IR 05000295/1987031

Insp Repts 50-295/87-31 & 50-304/87-32 on 871008-1119.No Violations or Deviations Noted.Major Areas Inspected: Licensee Action on Previous Insp Findings,Summary of Operations,Operational Safety Verification & ESF Walkdown

ML20236W003
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/03/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236V989	List: IR 05000295/1987031 ML20236V986
References
50-295-87-31, 50-304-87-32, NUDOCS 8712070217
Download: ML20236W003 (8)

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U.S; NUCLEAR REGULATORY COMMISSION

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REGION III= q Report Nos. 50-295/87031(DRP);50-304/87032(DRP).

Docket Nos. 50-295; 50-304: License Nos. DPR-39; DP.R-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, IL Inspection Conducted: ' October 8 through. November 19, 1987 I Inspectors: M. M. Holzmer l P.'L. Eng Approved B : J. M. Hinds, t2- 05- b7 actor Projects Section.1A Date Inspection Summary Inspection from October 8 through November 19, 1987 (Report f hos. 50-295/87031(DRP); 50-304/87032(DRP))

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Areas-Inspected: Routine, unannounced resident. inspection of licensee actio ! on previous inspection findings; summary of operations; operational safety { verification and engineered safety features (ESF) system walkdown; surveillance 1 observation; maintenance observation; and trainin Results: Of the five areas inspected, no violations or deviations were identifie < 8712070217 871204 PDR ADOCK 05000295 G ,,PDR l L_ _ - _ _ _ _ _ -

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I DETAILS- 1 Persons Contacted *G. Plim1,' Station Manage *E. Fuerst, Superintendent, Production ,

 *T. Rieck,. Superintendent, Services
 *W.' Kurth, Assistant Station _ Superintendent, Operations-  a
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R. Johnson, Assistant Station Superintendent, Maintenance d J. Gilmore, Assistant Station Superintendent, Planning R. Budowle, Assistant Station Superintendent, Technical . Services

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l ! L. Pruett, Senior Operating Engineer -) . N. Valos,_ Unit 2 Operating Engineer

M. Carnahan, Unit 1 Operating Engineer I

 *A. Ockert,' Training Supervisor .
 *R. Cascarano, Technical; Staff Supervisor
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 * Schultz, Quality Control Supervisor V. Williams, Station Health Fnysicis W. Stone, Regulatory Assurante Supervisor   (
 *C. Sprandel,' Quality Assurant a Engineer   1
 * T'Niemi, Mr. ster Mechanic
 *A. Bless, Regulatory Assurance Engineer   j i
 * Indicates persons present at the exit intervie l Licensee Actions on Previous Inspection Findings-(92701, 92702)
 (Closed) Open Item (295/85010-02) Revision of maintenance procedure P/DG001/3-1R, " Diesel Generator Refueling Outage Inspection Checklist,"-

to add inspection of fuel oil lines' to identify wear due to rubbin LER-295/85002 described a fuel oil leak due' to wear caused by rubbing of the steel tubing fuel oil line on an angle iron support. - Refueling outage inspections were deemed adequate to identify wear prior to' fuel line failure. P/DG001/3-1R was reviewed and'found to incorporate an item to check fuel oil lines for wear in step 35. This item is considered-close !

 (Closed) Open Item (295/85010-03) Revision of maintenance procedure P/DG001/3-2R, " Diesel Generator Major Overhaul Inspection Checklist, to -

add a step to verify proper alignment of the engine driven lube oil pum A new preventive maintenance procedure was also to'be developed to-

 ' improve the reliability of the diesel generator first-out annunciator panel. The inspector verified that both of these actions had been  .l completed. This item is considered close i  (Closed) Open Item (295/85018-02; 304/85019-03) Hydrostatic-testing of fire hoses. As reported in LER 295/85012, a quality assurance audit identified improper hydrostatic test pressures for fire hoses at Zio Following a revision to procedure PT-203, " Fire' Protection Fire Hose Test," to incorporate the correct test pressure, fire hoses were to be retested. The inspector verified that reinspection was performed by the Quality Assurance Department by reviewing its Audit Report land_ Follow-up, QA-22-85-1, dated April 4, 1987. This item is considered close ]

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 (Closed)LViolation'(295/87010-02;304/87013-02)hInadequate' preservation'-  ,
 ; protection,.and. control of material and' equipment.in, storage? contrary ..   '

q ito requirements:of;10 CFR 50, Appendix B, Criterion XII_I. The inspector , R

,  toured:the' warehouse, reviewed the results'of the licensee's corrective" Laction, reviewed the: records,'and check'ed~the revised procedures ass  .
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l identified in' the' licensee's response ~ 1etter of July 30,1987. Allfitems)

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 . -were ' determined'.to bel acceptable.1 This11 tem is: considered closedh s '   '
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j M T(Closed); Violation'(295/87010-03;.340/87013-03)?-' Inadequate.or' incomplete l ' '

corrective action to. resolve deficienciestidentified byfinternal Quality ' j

 : Assurance audits'of the control,' preservation,' protection,.and-   2  O j
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information requirements. for material and equipment.zin. storage,; contrary - 4-to 10 CFR 50, Appendix B,1 Criterion' XVI. Thefinspector looked at:the:' results-of the licensee's' actions in response'to this-violation.as; ' .. . , ?q

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 -identified .in the licensee's' response letter of ; July 30',L 1987,- and1found :

all items and actions acceptable. :This; item is' considered closed.; 1 M '1

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J j No violations or deviations were identified.- ,

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q Summary of Operations j Unit 1 4J i The unit. operated for the-entire inspection period at power levels up to -

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99%. . Unit 2 . o 1 The unit operated for the entire inspection per_iod at. power levels .up t . No violations or deviations were identifie q

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   , Operational Safety Verification and Engineered Safety Features System    ,

Walkdown (71707, 71709, 71710 & 71881)- q The inspectors observed control room operations' reviewed applicable 11og ,

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and conducted discussions with control room operators from' October 8 i through November 19,'1987. During these discussions and observations',, ,

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the inspectors ascertained that the-operators were alert, cognizant _of, ' plant conditions, and attentive to changes in those conditions,!and.that' they took prompt action when: appropriate. The-inspectors verified the 1 p operability of selected' emergency: systems, reviewed tagout records and- { verified the proper return to service of affected components. . Tours'of L H the auxiliary and turbine buildings and cribhouse'were conducted toe U observe plant equipment conditions, including potential.. fire hazards,' 1 l1 fluid . leaks, and excessive vibrations and to verify that maintenance l ,  ; requests had been initiated for equipment'in'need'of maintenanc M l 0 y The inspectors by observation and direct interview verified that selected '! physical security activities were being implemented-in accordance'with' '

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the station security pla j

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The inspectors observed plant housekeeping / cleanliness conditions and-verified implementation of radiation protection ' control From October 8, 1987 to November 19, 1987,'the inspectors walked down th' accessible portions of the safety injection system and the 2B diesel .; generator to verify operabilit These reviews and observations were conducted to. verify that facility-operations were in conformance with the requirements established under Technical Specifications, 10 CFR, and administrative procedures, d

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A primary-to-secondary leak.in'the 2A steam generator (S/G).was identified earlier in the~ operating cycle. The 2A S/G 1eak rate ha stabilized at approximately 100 gallons per. day. The Unit 2 safety , injection (SI). pump discharge headers have been pressurized since unit' startup. SI header pressurization is due to leaking' emergency core cooling system (ECCS) check valves, which are designed to' provide pressure isolation between the reactor coolant system (RCS) and.the lower pressure rated ECCS piping. SI discharge header pressure ha l]

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varied throughout the inspection period between 1400 and 1600 psi With regard to ECCS check valve. testing, which'was addressed in inspection report 295/87032; 304/87033, the. licensee,has tested check valves for Unit 2 following maintenance on air-operated valves and.found the leakage to be acceptable in all cases. . Twelve . Unit 1 ECCS check -) valves remain to be tested. This issue is discussed further in paragraph 5 of this repor l No violations or deviations were identifie . Monthly Surveillance Observation (61726)' 'i q The inspectors observed surveillance testing of the safety injection _ 'l systems and verified whether testing was performed in accordance with i adequate procedures, whether test instrumentation was calibrated .whether j limiting conditions for operation were. met, whether removal and .) restoration of the affected components were accomplished, whether test' l results conformed with technical specifications and procedure j requirements and were reviewed by personnel other than the individual  ; directing the test, and whether any deficiencies identified during the i testing were properly reviewed and resolved by appropriate management personnel. In addition, the inspectors reviewed surveillance test procedures and results for safety-related systems. The inspectors made the following comments to the licensee J The inspectors witnessed the performance of TSSP 76-87, "SI Cold Leg Check Valve Leak Check," and verified that the test procedure had - been properly approved for use, that the procedure was adequate, that test instrumentation was subjected to a pretest and post-test calibration, that the test data evaluation was appropriate, and that test results were reviewed by personnel other than those performing the tes =- -

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q The'inspectdsreviewedtheradiographsandass'oeiateddocumentatfoM for check v'aive's 2SI 8905A and B,-2SI 9004C and D, and 2SIL9012A" 'j

  .through'D, as'ubtained using TSS 15.6.112, " Evaluation of Componen l Internals Based on Radiography." The licensee stated that back-  ]
;   leakage. testing is used to verify thelfunctionalicapabilityLof the,  {

subject. valves; however, radiography is used:to; identify gross-

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failures of the subject' check valves,. i.e.; cracked springs. or - . , missing parts. : The inspectors noted. that although an NRC" letter dated February 23, 1980, states that: radiography is one'.of.several  :; acceptable methods of. assuring the. integrity of Event V valves 1 (pressure isolation valves between the.RCS and the ECCS, the failure " of which 'could' result in.a loss.of cool'ant accident outside' containment), there is no" recognized industry standard 1for- j

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determini19 component operability based solely on radiograph The inspectors reviewed the' test results for TSSP 84-87, " Testing of = 2SI 9002 and 2SI 9012 Check Valves." -Initial test results.indicatedL that valves 2SI 9012C, 2SI 9002B and.2SI 9002D exhibited leak' rates in excess of the' licensee's. acceptance criteria. ' Members of!the: , e, technical staff stated that a portion of the measured: leakage was.

l probably due to a leaking air-operated valve (A0V)(which was used to= i isolate the test instrumentation from the portion of test piping: " '; ' downstream of the valves being. tested.; The licensee issued work, 1 request Z64739 to troubleshoot the A0V:and to minimize;the amount; i of leakage through the A0V. A second' leak test for the 9002 and 9012 valves was conducted after the troubleshooting efforts.on th A0V were' complete. The licensee stated that preliminary test results ' of the followup. leak' test indicated that leakage through the.2SI

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9012C, 2SI 9002B and:2SI 9002D valves had'been reduced to an: acceptable value. Work performed on the A0V is discussed in

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paragraph The inspector reviewed the test results for PT-150,1" Hydroge j Recombiner Low Level Readiness Test." The inspector noted that >> after the hydrogen recombiner tripped during performance of the~ . test, the licensee properly declared the recombiner-inoperable and 1 initiated the actions required by the Technical Specification ~

        -j The problem was identified as' a temperature controller (IC-45) in .

need of adjustment. A satisfactory retest was performed on 'g ;

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  (f987)mber6 l The inspector reviewed TSGP-38,UD/G Control System Test."-   I No violations or deviations were identifie . Monthly Maintenance Observation (62703)

Station maintenance ictivities on the safety-related systems and components discussed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, 'and .in conformance  ! with Technical Specification <

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The following items.'were gansidered during this review: whether the limiting conditfoirMor qpe-ation were met while components or systems were removed fr<rr serviceiwhether approvals were obtained prior to initiating the work; whether activities were accomplished using approve procedures'and were-inspected as applicable; whether functional testing and/or calibrations were SUNwed prior. to returning components or systems to service; whether, quality control records were maintained; whether activities were accomplished by qualified personnel; whether parts and materials used were properly certified; whether radiological controls were implemented; and whether fire prevention controls were impienente ' t-

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Work rd) pests were reviewec'40' determine tne status of outstanding jobs and to assure that priority is assigned to safety-related equipmen maintenarse which may affect system performance, The inspectors witnessed pod for.s of the work conducted under work request Z64133. ThtWark request addressed the investigation and repair of the UnitC1. hfety injection "B" pump suction valve, IMOV-SIB 9238. Tho'inspectora noted that the disassembly, trouble-shooting and repMr activiths were conducted per maintenance procedure P/M016-2N, " Disassembly.. Inspection and Reassembly of Environmentally Qualified Safety Related and Non-Safety Related Liniitorque Operators SMB-00, SMB-000."

'During reassembly of 1MOV-SI8923B, the work crew discovered that a cage cf the procedure was missing. Nork was stopped, the missing page was located, and the derk was rtsumed. The inspectors noted that the ' personnel performing-the rtmir and assembly of the subject valve were !;nwledgeable and had been trained for this task.

l The inspedt.crs 'had the following comments on P/M016-2N: l Disasm; ably instructions were detaileJ; however reassembly instruatat:s in some cases stated, " reassemble...in reverse 1 order of disassembly." ThisJLWe of instruction may not be ] l appropriate for personnel rent!vely unfamiliar with this i l task. Individuals would have to flip back and forth in the l tmcedure',"wnich may be difficult if tie work is being conducted j in a radiation dose zone with the individual wearing gloves and ' a respirato I

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The individuals rebuilding IMOV-$18923B stated that this was i the first time they had seen thi lrmision of the procedur ' Training on procedure revisions prior to use would facilitate i maintenance wor * l The inspectors noted that the electrical maintenance personnel p who replaced bearings in the valve operator motor did not have a procedure for their activity. The; P,$pectors were. informed that auch a task was considered to be xithin craft capabilit l

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i.,  ; M , ' qFollowingi:onhlet.jon of ' maintenance onLIMOV-SI892'3Bqthe inspectori

  , verified fhat;the4SI system had been returned ;to seivice properly    %

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i IMOV-SI8923B wor Qp'erformed the:ta'sk inJa' timely?and efficient; * manner and.were clehrly-familiar with the equipment, i .

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      .    , .. The1 inspectors reviewedithe documentationLassociated with the      ,  -<
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1 repair of a steam leak onfcheck Mlverl MS0007. The valve.isi s 9A < :z located inithe stednXuupply.line do thef turbine-driveri auxiliary gj

  -,feedwat'erpump'(TDAEP).qhe'inspectornoted'thattwoworkrequestst      ,
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  'were written to repair ~ the steam leak.' LTheifirst work request L         L specified that thefepair.-be performed using Belzona.wThe rsecond; .        1 work? request specif4d the use ofifuricaditea The leak wi(tlepaired.:
  'dnd the~ valve'was returned to.servicdf     "

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The inspector also witnessed 'a portion Q Y L

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W of the+h f;.  ! } ockiconWucted unde work request Z 64739, which requestediverifidavlis ahd adjustment,.ofJ l

  ;thespingpreloadonvalve2A0V-S198948.. ThI licenice suspected         ,

thatleakageLthrdughthis,valvewascdds199erponeo/sjeditsufor-

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the backleakage tests of several ECCS pressurekisolatan valves.. ' 'i The inspectors had the:fcTwing comments with iegardito thdbrk "! performed: j

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The work crew had difficbty locating the valve at the starth, of the job. Although the-floor elevationiindicated 'on the % 4 j work request das correct (the;568 4 bot. elevation of the Aa 4 Unit 2 containment), the valve wasl3odated'at approximately: i ,

              ,p the 590-foot elqvation, approximat'ely '20. feet abigve.the floor, directly under Jhe grating at the 592-foot elevation. While -      '
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the wor $ crev did not takef anTexcessive amount of, time to' . < "A, locate the valve, the. inspect 6r.noted that;ALARA consideration I would have been optimized had additional;information regarding' 1 the correct location of the valve been provided on the work- ' request from the beginning.: The ivorkLcrew; stopped work until j a proper; radiation survey for the valve wasiconductedt s 1 t

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Initial measurement of the Air '1 valve diskL off its seat reve@ i th pressure R thefspring required preload tSITift had the: 1 been erroneously set, such thst"it'was beJow thelvald noted 1 on the manufacturer's' drawing.- -Thdycrk chiStcry indii{ited, I that the ~ valve' had been, disassembled 4Ndf rdssembled in 21985 ' i by contract-personne h/C /V p

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The pressure regulator used'to determine the air pressure required to lift the valve off  ;, 3) 1 number og calibration stickerto'its n' f,t. .seat

       %r a;did- of the' not3avs documentatf Oserial, on   ^

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l ass identifini ciat %' with the work' calibrated request pickaae regulato t " required.an., 7) j

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The actuator was found to be set'such that the actuator travel -

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was less than the 2 inches ~specified for the valve. The

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     ' actuator.was then adjusted to provide;thelrequired:2ninches ofe
     .. travel; this1 adjustment. increased.the'afr pressure ~ required'
    (foridisk lift to 25 'psig.1 This pressure lisihigherLthan that noted on the valve drawing'; however,'Lthisivalue was ! reviewed :

M' ' :S by the Technical Staff and deemed to beLacceptable~. -A memo-

    ' notingLthe justification and: acceptability ofsthe. increased-  4 o lift air pressure was written and -added. toithe equipment?'
    .~ history file for the valv '

l, The inspector noted that;the personne11 performing the work were-clearly familiar with ,the valvef and. accomplished their:: task!inJaj r timely and efficient: manner, o

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   'd ' Throughout.the inspection period' the licensee experienced:some
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    ' difficulty with maintaining adequate charging 1 flow, 'due to leak ge i,     through.the. Unit 2 45-gpm letdown; orifice and deficiencies ^ with  , ' <

,~ charging flow control valve 2 VC-FCV;121. Thel inspectors noted I that these two. conditions.werd identified before' the. start of the: ' last Unit 2 refueling outage. but have not been c'orrecte ', No violations or deviations were identifieda . Training During.theinspectionperiod,theinspectors'reviewediroutineactivities to assess the effectiveness of: training. . Selected evolutions;wer evaluated.to determine whether:,the classroom,~ simulator, or'on-the-job training received'was adequat g Operating! testing, and maintenance. activities were reviewed as discusse ~ l

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in this repor In' addition, deviation reports (DVRs) were. routinely-evaluated for training impact. No eventsireviewed this period weresfound to have significant training deficiencie ,

No training sessions were attended by therresident inspectors.

/ Exit Interview (30703) The inspectors met with licensee representatives 1(denoted in P.aragraph 1) L throughout the inspection period-and at'the conclusion'of the inspection.

m on November 19, 1987, to summarize the; scope and findings of.the? inspectionjactivities. The licensee acknowledged the; inspectors') .. comments. The inspectors also discussed the.likely informational! conten of.the inspection report with regard to documents or processes reviewed: by the inspectors during the inspection. The licensee did'not identif u .any such documents or procesces as proprietar l

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