IR 05000295/2013007

IR 05000295-13-007 & 05000304-13-007, 2/8/2013, Zion Nuclear Power Station

ML13077A139
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/14/2013
From:	Lipa C A NRC/RGN-III/DNMS/MCID
To:	Daly P ZionSolutions
Lipa C A
References
IR-13-007
Download: ML13077A139 (28)

Text

March 14, 2013

Mr. Patrick Daly, Senior Vice-President

and General Manager ZionSolutions , LLC 101 Shiloh Boulevard Zion, IL 60099

SUBJECT: NRC INSPECTION REPORT 05000295/2013007(DNMS); 05000304/2013007(DNMS) - ZION NUCLEAR POWER STATION

Dear Mr. Daly:

On February 8, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) Program and Fire Protection Program inspection at the permanently shutdown Zion Nuclear Power Station in Zion, Illinois. The enclosed inspection report documents the inspection results, which were discussed with you and other members of your staff on February 8, 2013.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, performed plant

walk-downs and interviewed personnel. A dditionally, on February 1, 2013, one of the NRC inspection team members met onsite with representatives from the City of Zion Fire and Rescue Department to review response actions and equipment capability.

Based on the results of this inspection, the inspectors identified one violation of regulatory requirements that was of more than minor safety significance. However, because this violation was of very low safety significance, and because the issue was entered into your corrective action program (CAP), the NRC is treating t he issue as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforc ement Policy. In addition, the inspection team identified several issues that were either minor in nature and/or represented potential weaknesses in your CAP or fire protection program, warranting your attention.

No response is required for the NCV. However, if you contest the subject or severity of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001. In accordance with Title 10 of the Code of Federal Regulations (CFR) Section 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made av ailable electronically for public inspection in the NRC's Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made publicly available without redaction.

We will gladly discuss any questions you may have regarding this inspection.

Sincerely,/RA/

Christine Lipa, Chief

Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety

Docket Nos. 050-00295; 050-00304 License Nos. DPR-39; DPR-48

Enclosure:

Inspection Report No. 05000295/2013007(DNMS);

05000304/2013007(DNMS)

cc w/encl: Zion Solutions Service List Suzi Schmidt, Illinois General Assembly JoAnn D. Osmond, Illinois General Assembly Barry A. Burton, Lake County Administrator Mark C. Curran, Jr., Lake County Sheriff Laurie Cvengros, Village Clerk, Village of Beach Park, Illinois Willard R. Helander, Lake County Clerk Jana Lee, Village Clerk, Village of Winthrop Harbor, Illinois Judy L. Mackey, City Clerk, City of Zion, Illinois Irene T. Pierce, Lake County, Illinois Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos.: 050-00295; 050-00304

License Nos.: DPR-39; DPR-48

Report Nos.: 05000295/2013007(DNMS)

05000304/2013007(DNMS)

Licensee: ZionSolutions , LLC Facility: Zion Nuclear Power Station (permanently shut-down)

Location: 101 Shiloh Boulevard Zion, IL 60099

Dates: January 22-25, February 1 &

February 4-8, 2013 (onsite); in-

office review January 28-31, 2013 NRC Inspectors: J. Neurauter, Reactor Inspector (Team Lead)

R. Langstaff, Reactor Inspector W. Slawinski, Health Physicist L. Rodriguez, Reactor Engineer

Approved by: Christine A. Lipa, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety

2 EXECUTIVE SUMMARY Zion Nuclear Power Station, Units 1 and 2 NRC Inspection Report 05000295/2013-007(DNMS); 05000304/2013-007(DNMS)

The Zion Nuclear Power Station is a permanently shut-down and defueled power reactor facility that was maintained in a SAFSTOR condition with spent fuel in wet storage from 1998 through 2010. In 2011, active decommissioning commenced and continued throughout the inspection

period. This team inspection was performed by four NRC regional inspectors to assess the ZionSolutions problem identification and resolution (PI&R) program, focusing on the overall effectiveness of the corrective action program (CAP). The inspectors also reviewed the licensee's fire protection program including control of hot work and combustibles. In addition, the inspectors met with Zion Fire Department representatives to review offsite response capabilities.

Summary - Problem Identification and Resolution On the basis of the samples selected for review, the team concluded that implementation of the CAP at Zion Nuclear Power Station was generally effective. The licensee had a low threshold for identifying problems and entering them into the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were implemented generally in a timely manner, commensurate with the safety significance. An Operating Experience (OE) program was developed, but its effectiveness was not assessed as part of the NRC inspection effort because it was in an early implementation stage. Audits and self-assessments were performed at appropriate frequencies and at an appropriate level to identify issues. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP or otherwise raise issues verbally through informal channels. The inspectors did not identify any impediments to the establishment of a safety conscious work environment (SCWE) at the Zion Nuclear Power Station.

Effectiveness of Problem Identification

• Issues were being identified at a reasonably low threshold throughout all levels of the licensee's onsite organization and generally were entered into the CAP system. However, non-supervisory craft workers preferred to verbally raise issues through their supervisor (foreman) and informally address issues through field adjustment rather than through use of the CAP process (Section 1.1).

Effectiveness of Prioritization and Evaluation of Issues

• Issues were effectively screened and prioritized commensurate with their safety significance in most instances. The scope and depth of CAP evaluations were adequate in that the apparent cause (AC), common cause and contributing cause were determined as appropriate. Evaluations generally determined the significance of issues, assessed regulatory compliance and reporting, and assigned effective remedial actions.

However, the inspectors determined that condition reports (CR) and their associated evaluations focused on individual human performance deficiencies and failed to look 3 more broadly at potential process or procedure weaknesses such as work planning, work control, resources and other cross-cutting components (Section 1.2).

Effectiveness of Corrective Actions

• The licensee generally implemented effective corrective actions in a timely manner to address identified deficiencies, commensurate with their safety significance. However, weaknesses in the CAP related to tracking and trending of issues limited the licensee's capability to prevent recurrence of previously identified deficiencies (Section 1.3).

Assessment of the Use of Operating Experience

• External OE was identified and disseminated across plant departments to determine applicability to the Zion site. However, the licensee identified weaknesses with its timeliness of OE screening reviews. As a result, the licensee recognized that untimely OE reviews adversely affected integration of OE into the performance of daily activities and therefore impacted the ability to prevent future occurrences of previous industry events (Section 1.4).

Assessment of Self-Assessments and Audits

• Self-assessments, audits, and other licensee assessments were typically effective at identifying issues and improvement opportunities. Corrective actions associated with identified issues were entered into the CAP at a low threshold and actions were assigned commensurate with their safety significance (Section 1.5).

Assessment of Safety Conscious Work Environment

• No issues were identified by the inspectors that would impede the establishment and existence of a SCWE at the Zion site. The Zion staff expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be freely communicated to supervision and safety significant issues were being corrected. Interviews did not reveal any instances that workers were reluctant to raise safety issues. Additionally, individuals were aware of the different processes available for raising safety concerns, including the station's CAP, raising concerns to supervisors and managers, and the station's Employees Concerns Program (ECP). Based on these limited interviews, the inspectors concluded that there were no significant concerns with the site SCWE (Section 1.6).

Summary - Fire Protection Program On the basis of the samples selected for review, the team concluded that implementation of the Fire Protection Program at Zion Nuclear Power Station was generally effective. The licensee generally maintained their fire protection plan, fire hazards analysis, and fire protection procedures consistent with their licensing basis and Title 10 of the Code of Federal Regulations (CFR) 50.48(f).

4 Assessment of Fire Protection Program

• Observed field conditions were generally conducive to safe decommissioning work and were not adverse to plant or personnel safety. However, a non-cited violation of very low safety significance was identified for failure to implement procedure ZAP 900-03 for control of transient combustibles. In addition, the inspectors identified the following weaknesses in the Fire Protection Program where the licensee failed to: fully update the fire protection report to reflect planned changes to pre-fire plans, ensure that fire retardant clothing was worn near hot work activities, and ensure that fire extinguishers used to support hot work activities were fully charged. The licensee implemented corrective actions or had corrective actions in-place to ensure compliance and prevent recurrence (Section 2.1).

5 Report Details

1.0 Problem Identification and Resolution (IP 40801 and 71152)

Assessment of CAP Effectiveness 1.1 Effectiveness of Problem Identification a. Inspection Scope The inspectors individually interviewed approximately 40 persons involved in licensed activities at various levels of the site organization to ascertain their views on the problem identification process associated with the Zion Station decommissioning project. The inspectors reviewed the licensee's CAP governing document and implementing procedures and also attended CAP meetings to assess both the development and the implementation of the program. Specifically, the inspectors determined if licensee and contractor personnel identified issues at the proper threshold, entered issues into the CAP in a timely manner, and whether the licensee assigned timely and appropriate prioritization for issue resolution. Additionally, the inspectors reviewed CRs that encompassed a variety of activities and departments to determine the extent that problems were identified and entered into the CAP.

b. Observations and Findings The inspectors determined that issues were being identified at a low threshold and generally were entered into the CAP system. The inspectors determined that workers were familiar with the CAP and felt comfortable raising concerns. As a result, over 1300 CRs were generated in 2012, which were distributed across the various site activities. A computerized database was used in most instances for creating individual CAP documents, although handwritten inputs were accepted as an alternate means of CR generation. The inspectors noted that issues identified by external organizations such as the U.S. Nuclear Regulatory Commission (NRC) or contractors were likewise entered into the CAP for resolution. The inspectors noted that the licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Through interviews, the inspectors determined that non-supervisory craft workers preferred to verbally raise issues through their foreman and not personally generate a CR for a variety of reasons. In particular, some working level individuals viewed the CR process as punitive in that it focused on reprimanding individuals irrespective of the circumstance. Others indicated that corrective actions were not always timely if a CR was generated, so field adjustments were made instead of generating a CR to allow work to continue and meet schedule demands. Notwithstanding these views, the inspectors determined that craft foremen routinely entered issues into the CAP system that were verbally raised by working level staff and took actions to address problems before safety significant work continued. While some issues were not documented in the CAP system and were addressed informally through field adjustments; overall, the inspectors concluded that, in-general, issues were being identified and documented in the CAP as intended.

6 No findings of significance were identified.

c. Conclusions Issues were being identified at a reasonably low threshold throughout all levels of the licensee's onsite organization and generally were entered into the CAP system.

However, non-supervisory craft workers preferred to verbally raise issues through their

supervisor (foreman) and informally address issues through field adjustment rather than through use of the CAP process.

1.2 Effectiveness of Prioritization and Evaluation of Issues a. Inspection Scope The inspectors reviewed the licensee's methods and practices to screen issues, assess their actual or potential significance and to determine if an evaluation was warranted.

The inspectors assessed the licensee's characterization of issues to determine whether the appropriate investigation method was used consistent with the licensee's procedures based on risk significance. The inspectors selectively reviewed CAP evaluation products completed in 2012, which consisted of apparent cause evaluations (ACEs), quick human performance investigations (QHPI), common cause evaluations (CCE) and issue reviews (IRs). More than twenty CAP product evaluations were reviewed by the inspectors. The reviews focused on the scope and depth of the licensee's evaluations to determine whether the fundamental cause of an issue was identified to allow corrective actions to be properly targeted.

b. Observations and Findings The inspectors concluded that the licensee was generally effective at prioritizing issues commensurate with their safety significance. The inspectors found that the majority of issues were not safety significant and were either closed to actions taken or characterized at a level appropriate for an IR evaluation. In most instances, issues were appropriately screened during daily Management Review Committee (MRC) meetings. Weekly MRC meetings were collegial, generally thorough and maintained a high standard for evaluation quality. Members of the MRC discussed issues in sufficient detail and challenged conclusions and recommendations as appropriate.

Overall, the inspectors found that the scope and depth of CAP evaluations were adequate in that the AC, common cause and contributing cause were determined as appropriate. The licensee's evaluations determined the significance of issues, assessed regulatory compliance and reporting, and assigned effective remedial actions for most issues. However, the inspectors determined that CRs and their associated evaluations focused on individual human performance deficiencies and failed to look more broadly at potential process or procedure weaknesses such as work planning, work control, resources and other cross-cutting components. As a result, the licensee may have overlooked more fundamental deficiencies that contributed to the issue or caused the

problem.

No findings of significance were identified.

7 c. Conclusions The licensee effectively screened and prioritized issues commensurate with their safety significance in most instances. The scope and depth of CAP evaluations were adequate in that the AC, common cause and contributing cause were determined as appropriate.

Evaluations generally determined the significance of issues, assessed regulatory compliance and reporting, and assigned effective remedial actions. However, the inspectors determined that CRs and their associated evaluations focused on individual human performance deficiencies and failed to look more broadly at potential process or procedure weaknesses such as work planning, work control, resources and other cross-cutting components.

1.3 Effectiveness of Corrective Actions a. Inspection Scope The inspectors discussed the CAP with the respective managers and reviewed the

ZionSolutions implementing procedures for the CAP to gain a general understanding of the program at the site and to review its effectiveness. As part of the dialogues, the licensee discussed the current capabilities of the CAP software package in use at the site. The inspectors reviewed over 40 open and closed condition reports and associated documentation including corrective actions, IRs, ACEs, CCEs, and a QHPI to determine the site's compliance with the CAP. The inspectors discussed some of these CAP products with members of the licensee's staff to assess the adequacy of the products.

The inspectors also attended the daily and weekly MRC meetings to determine the effectiveness of the CAP.

b. Observations and Findings The inspectors concluded that the licensee was generally effective in implementing corrective actions in a timely manner to address identified deficiencies, commensurate with their safety significance. For individual issues, the licensee generally implemented adequate corrective actions to resolve the immediate concerns.

Through a review of CRs, the inspectors noted that due dates for corrective actions were sometimes extended risking reoccurrence of the issue before remedial actions could be completed because of the CAP's liberal extension policy for the completion of corrective actions. This was previously identified by the licensee in a PI&R self-assessment dated January 16, 2013 and was entered into their CAP as CR-2013-000045. Furthermore, the inspectors noted that the licensee's CAP software package was limited in its capability to track and trend issues to the level desired by the licensee. Therefore, the CAP was limited in its capability to collectively look at issues to identify higher level process and/or programmatic deficiencies. The licensee mostly relied on the institutional knowledge of its personnel to identify negative trends that are entered into the CAP.

This deficiency was identified by the licensee in a CAP self-assessment dated May 24, 2012 and the PI&R self-assessment dated January 16, 2013. Several CRs were entered into the licensee's CAP to address this deficiency, such as CR-2012-000494, CR-2013-000034, and CR-2013-000039.

No findings of significance were identified.

8 c. Conclusions The licensee generally implemented effective corrective actions in a timely manner to address identified deficiencies, commensurate with their safety significance. However, weaknesses in the CAP related to tracking and trending of issues limited the licensee's capability to prevent recurrence of previously identified deficiencies.

1.4 Assessment of the Use of Operating Experience a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's OE program. Specifically, the inspectors interviewed the OE coordinator and reviewed implementing OE program procedures, a completed evaluation of an OE issue, and the current Focused Area Self Assessment (FASA) and corrective actions related to the OE program. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

b. Observations and Findings Based on the results of the inspection, the inspectors concluded that in general, external OE was effectively identified by the station through coordination with the Exelon OE program. The inspectors observed the OE coordinator's database for control of OE at the station. Industry OE was disseminated across plant departments to determine applicability to the Zion site in accordance with Attachment 1, "OPEX/LL Screening Review Checklist," of ZAP-700-17, "Permanently Defueled Operating Experience/Lessons Learned Program."

The inspectors reviewed in detail the licensee's screening review of external OE related to NRC Information Notice 2012-17, "Inappropriate Use of Certified Material Stress Report Yield Stress and Age-Hardened Concrete Strength in Design Calculations," dated September 6, 2012. The inspectors verified the licensee appropriately concluded this external OE to be applicable to the Zion site.

The licensee's FASA report related to PI&R , dated January 16, 2013, identified issues related to completion and timeliness of OE screening reviews. Corrective action for CR-2013-000061 stipulated that OE determined to be applicable to the Zion site should be included in the CAP as a Significance Level 4 CR. Corrective action for CR-2013-000063 stipulated a revision to ZAP-0700-17 to establish a due date for review checklists and a priority level for relevant OE items. The inspectors noted that these corrective actions had not been completed at the time of the inspection. As a result, the inspectors determined that it was premature to draw conclusion on whether the licensee was effectively integrating OE into the performance of daily activities, whether the licensee's program was sufficient to prevent future occurrences of previous industry 9 events, and whether the licensee effe ctively used the information in developing departmental assessments and facility audits.

No findings of significance were identified.

c. Conclusions

External OE was identified and disseminated across plant departments to determine applicability to the Zion site. However, the licensee identified weaknesses related to its timeliness of OE screening reviews. As a result, the licensee recognized that untimely OE reviews adversely affected integration of OE into the performance of daily activities and therefore impacted the ability to prevent future occurrences of previous industry

events.

1.5 Assessment of Self-Assessments and Audits a. Inspection Scope

The inspectors reviewed the licensee's FASA and quality assurance audit reports completed in 2012, to determine whether these evaluative tools were effectively managed, were of sufficient rigor to assess the subject areas and to determine whether identified issues were captured in the CAP system and being addressed.

b. Observations and Findings Self-assessments, audits, and other licensee assessments were typically effective at identifying issues and improvement opportunities. The inspectors concluded that audits and self-assessments were generally thorough, involved subject matter experts or otherwise were completed by personnel knowledgeable in the subject area. Corrective actions associated with the identified issues were entered into the CAP at a low threshold and actions were assigned commensurate with their safety significance.

For example, a self-assessment of the PI&R program completed late in 2012 was effective in identifying a number of issues needing management attention.

No findings of significance were identified c. Conclusions Self-assessments, audits, and other licensee assessments were typically effective at identifying issues and improvement opportunities. Corrective actions associated with the identified issues were entered into the CAP system at a low threshold and actions were assigned commensurate with their safety significance.

1.6 Assessment of Safety Conscious Work Environment a. Inspection Scope The inspectors reviewed the licensee's safety culture and SCWE surveys to assess if there were any organizational issues or trends that could impact the licensee's safety 10 performance. The inspectors reviewed the licensee's associated CR, ACE, and proposed corrective actions for identified survey issues of concern related to SCWE.

The inspectors assessed the licensee's establishment of a SCWE through the reviews of the employee concern program implementing procedures, discussions with the ECP manager, and interviews with managers and supervisors from various departments. In addition, the inspectors attended licensee plan of the day meetings, and daily and weekly MRC meetings related to CR review and disposition. The inspectors also attended new employee training sessions related to the CAP, ECP, and SCWE.

To further assess the Zion site's current safety culture and SCWE, interviews with personnel were conducted with a representative sample of station employees during the inspection.

b. Observations and Findings On June 4, 2012, the licensee initiated CR-2012-000518 to document that the licensee's SCWE survey performed in April 2012 indicated negative results. Specifically, the survey indicated the potential for an adverse trend with employees being reluctant to identify safety concerns and a concern with management's ability to effectively address safety issues. The licensee's ACE for CR-2012-000518 identified ACs for the four areas of concern identified in the licensee's April 2012 SCWE survey:

Concern 1: The possible existence of harassment, intimidation, retaliation, and/or discrimination of persons identifying problems AC: Senior management has not consistently or sufficiently demanded nor reinforced expectations that all levels of management establish and sustain a SCWE that eliminates actual or perceived harassment, intimidation, retaliation, and/or discrimination.

Concern 2: A lack of knowledge, willingness to use, and uncertainty about the effectiveness of the CAP

AC Senior management has not provided sufficient CAP training (initial and refresher) to workers and their superiors nor has senior management enforced appropriate performance expectations for management and supervision's implementation of and improvements to the CAP.

Concern 3: The employees perceived lack of management encouragement and support of workers identifying problems using CAP

AC Senior management has not provided sufficient CAP training (initial and refresher) to workers and their superiors nor has senior management enforced appropriate performance expectations for management and supervision's implementation of and improvements to the CAP.

11 Concern 4: A lack of familiarity with the ECP and indications of a reluctance to use ECP AC Appropriate actions have not been taken in response to indications that management expectations and regulatory obligations for management and supervisory implementation of ECP and the associated SCWE and safety culture principles were not being met.

To address the ACs, the licensee developed an action plan to improve the site's SCWE which included specific corrective actions with due dates for each area of concern.

The inspectors reviewed the effectiveness of selected licensee corrective actions to improve the site's safety culture (attributes included the safety-over production principle, procedural adherence, and conservative decision making) and SCWE (employee's were willing to identify safety concerns). The inspectors noted that:

• Senior site management had demonstrated an expectation for a strong safety culture and SCWE. Management understood the importance of the CAP and ECP and had taken steps to increase the effectiveness of these programs such as providing training to managers and supervisors for expected behaviors relative to the CAP and SCWE.

• The licensee provided new employee training in the areas of the CAP, ECP, and SCWE. The importance of and expectation for employees to identify safety concerns were a part of the CAP training module. In addition, the licensee's training for the ECP and SCWE provided management expectations for the ability of employees to raise safety concerns without fear of retaliation. In addition, the ECP and SCWE training module provided alternative methods (supervisor, ECP, anonymous, or NRC) to address safety concerns in addition to personally writing a CR.

• The licensee reinforced the importance of safety during plan of the day meetings. The licensee encouraged staff participation and a questioning attitude during daily and weekly MRC meetings related to CR review and disposition.

• Conditions were generally conducive to the establishment and existence of a SCWE at the Zion site. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. The staff also indicated that management had been supportive of the CAP by providing time and resources for employees to generate their own CRs.

• The staff expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be freely communicated to supervisors and safety significant issues were being corrected. Some employees indicated a number of low level items were not being corrected in a timely manner. The inspectors determined that the timeliness of the planned corrective actions for the examples given were commensurate with their safety significance.

12 * Plant staff was aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. All employees interviewed noted that any safety issue could be freely communicated to supervision, and safety significant issues were being corrected. Additionally, individuals were aware of the different processes available for raising safety concerns, including the station's CAP, raising concerns to supervisors and managers, and the station's ECP. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.

No findings of significance were identified.

c. Conclusions No issues were identified by the inspectors that would impede the establishment and existence of an SCWE at the Zion site. The Zion staff expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be freely communicated to supervision and safety significant issues were being corrected. Interviews did not reveal that workers were reluctant to raise safety issues. Additionally, individuals were aware of the different processes available for raising safety concerns, including the station's CAP, raising concerns to supervisors and managers, and the station's ECP. Based on these limited interviews, the inspectors concluded that there were no significant concerns with the site SCWE. 2.0 Fire Protection Program (IP 71801)

2.1 Assessment of Fire Protection Program Effectiveness a. Inspection Scope:

The inspectors reviewed the licensee's fire protection plan, fire hazards analysis, and fire protection procedures to ascertain whether the fire plans and procedures reflected the current status of the decommissioning facility and license conditions. The inspectors conducted plant tours to observe field conditions and assess whether field conditions contributed to safe decommissioning and did not represent conditions adverse to plant or personnel safety.

b. Observations and Findings:

(1) Failure to Implement Transient Combustibles Procedure:

Introduction: The inspectors identified a non-cited violation (NCV) of Technical Specifications for the failure to implement the transient combustibles procedure. Specifically, the inspectors identified a piece of plywood located between the electrical cabinets for the Spent Fuel Nuclear Island (SFNI) which was contrary to the transient combustibles procedure.

13 Description: On January 24, 2013, the inspectors identified a piece of plywood located on top of two spare electrical breakers located between the electrical cabinets for SFNI Buses 1 and 2. The plywood piece was rectangular with approximate dimensions of 2 feet wide x 3 feet long x 1 inch thick.

Procedure ZAP 900-03, "Fire Prevention for Transient Fire Loads," Revision 4, implemented the fire protection program for transient combustibles. Step F.3 of procedure ZAP 900-03, specified that lumber and other combustible material required for use in the plant for maintenance and operating activities shall be located to minimize the potential exposure of fire hazards to critical equipment.

The inspectors observed that the plywood was less than a foot from the switchgear for SFNI Bus 1 and SFNI Bus 2. As such, the switchgear for both buses was within the zone of influence for a potential fire involving the plywood. Step F.5 of procedure ZAP 900-03 specified that for work areas within the plant, excess combustible materials (e.g., scrap, unused materials, etc.) resulting from work activity in an area must be removed following completion of the activity, or at the end of the work shift, whichever comes first. The inspectors noted that there was no work being performed in the area at the time.

In response to the inspectors' identification of the transient combustibles, the licensee removed the wood from between the two electrical cabinets and initiated CR-2013-000105, "Piece of Wood between SFNI Bus 1 and 2."

Enforcement: Section 5.5.1.b of Technical Specifications requires, in part, that written procedures be established, implemented, and maintained for Fire Protection Program implementation. Procedure ZAP 900-03 implemented the Fire Protection Program. Step F.3 of procedure ZAP 900-03 specified that lumber and other combustible material required for use in the plant for maintenance and operating activities shall be located to minimize the potential exposure of fire hazards to critical equipment. Step F.5 of procedure ZAP 900-03 specified that for work areas within the plant, excess combustible materials (e.g., scrap, unused materials, etc.) resulting from work activity in an area must be removed following completion of the activity, or at the end of the work shift, whichever comes first.

Contrary to the above, on January 24, 2013, the licensee failed to implement procedure ZAP 900-03, a procedure for Fire Protection Program implementation.

Specifically, the inspectors observed a piece of plywood located between the electrical cabinets for SFNI Buses 1 and 2. The piece of wood was not located to minimize the potential exposure of fire hazards to critical equipment. In addition, the wood, an excess combustible material, was not removed following completion of the work activity.

The inspectors used Traditional Enforcement guidance to determine the significance of the violation. The inspectors determined that the violation was of more than minor safety significance because the presence of the transient combustible represented a credible fire scenario which could affect equipment important to the defueled condition. However, the violation is of very low safety significance (Severity Level IV) because the transient combustible was not a self 14 heating material or a low flashpoint liquid, limiting the potential for the plywood to combust. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance, was entered into the licensee's CAP as CR-2013-000105, and the piece of wood between the two electrical cabinets was removed. (NCV 05000295/13007-01; 05000305/13007-01, Failure to Implement Transient Combustibles Procedure)

(2) Changes to Pre-Fire Plans:

At the time of the inspection, the licensee was in the process of revising their pre-fire plans for use by the City of Zion Fire Rescue Department. The licensee no longer maintained a fire brigade except for responders trained to fight incipient fires using a fire extinguisher. In addition, fixed fire hazards were being substantially reduced or eliminated as the result of decommissioning activities. As such, the requirements specified in Sections 2.5.2.i and 2.6.12 of the Fire Protection Report were no longer fully required. The licensee planned to use plant arrangement drawings with fire suppression equipment identified for pre-fire plans.

The licensee had performed Fire Protection Report Change 2012-05, "Convert FP Water Suppression System to Duel Function FP/SW System," dated December 5, 2012, to update the Fire Protection Report to reflect their intended changes to the pre-fire plans. The inspectors noted that the screening criteria section of the Fire Protection Report change did not address the change to pre-

fire plans. The pre-fire plans were only addressed by an attached mark-up page for Section 2.6.12 of the Fire Protection Report. However, the mark-up pages did not address the discussion of pre-fire plans in Section 2.5.2.i of the Fire Protection Report. The inspectors did not consider the omission of the pre-fire

plans from the screening criteria section to be a violation of NRC requirements. Although 10 CFR 50.48(f) prohibits changes which reduces the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, the regulation does not explicitly require a screening for such changes. The omission of updating Section 2.5.2.i of the Fire Protection Report was considered minor because the change was reflected in 2.6.12 of the Fire Protection Report. The inspectors did not identify any issues with the change as being potentially a reduction in the effectiveness of fire protection considering the state of decommissioning and that the City of Zion Fire Rescue Department would provide the primary fire response.

Since NRC inspections at plants with permanently shutdown reactors are infrequent compared to plants with operating reactors, the inspectors reviewed draft changes, not typically reviewed, to the pre-fire plans to identify any issues that could adversely affect the effectiveness of the fire protection program or plant safety. The inspectors identified that the licensee had omitted fire suppression equipment, such as fire hose stations, from the draft pre-fire plans for the containment buildings. Because the revised pre-fire plans had not yet been implemented, no violation of NRC requirements was identified.

15 (3) Non-Fire Retardant Clothing Worn Near Hot Work:

The inspectors observed hot work activities inside the Unit 1 containment building. The Unit 1 containment building was classified a contaminated area within the radiologically controlled area. As such, at least a full set of anti-

contamination clothing was required for individuals entering the containment building. Individuals performing the hot work (e.g., cutting using torches) were wearing appropriate flame-retardant protective clothing. However, individuals performing fire watches to support hot activities wore protective covers over hard hats. The protective covers were made of paper versus a fire retardant material. The inspectors noted that individuals performing fire watch duties were often close enough to the hot work to have sparks hit them. The inspectors were concerned that the protective covers could be ignited by sparks from the hot

work. Licensee management had previously established expectations that paper not be worn for hot work activities. In response to the inspectors' observations, the licensee reinforced the expectation with line management. Additionally, the licensee reiterated the expectation during a craft all-hands safety meeting for individuals performing work inside containment. The licensee initiated CR-2013-000156, "Paper Hard Hat Covers Not to Be Worn by Fire Watches or Those Involved in Hot Work," issued February 7, 2013. The licensee also revised Procedure ZAP 900-04, "Fire Prevention When Welding, Cutting, or Grinding (Hot Work)," Revision 7, to specify that personnel performing hot work and fire watch duties shall wear appropriate protective clothing as determined by Safety and Radiation Protection Departments. The inspectors did not identify an explicit fire protection program requirement to use fire retardant clothing for hot

work activities.

(4) Lack of Fully Charged Extinguishers for Hot Work:

The inspectors observed fire watches extinguishing small fires from slag near hot work activities in the Unit 1 containment building using a water pump tank fire extinguisher. As a result of periodically using water from the extinguisher to provide spot cooling of slag from hot work, the inspectors considered the extinguisher to no longer be fully charged. Two of the three hot work activities observed did not have an additional fully charged extinguisher of an appropriate type.

In response to the inspectors' observations, the licensee initiated CR-2013-000153, "Observation That Fire Watches Are Partially Discharging Hot Work Extinguishers," issued February 6, 2013. The licensee revised Procedure ZAP 900-04 to explicitly require a full charged fire extinguisher to be available for hot work activities. In addition, the licensee discussed this issue during a craft all-hands safety meeting during the inspection. The inspectors did not identify an explicit fire protection program requirement to have fully charged fire extinguishers available for hot work activities.

16 c. Conclusions:

Observed field conditions were generally conducive to safe decommissioning work and were not adverse to plant or personnel safety. However, a non-cited violation of very low safety significance was identified for failure to implement procedure ZAP 900-03 for control of transient combustibles. In addition, the inspectors identified the following weaknesses in the Fire Protection Program where the licensee failed to: fully update the fire protection report to reflect planned changes to pre-fire plans, ensure that fire retardant clothing was worn near hot work activities, and ensure that fire extinguishers used to support hot work activities were fully charged. The licensee implemented corrective actions or had corrective actions in-place to ensure compliance and prevent recurrence.

3.0 Management Meetings

3.1 Exit Meeting Summary On February 8, 2013, the inspectors presented the inspection results to Mr. Patrick Daly and other members of the licensee's staff. The licensee acknowledged the results presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION Attachment SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee