began to flow out ,
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| of the room onto the turbine building basement floor._ Water also spilled 1 into the 2A storage tank room via the connecting door between the 2B and :
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| 2A rooms and probably through the common floor drain line Upon discovery, flow to the pertinent portion of the line was terminated and the room doors opened. The licensee estimates the amount of water in~the i two rooms as approximately 105,000 and 76,000 gallons for the 28 and_2A i storage tank rooms, respectivel Equipment requiring inspection prior to return to service, as identified by the licensee are: the diesel fuel oil transfer pumps associated with the 2A and 2B diesel generators, diesel fuel oil contained in both the 2A and 2B tanks, local valve controls for service water cross tie valves, '2 M0V SW0022 and 2 MOV SW0023, and the 20 condensate / condensate booster
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| (CCB) pump The CCB pump requires inspection due to the fact that water sprayed onto the 2D CCB pump when the 2B room ' door was opene ,
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| The licensee stated that inspection of the diesel fuel oil transfer pumps, including vibration analyses, revealed that the pumps were not damaged by the. flood. Members of the Inservice inspection group visually c inspected the 2A and 2B tanks and stated that the integrity of-the tanks !
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| had not been affected. Visual inspection and chemical analysis of the J diesel fuel stored in the tanks at the time of.the event did not identify any contamination from free wate *
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| The licensee noted that while this event occurred with the reactor in a -
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| safe condition, contributors to the event are significant in that the (
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| event is a wrong train event complicated by the fact that the components -
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| were not labelled. In addition, the work request Z60054 incorrectly specified the location of the valves which further exacerbated the even It is not known whether the out of service procedures were correctl l followed during this evolutio '
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| , The licensee is investigating the causes of the event and has required that all work performed by the maintenance contractor be checked by CECO I Maintenance staff personnel. In addition the Quality Control group was j required to review all work in progress immediately following occurrence !
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| of the event that was performed by maintenance contractor personnel with !
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| particular attention to out of services, equipment maintenance and work i package preparation and documentation. The crosstie MOVs and the 2D CCB l pumps will be inspected and repaired if necessary prior to return to l servic This.is considered an Unresolved Item pending review by NRC resident inspectors of the licensee's investigation and corrective actio l (304/87011-01(DRP)).
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| 8. Operational Safety Verification and Engineered Safety Features System i Walkdown (71707 & 71710) i The inspectors observed control room operations, reviewed applicable l logs and conducted discussions with control room operators from April 18 '
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| through June 1, 1987. During these discussions and observations, the inspectors ascertained that the operators were alert, fully cognizant of l plant conditions, attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified i proper return to service of affected components. Tours of the auxiliary and turbine buildings were conducted to observe plant equipment l conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspectors by observation and direct interview verified that selected physical security activities were being implemented in accordance with the station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. From April 18, 1987 to June 1, 1987, the inspectors walked down the accessible portions of the main steam, auxiliary feedwater and safety related electrical systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications, 10 CFR, and administrative procedure The resident inspectors made the following additional observations:
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| Plant shutdowns were observed from the control room on April 25, 1987 and May 10, 1987. During both shutdowns the inspector observed that operators frequently referred to plant procedures, that the procedures were properly approved and appropriate to the tas The inspector also noted that during the April 25 shutdown, there appeared to be excessive noise in the control room. The May 10 shutdown was well controlled and professionally performe R l
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| licensee that many puddles of water in the auxiliary building were caused by condensation due to the high humidity. This was apparently caused by the inoperability of the auxiliary building intake cooling coil None of these comments related to the violation of regulatory requirements or constituted degradations of safety, but were provided !
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| to the licensee for correction as appropriat i No violations or deviations were identifie . Monthly Surveillance Observation (61726) I The inspector observed Technical Specifications required surveillance testing on the containment spray additive and hydrogen recombiner systems i and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting 1 l
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| conditions for operation were met, that removal and restoration of the !
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| affected components were accomplished, that test results conformed with l technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and ;
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| resolved by appropriate management personne l The inspector also witnessed portions of the following test activities: '
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| PT-6A, "NaOH Spray Additive Tank Checks TSS 15.6.77, "Special Leak Test Recombiner Piping and Ductwork" !
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| With regard to PT-6A, the procedure specified (pneumatic) mixing of the Containment Spray Additive Tank prior to sampling, and S01-4 contains the procedure for a temporary connection from the tank to a nitrogen or air i supply, there is no requirement to verify that gas is actually bubbling ,
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| thru the tank. When questioned the operator was able to verify flo j With regards to TSS 15.6.77, the inspector had the following comments:
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| Step 5.4 directs test personnel to remove an 8 inch blind ;
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| flange from line RV004-8" x 1-R in the purge exhaust filter plenum !
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| area. Step 5.5 then directs test personnel to connect line RV004-8" i x 1-R to blank-off plate. It was not clear to the inspector how the !
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| connection was to be made. The test engineer stated that an elbow was typically use Step 6.1 contains a blank for recording the certified portable test instrument number; however, the type of instrument is not specified )
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| and calibration data is not required to be noted in the procedur !
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| The test engineer stated that there is only one certified test {
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| instrument that can be used for this test and that Technical Staff I personnel who are qualified to perform this test know which '
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| instrument to us i
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| ~ Step 6.1 is followed by a sketch of a portion of piping which was )
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| not explicitly labelled. The test engineer stated that the sketch a
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| was a schematic of the certified test instrument. discussed above and l that Technical Staff personnel qualified to perform this test knew what the sketch depicte i I
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| Step 7.4 required that the leak rate be recorded. Discussions with the test engineer revealed that although he was aware that the test value was the lowest leak rate obtained in the past
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| .three years, the leak rates associated with this test are not l trended. No requirement for trending of this data was found, i The inspector then examined the training and qualification requirements for performance of this test by technical staff l personnel. Review of the training records revealed-that personnel -)
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| qualified to perform this TSS who were employed by the licensee '
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| prior to September 1,1985 were " grandfathered" and that specific training documentation for individual.TSSs did.not exist. The group leader for this area of the technical staff stated that should a new technical staff engineer need to be qualified on a'particular TSS, i individual training would take plac The inspector noted that Zion administrative procedure (ZAP)
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| 10-53-2, " Qualification Requirements for Technical Staff Personnel Performing Surveillances Required By Technical Specification,"
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| states that outlines for training' individuals to perform surveill-ances shall be developed by the technical staff group . leader, approved by the Technical Staff Supervisor, and kept on file by the technical staff training coordinator. .The ZAP also requires that technical staff personnel be requalified every three years regardless of experience. The inspector noted that there was no !
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| provision for training technical staff on those surveillances not '
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| required by technical specification None of these comments related to the violation of regulatory requirements or constituted degradations of safety, but were provided to the licensee for correction as appropriat No violations or deviations were identified 10. Monthly Maintenance Observation (62703)
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| Station maintenance activities on safety related systems and components listed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides industry codes or standards and in conformance with Technical Specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were
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| inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by '
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| qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work rtquests were reviewed to determine status of outstanding j?bs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:
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| Work requests used to prepare portions of the service water system on Unit 2 for check valve inspection. Discussion of activities associated with these items are discussed in paragraph 7 of this repor Replacement of the 2B RHR pump seal and maintenance run of the pump prior to turnover to operation Calibration and venting of ILT-519, Narrow Range Steam Generator Level, l
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| Following completion of maintenance on ILT-519 the inspector verified j that these systems had been returned to service properl ;
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| The resident inspector made the following comments to the licensee:
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| During the calibration of ILT-519, a considerable amount of sediment was present in the sensing lin The Environmental Qualification Binder showed ILT-519 to be a Fischer-Porter differential pressure (dp) detector, whereas a Rosemount dp detector was installed in the field. The licensee stated that EQ binder changes are performed by Station Nuclear Engineering Department (SNED) and that SNED had.yet to provide this particular update. The engineer in charge of EQ was aware of the modification which added Rosemount dp detector None of these comments related to the violation of regulatory require-ments or constituted degradations of safety, but were provided to the licensee for correction as appropriat No violations or deviations were identifie . Licensee Event Reports (LER) Followup (92700)
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| Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had
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| been accomplished in accordance with Technical Specifications. The LERs '
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| listed below are considered closed: r UNIT 1 LER N DESCRIPTION
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| 295/86033 320 Degree Temperature Difference Between' Pressurizer Spray and Pressurizer Steam 295/86042 Automatic Start of OC Component Cooling Pump 295/86040 Improperly Terminated Leads on Environmentally J and Qualified Instruments 295/86040-1 )
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| Regarding LER 295/86040, the licensee identified three instruments having leads which had been landed on terminal blocks instead of being spliced ;
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| according to environmental qualification (EQ) requirements. The- I instruments were being inspected for proper splices as correct 1ve action- /j under LER 295/86026. The instruments were 1LT-503 and 504, wide range i steam generator level, and 1PT-403, wide range reactor coolant / pressur Unit I was in cold shutdown and the correct splices have been installe ,
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| The corresponding Unit 2 instruments were inspected and were found l satisfactory. This is considered an Unresolved Item ~pending determina-tion of enforcement by NRC Region III (295/87009-01(DRS); 304/37011-02(DRS)).
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| No violations or deviations were identifie ,
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| 3 1 12. Training (41400)
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| During the inspection period, the inspectors reviewed abnormal events and unusual occurrences which may have resulted, in part, from training deficiencies. Selected events were evaluated to determine whether the classroom, simulator, or on-the-job training received before the event was sufficient to have either prevented the occurrence or to have mitigated its effects by recognition and proper operator actio Personnel qualifications were also evaluated. In addition, the inspectors determined whether lessons learned from the events were incorporated into the training progra '
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| Events reviewed included the events discussed in this repor In
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| addition, LERs were routinely evaluated for training impac Review of technical staff training as it pertains to those surveillances required to be performed by the facility Technical SpecifiSations is f discussed in paragraph 9 of this report. Theinspectornofedthatthe *
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| large majority of technical staff personnel have been "grandfa@ered,"
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| as stated in ZAP 10-53-2, as being qualified to perform essentially all
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| TSSs at the Zion station. The inspector also noted that training ,
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| outlines pertinent to technical specifications are sparse when compared
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| to those for other groups such as operators or maintenance personne c'
| | On October 22, 1986, Comonwealth Edison Company identified three instruments inside the Zion Unit I containment having leads landed on terminal blocks as described in LERs 295/86040-00 and 01. These instruments were declared inoperable. As a result of this LER a significant deficiency was identified by l the NRC and described as an unresolved item in inspection reports 50-295/87009(DRP); i 50-304/87011(DRP). This item has since been determined by the NRC to be a violation of 10 CFR 50.4 The NRC is considering this violation for appropriate enforcement action and has scheduled an enforcement conference with you for August 11, 1988, at 9:00 l (CDT) in the Region III office to discuss the violation. At the enforcement conference, you should be prepared to discuss (1) the safety significance of l the violation as well as the number of systems and components affected in each l case; (2) the specific and underlying cause of the violation; and, (3) the actions taken or planned to correct the violation as well as to ensure yourself that Commonwealth Edison Company is currently in overall compliance with EQ requirement Furthermore, you should be prepared to discuss the violation in light of the |
| No additional training requirements or guidelines were identified for ,
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| | Modified Enforcement Policy for EQ Requirements which is described in the enclosure to Generic Letter 88-07, i.e., which items were promptly identified |
| surveillances which are not required by the facility technical specification _ .. .. . . . - .
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| | by you and were they promptly reported to the NRC? What were your best efforts to comply with the cule within the deadline? And if appropriate, why you believe that you clearly should not have known of these deficiencies prior to the November 30, 1985 deadline for being in compliance with the rules. We request that at the enforcement conference, you provide a handout that succinctly describes your position concerning these enforcement consideration |
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| d lF On May 26, 1987, the senior resident inspector presented a briefing session to the instrument mechanics regarding the role of the NRC as it applies to the Zion station. Topics covered included enforcement sanctions, delineation of inspection. responsibilities between resident and region based staff and the regulatory climat (
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| No violations or deviations were identifie '
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| 13. Generic Lette-
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| In a memoranduni dated February 28, 1986 from C. E. Norelius, Director, Division of Reactor Projects, to R. F. Warnick and others, resident
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| ,t inspectors were directed to review the licensee's response to recent
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| Generic Letters. A list of Generic Letters that applied to the Zion Nuclear Generating Station was supplied in a March 1986 memorandum from E. R. Schweibinz, Chief, Technical Support Staff (DRP).
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| The licensee respanse to the referenced Generic Letters has been reviewe Technical adequacy was not covered by this review, since that respons-ibilir.y was retained by NRR. In all cases, licensee response was adequate, in that corporate and plant management responded to the Letters; the licensee had a system for tracking their responses; the Generic Letters were correctly understood by the licensee; and action was appropriate and timely, including written responses to the NRC where required. The Generic Letters listed below were reviewed and considered closed:
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| Generic Letter Number Description 85-8E Inadvertent Boron Dilution Events '
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| 85-86 Quality Assurance Guidance For i Anticipated Transient Without Scram (ATWS) Equipment That is Not Safety-Related
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| 85-87
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| Implementation Of Integrated Schedules
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| For Plant Modifications 85-13 Transmittal Of NUREG-1154 Regarding The
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| ' Davis-Besse Loss Of Main And Auxiliary Feedwater Event 85-14 Commercial Storage At Power Reactor Sites Of Low Level Radiative Waste Not Generated By the Utility
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| ' 85-22< Potential For Loss Of Post-LOCA i
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| Recirculation Capability Due to ( Insulation-Debris Blockage
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| | Sincerely, 8808050081 880729 - " 0 PDR ADOCK 05000295 |
| ' | | * Hubert J. Miller, Director |
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| | Division of Reactor Safety cc: U. Potapovs, NRR $V \ |
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| | H. Wong, OE M |
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| | 4Mf' M. Holzmer, SRI RIII RIII N A ' |
| Regarding GL 85-06, " Quality Assurance Guidance For ATWS Equipment That Is Not Safety-Related", the licensee has committed in a letter to the NRC dated January 9, 1987 that the appropriate equipment will be installed ;
| | MP RIII Pil Gautam/jp Gardne,r Hinds Harrison 7 g ,b)O opte ' lulu Mijpf'( |
| during refueling outages: Spring of 1989 for Unit 1 and Fall of 1988 for j Unit '
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| Regarding GL-85-87, " Implementation Of Integrated Schedules For Plant 1 Modifications", the licensee's 1985 response to the NRC was adequat ,
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| l However, the NRC's present priority for investigating integrated i modification schedules is low and the licensee's present involvement in l integrated schedules.has consequently been limite '
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| g No violations or deviations were identifie ,
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| f 1 Site Visit By Chief, Reactor Projects Branch 1 and Chief, Reactor Projections Section 1A !
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| On April 21, 1987, a site visit was condticted by the Chief, Reactor f Projects Branch 1, R. F. Warnick, and Chief, Reactor Projects Section IA, W. L. Forney. The site visit included discussions with NRC resident j inspectors, a plant tour, discussions with licensee personnel and a j meeting with station managemen i l
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| During the meeting with station management, the Station Manager, i Mr. G. Plim1, reviewed station performance trends. Areas needing l improvement were the number of personnel errors and the number of i personnel contamination events. Improvements were noted in the total i
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| number of LER's to date for calendar year 1987, and for the length i time since a reactor trip at power. Mr. Warnick expressed concern l about the general Fdterial condition of the plant as indicated by both ,
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| his observations during the tour and by the large number of backlogged !
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| work requests. Mr. Pliml discussed actions to correct these concerns l which were in progress and stated that the material condition of the i plant would continue to be a high station priorit No violations or deviations were identifie i 15. Management Meeting On May 1, 1987, R. F. Warnick, Chief, Reactor Projects Branch 1, and W. L. Forney, Chief, Reactor Projects Section 1A met with Mr. N. Kalivianakis, Division Vice President, for Zion Station, of the Commonwealth Edison Company (CECO) in the Region III Office, Glen Ellyn, IL. The purpose of the meeting was to discuss the material condition, plant cleanliness and backlog of maintenance work requests at the Zion Station. Mr. Kalivianakis discussed actions being taken by CECO to correct these concerns and to establish accountability for their resolutio . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Two Unresolved Items disclosed during this inspection are discussed in paragraphs 7 and 1 ;
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| 17. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) i throughout the inspection period and at the coa:lusion of the inspection '
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| on June 1, 1987 to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comments. The inspector also discussed the likely informational content of the inspection repo,t with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietar )
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