IR 05000295/1987038

Insp Repts 50-295/87-38 & 50-304/87-39 on 871207-17. Violation Noted.Major Areas Inspected:Licensee Actions Re IE Bulletin 84-02 & Licensee Implementation of Generic Ltr 83-28 in Areas Including Equipment Classification

ML20149E784
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/07/1988
From:	Gardner R, Neisler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149E779	List: IR 05000295/1987038 ML20149E774 ML20149E782
References
50-295-87-38, 50-304-87-39, GL-83-28, IEB-84-02, IEB-84-2, NUDOCS 8801140016
Download: ML20149E784 (6)

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. U.S. NUCLEAR REGULATORY COMMISSION ,

REGION,III '!

i Reports No. 50-295/87038(ORS); 50-304/87039(ORS)

Docket Nos. 50-295; 50-304' Licenses No. OPR 39; DPR-48 Licensee: Commonwealth Edison Company '

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P.O. Box 767 Chicago, IL 60690

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Facility Name: Zion Nuclear Power Station, Units 1 & 2 .

Inspection At: Zion, Illinois Inspection Conducted: December 7-17, 1987  ;

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Inspector: ohn H.-Neisler I!7 bb  !

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bRonald A .

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Approved By: N. Gardner, Chief If7t8f ,

Plant Systems Section Date

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Inspection Summary Inspection on December 7-17, 1987 (Reports No. 50-295/87038(ORS); '

No. 50-304/87039(DRS)) .

j Areas Inspected: Routine announced inspection (,f the licensee's actions ,

regarding IE Bulletin 84-02 and the licensee's implementation of Generic *

Letter 83-28 in the areas of equipment classification, vendor interface, post maintenance testing and reactor trip system reliabilit Closed TI 2515/64R1 _

and.TI2515/9 (25564) (25591) -

Result 3: Of the five areas inspected, no violations or deviations were ,

identified in four areas. One violation was identified.in the remaining area .

(failure to control vendor technical information according to procedures). .j

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8801140016 880107 *:

PDR- ADOCK 05000205 ,939

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DETAILS Persons Contacted Principle 3.icensee Employees

• Plim1, Zion Station Manager

• T. Rick, Services Superintendent

'* Stone, Regulatory Assurance Supervisor

• T. Van De Voort,. Quality Assurance Superintendent

• A. Bless, Regulatory Assurance Engineer

• J. E. Rohde, Technical Staff Electrical Group Leader

• D. Wozniak, Zion Project Engineer - General Office

• K. Depperschmitt, Electrical Maintenance Superintendent

• L. Laspisa, Technical Staff Engir.eer

• C. Shultz, Quality Control Supervisor

• G. Tolksdorf, Maintenance Staff Engineer I. Netzel, System Engineer, Reactor Trip System L. Oberempt, Quality Assurance Engineer W. Lowe, Technical Staff Training Coordinator R. Wilson, NPRDS Coordinator J. Parker, Electric Department Training Coordinator P. Cantwell, Electric Maintenance Scheduler E. Campbell, Instrument Maintenance Superintendent W. T. Niemi- Mechanical Maintenance Superintendent

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L. Tresize, Document Control Supervisor

• Denotes those persons attending exit interview TI 2515/64 R1 (Closed) TI2515/91 (Closed)  ; Equipment. Classification The inspector selected four components in the_ reactor trip system and nine components in the containment. spray systems for examination during this inspection. The components selected were:

Reactor Trip System Containment Spray System e

Reactor Trip Breaker Lontainment Spray Pump 1A Manual Trip Switch Motor Spray Pump 1A Isolator Board Circuit Breaker', Spray Pump 1A Control Rod La+ch Assembly Valve ICS0005 Valve 1FCV-CS01 Valve 1CS0002 Valve ICS0003 Level Switch ILSL-CS05 i Flow Transmitter 1FT-CS06 l l

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r'or the selected components, the inspector performed the following reviews:

(1) The inspector reviewed the various Zion safety-related components lists. There are individual lists for vt!ves, instrumentation components and some electrical eqelpment, however, no safety-related component list'has been published for mechanical components. The licensee is currently esing P&ID's to identify mechanical safety related component -

During the inspection and at the exit interview, th; inspector was informed that a draft safety-related componeat list-for Zion had been developed and that it was scheduled to be reviewed and published in 1988. The inspector's review of the Zion list will be performed after publication of.the final document by the licensee. (50-295/87038-01, 50-304/87039-01)

(2) To determine the level of plant management oversight, the insoector reviewed procedures controlling maintenance, modifications, procurement and issue, inspection and testing of safety-related items, quality assurance procedures. audits and surveillances and corporate level procedures for activities impacting safety-related structures systems and components.

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(3) The responsibility for designating the safety classification of structures, systems and components at Zion is assigned to the licensee's project engineering department and the activity is controlled by SNED Procedure Q-12 "Equipment Classification."

Activities classification in the plant is controlled by Procedure ZAP 3-51-1 "Origination and Routing of Work Requests."

(4) The inspector reviewed approved procedures for maintenance, modifications, procurement, inspection, storage and testing of safety-related structures, systems and component (5) The inspector selected names of persons performing safety-related I activities from work requests issued for maintenance and repair I of safety-related equipment. Training records indicated that I each person had received specialized training to qualify him to work on the :quipment covered by the work reques (6) The inspector reviewed six audit reports.and seven surveillance '

reports dccumenting Quality Assurance audits and surveillances I involving safaty-related activitie The Quality Assurance organization maintains a scisdule of planned audits and surveillances for safety-related activities at the plan ..

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(7) The corrective action program for safety-related. equipment is described in tha. licensee's Quality Assurance Manual. The inspector's' review of corrective action for audit and survcillanca findings revealed that corrective action for these findings was timely and adequate. .The Quality Assurance Department also schedcles follow-up inspections of corrective actiores three month 3 after corrective action is complete and a finding closed to. determine whether the correctit a action was adequate to prevent recurrence of the proble (8) Review and evaluation of information concerning malfunction of equipment is by the licensce's nonconformance (NCR) and deviation report (DR) program. Both NCRs and DR's are reviewed by management and engineering, and when appropriate by the architect / engineer and vendor to determine the suitability of ,

the equipment to perform its design functio (9) The inspector reviewed safety-related modifications on th reactor trip system and the containment spray system. The modification packages, work requests, drawings, travelers ~and-inspection documentation were clearly identified as safety-related activitie No violation or deviations were identifie b. Vendor Interface The inspector reviewed the licensee's Procedure ZAP 6-52-5, "Zion Station Equipment Technical Information Control, Program." TPis procedure was established to control the use, distributio'n and  :

revision of safety-related vendor equipment technical information (ETI). Responsibility for control of ETI is assigned to the equipment technical information control cente ZAP 6-52-5 Section F.2.1 state?4 "If during the performance of a procedure er work request on a safety-related. . . . .. . piece of equipment, ETI is used to perform the task, that ETI shall be controlled per this procedure." Centrary to the above,- the inspector found uncontrolled ETI (vendor mar.uals) being used for performing safety-related activities in the instrument, electrical and mechanical maintenance department The failuro to follow apprcyed >

procedures is a violatior, of 10 CFR 50 Appendix B Criterion (50-295/87038-02, 50-304/87039-02) '

The inspecto' reviewsd vendor recommendeo modificatrons on the RT5 circuit breakers. The modifications were the shunt crip modification, replacement of the shunt -trip and undervoltage trip attachment with Class IE ettachments and the modification to provide on-line functional testing. All three modifications were complet i

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- Post Maintenance Testing The inspector selected one pump, one circuit break- , one mctor and

. one vs've for review to verify that the licensee was implementing a post maintenance test progra For the selected components; the inspector determined 'ie following:

(1) Written instructions and procedures for the performance _ of. post

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maintenance testing have been developed for plant safety related equipment. -The inspector reviewed 17 completed work requests and five completed procedures to verify that post maintenance testing was being accomplished in accordance'with licensee commitment (2) Criteria and responsibilities for maintenance approval and for designating activities as safety-related and non-safety-related have been established in Procedure ZAP 3-51-1 "Origination and Routing of Work Requests." All the work requests reviewed by the inspector had the proper safety classificatio (3) Methods for performing functional testing following maintenance for safety related components have been developed and are delineated in published technical staff procedures, operator surveillance procedures, and in maintenance and surveillance procedure (4) The inspector reviewed completed work requests and supporting documentation retrieved from the document control records storage. The documentation contained approvals of work requests, the iaentity of persons who performed the activity and the individuals who performed the inspection (5) The inspector verified that the licensee was performing surveillances of the shunt trip attachment by reviewing completed surveillance procedures and surveillance report (6) Tht inspector reviewed completed surveillance procedures and chucklists to verify that the licensee is indepen ently d testing the ability to manually trip the RTS breakers through the use o. either the undervoltage trip attachment (UVTA) or the shunt

' rip attachmen ,

No violations or deviations were identifie Reactor Trip System Reliability The inspector verified that the licensee has established a preventive

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maintenance and surveillance program for the reactor trip breaker The program includes procedures for maintenance, lubrication, UVTA and STA trip force measurements, breaker cleaning and breaker adjustments.

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The : licensee is performing monthly testing of the diverse trip features of each reactor. trip braaker. -The testing includes on-line testing of the UVTA and STA in addition to'the tests utilizing trip signals from the reactor trip syste The inspector ascertained that a program for replacement of _ reactor trip breaker components had been developed based on life cycle established by -the Westinghouse Owners Gr'.up recommended life or '

, 2500 cycles. The Zion program requires replacement of the shunt trip and undervoltage trip attachments at.12 year intervalt. a-suming :

that each breaker is cycled 200 times each year.

, No violations or deviations were identifie ,

3. (Closed) IE Bulletin 84-02 Failures of General Electric Type HFA Relays in use in Class 1E Safety i Systems. The licensee has replaced all normally energized HFA relays with relays with century series coil All relays in de-energized applications have been replaced except for five relays in Unit 2 valve -

interlock applications. The replacement relays are on-site and are -

scheduled to be installed during the next Unit 2 outag ;

' Open Items ,

Open items are matters which have been discussad with the licensee, which !

will be reviewed furthec by the inspector, and which involve some action on the part of tha NRC or licensee or bot One open item disclose ?

during the inspection is discussed in Paragraph 1.a.(1).  ;

P Exit Interview ,

The inspector met with licensee representatives-(denoted under [

Paragraph 1) at the conclusion of the inspection and summarized the scope l and findings of the inspection. The licensee acknowledged the inspectors comments. The inspector also discussed the likely' informational content- '

of the inspection report with regard to documents or processes reviewed ,

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by the inspector during the inspectio The' licensee'did not identify any such documents or processes as proprietar [

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