ML20129F076

Insp Repts 50-295/96-08 & 50-304/96-08 on 960608-0726. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20129F076
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/16/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129F027	List: ML20129F023 ML20129F055 ML20129F076
References
50-295-96-08, 50-295-96-8, 50-304-96-08, 50-304-96-8, NUDOCS 9610010244
Download: ML20129F076 (33)

See also: IR 05000295/1996008

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION lli

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Docket Nos: 50-295, 50-304

License Nos: DPR-39, DPR-48

Report No: 50-295/96008, 50-304/96008

) Licensee: Commonwealth Edison Company

, Facility: Zion Nuclear Plant, Units I and 2

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Location: Opus West III l

1400 Opus West III

Downers Grove, IL 60515 ,

Dates: June 8 through July 26, 1996 1

Inspectors

R. A. Westberg, Senior Resident Inspector ,

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D. R. Calhoun, Resident Inspector 1

D. M. Chyu, Resident Inspector I

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D. E. Jones, Reactor Engineer, RIII l

S. Orth, Health Physics Specialist '

T. Kobetz, Senior Resident Inspector,

Point Beach Nuclear Plant

K. Stoedter, Resident Inspector, Clinton

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Nuclear Plant

J. Adams, Reactor Engineer, RIII

J. Lennartz, Reactor Safety Inspector

j H. Peterson, Reactor Safety Inspector

J. Yesinowski, Illinois Department of

Nuclear Safety (IDNS) Inspector

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Approved by: Lewis F. Miller, Jr., Chief I

Reactor Projects Branch 4 l

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9610010244 960916

PDR ADOCK 05000295

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EXECUTIVE SUMMARY

Zion Nuclear Plant, Units 1 and 2 1

NRC Inspection Report 50-295/96008; 50-304/96008

This integrated inspection included aspects of licensee operations,

engineering, maintenance, and plant support. The report covers a five-week

period of resident inspection. In addition, it included the results of

announced inspections of chemistry, operator licensing, and operational

performance.

Operations

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. The Operating Engineer's decision not to perform a service water valve  ;

lineup verification and a root cause analysis as part of the plant 4

restart on May 19 was considered a weakness in the self-checking program i

(section 01.3). j

. A fuel handler demonstrated inattention to detail by allowing an

unqualified person to perform rigging which resulted in the drop of a

portable filtration unit in the fuel transfer canal (Section 01.4). The

subsequent recovery effort was good and showed teamwork (Section 01.5), i

. A non-cited violation was identified for failure to perform all the I

administrative requirements, such as, quality control review, operating

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engineer review, and drawing review by design engineering prior to

returning a steam flow instrument channel to service (Section 03.1)

. A violation was identified when a licensed operator inadvertently placed

an excessive load on the 2B emergency diesel generator (EDG) during

performance of a monthly Technical Specification (TS) surveillance.

This is a no response violation (Section 04.1).

. The Unit I reactor coolant drain tank pumps were operated deadheaded for

two hours due to an out-of-service error and inattention to detail

(Section 04.3)

. The Unit Supervisor's command and control during the dynamic simulator

examinations was considered a weakness. Additionally, inattention to

detail, self checking, and use of annunciator response procedures

contributed to Job Performance Measure (JPM) failures (Section 04.4).

. The continuing training program was considered satisfactory with

examination overlap a strength (Section 05.1).

. A licensed operator's questionable medical qualifications were not

resolved in a timely manner. Tracking and resolution of questionable

medical qualifications was considered a weakness (Section 05.2).

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. A violation was identified for crediting watchstanding time for

individuals in positions that did not require a license as defined in

the facility's technical specifications and subsequently designating

them as on-shift Unit Supervisors without prior completion of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

in the Unit Supervisor position under the direction of a senior operator

(Section 05.3).

. Some control room administrative processes, such as, newly implemented

computer systems for electronic work control. and out-of-services,

appeared to be an additional burden on the ' operators (Section 06.2).

Maintenance

. The system engineer (SE) performed well by identifying a scaffolding

interference problem around the Unit I high pressure turbine. However,

the contractors demonstrated poor maintenance practices in erecting the

scaffolding. In addition, the scaffolding procedure did not require

sufficient management review (Section M1.2). ,

Enaineerina  ;

. A violation was identified for the untimely response of system

engineering in documenting and addressing a bypass flow condition around ,

the charcoal filters (Section E2.1).

. A violation was identified by the inspectors for the failure to document

the spent fuel pool rerack analysis in the FSAR (Section E3.1).

Plant Suonort

. A violation was identified for the failure to incorporate the rerack

analysis in the FSAR.

. The licensee's water chemistry control program was considered strong l

(Section R1.1). <

. Although the post accident sampling system and routine sample line flow

instruments were unreliable, the chemistry staff ensured that sample

line purge times were adequate (Section R1.2).

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. Chemistry technicians demonstrated good analytical techniques, with the l

exception of some weaknesses concerning attention to detail. Improperly .i

labeled chemistry standards were identified in the chemistry laboratory. 1

. A violation, a non-cited violation, and an unresolved item were

identified concerning inadequate adherence to radiological control

procedures (Sections R4.1, R4.2, and R4.3).

. Site quality verification (SQV) audits of the radiological environmental

monitoring program were thorough, with some minor exceptions. The

inspectors identified weaknesses in radiological practices that were

similar to previous SQV findings (Section R7.1).

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. The inspectors identified two examples of a violation where the licensee

failed to initiate a fire protection impairment permit for the 1A EDG

carbon dioxide fire suppression system while replacing a discharge timer

and to generate a station deficiency report (Section F1.1).

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Report Details

SLmmarY Q L d]RMt S1Atus

L_0cerations

01 Conduct of Operat' ions

01.1 Sfqneral Commqats GML_lR07 and 71715)  !

Using Inspection Pro:edures 71/07 and 71715, the inspectors conducted

frequent rey!ew of ongoing plant operations. A special inspection of

operations activities was conducted from May 20 to 24 using Inspection

Procedu.aes 71707 and 71715. The focus of the inspection was to observe

and assen both day-to-day activities and actions during non-routine

activities; such as startup operations and recovery from transients. In

addition., an operating licensing Requalification Examination

Administration Inspection was conducted in accordance with Inspection

Module 71001.

01.2 Shift Turnover Observations

a. Inspection Scope (71707)

On May 21, the inspectors observed the shift engineer's turnover and the

following shift meeting.

b. Observations and Findinas

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The shift engineer's turnover was conducted in a professional and

systematic manner. Interruptions were minimized by good access control

to the control room complex area. The shift engineers complied with

Zion's new Station Operating Standards in the performance of their

turnover.

The shift engineer conducted the shift meeting in a professional manner.

The meeting was attended by all members of the operational staff, plant

support personnel (radiation protection and chemistry), nuclear

engineering, site quality verification, and plant management. Following

normal discussion of the plant status, the plant manager discussed

recent configuration control errors. The inspectors observed two way

communications between operators and the plant manager concerning the

contributing factors to recent human performance errors.

c. Conclusion

The recently implemented Station Operating Standards were being used by

all control room personnel. The inspectors observed that the nuclear

station operators (NS0s) attention to the control room panels was

excellent even during periods of potential distraction.

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01.3 Unit 2 Reactor Startuo Observation

a. Inspection Scope (71707)

On May 21 and 22, the inspectors observed the Unit 2 startup,following a

May 19, shutdown initiated due to the inoperability of two emergency

diesel generators.

b. Observations and Findinas

The licensed shift supervisor (LSS) overseeing the startup received

several distracting telephone calls. Some of these calls were not

directly related to the startup and probably would have been better

managed by someone not directly involved in the startup.

The operators had to respond to numerous rod deviation alarms while

pulling the control bank rods. The rod deviation alarms were due to the

rod position indication (RPI) system and the control rod step counters

being out-of-tolerance greater than 12 steps. The licensee stated that

a lag time between the process computer's calculations and the RPI

system's position indication contributed to the numerous alarms.

Although this problem did not directly impact safety, it distracted the

operators from other ongoing startup activities.

The inspectors noted good nuclear engineering (NE) support to the

operators during the startup activities. This was particularly evident

when the operators received a rod bottom drop alarm. The operators

entered the appropriate Abnormal Operating Procedure to recover from the

alarm and with the assistance of NE, successfully adjusted the position

indication for the affected rod.

During a review of the licensee's preparations for startup, the

inspectors observed that the trip analysis section in GOP-0, " Plant

Startup," had not been completed by the OE. The plant shutdown was not ,

a result of a trip; therefore the trip analysis section was not '

required. The inspectors noticed that listed items, such as, root cause

of the manual trip and proposed corrective action, were equally

applicable to startups following unplanned shutdowns. The trip analysis

section would have provided an additional check to ensure activities

required for startup were completed.

c. Conclusion

The inspectors also considered the OE's decision not to perform a root

cause analysis as part of the trip analysis was another example of

weaknesses in the licensee's self-checking program.

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01.4 Imoroner Riaaina of a Portable Filtration Unit

l a. Insoection Scone (71707)

i On June 12, a portable filtration unit fell approximately seven feet l

i onto the transfer canal island due to a radiation protection technician  !

! (RPT) improperly rigging the unit. The inspectors interviewed the '

i individuals involved with the rigging of the filtration unit, reviewed

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the station's recently developed rigging procedure, and attended

i training on the new procedure.

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i b. Observations and Findinas

The 1480 pound filtration unit which measured 46":long, 29.5 wide, and

51" high. It developed an air leak while in the transfer canal;

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therefore, the unit needed to be lifted out of the canal for a

inspection using the fuel building crane. A fuel handler (FH), who had

, been trained in rigging operations, was assigned to perform the rigging

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! The FH attempted to use a rope to guide two slings, which were attached

! to the filtration' unit, onto the hook. However, the FH, due to his

{ physical location, was not able to connect the slings unto the hook.

Therefore, a RPT who was assigned RP coverage, assisted him. The RPT

l mistakenly connected the rope onto the hook instead of the two slings.

. The FH did not notice that the rigging was improper as the unit was

! lifted from the transfer canal. While the unit was being lifted, the

i rope broke and the unit dropped approximately seven feet onto the

i transfer canal island.

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l The licensee suspended all transfer canal activities. The licensee

conducted an investigation which revealed the following root causes

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a shackle should have been used for connecting the two slings onto the 4

hook; 2) an unqualified RP technician was allowed to connect unit; and

j 3) management oversight was lacking.

c. Conclusion

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j The inspectors reviewed the licensee's root causes for this event and i'

concluded that the FH demonstrated inattention to detail when he allowed

an unqualified person to perform the rigging activity.

01'.5 Good Teamwork and Communication Durina Portable Filtration Unit i

i Retrieval

a. Inspection Scone (71707)

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On June 21, the FHs successfully rigged and retrieved the portable

.! filtration unit from the transfer canal. The inspectors observed the

i rigging and lifting of the unit, attended the as low as reasonable

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achievable (ALARA) meetings, and verified personnel respirator

i certifications and instrument calibration dates were current.

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b. Observations and Findinas

The ALARA coordinator conducted two briefings for the retrieval

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evolution. One briefing was for a RPT to enter into the canal to obtain

smears and a survey; the other briefing was for a FH to enter into the

canal to connect the slings to the hook on the fuel building crane.

Both the FH and the RPT had to don respirators to enter the transfer

canal. The inspectors verified that their respirator certifications

j were current and that the RPT's instrumentation was within its

calibration period.

Prior to the lift, the inspectors verified that the FH had completed the

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plant's required rigging training and that the portable filtration unit

had been properly rigged.

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c. Conclusion

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The inspectors concluded that the retrieval of the unit was conducted in

a very controlled manner. In support of the retrieval effort, the

inspectors considered that the ALARA coordinator demonstrated good

leadership and provided clear directions and expectations during the

i ALARA briefings. The inspectors also observed good communication and

coordination among fuel handling, radiation protection, and

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decontamination personnel during retrieval of the portable filtration  !

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unit. l

l 03 Operations Procedures and Documentation

03.1 Steam Flow Channel Imoronerly Returned to Service

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! a. Inspection Scope (71707)

i' On June 12, operations personnel identified that a steam flow channel

had been improperly returned to service by instrumentation mechanics  !

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(IMs) personnel. The inspectors attended the investigation meeting.

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! b. Observations and Findinas

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!. As part of a design change, IMs replaced steam flow transmitter, IFT-  !

512. After the transmitter was replaced, the IMs incorrectly returned

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the transmitter's associated bistable to service upon successfully

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completing the calibration. The transmitter replacement work was

governed by ZAP 510-02C, " Exempt Change Program," Revision 5.

This procedure required the completion of certain administrative

i requirements prior to closing and declaring the work package

operational. However, these administrative requirements, which included

a quality control review and release, operating engineer review, and

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drawing review by design engineering 3 had not been completed prior to

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returning the steam flow channel to service.  ;

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A contributing factor to the occurrence of this error was that the work

package did not have a PT-14, " Inoperable Equipment Surveillance Test," i

Revision 6 (used to track inoperable safety related equipment) or an

out-of-service (005) as described by ZAP 300-06, "Out of Service i

Process," Revision 8 associated with the work package. The use of j

either an 00S or a PT-14 would have assured the steam flow channel was -

returned to service only after verifying that all administrative I

requirements had been met.  !

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The licensee initiated timely and effective corrective actions which 1

included administrative closeout of the work package and properly j

restoring the channel to service. Concurrently, the licensee conducted

a meeting with all the involved departments to determine the root causes

and long-term corrective actions for the event. The licensee determined

that the work package was incorrectly considered closed. A. standing

order was issued to assure that all design change work packt.ges had

either an 00S or an PT-14 associated with each work package.

c. Conclusion ,

Although the channel was returned to service incorrectly, the channel

was technically operable because the IMs had successfully performed the l

required calibration. The failure to perform all the administrative '

requirements as required by ZAP 510-02C, prior to returning the steam )

flow channel to service, is a violation of 10 CFR 50, Appendix B, 1

Criterion V, " Instruction, Procedures, and Drawings." However, this

violation was identified by the licensee and could not have been s

reasonably prevented by the licensee's corrective action for a previous ,

violation or a previous licensee finding that occurred within the past

two years. Therefore, this licensee-identified and corrected violation

is being treated as a Non-cited Violation, consistent with Section

VII.B.1 of the NRC Enforcement Policy (50-295/304-96008-01(DRP)).

04 Operator Knowledge and Performance

04.1 Diesel Generator 2B Excessive load Event

a. Inspection Scope (71707)

On July 15, a licensed operator inadvertently placed an excessive load

on the 2B EDG during performance of a required TS surveillance test.

The inspectors interviewed the nuclear station operator (NS0) and the

unit supervisor involved in this event. The inspectors also reviewed

the EDG's design in the UFSAR and inspected the control room snitches

involved in the event,

b. Observations and Findinas

At 5:20 p.m., while testing the 2B EDG using PT-11-DG28, "2B Diesel

Generator Loading Test," Revision 6, the NSO attempted to manipulate the

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voltage adjust rheostat to raise KVARs from 700 to 750. However, he

inadvertently manipulated the speed control rheostat (governor). ' The

NSO realized his error, returned the speed control rheostat to its

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original position, and notified the unit supervisor. The operator's

error resulted in loading the EDG to 4.606 megawatts (MWs) for -

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approximately 5 seconds. The load was greater than the 4 MW required by

the surveillance; however, the licensee determined that this error had

not invalidated the surveillance. The inspectors verified that the EDG

had not exceeded its rated capacity of 5 MW.  ;

Due to these two events involving misoperation of EDGs, the licensee

implemented a standing order (S0) on July 17 for4 diesel generator  ;

testing oversight. The 50 stated that a higher level of attention and  :

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oversight was required and that a complex evolution briefing would be

held prior to all EDG performance testing. It also stated that shift

supervision would monitor all EDG testing and submit a completed

Management Monitoring Report.

c. Conclusion

The inspectors concluded that although the 2B EDG had not been

overloaded, this event was identical to a previous misoperation of the i

2A EDG which occurred on May 19 (see NRC Inspection Report 50-295/304- l

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96007).

PT-11-DG2B, Paragraph 5.0, "2A Diesel Operability Test," Step 18.a.1.

states " increase load in 200 kilowatt steps per minute until desired

load is reached on 2JI-AP57, " Output KW" while following the guidelines

of attachment 1, 2B D/G START /STOP AND LOADING / UNLOADING RECORD." Step

22 states " decrease load in 200 kilowatt steps per minute until desired

load is reachod on 2JI-AP57, " Output KW" while following the guidelines

of attachment 1, 2B D/G START /STOP AND LOADING / UNLOADING RECORD."

Attachment I requires the EDG to be held at full load for 210 minutes

and defines full load as a 4 MW.

Failure to accomplish steps 18.a.1.and 22 of the 2B DG operability test

in accordance with PT-11-DG2B by increasing and decreasing the load on

the 2B E0G by approximately 600 KW in 5 seconds is a violation of 10 CFR

Part 50, Criterion V. However, no notice of violation was identified in

this case due to the escalated actions taken on August 23, 1996, in

response to Inspection Report 50-295/304-96007(DRP) and because the

criteria in NUREG-1600, the " General Statement of Policy and Procedures

for NRC Enforcement Action, "Section VII.B.4 were met.

04.2 Non-Licensed Operator Rounds

a. Inspection Scone (71715)

During the special inspection of operational performance conducted from

May 20 to 24, the inspectors toured the plant with equipment operators

and attendants to assess their knowledge and the quality of their

rounds.

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b. Observations and Findinas

The inspectors accompanied two non-licensed operators during their plant

rounds. In both cases, the individuals were well trained and had a

strong knowledge of the plant. However, instances were noted which

demonstrated the lack of a questioning attitude. The most significant

was that an operator did not question a door that was propped open to

allow an air hose to be routed to a work area. The control room had not

been notified of the condition, and it was not until the inspectors

identified the condition to the operator that.the appropriate actions

.were taken. The inspectors were concerned that the door that had been

propped open was a fire door; however, subsequent inspection determined

that it was not.

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The inspectors concluded that the equipment operators had strong

knowledge. However, the lack of a questioning attitude was observed for

a potential fire protection concern.

' 04.3 Unit 1 Reactor Coolant Drain Tank Pumos Run Without a Discharae Path

a. Insnection Scone (71707)

On June 24, the licensee identified that both Unit I reactor coolant-

drain tank (RCDT) pumps were deadheaded due to failure to realign the

RCOT flow path- following a placement of an 00S for a holdup tank (HUT)

maintenance activity. The inspectors interviewed the shift engineers

and the radwaste supervisor, reviewed the DOS checklist and ZAP 300-06,

"Out of Service process," Revision 8, and discussed the pump operability

with the SE.

b. Observation and Findinas

On June 23, the HUT was taken DOS for maintenance activities on the

HUT's recirculation pump and valve. The operations work group prepared

the DOS checklist and special instructions informing the oncoming

licensed shift supervisor (LSS) that the normal flow path from RCDT to

the HUT would be isolated because of the 00S. However, the LSS did not

see the special instructions and failed to verify the effect the 00S

would have on the plant in accordance with ZAP 300-06. Therefore, the  !

need to realign the RCDT pump discharge path was not recognized and was

not communicated to the incoming crew.

The RCDT pumps started, as required, when they reached their respective

RCDT level setpoints of 46 and 82 percent. The equipment operator noted

that the level was not decreasing and identified the problem. The

licensee found that the normal discharge flow path from the RCDT tank to

the HUT was isolated because of the 00S. The 1A pump was deadheaded

about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the B pump for several minutes. Subsequent testing

showed that the pumps were not damaged.

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c. Conclusion

On August 8, 1995, a similar event occurred where the Unit 1 RCDT pumps

were started and run without a discharge path due to improper valve

alignment. The inspectors considered that this operational error was

another example of inattention to detail.

04.4 Licensed Ooerator Evaluations (71001)

a. Inspection Scone (71001)

The inspectors observed and evaluated operator performance during a

requalification examination administration June 12 through 14, 1996, for

two crews' dynamic simulator examinations and a sample of Job

Performance Measures (JPMs).

b. Observations and Findinas

During the dynamic simulator examinations the Unit Supervisors (US)  !

demonstrated weaknesses regarding command and control. This was also

identified by the facility evaluators as a generic issue. One licensed

individual failed two JPMs which resulted in an unsatisfactory

evaluation while four other licensed individuals failed only a single i

JPM which resulted in a satisfactory evaluation overall. The JPM's t

failed were " Lineup the Feedwater System for Automatic Operation," and

" Respond to Main Generator High Stator Water Conductivity."

c. Conclusion

The inspectors concluded the crew's and individual operator's

performance during the dynamic simulator examination was satisfactory.

However, the US's command and control during the dynamic simulator

examinations was considered a weakness. Additionally, the inspectors

concluded that inattention to detail, lack of self checking, and failure

to use Annunciator Response procedures contributed to the JPM failures.

05 Operator Training and Qualification

05.1 Licensed Ooerator Reaualification Proaram Review

a. Inspection Scone (71001)

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The inspectors reviewed examination materials, records, and procedures

pertaining to the licensed operator requalification training program on

, June 10 to 14. In addition, the inspectors observed the

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requalification examination administration.

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b. Observations and Findinas

No written examination questions, dynamic scenarios, or JPMs

administered during the annual examinations were repeated from week to

week or from the previous year for the current examination cycle. The

inspectors consider the lack of examination overlap a strength.  !

The licensee evaluator's abilities to identify weaknesses, effectively

use followup questioning, and evaluate operator performance were

considered good. The use of competencies in addition to identified.  :

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critical tasks as evaluation criteria during JPM performance was also  ;

considered good. '

The following were recent program changes:

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1. The licensee evaluators identified and evaluated generic training

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issues during the annual examinations which are then incorporated  !

into the training program and assigned to specific crews, specific  !

individuals or all licensed personnel as appropriate.  !

2. . The crews conducted facilitated self critiques following simulator

training sessions and the training staff debriefed with the shift

engineer following the training week.

c. Conclusion

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The inspectors concluded that the licensee's continuing training program l

was satisfactory. The program was revised based on operational

performance and industry events, and satisfactorily evaluated operator

skills. The inspectors considered the lack of examination overlap a

strength. The recent program changes described above were considered +

good.

05.2 Conformance With Ooerator License Conditions. Medical Oualifications

a. Inspection Scone (71001)

The inspectors reviewed the licensee's medical program for licensed '

operators on Juna 10 to 14 and assessed compliance with 10 CFR 55.53

requirements.

b. Observations and Fir, ding

The licensee had commit';ed to develop and initiate a medical program

procedure following the 1395 NRC requalification inspection (Inspection

Report 50-295/304-95013(DRS), section 2.2, page 3). On July 16, 1995,

the licensee revised IAP 200-09A, " Control of 10 CFR 55 Requirements for

Licensed Individuals," Revision 2, section G.3.b, page 4, to require the

Training Department to enter an individual's last NRC physical ,

examination date into the biennial Medical History computer database for

tracking.

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The inspectors identified that an operator's biennial NRC physical had

not been updated as required by ZAP 200-9A. The medical examination was

due by May 23, 1996, but appeared to be a month overdue based on the

database information. The inspectors determined that the medical

examination was performed during April; however, certain medical

conditions identified required resolution. Notification to the NRC of

the situation appeared adequate but the issue was not resolved in a- i

timely manner. As of June 14, the licensee was still waiting for i

information from the operator's personal physician regarding the medical I

condition and therefore had not resolved the issue.

The inspectors questioned the licensee regarding tne operator's '

availability and license status. The licensee assumed that the medical

qualifications were satisfactory. Therefore, the operator was still on

the Active License List and allowed to be on shift. However, the

individual was on vacation.

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The licensee could not resolve the questionable medical qualifications

prior to the individual's return from vacation and removed the .

individual from licensed duties on June 18 pending resolution.

. Additionally, the operations department issued a memorandum regarding

this issue to licensed individuals on June 21 as a corrective measure.

The memorandum expectations included training department scheduling of

all required physicals three months prior to the due date and the

individual license holders were to personally resolve any matters thirty .

days following notification of any discrepancies.

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c. Conclusion

The inspectors determined the licensed operator medical program

procedures did not detail program limitations, expectations, and -

responsibilities to preclude an individual from standing watch with

questionable medical qualific1tions. The procedures in place could have '

allowed the medical condition to continue for an indeterminate amount of

time. The licensee did not expedite the medical qualifications'  !

resolution until after the NRC inspectors questioned the operator's

status. The inspectors considered the licensee's tracking and

resolution of questionable medical qualifications a weakness.

05.3 Conformance with Goerator License Conditions. Maintainina Active Status

a. Inspection Scene (71001) '

The inspectors reviewed the licensee's program for maintaining active

operator licenses on June 10 to 14 and assessed the licensee's

compliance with 10 CFR 55.53 requirements.

b. Observations and Findina

The inspectors identified that the licensee allowed two licensed senior -

operators to take credit for. active license duty watchstanding in the

work control organization, specifically the Outage 00S Team, which was

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,

not a required licensed shift crew position defined in the facility's

technical specifications. This practice occurred during three calendar

quarters of 1994 (first, second, and fourth). Subsequently, the

operators were designated as on-shift Unit Supervisors, responsible for

directing licensed activities of licensed operators, without completing

40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift funt.tions in the Unit Supervisor position under the

direction of a senior operator.

The inspectors questioned the licensee regarding whether active licensed

duty credit for watchstanding in support positions was still being

practiced. A licensee representative stated that Zion had performed a

detailed review and confirmed that this practice only occurred in 1994.

In addition, the inspectors identified that the computer database which

tracked licensed duty watchstanding time had no controls to preclude

giving credit for a full 12-hour watch when an individual stood only a

partial watch. For example, the computer database took information

regarding shift position manning from the logs at the start of each

shift and automatically credited the Updated Active Licensee Log with a

12-hour shift. However, if an operator left the watch position a few

hours after logging in, for any reason, the computer database system did

not have the capability to properly credit the individual for only a

partial watch. Therefore an operator could be incorrectly credited for

a full 12-hour watch.

c. Conclusion

The inspectors concluded that the licensee's practice for crediting

watchstanding time for senior operators in positions that did not

require the individual to be licensed as defined in the facility's

technical specifications and subsequently designating them as on-shift

Unit Supervisors without prior completion of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in the Unit

Supervisor position under the direction of a senior operator were

contrary to NRC requirements and a violation of 10 CFR 50.54(1), "

Conditions of License," 55.53, " Conditions of Licenses," and 55.4,

" Definitions" (50-295/304-96008-02(DRS)). The inspectors also concluded

that the computer database that tracked licensed duty watchstanding time

to maintain active operator's licenses was a weakness.

05.4 Reaualification Trainina Records

a. Inspection Scope (71001)

i

1

The inspectors reviewed training records to ensure compliance with 10

CFR 55.59(c)(5), "Requalification Program Requirements - Records," on

June 10 to 14.

b. Observations and Findinas

The inspectors determined that the licensee satisfactorily maintained

the required training records in the program notebooks. Also, the

licensee implemented crew notebooks in May 1996 which maintained

requalification records with more emphasis on self assessment. The

15

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inspectors noted that the crew notebooks kept post training briefs,

'

l summary of crew's self assessments, simulator training student feedback

forms, and simulator trainee critiques.

3

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c. Conclusion

i

The inspectors considered that the crew notebooks had the potential for

i

being a good self assessment and feedback tool. The crew notebook was

still too new to fully assess its effectiveness.

l .06 Operations Organization and Administration

a. Insnection Scone (71707)

e

i

i During the special inspection of operational performance conducted from

May 20 to 24, the inspectors reviewed the licensee's Operator Workaround

List, implementation of computer systems, and control room logs.

-

b. Observations and Findinas

The licensee implemented an Operator Workaround List to track items that

would inhibit operator response to normal and off-normal events. The

inspectors noted the following weaknesses with the implementation and

j use of this list:

'

.

The list was not routinely reviewed by licensed operators to

!

ensure awareness of all plant conditions. The operators only

reviewed the list during periodic training. The list was not

treated by the operations department as a living document to

,'

maintain operator awareness of 00S equipment and its subsequent

effects on the plant.

.

.

The list contained between 70 and 80 items. A review of these

,

items showed that the threshold for adding an item to the list was

'

low. The number of items on the list diluted the importance of

each item in lieu of focusing on equipment deficiencies which

impacted operator response in accordance with station procedures.

'

4

.-

The inspectors interviewed several levels of the plant management

and staff to determine their understanding of the definition of an

operator workaround. The inspectors did not receive consistent

j answers from those interviewed.

The inspectors noted that the operations staff received insufficient

! training on newly implemented computer systems for administrative

j

control of work activities, such as the electronic work control system,

the PT-14 system used for tracking 00S equipment, and the workaround

4

list. The inspectors observed that, between crews, there was some

disagreement as to when to use the new computer systems and the old hand

written systems.

4

j 16

.

There appeared to be excessive redundancy in keeping control room logs.

Each unit operator maintained a log, as did their supervisor. In

addition, the shift engineer also maintained a station log. During i

interviews with shift engineers, they stated that their logs consist of !

their logs and entries from both the operator and supervisor logs.

Keeping three redundant logs added to the overall administrative burden

of operations supervision and distracted personnel from the other shift

duties and their ability to make plant tours.

c. Conclusion

The inspectors concluded that the implementation of new computer

processes has introduced additional administrative burdens on operations

supervisors. These, with existing burdensome administrative tasks such

as answering telephone calls to the control room and maintaining j

redundant operator logs, had made it difficult for operations

supervisors to perform routine plant tours to observe material condition

and ongoing work activities, according to the supervisors.

II. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

a. Insoection Scone (62703)

The inspectors observed all or portions of the following work

activities: 1A SI pump recirculation line modification; 1A EDG CO,  ;

discharge timer replacement; 2A EDG lube oil cooler, jacket water cooler  !

and intercooler cleaning and inspection; and the IC SG atmospheric

relief valve replacement

b. Observations and Findinas

The inspectors observed that the craft personnel performing the work

were knowledgeable of their assigned task. Work packages were available

at the work location and were used by the craft. The inspectors

reviewed the work packages and considered them acceptable. ,

1

l

c. Conclusion

The inspectors concluded that the maintenance activities observed were

performed well with the except of the 1A EDG CO, discharge timer j

replacement (see Section F1.1).

I

M1.2 Imoronerly Erected Scaffoldina

a. Inspection Scope (62703)

l

l On June 18, the turbine / generator system engineer (SE) identified that  !

l scaffolding in the Unit I high pressure turbine area could potentially

17

l I

l

,

interfere with the operation of two governor control valves. The

inspectors interviewed the SE, the scaffolding foreman, the shift

engineer, and the root cause investigator.

b. Observations and Findinas

!

I

On June 13, contractors erected scaffolding to inspect a steam leak from

an expansion joint located between the high pressure turbine and the "B"

moisture separator reheater. The scaffolding was approved by the

'

!

scaffolding foreman on June 14. However, a need to investigate j

additional steam leaks from different areas of the high pressure turbine

required modification of the scaffolding. i

l

On June 17, the scaffolding was modified and the scaffolding handrail

poles were routed through two governor control valve actuator arms and

pivot points. Subsequent to the scaffolding modification, a walkdown

was not performed by the scaffolding foreman. The scaffolding remained

in place until June 18, when the turbine / generator SE noted the i

,

interference. The SE took immediate actions to restore the scaffolding

to an acceptable condition and initiated a station deficiency report on

the incident.

The licensee performed a Level 3 root cause investigation. Planned

corrective actions include a revision to ZAP 920-01, "Use of Scaffolding  :

and Ladders," Revision 4, to require operations personnel to perform a

walkdown of modified scaffolding.

,

I

i

c. Conclusion

The inspectors considered that the licensee demonstrated poor attention

to detail by failure to recognize the interference of the scaffolding

.

!

with the actuator arms. Zap 920-01 was also inadequate, in that, it did

not require an additional walkdown by the foreman following

modifications. However, the SE performed well in walking down his

system and discovering the interference with the turbine / generator's

governor control valves.

III. Enaineerina

E2 Engineering Support of Facility and Equipment

E2.1 Unknown Bvoass Flow Around Charcoal Bed

a. Insoection Scope (37551)

On June 21, the inspectors observed that there were several holes in two

ventilation ducts in the fuel handling building. On July 1, the

inspectors walked down the duct with the SE and reviewed the associated

ventilation piping and instrument diagrams.

18

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l

l \

l

I

b. Observations and Findinas

!

On June 21, the inspectors informed the Fuel Handling (FH) Supervisor

that several in-line manufactured (drilled) holes were found in one duct

and that a puncture hole was found in another duct in the fuel building. i

The inspectors were concerned that the puncture created a potential i

inleakage point that was not routed through charcoal filters. The FH

supervisor stopped all transfer canal work and contacted the control

room (CR). The CR dispatched an operations supervisor and requested 3

assistance from the SE.

I

'

When the SE arrived at the fuel building, he misinterpreted which duct

the inspectors had referenced with the punctured hole, because there i

were four ducts in the general area. The SE concluded that the holes i

i were not a concern because the holes were in the supply ventilation

duct; therefore, the inleakage from the fuel building into the supply j

ventilation duct could not occur. Plugs were subsequently installed in

l

the holes. 4

'

' On July 1, the inspectors and the SE walked down the ventilation systems

and identified that the duct containing the punctured hole was actually

the exhaust ventilation duct from the HUT room. The air flow in the

exhaust duct was routed through HEPA filters but not charcoal filters.

Therefore, this inleakage point created a unfiltered bypass flow around

the charcoal filters which needed to be evaluated.

l On July 8, after prompting by the inspectors, the SE took actions to

i formally evaluate the issue and initiate a PIF. The SE obtained flow

l measurements in the exhaust duct which indicated a bypass flow of 2

l

'

standard cubic feet per minute (scfm). This bypass flow rate was

bounded by the bypass flow rate leakage limit, of 11 scfm, for the

charcoal filter efficiency test. Therefore, the SE concluded the bypass

l flow from the hole was not significant.

i

In addition, the SE considered the installation of a plug into the

l

punctured hole was an acceptable permanent repair. After the inspectors

expressed a concern about the repair being temporary, in that the plug

l

could be removed and the deficient condition returned, the SE stated he

l would write an action request to properly repair the hole with a metal

patch.

!

C. Conclusion

l

l Although the bypass flow around the charcoal bed was not significant,

i the failure of the system engineer to take prompt corrective actions to

l document and address this condition adverse to quality until prompted by

the NRC inspectors is a violation of 10 CFR 50, Appendix B, Criterion

XVI (50-295/304-96008-03(DRP)).

19

e

E2.2 Good Discovery and Followuo of Missina Parts Evaluation

a. Inspection Scope (37551)

' On May 17, in preparation for replacement of blocking latch relay, BR5-

1A, in the safeguards test cabinet, the system engineer discovered that

a parts evaluation was required by ZAP 510-08," Evaluation Guidelines for

new and replacement parts components and material," Revision 1(G). The

evaluation was needed to determine the suitability of the replacement

'

latch relay that was not an ider.tical replacement to the original latch

relay. The SE also identified that one had not been completed for a

previous latch relay, BR2-A, replacement in March 1996. This inspectors

interviewed the system and design engineers and reviewed the work

packages.

b. Observations and Findinas

The latch relays are used so that safeguards testing can be performed

without component actuations. In addition, the blocking latch relays do

not perform a safety function. However, these relays were installed in

a panel where they could affect other safety related components. The

replacement was not a like-for-like replacement because the old and new

latch relays were different and were mounted differently than before.

Therefore, ZAP 510-08 required that an suitability evaluation, which

would also require a separate seismic mounting evaluation, be performed.

After identifying that a parts evaluation was required, the SE initiated

the appropriate actions to request a parts evaluation for the May 17

latch relay replacement. The evaluation concluded that new latch relays

were an acceptable replacement and that seismic mounting of the new

latch relay was not a concern. Therefore, the evaluation also supported

the acceptability of the March 1996 latch relay replacee. ant.

The SE also generated a PIF for the earlier latch relay work. For the

earlier replacement, a procurement parts evaluation was mistakenly used

for the suitability parts evaluation which would have addressed the

seismic aspect of the latch relay. This error was an oversight on the

part of electricians and the SE involved in the March 1996 work. In

addition, the inspectors requested the system engineer to perform a

review of all latch relay replacements to determine if there were any

latch relays had been installed without having a parts evaluation

completed. The system engineer's review concluded that the new latch

relays had been installed only during the March and May 1996 latch relay

replacement work activities,

c. Conclusion

The inspectors considered that the SE demonstrated good engineering

involvement for the May 17 latch relay work as well as in the discovery

and followup to the missing parts evaluation for the March latch relay

'

replacement. Failure to perform a parts evaluation for the March 1996

relay replacement is a violation of 10 CFR 50, Appendix B, Criterion

20

1

l

i

'

III, " Design Control." However, this violation was identified by the

licensee and could not have been reasonably prevented by the licensee's

corrective action for a previous violation or a previous licensee a

finding that occurred within the past tuo years. In addition, a parts

evaluation was performed and the violation was corrected by the end of

the inspection. Therefore, this licensee identified and corrected

violation is being treated as a Non-cited Violation, consistent with

,

i

Section VII.B.1 of the NRC Enforcement Policy (50-295/304-96008- '

04(DRP)).

E3. Engineering Procedure and Documentation

E3.1 Review of UFSAR Commitments )

l

A recent discovery of a licensee operating its facility in a manner

contrary to the Updated Final Safety Analysis Report (UFSAR) description

l

'

highlighted the need for a special focused review that compares plant

practices, procedures and/or parameters to the UFSAR descriptions. The

inspectors reviewed the applicable portions of UFSAR that related to the

'

I

areas inspected. The following inconsistency was noted between the l

wording of the UFSAR and the plant practices, procedures and/or j

i parameters observed by the inspectors.  !

a. Inspection Scone (71707)

While investigating the hole in the exhaust ventilation duct from the

Unit 1 HUT tank room, the inspectors identified that UFSAR, Section

15.7.4.1, " Fuel Handling Accident in the Fuel Building," had not been

updated to reflect the reracking analysis for the spent fuel pool. The

inspectors interviewed a nuclear system engineer and a regulatory

assurance engineer,

b. Observations and Findinas

The licensee changed the spent fuel pool arrangement (reracking)

described in Section 15.7.4.1 of the UFSAR in August 1993, and had not

incorporated this change into the UFSAR as of August 30, 1996.

On July 10, the system engineer informed the inspectors that the UFSAR

section 15.7.4.1 should have been updated along with the last UFSAR

update in 1995. The inspectors noted that the reracking change should

have been completed no later than twenty four months after the change.

While preparing the UFSAR change to incorporate the rerack analysis done

HOLTEC, the SE identified that the analysis did not use an organic

filter efficiency of 70% as specified in Regulatory Guide 1.25,

" Assumptions Used For Evaluating the Potential Radiological Consequences

of a Fuel handling Accident-in the Fuel Handling and Storage Facility

for Boiling and Pressurized Water Reactors." Therefore, as a

conservative measure, the SE recalculated the HOLTEC results using RG

1.25 and determined that the total iodine dose received to the thyroid

increased from 27.2 REM to 40.8 REM.

21

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,

The SE submitted an engineering request to determine if the HOLTEC

analysis should have included the assumptions in RG 1.25. The SE also

stated he would initiate a change to the UFSAR to include the HOLTEC

analysis using RG 1.25.

The SE documented the subject UFSAR discrepancy in a letter. dated July

29, 1996. This-letter is included as Attachment 2 to this report.

c. Conclusion

The inspectors considered the failure to properly update the UFSAR and

use the correct analysis demonstrated a lack of attention to detail and

is a violation (295/304-96008-05(DRP)) of 10CFR E0.71(e)(4).

IV. Plant Suncort -

R1 Radiological Protection and Chemistry Controls

R1.1 Plant Water Chemistry and Chemistry Ouality Control

a. Inspection Scone (84750)

The inspectors reviewed the licensee's water chemistry control program

including the level of' chemical contaminants in primary and secondary

systems and staff review of the data. The inspectors also reviewed the

laboratory and in-line instrument quality control program including

calibrations, performance testing, and interlaboratory analysis

programs.

b. Observations and findinas

The licensee's water chemistry control program was considered a

strength. The chemistry department's monthly and cycle reviews

contained good evaluations of the water quality for both units.

Overall, water quality for both units was good. The licensee's water

quality program was consistent with industry guidelines, and primary

water quality was very good. However, circulating water inleakage was a

problem for Unit 2 throughout the current operating cycle. Frequently,

the licensee diverted steam generator (SG) blowdown from Unit I to Unit

2 to aid in the removal of contaminants from Unit 2. Coasequently, both

Unit I and Unit 2 SG sodium, chloride, and dissolved oxygen

concentrations were slightly elevated for periods of time. The licensee

took appropriate actions to reduce the level of contaminants and return

the systems to normal chemistry levels.

The quality control (QC) program for laboratory and in-line instruments

was well implemented. The chemistry staff properly identified and

.

evaluated QC data trends. However, the inspectors noted some weaknesses

in the documentation of QC data reviews for analytical instrumentation.

The licensee's performance in interlaboratory comparison programs

22

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_ . _ _ - _.. . .. ,

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i

indicated excellent analytical accuracy. The inspector noted a minor

non-conservative bias'in the licensee's high purity germanium gas i

geometry, which the licensee planned to evaluate. '

c. Conclusion i

The licensee's water chemistry control program was considered a l

strength, with good review of operational data.. Periods of Unit 2  ;

circulating water inleakage resulted in slightly ' elevated concentrations  !

of. chemical impurities in. steam generator chemistry. Quality control of 1

laboratory and in-line instruments was effectively implemented.  ;

RI.2 Post Accident Samnlina System (PASS) Operability and Quality Control '

a. Inspection Scone (84750)

The inspectors reviewed the post accident sampling system (PASS), which

'

was used to obtain reactor coolant samples under both accident and ,

routine conditions. The inspectors reviewed PASS operability, QC

results, and maintenance history. The inspectors also verified the  !

adequacy of the licensee's sample line purge times. ,

i

b. Observations and Findinas ,

l

Historically, the licensee has had difficulties in maintaining PASS i

operability. Several in-line instruments have required continual

corrective maintenance, resulting in low availability. Based on an ,

evaluation of its NRC commitments for the PASS, the licensee performed a

'

safety analysis and reduced its in-line monitoring commitments. The

licensee's evaluation demonstrated that several in-line monitors could

be eliminated without losing the ability to monitor significant

parameters. As a result of this evaluation, the licensee was in the

process of abandoning all of its PASS in-line monitoring

instrumentation, with the exception of the gas chromatograph. The

licensee expected that the reduction in instrumentation would focus

efforts in maintaining the remaining instrumentation and would improve

the overall operability of the system. The inspectors reviewed the

licensee's PASS QC results, which indicated that samples obtained from

the PASS were representative of primary coolant and that the PASS 1

dilution factor was accurate.

The inspectors also reviewed the status of the licensee's replacement of

sample line flow orifices in the PASS. The licensee had previously

identified problems concerning several sample line pressure indications.

In 1993, the chemistry staff initiated an action request to replace the i

instrumentation. Subsequently, the licensee had performed an initial ,

engineering evaluation and had obtained replacement parts, but the new i

equipment design could not be installed into the available space. At  ;

the time of this inspection, system engineering representatives i

l indicated that current PASS sample line pressure indications did not

l accurately correlate to sample line flow rates. The inability to- _

accurately determine sample line flow impacted the licensee's ability to l

.

23

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_ _ _ _ _ _ _ _ _ . _ .

_ _ _ _ ._,

i

ensure that sample lines were adequately purged prior to obtaining .

required samples. However, chemistry and system engintering personnel '

indicated that resolving the design concerns and completing the repairs

was of low priority.

The inspectors reviewed the licensee's chemistry sample purge times. ' At

a fixed pressure indication in the sample lines, the chemistry staff had

evaluated PASS and normal sample flow to ensure adequate purges of

sample lines. Based on this analysis, the sample purge times for PASS

and routine sample points were adequate. If the evaluated sample line

pressure could not be obtained, additional guidance would be provided by-

chemistry management.

c. Conclusion

Although post accident sampling system and routine sample line flow

instrumentation were unreliable, the chemistry staff ensured that sample

line purge times were adequate to obtain representative samples.

R.1.3 Imolementation of the Radioloaical Environmental Monitorina Proaram

(REMP)

a. Insoection Scone (84750)

The inspectors toured the environmental air sampling stations and

reviewed the 1995 annual report and environmental sample results.

b. Observations and Findinas

The environmental air sampling stations were in good material condition.

Air sampler flow meters were calibrated as required. The inspectors

identified that the ~ text of the offsite dose calculation manual (ODCM)

contained minor inconsistencies and that the 1995 Annual Report

contained sample results for indicator milk samples when only control

milk locations existed. These inconsistencies indicated minor

weaknesses in the review of the program.

c. Conclusion

i

The licensee effectively implerr.ented the REMP and no measurable  !

radiological impact on the environment from plant operations was I

identified. '

R4 Staff Knowledge and Performance in RP&C

R4.1 Chemistry Sample Collection and Laboratory Practices

a. Inspection Scope (84750)

1

The inspectors observed the analytical technique and radiation 1

protection practices demonstrated by chemistry technicians (cts).

Observations included cts obtaining primary coolant and secondary system 4

!

24 l

l

l

samples and performing analyses in the chemistry laboratory. The

inspectors also reviewed the preparation and control of laboratory

standards and reagents.

b. Observations and Findinas

The inspectors identified two iron standards in the chemistry laboratory

which had been incorrectly labeled with respect to shelf life. The CT,

who had prepared the 4 part per million iron standards, labeled the

standards as expiring after six months instead of the three months

directed by chemistry procedures. The chemistry superintendent

indicated that the standards had been used in an optional analysis.

Since the standards were not used in an analysis required by Technical

Specifications or by other requirements, no violation was identified.

The inspectors also identified some inconsistencies in the method in l

which reused sample containers were pre-rinsed with sample to reduce l

cross chemical contamination of samples. The licensee planned to review

the practices and ensure that proper analytical practices were J

implemented. j

On July 9,1996, the inspectors identified that CT contamination control l

practices were inconsistent with Zion administrative procedure. ZAP 620- l

03, " Transportation, Conditional, and Unconditional Release of

Radioactive Materials," revision 2. After collecting primary coolant

samples, the CT rinsed the outside of the containers with deionized  !

water to reduce the potential for contamination and performed a l

radiation survey of the sample with an ion chamber. Subsequently, the

cts removed the samples and instruments from the primary sampling room l

(a posted, contaminated area). However, the CT did not perform a

surface contamination survey of the materials nor did the CT re-package

the materials to prevent the spread of contamination, as required by ZAP

620-03. Chemistry and radiation protection (RP) management indicated

that it was a longstanding practice to transport chemistry samples via

an elevator between the primary sampling room and the chemistry

laboratory, which was not a posted contaminated area, without surveying

the materials for surface contamination. The lack of assurance that

instruments and sample containers were free of contamination introduced

a potential for the spread of contamination within the Auxiliary

Building. Although the licensee's historical data did not indicate a

significant contamination problem, the licensee suspended the practice

and implemented more stringent radiological controls.

c. Conclusion

The chemistry technicians demonstrated good analytical chemistry

techniques, with the exception of some weaknesses concerning attention

to detail relative to laboratory standards.

25

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TS 6.2.2 requires, in part, that radiation control procedures be ,

prepared and implemented. The failure to properly remove items from the

primary sample room (a posted, contaminated area) in accordance with

1 procedure ZAP 620-03 is a violation of TS 6.2.2 (50-295/304-96008-

, 05(DRS)).  !

!

R.4.2 Decontamination of the Fuel Transfer Canal

a. Inspection Scone (83750)

! The inspectors reviewed personnel performance during the decontamination

j of the Fuel Building transfer canal.

b. Observations and Findinas

} On June 10, 1996, the licensee identified that a contractor failed to

, follow station procedures 'after alarming a personal contamination

!

monitor (PCM). Instead of obtaining RP assistance, the individual

i performed a survey and identified the contamination on his clothing. i

' The individual disposed of the contaminated section of clothing and

successfully passed through the PCM. After the individual informed his

supervision of his actions, RP personnel escorted the individual to the i

.

decontamination area of the AB, surveyed the individual, and retrieved a 1

1

contaminated piece of clothing from a garbage receptacle. The licensee

i documented the event in a problem identification form (PIF). This item

, is unresolved pending further NRC review (50-295/304-96008-06(DRS)). j

] On June 7, 1996, the licensee identified that contrary to ZAP 600-3,

l " Radiation Work Permit Program," Revision 3, a fuel handler failed to

follow the applicable radiation work permit and removed equipment froa

! the fuel transfer canal without a RPT present. Under the circumstances, .

the individual believed that he was authorized to remove tools from the

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$

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fuel transfer canal. The inspectors discussed the event with the

responsible RP personnel, who indicated that an RPT found the equipment 1

in an unlabeled bag. The RPT took control of the equipment and measured i

i

a dose rate of 50 mrem /hr on contact with the tools. The individual was  ;

wearing the required dosimetry (i.e. thermoluminescent dosimeter and 1

. electronic dosimeter), which would have alarmed if the dose rate from i

j the tools had been significantly greater. The licensee took immediate

corrective actions including a halt in the fuel transfer canal

l activities and additional instructions to the work groups.

1

I Failure to follow the radiation work permit procedure is a violation of

i 10 CFR Appendix B, Criterion V, " Instructions, Procedure, and Drawings."

l However, this violation was identified by the licensee and could not

j have been reasonably prevented by the licensee's corrective action for a

previous violation or a previous licensee finding that occurred within

'

the past two years. Therefore, this licensee-identified and corrected

'

violation is being treated as a Non-cited Violation, consistent with

j Section VII.B.1 of the NRC Enforcement Policy (50-295/304-96008-

,

2

07(DRS)).  !

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l 26

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3

c. Conclusion

The inspectors concluded that personnel performance issues, both l

radiological and maintenance, have had negative effects on the progress

of the fuel transfer canal decontamination project.

R4.3 Conclusions l

Chemistry technicians demonstrated good analytical techniques, with the

exception of some weaknesses concerning attention to detail. Improperly

labeled chemistry standards were identified in the chemistry laboratory.

In addition, a violation, a non-cited violation, and an unresolved item

were identified concerning inadequate adherence to radiological control

procedures.

1

R7 Quality Assurance in RP&C Activities

R7.1 Ouality Assurance Assessments (84750)

a. Inspection Scooe (84750)

4

The inspectors reviewed audits performed by the licensee's site quality l

verification (SQV) staff of radiation protection and chemistry program

implementation,

b. Observations and Findinal

The SQV staff performed annual reviews of the REMP implementation. The l

SQV staff reviewed the performance of the environmental sample l

collector, REMP sample results, land use census, and annual report.

SQV's audit of sample collector activities and land use census data were

comprehensive. Findings concerning the land use census were well

documented and resolved.

Based on positive performance indicators, the SQV department had reduced

its auditing schedule of the chemistry program. Chemistry performance

was assessed via field monitoring reports and selected review of ,

chemistry activities. The SQV oversight of chemistry activities t

appeared acceptable; however,1994 chemistry findings concerning

adherence to RP procedures were not fully resolved,

c. Conclusion i

Based on NRC observations of minor inconsistencies in the ODCM and l

annual report (See Section R.1.3), the inspectors concluded that the '

review of the annual report data and ODCM was not as comprehensive as ,

the review of REMP. The inspectors identified weaknesses in j

radiological practices (See Section R4.1) that were similar to SQV

findings in 1994.

I

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27

F1 Control of Fire Protection Activities

F1.1 Inonerability of the 1A Diesel Generator CO, System Not Recoanized

Durina C03 Discharaer Timer Replacement

1

a. Insoection Scope (71750)

On July 2, the inspectors identified that replacement of the 1A EDG CO,

discharge timer on July I had rendered the automatic function of the CO,

system inoperable. The inspectors reviewed the work package and

interviewed fire protection, electrical maintenance, and operations

personnel.

b. Observations and Findinas

On July 1, the onshift operations crew informed the electricians that

the timer could be replaced without taking the CO, system out of

service. But, with the discharge timer removed, the automatic function

of the CO, system was rendered inoperable.- This inoperable status was

not recognized by fire protection, operations, nd electrical

maintenance personnel during the work. The inspectors were informed, by

the electrician, that all the individuals involved were focused on

preventing the inadvertent operation of the C0 system; therefore, the

fact that the CO, system would not automaticalfy operate was not

identified.

Prior to approving the work, the onshift crew conferred with the fire

protection SE. A decision was made to issue the CO, lockout key to the

electricians to re-enable and disable the CO, system at their

discretion. Whenever the CO, lockout key was used, the automatic

function of the C0 system was impaired. However, the electricians

proceeded with replacing the timer without using the CO, lockout key

because they felt the key would not prevent actuation. The inspectors

subsequently reviewed the electrical prints with an electrician and

determined that the use of the CO2 lockout key does prevent actuation.

Although the key was not used, the CO, system was impaired due to the

timer being replaced.

This timer replacement work impaired the automatic function of the CO,

system. ZAP 900-02, " Fire Protection System Impairments," Revision 2,

required the initiation of an impairment permit and establishment of a

continuous fire watch. However, FP and operations personnel did not

perform these required actions because operations )ersonnel considered

issuance of the CO2 lockout key had not impaired tie automatic actuation

of the system. However, the continuous fire watch requirement was

coincidentally, accomplished due to another impairment requirement

already in place.

The practice of rendering the C0 system inoperable and not initiating a

fire impairment permit because tbe CO, lockout key has been issued has

been longstanding. This practice has not been in compliance with fire

protection program requirements of ZAP 900-02 which required that an

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impairment be initiated when impairing the fire protection system. This

practice demonstrated a lack of understanding of the fire protection

system and its requirements.

i The licensee implemented the following corrective actions: 1) revising

the fire impairment procedure to require the initiation of a fire

impairment permit when rendering the CO, system inoperable; 2) adding

lockout key to assure an impairment was

additional labelling

initiated prior to issuingonthe

the CO, key; 3) adding a placard adjacent to

local lockout key switch to assure an impairment was generated prior to

using the key; and 4) issuing a standing order informing operations

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personnel of the requirement to assure an impairment was issued prior to

l using the key.

c. Conclusion

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ZAP 900-02, " Fire Protection System Impairments," Revision 2, states

that a barrier impairment permit was required for fire protection

equipment that was impaired. Failure to initiate a barrier impairment

permit is a violation of 10 CFR 50, Appendix B, Criterion V, (50-

295/304-96008-08a(DRP)). The inspectors considered that the fire

!

protection, operations, and electrical maintenance personnel

demonstrated a lack of understanding of the operation of the CO, system

and requirements in ZAP 900-02. The station's implemented corrective

actions should be appropriate to prevent recurrence. However, there was

a deficient knowledge level that appeared to exist among numerous

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departments with respect to the fire protection system.

Although the licensee' implemented corrective actions to address the

problem, the station was untimely in documenting the inoperability of

the 1A Diesel Generator CO

generated for approximately, 23System; a station

days after July 1.deficiency report

ZAP 700-08, was not

" Problem

Identification Process," Revision 10, required that a PIF be generated

within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovering an issue. Failure to document this issue

' on a P1F, as required by ZAP 700-08, is a violation of 10 CFR 50, i

Appendix B, Criterion V (50-295/304-960008-08b(DRP).

V. Manaaement Meetinos

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X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee

! management at the conclusion of the inspection on July 26, 1996. The

licensee acknowledged the findings presented.

l The inspectors asked the licensee whether any materials examined during l

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the inspection should be considered proprietary. No proprietary

information was identified.

.

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. _ _ . . _ _ . _ _ _ . . . _ _ _ . _ _

+

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Tuetken, Vice President, Zion Station

G. Schwartz, Station Manager

B. Giffin, Engineer Manager

B. Fitzpatrick, Operations Manager

L. Simon, Maintenance Superintendent

R. Cascarano, Assistant Operations Manager

W. Stone, Regulatory Assurance Supervisor

D. Hatton, Site Construction Superintendent

T. Hill, Mechanical Maintenance Master

R. Lane, Maintenance Engineering Supervisor

K. Depperschmidt, Instrument Mechanic Master

M. Rode, Fuel Handling Supervisor

J. LaFontaine, Work Control Supervisor

W. Demo, Assistant Superintendent to Operations

G. Ponce, Electrical Maintenance Master

M. Weis, Services Director

B. Schramer, Chemistry Supervisor

G. Kassner, Radiation Protection Supervisor

E

G. Grant, Director, Division of Reactor Safety

L. Miller, Chief, Reactor Projects Branch 4

IDM

J. Yesinowski  !

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INSPECTION PROCEDURES USED

IP 37551: Engineering

IP 62703: Maintenance Observation

IP 71001: Licensed Operator Requalification Program Evaluation

IP 71707: Plant Operations

IP 71715: Sustained Control Room and Plant Observation i

IP 71750: Plant Support Activities l

IP 83750: Occupational Radiation Exposure

IP 84750: Radioactive Waste Treatment and Effluent and Environmental

Monitoring

Items Opened. Closed. and Discussed

Opened

50-295/304-96008-01 NCV improper return to service of a steam flow channel

50-295/304-96008-02a VIO personnel error and misoperation of EDG switch

50-295/304-96008-02b VIO failure to initiate a barrier impairment permit  !

for the inoperability of EDG CO, system.

50-295/304-96008-02c )

VIO failure to initiate a PIF when the automatic '

function of the CO, system was rendered inoperable.

50-295/304-96008-03 VIO failure of the system engineer to take prompt

corrective actions for puncture in exhaust duct from

the HUT room

50-295/304-96008-04 VIO improper crediting of standwatch hours for

maintenance operator licenses

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50-295/304-96008-05 NCV failure to perform parts evaluation

50-295/304-96008-06 URI failure to properly update the FSAR

50-295/304-96008-07 VIO failure to perform survey prior to removing

material from contaminated area.

50-295/304-96008-08 URI contractor decontaminated himself after alarming

monitor

50-295/304-96008-09 NCV personnel removed equipment from the fuel transfer

canal with RPT present

Closed

None

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- - - = - .- . ._. - - - - . . - - .. ..

1

DEFINITIONS

Violations For Which a " Notice of Violation" Will Not Be Issued

l

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The NRC uses the Notice of Violation as a standard method for formalizing the

existence of a violation of a legally binding requirement. However, because

i

!

the NRC wants to encourage and support licensee's initiatives for self-

identification and correction of problems, the NRC will not generally issue a

Notice of Violation for a violation that meets the tests of 10 CFR 2,

Appendix C, Section V.A. These tests are: 1) the violation was identified by

the licensee; 2) the violation would be categorized as Severity Level IV or V;

3) the violation will be corrected, including measures to prevent recurrence,

within a reasonable time period; and 4) it was not a violation that could

,

reasonably be expected to have been prevented by the licensee's corrective

l

action for a previous violation. A Violation of regulatory requirements

l

identified during this inspection for which a Notice of Violation will not be

issued is discussed in Paragraphs 03.1, E2.2, and R.4.2.

Unresolved Items

'

Unresolved Items are matters about which more information is required in order

to ascertain whether they are acceptable items, violations, or deviations.

Unresolved items disclosed during the inspection are discussed in Paragraphs

04.1 and R4.2.

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LIST OF ACRONYMS USED

AB Auxiliary building

ALARA As Low As Reasonably Achievable

CT Chemistry Technician

EDG Emergency Diesel Generator

EWCS Electronic Work Control System

FH Fuel Handler

FP Fire Protection

FSAR Final Safety Analysis Report

HUT Holdup Tank

IDNS Illinois Department of Nuclear Safety

IFI Inspection followup item

IM Instrument Mechanic

JPM Job Performance Measures

LSS Licensed Shift Supervisor

MM Mechanical Maintenance

NCV Non-cited Violation

NE Nuclear Engineer

NLO Non-licensed Operator

NSO Nuclear Station Operator

ODCM Offsite Dose Calculation Manual

OE Operating Engineer

00S Out-of-service

PASS Post Accident Sampling System

PCM Personal Contamination Monitor

PDR Public Document Room

PIF Problem Identification Form

PORV Power Operated Relief Valve

QC Quality Control

RCDT Reactor Coolant Drain tank

REMP Radiological Environmental Monitoring Program

RP Radiation Protection

RP&C Radiological Protection and Chemistry

RWP Radiation Work Permit

RPT Radiation Protection Technician

SALP Systemic

SE System Engineer

SI Safety Injection

SQV Site Quality Verification

Technical Specification

.

TS

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URI Unresolved Item

US Unit Supervisor

VIO Violation

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