ML20203H884
| 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: |
| 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
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.
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
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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
21
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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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