IR 05000295/1987010

Safety Insp Repts 50-295/87-10 & 50-304/87-13 on 870511-21. Violations Noted:Inadequate Storage of Matl & Equipment & Lack of Sufficient Corrective Action Re Licensee Identified Concerns W/Storage

ML20234E688
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/30/1987
From:	Jablonski F, Maclean P, Sutphin R, Tella T, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234E643	List: IR 05000295/1987010 ML20234E640 ML20234E667
References
50-295-87-10, 50-304-87-13, NUDOCS 8707070648
Download: ML20234E688 (9)

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A U.S. NUCELAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/87010(DRS); 50-304/87013(DRS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, Illinois Inspection Conducted: May 11-21 d M # Z , 1987 Inspectors: T. E. Vandel Date - fdd7

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R. N. Sutphin G [Jo [#7 Date (kfd!wn P'. J. MacLean 4 - id e @

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'f Approved By: J lonski, Chief Quality Assurance Programs b/M/8 7 Datd

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i Section Inspection Summary Inspection on May 11-21, 1987 (Reports No. 50-294/87010(DRS);

No. 50-304/87013(DRS))

Areas Inspected: Routine safety inspection of previously identified concerns; Annual review of the QA program including audits; receipt, storage and handling; procurement; surveillance; maintenance; and corrective action in accordance with selected sections of inspection procedures 35701, 38701, 38702 and 40704, 61700, 62700 and 62702, 92701, 92702, and 9272 Results: Two violations were identified in two of the eight areas inspected -

inadequate storage of material and equipment; and lack of sufficient corrective action regarding licensee identified concerns with storag gg7oM"BE$s G

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DETAILS

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1. Persons Contacted Connonwealth Edison Company (CECO) {

• G. Plim1, Station Manager

• J. Ballard, Quality Control Supervisor

• R. Budowle, Assistant Superintendent Technical Services

• K. Depperschmidt, Electrical Maintenance Scheduler

• E. Fuerst, Production Superintendent

• D. Johnson, Stores Supervisor

• R. Johnson, Assistant Superintendent Maintenance

• J. Rappeport, Quality Assurance Engineer ,

l *T. Rieck, Services Superintendent l

• C. Schultz, Regulatory Assurance Supervisor

• Stone, Quality Assurance Superintendent

• Denotes those attending the exit meeting on May 27, 1987. Other station technical and administrative personnel were contacted during the course I of the inspectio . Licensee Action on Previous Inspection Findinas (Closed) Unresolved Items (295/82020-09; 304/82018-10): No master schedule of required surveillance. The inspector reviewed the master surveillance schedule print-out of April 21, 1987, and determined that requirements for a master schedule were met. This item is close (0 pen) Open Items (295/85032-01; 304/85033-01): Licensee to identify administrative policies and procedures used to control lists of structures, systems and components to which the QA program applies. These lists included (1) Safety-Related Mechanical Equipment, (2) Electrical Instrument Diagrams (P&ID'sEq)uipment, (3) Instruments,

, and (5) Masonry (4) Piping and Walls. The licensee !

was able to furnish information relative to the control of all of I these items except masonry walls. This item remains open, iClosed)OpenItems(295/85032-02;304/85033-02): Licensee to revise I Procedure No. ZIAP 5-51-12 and establish policy about Appendix A to l 5-51-12 for Instrument Maintenance (IM) Department. The licensee revised ZIAP and included the contents of previous Appendix A as a new Appendix This item is close l (0 pen) Unresolved Items (295/85032-04; 304/85033-04): Review of licensee's program to identify and functional test Main Turbine Stop i Valve Limit Switches per Technical Specification Table 3.1-2, Item 1 The licensee drafted a revision to the Technical Specification to l

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essentially be in accordance with the Westinghouse Standardized Technical Specification. This proposed ammendment was approved by the onsite safety review committee and submitted for offsite revie This item will remain open pending results of the offsite review and submittal to the NRC for acceptanc e. (Open) Violations (295/86026-01; 295/86026-02): 18 diesel repairs were performed with inadequate descriptions of work functions and inappropriate instructions, and work packages did not contain sign offs as require (1) Corrective action commitments contained in the licensee's letter of response dated March 20, 1987, were reviewed for both violations. All items were adequately completed with the following exception:

• Violation 1 - item b requires that the QA Superintendent sign off the " Correction Action Approved" section in order to complete the diesel procedure revie (2) Corrective actions to avoid further violation were reviewed with l the following result '

• Violation 1 - items a-c appeared to require further verifications on the licensee's part to assure that corrective actions were adequate; item d remains incomplete pending completion of applicable procedures 1 review and revision currently scheduled for October 31, 198 * Violation 2 - item a remains to be completed by October 31, 1987; item b review included administrative procedures ZAP 14-52-2 and ZAP 3-51-1 both revised on April 30, 198 Implementation and verification activities were not reviewe This item is ope Considering the significance of the diesel engine failure, the Commonwealth Edison QAM was reviewed to establish authority for review and approval of proposed corrective action, and for final review and acceptance of all completed wor Sections QR 1.4.10.B.d, 16.5, and 18.5 of the QAM delineated the requirements for QA personnel to review and verify implementation i of actions to preclude recurrence of the violations. This '

violation will remain open pending final review of the actions taken by QA to preclude recurrence of the diesel engina type failure ,

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I 3. QA Program Review l The purpose of this inspection was to evaluate implementation of the licensee's QA Program in the areas of audits; receipt, storage and handling; procurement; surveillance; maintenance; and corrective actio The inspection was performed by reviewing procedures, records and audits, conducting interivews, and observing activities. In addition, the effectiveness of licensee management involvement and control, staffing, training, and qualifications was evaluate Training This portion of the inspection was performed to review training activities because of revisions to the QA manual. QA training Directive NSDD-T03, Revision 5, outlined the required training and retraining for all site personnel active in the QA program. The )

inspectors selected revisions 87-01, 87-02 and 87-03 for revie I The inspectors determined that all personnel had received retaining {

for those revisions, and were trained to the current revisio J No violations were identifie Auditing l

This portion of the inspection was performed to determine if the site I auditing program conformed to regulatory requirements, commitments j and industry standards. The inspectors accompanied site QA auditors ;

during a portion of Audit No. 22-87-15 Class 1E Electrical Environmental Qualifications. The following information was obtained- ]

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• The auditor's were certified in accordance with the licensee's 1 existing program that met the requirements of ANSI N 45.2.2 * An audit plan was prepared and approve The plan had 18 checklist I items that were utilized during the audi * The audit was performed well and potential concerns were carefully assessed by the auditors and QA managemen * Results of checklist items were carefully documented and accurately portrayed the results achieve i

• Concerns and/or findings were promptly handled, with good and timely closur * Audits were conducted in accordance with the approved audit schedul No violations were identifie _ _ __-_ ____ __

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l Procurement Program l This portion of the inspection was performed to review the licensee's ,

program relating to procurement and determine if activities wer l conducted in conformance with regulatory requirements, commitments, j industry guides and standards. The inspection included detailed i check of a procurement initiated in March 1987 and received in May 198 ;

Purchase Order 313329, was for procurement of austenitic stainless steel pipe, per the 1986 ASME Code,Section III. The licensee committed to Regulatory Guide 1.38-3/73 that endorses ANSI Standard N45.2.2-1972,

" Packaging, Shipping, Receiving, Storage and Handling of items for Nuclear Power Plants (During the Construction Phase)," which is considered applicable during the operation phase. Sections 4. and 4.3.3 establish criteria for handling stainless st. ee ,

The licensee also committed to ANSI N45.2.13-1974, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants." Section 3.2.2 establishes criteria for the content of procurement document '

Both ANSI references included the word shall, implying mandatory requirements; however, special instructions about precautions for handling of austenitic stainless steel were not included, as such, in the purchase order. The licensee concluded that the requirements were probably included indirectly in other references in the procurement documents; however, these references will be reviewed by the licensee to determine if the requirements were actually communicated to the supplier as required. This matter is unresolved (295/87010-01; 304/87013-01).

l No violations were identified; however, one unresolved item was l identifie Receipt, Storage, and Handling '

l This portion of the inspection was performed to review the licensee's activities to control receipt, storage, and handling of equipment and materials to determine if it was inconformance with regulatory !

requirements, licensee commitments, and industry guides and standard j The inspection included checking on the condition and status of a '

variety of items stored in Warehouse The inspector determined that instructions, procedures, and audits generally addressed requirements, commitments and standards in an acceptable manner; however, the condition and status of stored safety related items indicated that implementation of those items was not effective. Storage of safety related items was generally covered by ANSI Standard N 45.2.2, Zion Administrative Procedures

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i No. ZAP-13-52-1, No. ZAP-13-52-2, and Stores Instruction - Generating Station Operation - No. 2. The following problems were identified by the inspector with the storage of safety related items; however, in only one case was a deleterious affect note * Several lots of elastomeric items were stored in a manner that did not exclude air, contamination, and ligh * Two lots of items requiring " Shelf-Life" control had expired, on the shel * One lot of items, with an expired shelf life, had a new date ,

added on the tag without a justification form on fil l l

• Several lots of printed circuit boards were stored without anti-static wrapping, bags, or edgeliners; and were not 4 protected from airborne contaminants or temperature extremes, nor stored vertically or in such a way to prevent stackin !

• Several lots of threaded snubber parts were rusty, dusty, and l dirt * Pump inlet and outlet openings were not covered, plugged, or protecte * Packaging of many items, protection of pump impellers, and {

protection of machined surfaces were imprope j

• Several computer data records about existing stock items appeared to be incorrect or incomplet .

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• Delivery doors to the warehouse were left open at times exposing the warehouse to the weather, and potential ingress damage from insects, birds, and rodent Collectively, these problems are considered a violation of 10 CFR 50, l Appendix B, Criterion XIII, " Handling, Storage, and Shipping," as l implemented by Section 13,0 of the Commonwealth Edison Company l

Topical Report CE-1-A, the Quality Assurance Manual, the Zion station Administrative procedures, and applicable work instructions (295/87010-02; 304/87013-02).

One violation was identifie Corrective Action This portion of the inspection was performed to review the licensee's ability to implement a comprehensive corrective action program to

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i correct safety-related problem The inspection was performed by i reviewing corrective actions associated with the areas of activity covered by.this inspection but specifically focused on.the area of i receipt, storage, and handling,_for the years of 1985, 1986, and '

.1987. Licensee findings, observations, and deficiencies in these areas were reviewed for comparison with problems identified by the inspecto Several licensee audit findings were similar to those identified i by the inspector, and several corrective actions had been initiated I or requested. In one case, for Audit QAA 22-86-20, of July 11-30, 1986, it could not be verified that the shelf-life program had been ;

adequately implemented. As described in Section 3d, items had already l passed the date of established shelf lif The corrective action l response was commitments to have a complete walkdown of all safety-l related items to verify that the items were included in the computer i database by December 15, 1986, and to complete shelf life activities !

with the data computerized by February 1987. The preceeding examples

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of problems in the area of meterial storage indicated that the actions i taken to correct the problems were inadequate. This.is considered a l violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" 1 (295/87010-03; 304/87013-03). i i

One violation was idenfite Surveillance Procedures and Records This portion of the inspection was performed to review the licensee's program relating to surveillance procedures and records to determine if the surveillance of safety-related systems and components was scheduled and conducted in accordance with approved procedures as required by the Technical Specifications (Tf), In-Service Inspections (ISI); In-Service Test (IST), for Pumps and Valves, and NRR-Approved Fire Protection / Prevention Progra QA audits of TS surveillance and associated activities were reviewed by the inspector. The audits were performed in an adequate manner and results obtained indicated adequate performance by the licensee in this are The Zion Operating General Surveillance Schedule, of surveillance for the period of May 15, 1987 thru May 22, 1987, was reviewed in detail by the inspector for both Units 1 and Items on this schedule were verified in reference to the MSS and determined complete and correc .

Surveillance procedures, data sheets, and records were generally complete, correct, and in accordance with requirement No violations were identifie _ __-_-_-_-___-___ - _ -__-______-___

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g. Maintenance This portion of the inspection was conducted to review the performance of preventative and corrective maintenance activities on diesel generator 2B during a diesel outage, and to observe resultant corrective measures subsequent to the 18 diesel failure in October 1986 (See Paragraph 2e).

This inspection was performed by review of related Work Request l packages, conduct of interviews with the responsible foreman and the Master Mechanic, review of QA surveillance and/or audits and I by observations of work on the 28 diese )

i (1) Work Request packages reviewed: j

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• No. Z 55343 DG 2B Refueling outage Inspection (nearing completion during this inspections)

• Seven minor routine items of corrective maintenance identified prior to shut down needing correction during the refueling outag l (2) The following changes and improvements to the. traveler package  !

and its control for the 2B diesel, compared to the original 1 18 diesel traveler, were noted:

• Stricter controls regarding revisions to the packages i

• Assurance of Hold Point sign off '

• Effective traveler form

• Detailed instructions and inclusion of acceptance criteri (3) Observation of 2B work activities in progress as follows:  !

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• Old instruction travelers were in use f

• Work progressed to completion, traveler packages were ,

signed off, and testing of the component would begin l

• Surrounding area surprisingly clean and without debris l * No QA involvement was noted except for a surveillance report I that was written while QA accompanied the inspector No violations or deviations were identifie h. Conclusion l Based on the above evaluation, the inspectors reached the following l conclusions about the licensee's implementation of a QA program in the areas of audits, material handling, procurement, surveillance, maintenance, and corrective actio .

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• Training was adequate in the area of QA program changes;

• Audit personnel were well qualified and trained;

• Audits and surveillance were adequate and conducted according to schedule; corrective actions were adequate except in the area of material storage where two violations were identife Neither violation was significant because none of the cited 4 examples caused or contributed to ineffective or unsafe l performanc * QA management involvement was lacking in the area of ensuring that followup actions were taken to preclude recurrence of maintenance related problem . Unresolved Items An unresolved item is a matter about which more information is required i in order to ascertain whether it is an acceptable item, and open item, j a deviation, or a violatio An unresolved item disclosed during the inspection is discussed in Paragraph 3 . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on May 27, 1986. The inspectors summarized the purpose and findings of the inspections. The inspectors also discussed the likely informational  !

content of the inspections report with regard to documents on processes I reviewed during the inspections. The licensee did not identify any such documents / processes as proprietar i

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