IR 05000295/1988009

Insp Repts 50-295/88-09 & 50-304/88-10 on 880225-0413. Violation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Summary of Operations & Erroneous Setting of Main Steam Safety Valve Lift Setpoints on 880329

ML20151W776
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/27/1988
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151W751	List: IR 05000295/1988009 ML20151W747 ML20151W764
References
50-295-88-09, 50-295-88-9, 50-304-88-10, NUDOCS 8805030489
Download: ML20151W776 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-295/88009(DRP); 50-304/88010(DRP)

Docket Nos. 50-295; 50-304

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License Nos. 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, IL Inspection Conducted: February 25 - April 13, 1988 Inspectors: M. M. Holzmer P. L. Eng D. J. Damon ,

Approved By:

k J. M. Hinds, Chief f/' .f 7/#t ggd Reactor Projects Section IA Date Inspection Summary

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Inspection from February 25 - April 13, 1988 (Report Nos. 50-295/88009(DRP);

i 50-304/88010(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; summary of operations; erroneous setting of main steam safety valve lift setpoints; March 29, 1988, unit 2 engineered safety feature actuation and power reduction during engineered safety feature *

(ESF) logic testing; Unit I large bore steam generator snubber test failures; Unit i reactor vessel head leak repairs; operational safety verification and ESF system walkdown; surveillance observation; monthly maintenance observa-tion; training; response to regional request for information on main steam

, safety valves; March 8, 1988, site visit by the Deputy Executive Director for Operations; and March 28, 1988, site visit by the Director, Division of Reactor Safet Results: Of the 13 areas inspected, no violations or deviations were identified ,

i in 12 areas, and one violation was identified in the remaining area (lack of  :

administrative controls for a temporary alteration).  !

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8805030489 880429 PDR ADOCK 05000295 Q DCD i

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DETAILS Persons Contacted

• G. Plim1, Station Manager

• E. Fuerst, Superintendent, Production

• T. Rieck, Superintendent, Services

• Kurth, Assistant Station Superintendent, Operations R. Johnson, Assistant Station Superintendent, Maintenance J. Gilmore, Assistant Station Superintendent, Planning R. Budowle, Assistant Station Superintendent, Technical Services M. Carnahan, Unit 1 Operating Engineer N. Valos, Unit 2 Operating Engineer R. Cascarano, Technical Staff Supervisor C. Schultz, Quality Control Supervisor V. Williams, Station Health Physicist

• Stone, Quality Assurance Supervisor

• K. Depperschmidt, Master Electrician W. T'Niemi, Master Mechanic

• A. Bless, Regulatory Assurance Engineer

• T. Printz, Assistant Technical Staff Supervisor

• Indicates persons present at the exit intervie . Licensee Actions on Previous Inspection Findings (92701, 92702)

(Closed) Violation (295/81011-01; 304/81007-01): Fire brigade training sessions were not held in the fourth quarters of 1979 and 1980. In addition, there was no feedback mechanism provided to complete the training exercise. The licensee performs classroom fire brigade training on a quarterly basis with a tracking system to ensure that all members of the fire brigade attend the required quarterly training. Attendance records are maintained in the training building. At the conclusion of each presentation, a critique session is held so that students can provide oral feedback to the instructors. There is no formal feedback mechanism. The adequacy of the licensee's fire brig Me training will be reviewed during future inspections. This item is considered close (0 pen) Unresolved Item (295/81011-02; 304/81007-02): Failure to provide

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each fire brigade member with annual practice sessions using actual fire extinguishing equipment and emergency breathing apparatus under strenuous conditions in accordance with Technical Specification 6.1.E and NFPA Code-1975, section 27. Fire brigade members now attend quarterly classroom training and annual training using fire extinguishing l equipment. Since 1984, the licensee has provided annual training using emergency breathing equipment in a "smoke house" constructed on the sit Fire drills are held quarterly, and attendance at a minimum of two drills per year for each fire brigade member is required and tracked using the attendance list on the Fire Drill Evaluation Form. All other training for fire brigade members is documented and tracked by the training

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department. This item will remain open pending NRC review of the adequacy of the licensee's practical training session (Closed) Unresolved Item (295/81011-03; 304/81007-03): -This item

concerns the NRC's inspection of the licensee's planned strategies for fighting fires in specific areas, and was open pending completion of an inspection in this are Inspection module 64704, issued on February 12, 1986, establishes the basis for inspection of the fire protection prevention program. This module requires inspection of strategies for fire fighting in all safety-related areas and areas in which a fire would present a hazard to safety-related equipmen Planned fire fighting strategies will be inspected as appropriate during the next performance of inspection module 64704. This item is considered close (Closed) Violation (295/86019-04; 304/86018-04): Inattentive fire watche Fire watch tracking now includes hourly logging of fire watch rounds, and hourly reporting to the shift control room engineer. Fire watches are now performed by the station security guard force, and the results of periodic observations of fire watches by NRC inspectors indicate that there have been no recurrences of inattentive fire watche This violation is considered closed.

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i (Closed) Open Item (295/87017-04; 304/87019-03): Various licensee nuclear

general employee training (NGET) practices. The inspector attended a licensee NGET class and noted that pertinent training records are now accessible to the training staff for verification of previous training by individuals going through NGET training. The inspector also noted that new NGET cards are not issued until old cards are turned i No violations or deviations were identifie . Summary of Operations Unit 1 Unit I remained in the cold shutdown and refueling modes during the entire inspection perio Unit 2 Unit 2 operated for the entire inspection period at power levels up to 99% power. On March 12, 1988, Unit 2 reactor power was reduced to 65%

due to incorrectly set main steam safety valve lift setpoints (see paragraph 4). On March 29, 1988, Unit 2 reactor power was reduced to below 50% due to the loss of the only remaining control rod drive ventilation fan (see paragraph 5).

No violations or deviations were identifie . .

A Erroneous Setting of Main Steam Safety Valve Lift Setpoints (93702)

On March 12, 1988, at about 2:30 p.m., Unit 2 reactor power was reduced from 99% to 65% and the power range nuclear instrumentation system (NIS)

trip setpoints were reduced to 74% after the licensee learned that three steam generator (SG) safety valves were inoperable because their lift setpoints were outside the allowable tolerance listed in table 4.7-1 of the Zion Technical Specifications (TSs).

On the morning of March 12, 1988, at about 10:30 a.m. , with Unit 1 in cold shutdown for a refueling outage, the licensee was reviewing requests to the SG safety valve vendor (Crosby) for lift setpoint testing of the Unit 1 safety valves. These documents, which were being prepared as in previous outages, requested that the valves be lift tested and that the

"as-left" lift values be within +2 percent of the setpoints specified in

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table 4.7-1 of the Zion TS It was discovered that the TS mandated tolerance for lif t setpoints is +1 percent. A review of the Unit 2 safety valve test data from the Erevious outage revealed that three safety valves had "as-left" lift setpoints outside the il percent tolerance (although they were within the 12 percent tolerance specified by the licensee to Crosby). Two of the three valves were located on the A steam line, and the other valve was on the D steam line. The valve

setpoints were 0.11, 0.48, and 0.03 percent beyond the 1 i percent tolerance, respectivel The licensee declared the three safety valves inoperable at 1:37 p.m. on March 12, 1988, and initiated the Ur.it 2 power reduction from 99% power at 1:45 p.m. Reactor power reached 65% at 2:30 p.m., and the NIS power '

range high flux reactor trip setpoints were reset to 74% by 3:45 p.m. the same da TSs require that the NIS trip setpoints be reduced within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> i l The licensee performed testing on the affected safety valves on March 10, 1988, restoring the "as-left" lif t setpcints to within TS tolerance, after which the unit was returned to full power. The licensee issued an event report (LER) for this event on April 11, 1988, which will receive additional NRC revie :

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No violations or deviations were identifie . March 29, 1988, Unit 2 Engineered Safety Feature (ESF) Actuation And Power Reduction During ESF Logic Testing (93702)

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On March 29, 1988, at about 9:45 a.m., a Unit 2 containment phase A isolation occurred during the performance of ESF logic test PT-10. The l phase A isolation caused several automatic containment isolation valves

! to close, including 21A01A and 2IA01B, which isolated the instrument air (IA) supply to the containment. The loss of IA caused air-operated

. valves (A0Vs) inside containment to stroke to their fail positions.

l Loss of IA also isolated letdown and shut the pressurizer spray valves, s

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Consequently, pressurizer pressure increased until both power-operated relief valves (PORVs) momentarily opened. The licensee reset the containntent phase A signal and returned actuated corrponents to their normal states, and returned pressurizer pressure to norma ?

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l Approximately five minutes after the containment phase A actuation, the running control rod drive (CRD) vent fan tripped. When the licensee ;

attempted to restart the fan, it immediately tripped again. The '

redundant fan was out of service for repair and was unavailable. CRD vent fans are not covered by Technical Specifications, but the nuclear steam supply system (NSSS) vendor, Westinghouse, has recommended that the licensee imediately shut down and minimize control rod motion when there is no forced ventilation to cool the CRDs in order to protect the .

CRD coils. The licensee had written a standing order to that effect on !

January 22, 1988, when the first fan was taken out of service for repai When the licensee was unable to restart the tripped fan, a shutdown was initiated immediately. The power reduction was halted at about 10:00 a.m. CST when the tripped CRD vent fan was restarted after its circuit breaker was replaced. The resident inspectors observed the rampdown from '

the control roo The licensec believes that the cause of the containment phase A actuation was operator error. The containment phase A actuation manual pushbutton on the main control board is immediately to the left of the two ,

pushbuttons which were to be depressed in accordance with PT-10. This error would have produced the observed results. There does not appear l to be a connection between the containment phase A actuation and the CRD vent fan trip, but the licensee has not completed its investigatio The phase A actuation was reported to the NRC in accordance with the requirements of 10 CFR 50.72, and the licensee will issue a 30 day event report (LER), which will be reviewed by the resident inspecto No violations or deviations were identifie . Unit 1 Large Bore Steam Generator Snubber Test Failures (93702)

During the period of March 24 through April 13, 1988, the licensee reccrded five failures of large bore steam generator snubber test The snubbers, manufactured by Bergen-Patterson, were designed to lock up at snubber tension and compression velocities of 0.4 to 28 inches per minute, and after lockup, to allow further movement (bleed rate) at 0.02 to 0.18 inches per minute. The failures were all due to bleed rates i which were below the minimum acceptance criterion.

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The licensee expanded its testing sample to include all 16 large bore l snubbers on Unit 1, using testing services supplied by Paul Monroe, t

Energy Products Division. In addition, the licensee contracted Wylie

! Laboratories to assist in the testing.

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The licensee is investigating the root cause of the test failure Because of the possibility that Unit 2 snubbers may be affected, the licensee conducted stress analyses to determine whether bleed rates as low as zero inches per minute were acceptable. The licensee reported to the NRC that results of these analyses indicated that stresses of main l steam and reactor coolant piping and steam generator nozzles and supports l were within acceptable limits for continued Unit 2 operation. In the

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event that a cooldown were to be conducted with a steam generator snubber

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locked up and having'a zero bleed rate, additional analyses (and possibly

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repairs to support components) would be necessary. These results, as well as the licensee's root cause analysis and corrective actions, will be reviewed by a Region III inspection specialist in Inspection Report Nos. 295/88010; 304/8801 No violations or deviations were identifie . Unit 1 Reactor Vessel Head Leak Repairs (93702)

A visual inspection of the reactor vessel head around the head flange ,

revealed several streams of boric acid crystals. The inspection was i performed in response to recent concerns reported in NRC Information '

Notice 86-108 and its Supplements 1 and 2. The source of the boric acid ,

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leakage was determined to be from a valv l While inspections were performed under the head shroud, the licensee

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identified small amounts of boric acid residue coming from canopy seal :

welds on control rod housings E9, G5, and L5. The licensee then '

contacted the NSSS vendor, Westingnouse, to recommend a course for repair. Evaluation of the repairs, as well as the licensee's evaluation of the potential effects of boric acid corrosion, will be considered an Open Item (295/88009-01).

No violations or deviations were identified. One open item was identifie . Operational Safety Verification and Engineered Safety Features System Walkdown (71707, 71709. 71710 & 71881)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from February 25 through April 13, 1988. During these discussions and observations, the inspectors ascertained that the operators were generally alert and cognizant of plant conditions, and took prompt action when appropriat The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified the proper return to service of affected components. Tours of the auxiliary building, turbine building, steam tunnels, cribhouse and Unit 1 containment were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive v:bration The inspectors by observation and direct interview verified that selected physical security activities were being implemented in accordance with the station security pla The inspector noted on one or.casion that a reactor operator in the control room was not displaying his security identification badge as required by station procedures. Station procedures require that security identification badges be worn on the front of the body above the waist. The individual in question had his security identification badge in his jacket pocket. Licensee management was informe . .

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The licensee stated that immediate corrective actions taken included personal 'ounselling of the-individual and talks between the Assistant Superintes.Jent of Operations and each shift. Further corrective actions will include separate discussions with each of the department heads and shift engineers to emphasize the importance of displaying security identification badges properly, placement of posters emphasizing the importance of wearing badges properly, an increase in tours of the control room by security personnel, and the development and dissemination to all plant personnel of ti station policy on disciplinary actions to be taken for those individuc.s who do not display their security identi-fication badges properly. Completion of these corrective actions by the licensee will be tracked as an Open Item (295/88009-02; 304/88010-01).

The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. From February 25, 1988, to April 13, 1988, the inspectors walked down the accessible portions of the main steam, electrical distribution, and diesel generator systems to verify operabilit During a maintenance inspection in the Unit 1 auxiliary building equipment drain tank (ABEDT) room the inspectors observed evidence of packing leakage and flange leakage (boron encrustation) from the following valves:

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1 MOV-VC 1120

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1 MOV-VC 112E

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1 MOV-RH 8804A

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1 MOV-RH 88048

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1 SI 8927 After discussion with the licensee and a reinspection by an in-service inspection (ISI) engineer, work requests were initiated to correct any active leaks which remained and to remove boron encrustation from affected components. Tnese components were last inspected under the ISI program on December 17, 1986, at which time small amounts of boron leakage were evident. At that time, no work requests were initiated because the leakage was not recordable according to the ISI code (ASME Section XI). The ISI engineer noted that there was more encrusted boron on the valves now than at the time of his last inspection. His rein-spection was documented on Visual Examination Data Form VT-2-1.1, and included work request numbers for the leaking component During(an observation of a test performed in the Unit 2 containmentCS) pump room, spray boric acid and sodium hydroxide residue from various leaks. The material condition of the room was significantly worse than that of other safety related equipment rooms. The licensee has already decontaminated the Unit 1 CS pump room, and plans to decontaminate the Unit 2 CS pump room in the futur The inspectors noted that although Unit 1 was in a refueling outage, the licensee continued to emphasize the importance of maintaining the plant in a generally clean condition. The inspectors noted that painting activities are continuing throughout the outag . _ . _ _ . .. _ - . - _ .

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No violations or deviations were identified. One open item was identifie . Monthly Surveillance Observation (61715, 61726 and 70313)  ;

The inspector observed portions of Technical Specifications required l surveillance testing on the containment spray and diesel generator systems and verified whether testing was performed in accordance with adequate procedures, whether test instrumentation was calibrated, whether limiting conditions for operation were met, whether removal and restoration of the affected components were accomplished, whether test  ;

results conformed with Technical Specifications and procedure i requirements and were reviewed by personnel other than the individual  ;

directing the test, and whether any deficiencies 'dentified during the

testing were properly reviewed and resolved by appropriate management personne l The inspector also witnessed portions of the following test activities:  !

l TSS 15.6.10A Type A Containment Leak Rate Test on Unit 1  !'

TSGP-31 Setting Minimum Flow Stops For FCV-CS01,2,3 PT-6 Containment Spray System Tests and Checks

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PT-11 Ofesel Generator Loading Test  :

2F-CS02A/B Containment Spray Eductor Flow Ratio Control Test  !

I TSGP-31 was perfonned to set the position of the minimum flow stops of FCV-CS01,2, and 3 followir:9 a change to the system. These flow control valves (FCVs) ensure that a portion of the discharge from each CS pump *

i is continuously diverted through an eductor which draws sodium hydroxide i

, (NaOH) from the spray additive tank for containment iodine removal '

following a loss of coolant accident (LOCA).

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The FCVs are operated by a ratio controller which is designed to maintain

a 1 to 10 ratio between CS pump flow diverted to the eductor inlet and CS

i pump flow to the spray header. The minimum flow stops for these FCVs i were being removed due to problems with binding and scoring of the valve

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packing glands. The FCV air operators would then be relied upon to assure ,

that the minimum flow is maintained. While reviewing TSGP-31, the i following concerns were identified:

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The inspector asked whether the change involved part of the original design, and therefore whether reviews should have been performed ,

pursuant to 10 CFR 50.59 before the chang l

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The minimum flow acceptance criterion in TSGP-31 is 135-145 gpm, i but the minimum flow specified in the CS pump monthly test, PT-6, ,

is 190 gpm. The inspector asked the licensee to explain the

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discrepancy between these two numbers, and to provide the bases for these different acceptance criteria.

These concerns will be considered an Open Item pending resolution by the licensee (295/88009-03; 304/88010-02)

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No violations or deviations were identified. One open item was identifie . - Monthly Maintenance Observation (62703)

Station maintenance activities on the safety-related systems and components listed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with Technical Specification "

The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

Overhaul of the 1A Diesel Generator Overhaul of the 18 Diesel Generator Environmental Qualification limit switch inspection for valve 1 MOV-SI 8804A Environmental Qualification motor operator inspection for valve 1 MOV-SI 8811B While observing the inspection of 1 MOV-SI 8804B, the inspector noted that:

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On an attached jumper / lifted lead form, the electrician recorded that a print was incorrect. The inspector asked for a copy of the drawing change request (DCR) fonn which was issued as a resul The parts list for procedure E 025-1, "NAMC0 Limit Switch Environmental Qualification Inspection / Replacement," listed two parts for which the part numbers on the attached quality assurance red tags did not completely agree:

E 025-1 Part N Red Tag Part N EA181-10160 Rev. C EA181-10160 EA181-10102 18110102 The inspector requested that the licensee provide records of receipt inspection or other records to demonstrate whether these differences are significan ,

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While observing tae EQ inspection of the motor operator for valve 1 MOV-SI 88118, the inspector noted that:

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The sealtite (flexible conduit fitting for the motor operator power leads) was identified as damaged. The inspector requested that the licensee provide an evaluation of the root cause and proposed corrective actio The electrician recorded what were apparently unqualified wires and lugs on pages 12, 13, and 14. A subsequent comment indicated that

, the suspect components were actually acceptable. The inspector requested EQ documentation to establish the acceptability of the identified deficiencies.

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This is considered an Open Item pending receipt and review of the i information requested above (295/88009-04).

The inspector also noted that valves 1 MOV-SI 8811 A and B are located in a pressure retaining enclosure ("cans"). These cans were originally designed to withstand post-accident containment pressures. In order to provide access for electricians to inspect the motor operator, the licensee's mechanical contractor was tasked with removal of the can for 1

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MOV-SI 88118. Due to a labelling error, and failure to correctly verify that work was done on the correct component, the contractor removed the can for 1 MOV-SI 8811A by mistake. The error was immediately identified by electricians when they checked wiring labels at the beginning of their >

EQ inspectio The inspector noted that the work request for 1 MOV-SI 8811B (Z64511)

specified stroke testing in accordance with routine periodic tests, j The inspector questioned whether a type C leak rate test needed to

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be performed in accordance with 10 CFR 50, Appendix J, after the can was reclosed. The licensee was requested to provide this information prior to leaving cold shutdown. This is considered an Open Item (295/88009-05).

Following completion of maintenance on the 1A and 18 diesel generators,

. the inspector verified that these systems had been returned to service !

I properl No violations or deviations were identified. Two open items were

identified.

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i 11. Training (41400)

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During the inspection period, the inspectors reviewed abnormal events and unusual occurrences which may have resulted, in part, from training deficiencies. Selected events were evaluated to determine whether the classroom, simulator, or on-the-job training received before the event l

was sufficient to have either prevented the occurrence or mitigated its effects by recognition and proper operator action. Personnel qualifi-cations were also evaluated.

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The inspector attended the licensee's initial nuclear general employee training (NGET). The inspector noted that due to the large number of ,

contract personnel being employed during the Unit 1 outage, contract personnel were serving as NGET instructors. The inspector noted that a great deal of material was presented in a short amount of time. Of the eight people in attendance, seven passed. Provision for remedial ,

training was made for the individual who did not pass the course.

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No violations or deviations were identifie . Regional Request for Information on Main Steam Safety Valves (92701)

By memo dated January 28, 1988, the resident staff was requested to provide certain infonnation regarding the licensee's main steam safety valves (MSSVs) to the Division of Reactor Safety. The resident staff provided specific MSSV information such as the licensee's response to I

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and E Information Notice 86-05, " Main Steam Safety Valve Test Failures and Ring Setting Adjustments," the make and model numbers of the MSSVs installed at the Zion Station, the guide and nozzle ring setting of the i MSSVs, a description of the maintenance and test programs applied to the '

MSSVs, and a comparison of the design relief flow capacity and calculated .

relief capability of the MSSVs. This information was forwarded by memo '

from the resident staff to the regional office on March 25, 1988.

] No violations or deviations were identifie I i

13. March 8,1988 Site Visit By Deputy Executive Director for Operations (37700)

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On March 8, 1988, a site tour was conducted by the resident inspector for Mr. James M. Taylor, Deputy Executive Director for Operations;

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Mr. Richard W. Cooper, Headquarters Regional Coordinator, Region III; Mr. William Forney, Chief, Projects Branch I, Region III; and i Mr. Jan Norris, Licensing Project Manager for Zion. Following the plant j tour, Messrs. Taylor, Cooper, Forney and Norris met with the plant manager and other members of plant e.anagement. Mr. Taylor noted that

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the plant should continue to strive for excellence and that any serious deficiency exhibited by any nuclear power plant would have a significant 1

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effect on the nuclear industry as a whole. Mr. Taylor cautioned the meeting attendees to avoid complacency and to maintain a critical view

! of plant activities although plant conditions were improving. Mr. Taylor

, also noted that technical staff activities required scrutiny in light of *

recent events at other nuclear facilities and encouraged the plant staff

to work as a team. Mr. Taylor also stated that the NRL would continue to j monitor plant activities and associated progress.

I During the plant tour, Mr. Taylor noted that a control room charcoal i booster fan located in the auxiliary building air conditioning room i

appeared to be missing. The charcoal booster fan provides a filtered source of air from the turbine building to the ontrol room ventilation system to make up for ventilation system losses. The control room charcoal booster fans, OA and 08, r e installed in parallel downstream l

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of charcoal filters. Mr. Taylor also noted that there were no tags or i other documentation in the vicinity of the missing fan. Subsequant followup by the resident' staff revealed that on March 4,1988, the OB control room charcoal booster fan would not start when manually actuated from the control room and that a PT-14 "Inoperable and Required Redundant Equipment Surveillance Test Sheet," had been initiated for L the fan. The licensee stated that the subject fan had been removed for repair and a blank flange had been installed to preclude entry of unfiltered air into the control room makeup up air supply through the i hole left in the duct by removal of the OB fa The residents informed the licensee that installation of the blank flange

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on the supply plenum to the charco41 booster fans constituted a plant modification. The residents asked the technical staff system engineer

! how the installation of the blank flange on the supply plenum to the ,

control room charcoal booster fans had been controlled. The engineer "

stated that such installations were normally performed because they '

were obviously required and that no documentation for such installations existe CFR 50, Appendix B, Criterion III, Design Control, requires that design changes, including field changes, shall be controlled and approved in a manner consistent with that applied to the original design. The licensee's approved Quality Assurance Topical Report, CE-1-A, Quality '

Procedure (QP) 3-51, Attachment A, states that the ANSI and ASME definition for modifications includes temporary alterations such as  !

jumpers, lifted leads, bypass hoses, blind flanges, setpoint changes, electrical trip settings and overload heater size changes which are administrative 1y controlled by Comonwealth Edison outside the scope of the licensee's quality assurance manua Zion administrative procedure ZAP-0, "Conduct of Operations," section  :

5.3.10, requires that temporary alteration activities be conducted in '

accordance with ZAP 3-51-4, "Procedure Governing the Use of the Temporary Cables, The Lifting of Terminated Wires, the Bypassing of Alarms, or the Installation of Mechanical Blocks or Bypasses," however, not all the items identified in QP 3-51 are addressed in ZAP 3-51- ZAP 3-51-4 specifically addresses the administrative controls prescribed for the use of temporary jumper cables and terminated leads, for the

! bypassing of alarms, and for the installation of mechanical blocks and bypasses. The scope of ZAP 3-51-4 states that the requirements of ZAP i 3-51-4 includes all safety-related and non-safety-related systems and t

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circuits. A technical review is required for all proposed change ZAP 3-51-4 also states that if the proposed change is to a safety-related  !

system, on-site review and approval of the change shall be completed

{ prior to installation. The ZAP also states that use nf jumper, lifted L

! lead, or block bypass logs are not necessary under the following cir-l cumstances:

l i An installation and removal record is kept as part of the test j or maintenance procedure.

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off for restoration of the system to norma The test or maintenance procedure is reviewed for completeness prior to returning the equipment to an operable conditio [

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l Contrary to the above, on March 4 through 15, 1988, a i;emporary alteration was not conducted in accordance with ZAP 3-51-4, in that a !

,- blank flange was installed on the supply plenum to the control room charcoal booster fans and no temporary alteration controls required by

.. ZAP 3-51-4 were use The work package associated with the repair of the OA control room charcoal booster fan did not include instructions regarding the L installation or removal of the blank flange on the supply plenum between the charcoal filter bank and the booster fans. Furthermore, the PT-14 and.the block / bypass log did include any reference to the blank flang In addition, neither a technical review nor an on-site revi W regarding the blank flange was performe Failure to perform a review of the effects of installing a blank flange in the control room makeup ventilation system is considered to be a violation (295/88009-06; 304/88010-03(DRP)). ,

r One violation and no deviations were identifie ;

14. March 28, 1988 Site Visit by Director, Division of Reactor Safety (30702) <

On March 28, 1988, a plant tour was conducted by the senior resident .

. inspector for Mr. Hubert J. Miller, Director, Division of Reactor Safety.

Mr. Miller was onsite to participate in the entrance meeting for the Zion Safety Systems Outage and Maintenance Team Inspection which will be i conducted at Zion during the periods March 28 through April 2, 1988, and [

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April 11, 1988 through April 29, 1988, 15. Open Items

.

! Open Items are matters which have been discussed with the licensee which j will be reviewed further by the inspector and which involve some action ,

on the part of the NRC or licensee or both. Five Open Items disclosed during this inspection are discussed in paragraphs 7, 8, 9, and 10.

1 Exit Interview (30703) ,

$ The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection !

on April 13, 1988, to sumarize the scope and findings of the inspection i j activities. The licensee acknowledged the inspectors' comments. The ,

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inspectors also discussed the likely inf m itional content of the ,

! inspection report with regard to documr< ; ,r processes reviewed by the !

l inspectors during the inspection. The *y asee did not identify any such l documents or processes as proprietary, i

f

! 13 k ..