IR 05000295/1993018
| ML20058M704 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/14/1993 |
| From: | Gill C, Nejfelt G, Salehi K, Shafer W, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058M694 | List: |
| References | |
| 50-295-93-18, 50-304-93-18, NUDOCS 9312210080 | |
| Download: ML20058M704 (25) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lil
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i Reports No. 50-295/93018(DRS); No. 50-304/93018(DRS)
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i Docket Hos. 50-295, No. 50-3b4 Licenses No. DPR-39; No. DPR-48
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i Licensee:
Commonwealth Edison Company l
Executive Towers West 111
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1400 Opus Place - Suite 300 Downers Grove, IL 60515
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Facility Name:
Zion Nuclear Power Station - Units 1 and 2 l
Inspection At:
Zion Nuclear Power Station, Zion, IL
Inspection Conducted: October 4 through 29, 1993 Inspectors:
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NRC Consultants:
0. S. Mazzoni (Systems Research International)
S. A. Traiforos (SAT Consultants)
Approved By:-
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/1. /h P hafer,' Ch eT Date '
t Maintenance and'0utages Section
Inspection Summary inspection conducted October 4 through 29. 1993 (Recorts No. 50-
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295/93018(DRS): No. 50-304/93018(DRS)1 l
Areas Inspected: An announced team inspection of engineering and technical support and related management activities. The inspection was conducted
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utilizing portions of inspection procedures 37550, 37700, 92701, 92702, and
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92720 to ascertain whether engineering and tecnnical support was effectively l
accomplished and assessed by the licensee.
Results: Based on the items inspected, overali performance in engar.eering and l
technical support was considered acceptable.
- o violations or de. ations were
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identified.
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t 9312210080 931215 PDR ADOCK 05000295
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Inspection Summary
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The most significant strength, relating to engineering support, appeared to be-management's commitment to substantial improvements for the emergency diesel generators and the essential service water system.
The most significant weaknesses were minimum compliance attitudes reflected by
'f some engineers and management, the failure to identify and correct or evaluate
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plant conditions with possible adverse impacts on plant safety and 50.59 I
safety evaluations or screenings that did not always appear to address new types of possible failures.
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DETAILS j
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l 1.0 Principal Persons Contacted
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Commonwealth Edison Company (CECO)
.l R. Tuetken, Zion Site Vice President
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K. Ainger, Supervisor, Modification Design Engineering l
A. Broccola, Station Manager
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R. Chrzanowski, System Engineering Supervisor
K. Dickerson, Regulatory Assurance, Compliance Group i
S. Kaplan, Regulatory Assurance Supervisor
M. Lohmann, Site Engineering and Construction Manager j
E. Martell, Component Cooling Water System Engineer
D. Pederson, Emc.;ency Diesel Generator System Engineer i
M. Rauckhorst, Supervisor, Station Support Engineering i
T. Van De Voort, Diesel Project Lead Engineer l
D. Wozniak, Technical Services Superintendent i
i U. S. Nuclear Reoulatory Commission (USNRC)
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H. Farber - Chief, Projects Section lA
P. Lougheed - Resident Inspector
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M. Miller - Resident inspector W. Shafer - Chief, Maintenance and Outage Section j
J. D. Smith - Senior Resident Inspector
- Denotes those present at the exit meeting on October 29, 1993.
i Other persons were contacted as a matter of course during the inspection.
l 2.0 Licensee Action on Previous Inspection Findinas A number of problems or concerns identified in past NRC inspections were
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reviewed for appropriate licensee corrective actions.
The items reviewed and the inspectors' evaluations of the actions to address these issues are
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discussed in this section.
2.1 (Closed) Unresolved item (295/304/90014-05(DRS)):
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Possible inadequate root cause analysis of repetitive equipment failures of
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service water system packing leakage.
The inspector verified that the licensee tracked service water valve and other equipment deficiencies.
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this item was issued, the NRC has issued several violations on inadequate root i
cause investigation and corrective actions.
(See Sections 2.2, 2.4, and 2.5 t
of this report.)
Because of these subsequent violations, this item is closed.
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2.2 (Closed) Violation (295/304/91009-01(DRS)):
Failure to identify and correct deficiencies in the Unit 2 system auxiliary transformer deluge system. The inspectors reviewed licensee actions taken to
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resolve this problem including those described in the response letter dated
October 11, 1991.
The equipment deficiencies, surveillance procedural inadequacies, and the programmatic weakness in the Zion root cause analysis program had been corrected. Although two subsequent inadvertent transformer deluge system activations occurred, these were due to isolated personnel errors which were
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unrelated to the original problem. The specific failure of not verifying the deluge system spray patterns was corrected by including the spray pattern verification in revised surveillance procedures.
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The inspectors have no further concerns on this issue and this item is closed.
2.3 (Closed) Violation (295/91014-01:(DRSill Failure to correctly translate design basis information of the auxiliary feedwater system to the specification for the auxiliary feedwater discharge valves and to verify and check the adequacy of the revised design.
The inspectors reviewed licensee actions taken to resolve this problem including
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those described in the response letter dated September 11, 1991.
Required action on this issue included revision of procedures to ensure that design basis information was included in design documents and to verify that the design changes to the auxiliary feedwater discharge valves was adequate.
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The inspectors verified that applicable procedures had been adequately revised and that the required modifications had been successfully completed for the valves for both units.
The inspectors have no further concerns on this issue and this item is closed.
2.4 (Closed) Violation (295/304/92009-OlAfDRS)):
Failure to determine the cause and to take adequate corrective actions cn the failure of a 4 Kv breaker. The inspectors reviewed licensee actions taken to resolve this problem including those described in the response letter dated July 10, 1992.
The licensee concluded that this was a failure to report items at a low threshold level for investigation and followup. The licensee established a criterion to report on a Problem Identification Form (PIF) if equipment did not perform as expected on the first attempt.
Additional discussion of corrective action is included in Section 4.3.2 of this report.
The inspectors have no further concerns on inis issue and this item is closed.
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2.5 (Closed) Violation (295/304/92009-OlCfDRS)):
Failure to determine the cause and to take adequate corrective actions on i
diesel generator failures. The inspectors reviewed licensee actions to i
resolve this problem including those described in the. response letters dated
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July 10 and August 14, 1992.
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i A modification to the diesel engine control system, which included provisions
for monitoring and recording of measurable engine parameters, had-been-f developed and was being installed on three of the diesels during the dual unit outage. The monitoring and recording of measurable engine parameters would be i
of significant benefit in engine troubleshooting and investigation for cause i
of failures or problems. Duplication of engine failure conditions would not l
be necessary.
j In addition to this, significant improvements were made in the overall
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I corrective action program. This program is discussed in Section 4.3.2 of this i
report.
The inspectors have no further concerns on this issue and this item is closed.
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2.6 (Closed) Vjolation (295/92023-01(DRS)):
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Inadequate 50.59 safety evaluation. The inspectors reviewed licensee actions (
taken to resolve this problem including those described in the response letter dated December 31. 1992. The inspectors determined that the actions taken i
were appropriate and met regulatory requirements.
l The inspectors have no further concerns on this issue and this item is closed.
2.7 (Closed) Inspection Followup Item (295/304/92023-02(DRS)):
Concerns regarding the possible inadequate instructions for performing material engineering technical evaluations and alternate replacement part
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evaluations.
The inspectors reviewed licensee actions taken to address-this issue and determined that the actions were appropriate and met requirements.
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The inspectors have no further concerns on this issue and this item is closed.
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2.8 (Closed) Violation (295/92023-03(DRS)):
Inadequate post maintenance testing.
The inspectors reviewed licensee actions to resolve this problem including those described in the response letter dated December 31, 1992. The inspectors determined the actions to be appropriate and met the requirements.
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The inspectors have no further concerns on this issue and this item is closed.
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2.9 (Closed) Inspection Followuo Item (295/304/92023-05(DRS)):
Concerns regardin5 the possible inadequate procedure and training in the evaluation of MOV strip charts._ The inspectors reviewed licensee actions j
taken to address this issue and noted the licensee's improvement in their
procedure in direct response to the concern.
The inspectors have no further
concerns on this issue and this item is closed.
3.0 Inspection Ob.iectives
The objectives of the inspection were to determine if engineering activities i
supporting the Zion Power Station were properly coordinated and effectively controlled and implemented. The inspectors focused on the identification and l
resolution of technical issues and problems, design changes and modifications,
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and internal assessments of engineering.
This was accomplished by observation of work activities, interviews with selected personnel (including engineers i
and engineering management), and reviews of records, procedures, and
associated documentation.
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3.1 Performance Data and System Selection i
The selection of systems and components for emphasis during this inspection
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was based on a review of data from licensee event reports, latest SALP information, and discussions with cognizant NRC personnel.
The systems i
selected were the Emergency Diesel Generators (EDGs) and the Component Cooling Water (CCW) system. Modifications and records for specific electrical, _
mechanical, and instrumentation components of these systems were selected for
review.
Activities and documentation involving other systems and components i
were selected and reviewed during the inspection to supplement the selected
systems.
Consideration was given to the systems and components considered
most safety significant.
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3.2 Observations of Plant Conditions
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On October 5,1993, the inspectors performed a walkdown of the EDG and the CCW
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systems to observe the material condition, indications of equipment problems, i
housekeeping and other unusual conditions.
Both units were operating during i
this portion of the inspection.
The material condition of some other areas of l
the plant was observed at other times during the inspection.
j The inspectors concluded that the material condition was poor and several
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unevaluated conditions with possible adverse impacts on plant safety were
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noted.
Seismic and equipment operability concerns were raised and i
housekeeping was less than adequate. Unacceptable housekeeping practices
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resulted in some potential fire hazards. The adverse conditions noted were
corrected promptly or engineering evaluations were conducted immediately to j
determine the possible adverse impact on plant equipment. These evaluations
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indicated that the safety impact of the noted conditions was minimal; however, the evaluations were not made until after the conditions were identified by
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the inspectors.
Equipment or components in need of repair were properly
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identified and many were scheduled for repair or replacement during the dual i
unit outage.
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Unusual conditions noted included scaffolding installed over and around
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important plant equipment, liquid and steam leaks and equipment such as tool
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boxes, ladders, etc. stowed near important plant equipment and loose parts,
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rags and other miscellaneous material scattered on the floors and near
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equipment in the facility. These conditions were noted independently by
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several inspectors. and were considered worse than an average plant.
Licensee personnel' stated that the following additional actions would be taken -
to improve plant material condition and housekeeping. A complete walkdown of
each unit to evaluate material condition and housekeeping would be completed
prior to releasing each unit for startup from the dual unit outage. All (
unusual conditions would be dispositioned.
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System engineers had been instructed to note and question any unusual conditions, including housekeeping, in the vicinity of the system or system
equipment, when they performed the required periodic walkdown of the assigned
systems.
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3.2.1 Emergency Diesel Generators i
lhe inspectors walked down the EDGs, including the EDG rooms, EDG switchgear h
rooms, and the EDG fuel oil storage rooms.
The following observations were l
made.
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EDG Rooms f
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Extensive scaffolding was installed over critical equipment-in three of
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the EDG rooms and personnel were working all around the diesels and equipment.
In response to inspector questions, licensee personnel i
stated that_ the EDGs were considered operable and the work being l
performed was associated with modifications planned for installation l
during the upcoming outage. They also stated that no equipment, i
required for EDG operability, was affected.
In response to questions about seismic qualification for the I
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scaffolding, documents were provided that indicated that the scaffolding l
in the "0" EDG room was installed in January 1993, and had been in place i
since that time. The scaffolding was not seismically qualified;
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however, an engineering evaluation for seismic and operability
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considerations for the 0 EDG was completed in February,1993.
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personnel also stated that the plant procedure for installation and
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control of scaffolding was to be revised to provide better control of
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EDG Switchgear Rooms
Unrestrained robot fire watch devices were found in all EDG switchgear I
rooms.
These devices were heavy and were on wheels.
There was a
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concern as to the seismic qualification of these devices.
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personnel stated later that these devices were removed and the use and j
conditions for use would be evaluateu.
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Electrical cables were observed hanging out of tray T2493-24 in one of l
the switchgear rooms. The licensee responded that this cable overfill
was identified in a previous SSOMI, and that ECN 22-00244E (Mod M22-1-
,90-514 minor) war issued to add side rails to the cable tray at this
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routing point. The cables will be retrained to be below the new side l
rails as part of this modification. There was no concern with
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structural overloading of the tray.
l A ladder was found stored against the wall and a loose sling was i
observed in the EDG "0" switchgear room. Unrestrained tool cabinets
were found in the EDG "lA" and "2A" switchgear rooms. An improperly l
aimed emergency light was found in the EDG "2A" switchgear room.
Wobbly
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and apparently nonseismic fans were found on a transformer in one of the
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EDG switchgear rooms and an aerosol can with flammable contents was
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found on an electrical breaker in one of the switchgear rooms.
o EDG Fuel Oil Storage Rooms l
Spilled diesel fuel was noted adjacent to the fuel tank in one of the j
EDG fuel oil storage rooms and two ladders were found in another.
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i fuel oil had been absorbed into the concrete and was considered a l
potential fire hazard.
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3.2.2 Component Coolina Water System
The inspectors walked down the accessible portions of the CCW system.
Results j
of this walkdown follows:
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Excessive water leaks indicated that some valves were badly in need of repair.
r Licensee personnel indicated that the leaks had been previously identified and
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tnat the valves involved were scheduled for repair or replacement during the dual unit refueling outage.
Scaffolding was installed in one area of the 1A Safety Injection Pump Room.
Although the scaffolding was not seismically qualified, an engineering
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evaluation for seismic and operability considerations was performed
immediately.
This evaluation indicated that_the safety impact of the
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scaffolding was minimal; however, the evaluation was not made until after the l
conditions were identified by the inspectors.
In addition, licensee personnel
found that the scaffolding was installed by mistake almost a year before and
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licensee maintenance and engineering personnel were not aware of the
installation.
Licensee personnel stated that the plant procedure for
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installation and control of scaffolding was to be revised to provide better control of scaffolding.
q Mop heads had been left on the floor in the 2A and 2B residual heat removal i
pump rooms.
A mop in a bucket of water was also found at elevation 579', near column H23.
Unsecured ladders, unused scaffolding, and miscellaneous tools
were also noted in the vicinity of CCW equipment.
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3.2.3 Other Plant Areas
i The inspectors also observed other plant areas during the inspection.
l Conditions in other areas of the plant were similar.to those noted in the EDG l
and CCW areas.
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Of particular interest was the auxiliary building ventilation system. The auxiliary building ventilation system included three independent ventilation supply fans with separate ventilation ducts. One of the three fans had failed j
and was to be repaired.
The work had been started early in 1993 and the
equipment had been left disassembled pending receipt of a replacement fan l
motor.
The job was not expected to be completed for more than a year.
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One end of the six foot open duct, located 15 to 20 feet above another l
independent ventilation train, was covered with plastic and the other was
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covered with two pieces of sheet metal, held in place with ten
"C" clamps, in i
addition, two round coupling duct pieces, weighing about 276 pounds each, were
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stored at the floor level, secured by a small rope. The possible impact of
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the disassembled components on other equipment in case of a seismic event.had l
not been evaluated and leaving equipment disassembled for more than a year did j
not appear to be a good practice.
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This matter was discussed with licensee personnel and an engineering i
evaluation was performed to determine the possible impact of the stored parts
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on other adjacent equipment. The evaluation indicated that, in case of a
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seismic event, the parts would not impact the function of other safety related
systems or equipment in the area.
3.3 Engineerino and Technical Suncort
.j Engineering and technical support at the Zion Power Station was provided by I
two separate organizations. Systems engineering. support was provided by the Technical Services organizations and the Site Engineering and Construction organization provided the support for design changes and modifications.
The inspectors reviewed the engineering support provided by both organizations.
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3.3.1 Systems Enaineerina Support Systems engineering support was provided by two organizations supervised by the Technical Services Superintendent. The plant technical staff provided systems engineering support for all systems except for the EDGs. A diesel team had been organized to provide engineering support and resolve problems associated with the EDGs and EDG related activities. This diesel team provided the EDG system engineering support.
Systems engineers provided oversight for the assigned systems; these engineers focused on daily operations and maintenance activities of the assigned systems. The engineers aided plant operations and maintenance personnel in resolving technical issues and problems and were involved in complex maintenance evolutions in the assigned systems. They also coordinated potential design changes with other engineering organizations.
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Based on the inspection results, the inspectors concluded that the system engineering staff was experienced and qualified. Although system engineers appeared knowledgeable of the assigned systems, the inspectors noted several system engineers with less than two years experience that were responsible for complex systems.
The licensee was aware of this condition. The apparent inexperience of some of the system engineers, although of concern to the inspectors, did not appear to be a significant problem in the areas reviewed.
The engineers exhibited a good sense of system ownership and commuaication and coordination with plant management, operations, maintenance, and other plant organizations was effective.
The inspectors found adequate involvement of system engineers in modifications, temporary alterations, and plant support activities.
3.3.2 Enoineerina Support for Preventive and Predictive Maintenance The inspectors reviewed the involvement of engineering in preventive and predictive maintenance activities. The plant was in transition from an emphasis on failure based maintenance to performance based maintenance.
This new emphasis had resulted in changes that appeared to have improved the quality of communications and support between engineering and maintenance in preventive and predictive maintenance.
3.3.2.1 Support for Preventive Maintenance (PM)
The inspectors reviewed engineering involvement to support preventive maintenance for a recent three month period, July 1,1993 to September 30, 1993, when both units were operating.
Problems discovered during preventive maintenance activities were analyzed by engineering to correct potential problems, such as an unsatisfactory spray pump flow, which was slightly Delow the specified minimum flow rate.
System engineers were familiar with preventive maintenance procedures and reviewed PM-task data when significant or repetitive problems were noted.
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sample period there were approximately 240 preventive maintenance tasks performed for both units.
The involvement and performance of the engineering staff in support of preventive maintenance was considered good and no significant preventative maintenance weaknesses were attributed to a lack of or poor engineering involvement and support.
3.3.2.2 lupport for Predictive Maintenance The inspectors reviewed engineering involvement in the support of predictive-maintenance.
Predictive maintenance included vibrational analysis. oil sample analysis, and thermography as well as other condition monitoring and trending / diagnostic techniques.
These predictive and preventive maintenance data were used to establish equipment base lines, and to as.sess equipment B
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~i performance. Most data-was analyzed by on site engineering specialists with assistance from corporate engineering. Oil samples were routinely analyzed by
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corporate engineering to identify possible equipment problems and equipment
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abnormal i ties.
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The involvement and performance of the engineering staff in support of predictive maintenance was good.
Predictive maintenance methods were
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effectively used to detect adverse equipment conditions prior to equipment
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failure.
Limited success, however, had been achieved with thermography,'which was in the initial stages of implementation.
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Repairs were made to correct adverse conditions or additional checks / tasks were added to the preventive maintenance program as considered necessary.
Examples of problems noted were as follows:
o Vibration analysis data was used to identify coupling and-pump
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bearing clearance problems with the 1A chemical and volume control
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charging pump in January 1993.
In addition, monitoring of check '
valve vibration was used to identify several check valves that required maintenance.
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Analysis of oil samples was used to identify problems with a circulating water pump as well as to identify sources of equipment oil contamination.
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Thermography was used to identify elevated temperatures on one of l
the battery jumper cables for the horizontal fire pump.
l The abov6 examples illustrate that the effective application of these diagnostic tools and the analysis of predictive maintenance data resulted in (
more effective use of maintenance and engineering resources.
l 3.3.3 Review and Evaluation of NRC and Industry Information The inspectors evaluated the effectiveness of the licensee's method for review j
and evaluation of NRC and industry information.
This review included the
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methods used to assure that vendor, industry, and NRC generic information was
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controlled, distributed, and evaluated and that corrective actions were taken
as appropriate.
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i The Regulatory Assurance Department had the overall responsibility for
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coordination of review and evaluation of this information.
Upon the receipt of a notice or other information an initial screening for applicability was a
performed.
According to the information provided by the licensee, only 40 to
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50 percent of the incoming documents qualify as applicable to this facility.
- All documents were logged and tracked in accordance with the procedure L.1,
" Operating Experience Pr ogram"
Distribution to the responsible organization for impact evaluation and determination of possible required action was coordinated with corporate engineering.
The inspectors were told that a; proximately 80 percent of all
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I applicable documents were reviewed by engineering. Assigned departments were I
required to provide a response to Regulatory Assurance noting any plant impact with recommendations for action if needed. All of the applicable NRC and
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industry information was tracked by Regulatory Assurance until the issues were closed.
Regulatory Assurance was also responsible for assembly of the
response package and preparation of the cover letter if a response was i
required.
In order to determine the effectiveness of this system, the inspectors i
selected recently issued NRC Information Notice (IN) 93-72, " Observations from Recent Shutdown Risk and Outage Management Pilot Team Inspections." This IN
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was issued September 14, 1993, and the selection seemed to be appropriate
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since the plant was in a dual unit outage with modifications to be performed
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on three EDGs and the service water systems supplying both units.
The inspectors verified that the IN 93-72 had been received by regulatory assurance and was located in the regulatory assurance files.
There were no
indications that the IN had been distributed.
Licensee personnel stated that
corporate engineering was coordinating this particular IN and were not aware of any schedule or actions that would be taken on this IN.
Engineering personnel, responsible for shutdown risk, had not received a copy
of the IN and were not aware that the document existed. No problems were
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noted in the shutdown risk evaluations or implementation for the dual unit
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outage; however, the failure to perform an initial screening and distribute the document to appropriate personnel before the dual unit outage was not considered a good practice.
This item was discussed with licensee personnel.
The licensee's Lessons Learned Program, which provided interface and communication on problems at other CECO, plants appeared to be working-i effectively.
For example, the inspectors noted that engineering at Zion had systematically reviewed the applicability of a motor operated valve pinion pin and gear problem, identified at Quad Cities.
3.4 Desian Changes and Modifications The Site Engineering and Construction organization had the primary responsibility for coordination, evaluation, development, and installation of design changes and modifications.
This organization was divided into three
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groups which included engineers with mechanical, electrical and other engineering specialties.
The primary purpose of the group was to develop and i
coordinate plant modifications, including design, safety reviews, i
installation, and post modification testing.
Each modification was assigned to an engineer who was actively involved in all phases of the modification.
The engineers completed walkdowns, as necessary, to ensure proper design implementation and resolution of installation problems.
Based on the inspection results, the inspectors concluded that, in most cases.
these engineers were experienced and qualified. Most engineers appeared
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knowledgeable of the assigned modifications; however, the lack of knowledge of j
the modification and inattention to detail led to two safety related exempt i
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changes being inappropriately classified and completed as nonsafety related
(see Section 3.4.1.3).
Communications and coordination between site engineering, system engineers, plant management, operations, maintenance, and
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other plant personnel were effective.
3.4.1 Review of Modification packaoes and Records The inspectors reviewed selected portions of both open and closed modification f
packages, with emphasis on the selected systems, to verify the packages were complete and accurate, the modifications were adequately controlled, and
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regulatory requirements were met. The review included verification that the description of the modification, the 10 CFR 50.59 safety evaluation, installation instructions, documentation of work performed, post-modification
testing requirements and test records were adequate.
In some cases, other supporting records associated with the modifications, such as calculations, were selected and reviewed to verify the adequacy and accuracy of the
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engineering process.
Most of the modification packages and supporting records appeared to be adequate; however, some problems were noted.
Some supporting calculations and 50.59 safety evaluations or screenings were considered weak and indicated a lack of attention to detail.
Safety evaluations and calculations are
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discussed in Sections 3.4.1.4 and 3.4.1.5 of this report.
With the exception of the noted deficiencies, modification records reviewed indicated that modifications were adequately controlled and were consistent with regulatory requirements.
The inspectors concluded that the modification process was effective.
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3.4.1.1 Review of Open Modification Packages The inspectors reviewed selected portions of ten open modification packages and supporting records. The packages reviewed and the review results follow:
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o M22-0-90-022 -- Provide a common collection point for auxiliary building
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equipment drains.
o M22-0-91-026 -- Replace 52 component cooling water system valves 'and
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install 4 new isolation valves to f acilitate future maintenance.
O M22-1-92-002 -- Install a temporary service water system and a temporary spent fuel pool cooling system.
Concerns noted on the review of this modification are discussed in
Sections 3.4.1.5 and 3.4.1.6 of this report.
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O M22-1(2)90-188 -- Change the rotor limit switches for various motor operated valves.
Discrepancies were noted in the documented review and approval dates for the planning sessions for this modification. The inspectors concluded that there was no safety significance associated with these discrepancies; however, licensee personnel were advised of the importance of correct dates on records.
Licensee personnel reviewed
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other documents and coocluded that the problem was an isolated case.
o M22-1(2)90-550 ---Replace the eight service water backwash strainer
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discharge valves.
The inspectors were concerned that the initial problems with these valves were noted in 1989 and the replacement of the eight valves was
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scheduled for the current outage, more than four years later.
O M22-1(2)-91-032 -- Replace 94 service water system valves and install 109 new valves and various piping modifications.
o M22-2-88-047 -- Replace the 2B Diesel Generator Starting Air System with
a new Starting Air System
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o M22-2-89-029 - Install limit switches for the reactor fuel transfer
system.
3.4.1.2 Review of Closed Modification packages The inspectors reviewed selected portions of five closed modification packages and supporting records. The packages reviewed and the review results follow:
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M22-1-91-017-A -- Add Test Connection and Valve on the IVSW to CI Valve
IMOV-9414.
o M22-1-91-017-B -- Add Test Connection Between CI Valves IMOV-9438 and IFCV-CC685 to Allow for Type C Testing.
o M22-1-91-017-C -- Add Test Connection and Spectacle Blinds to Allow Testing of CI Valve IRC8079.
o M22-1(2)-90-028 -- Non-Safety Cross Trio and Diesel Generator Circuit j
Breaker Trip on Safety Injection During Test" The team could not find any objective evidence of the failure mode of the additional trip in the closed position, and the associated impact on safety of undue tripping of the' Diesel Generator output circuit breaker.
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M22-2-92-001A/B - Provide a chlorination system to prevent infestation
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of the service water system by zebra mussels.
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3.4.1.3 Review of Exemet Chanae Proaram An Exempt Change (EC) Program was developed in 1992 to expedite the review and
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approval of modifications of minor significance and with low potential to-significantly reduce the margin of nuclear safety. These modifications were
called " Exempt Changes" and were process modifications which were exempt from the specific requirements of the modification and minor plant change processes.
The inspectors reviewed Procedure ZAP 510-02C, " Exempt Change Program,"
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Revision 2, to ensure that the process provided adequate controls and.that regulatory requirements were met. The EC process could be used for both i
safety related and nonsafety related components and systems.
The inspectors concluded that the EC process provided a viable and effective
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method to control minor modifications of low significance. With the exception
of the noted deficiencies, the records reviewed indicated that exempt changes
were adequately controlled, were consistent with regulatory requirements and
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the process was effective.
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The inspectors selected three closed EC packages for review to evaluate the-control and implementation effectiveness of the EC process. During the review of exempt ~ changes, the inspectors noted that two of the changes reviewed were
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designated as nonsafety related and were not properly classified as safety-related.
The cause of these errors appeared to be a lack of attention to details by the individuals involved in planning and work evolutions, rather than specific problems with the EC process.
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o EC 93-00017 -- Uninterruptable Power Supply Room and Trolley
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Installation.
O EC 92-00033:
Install Drain Valves on the Generator End of the Lef t and i
Right Air Intake Headers on the 2A Diesel Generator.
o EC 92-00034:
Install Drain Valves on the Generator End of the Left and
Right Intake Headers on the 2B Diesel Generator.
j The results of this review are summarized below.
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The engineering change notice and the modification approval letter for ECs
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92-00033 and 92-0034 correctly identified that the drain valves and associated i
fittings for these changes were nonsafety related. The documents failed to note, however, that the welding of the drain valve configuration onto the intake manifolds, the removal of the manifold end flange to check for and-
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remove any debris the replacement of the flange, and the post installation
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testing were safety related activities.
Based on this information the EC was incorrectly classified and worked as nonsafety related.
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In response to inspector concerns, licensee personnel verified the quality and j
acceptability of the 2A and 2B EDG welds by conducting nondestructive testing
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of the welds, reviewing welder qualifications and verifying that safety i
related welding materials were used.
In addition, licensee personnel issued a modification addendum letter for the three open ECs for similar work on the
1A, 1B, and 0 EDGs to correct these changes. A PIF was written on the problem
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to initiate an investigation for the causes and to determine the need for
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possible corrective action. While portions of these ECs should have been i
considered safety related, a prompt review by the licensee revealed that the work had been performed in a quality manner. As a result of the licensee's
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prompt action to ensure quality and prompt action to prevent recurrence on the remaining three EDGs, no violation is being issued on this matter.
The licensee's review of other non-safety related ECs did not identify any ECs which were improperly classified.
EC 92-00033 and EC 92-00034 appeared to be
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isolated examples and the inspectors had no further concerns on this issue.
j 3.4.1.4 Review of Safety Evaluations and Screeninas
The inspectors reviewed the sa"ety evaluations or screenings for the selected
i modifications, exempt changes :and temporary alteration packages to assess the
adequacy of the 10CFR 50.59 evaluations.
The safety evaluations / screenings i
were reviewed for completeness, accuracy, and compliance with regulatory requirements.
All of the packages reviewed contained the 10CFR50.59 safety evaluations or screening and some of the packages contained supporting information.
Packages
reviewed included modifications, exempt changes and temporary alteration
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packages.
Specific concerns on safety evaluation / screening were as follows:
o M22-1(2)-90-028 -- Non-Safety Cross Trip and Diesel Generator Circuit Breaker Trip on Safety Injection During Test"
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The safety evaluation did not address the failure mode of the additional trip in the closed position, and the associated impact on safety of undue tripping of the Diesel Generator output circuit breaker.
o M22-1(2)-90-34 -- Upgrade the diesel generator controls.
I The safety evaluation did not address the loss of the 125 VDC control
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power.
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o M22-1(2)-91-0025 -- EDG 0 Breaker Logic Control
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The safety evaluation did not address a possible coil short circuit condition or the contacts failing open.
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o TA 93-028 -- Install EpROMs in Protection S t III
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The safety. evaluation. indicated that deleterious effects on the safety l
systems would not occur, by reference to-a " test." However, the team i
could not find any objective evidence in the modification package of any
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test to substantiate that there would be no impact on safety.
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Although most safety evaluations were good, in some cases, all aspects of the l
change were not addressed.. For example, some evaluations had not considered
all potential failure modes and the effects of the possible failures on
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safety.
Some failure schemes needed clarification.
Based on the review and
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subsequent discussions with licensee personnel, the inspectors concluded that i
the safety evaluations were acceptable; however, improvement in this area was
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needed.
l 3.4.1.5 Review of Calculations In order to complete the assessment of the design change'and modification
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process, the inspectors reviewed portions of selected calculations that were required to be performed or revised by the selected modifications.
.l Calculations were reviewed for completeness, accuracy, validity of l
assumptions, and conservatism with emphasis on how well the calculations
supported the respective modification.
Some of the calculations were i
performed by licensee personnel while others were performed by contractors.
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The review included a number of calculations on the Temporary Service Water i
System and the Temporary Spent Fuel Pool System.
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Based on the review of calculations, the inspectors concluded that, overall, i
calculations were acceptable.
Several calculation errors were noted and, in:
r some cases, nonconservative inputs, unconfirmed design inputs and unsupported
assumptions were used Although most of the individual problems in this area
were not considered to have a significant effect on equipment function,
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improvement was needed in this area.
This matter was discussed with' licensee i
personnel.
The following concerns were noted during the review of calculations:
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Calculation 22S-2-007E-Oll, "125 VDC 211 First Minute Peak Loading,"
Revision 1, dated May 4, 1993.
t This calculation did not evaluate the effect of random motor starting.
The calculation also' assumed that the seal oil pump would start at one i
second after the loss of offsite power; however, this was not the worst
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starting time. While the worst starting time would probably be very l
remote, the calculations failed to consider this situation.
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Calculation 22S-B-007E-012, "DC Power Feed Coordination," Revision 1, i
dated April 8, 1993.
j This calculation assumed that fuses and breakers performed equally in ac and dc circuits. This assumption could not be verified.
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o Calculation 22S-2-007E-Oll, "125 VDC 211 First Minute Peak Loading,"
Revision 1, dated May 4, 1993.
This calculation contained an unsupported assumption.
Licensee personnel were able to provide background information to support.the assumption after the inspectors questioned the assumption.
o Calculation 8747-80-001, "Non Safety Cross Trip Time Delay Relay Setting" This calculation contained the wrong sign off date.
The recorded dates indicated that the calculation was approved prior to being reviewed.
Calculation No. 22N-0-130E-003, Heat Trace Circuit Design (East Side),
O Revision 0, dated January 19, 1993. This calculation was for freeze protection of the temporary service water system.
The temporary service water system was classified as nonsafety related.
I The calculation contained no justification for using -20 F as the minimum outside temperature and 20 mph as the maximum wind velocity.
The updated safety analysis report (UFSAR). listed these extremes as -26 F and 87 mph respectively. However, local meteorological data supported the choices made.
The calculation also contained contradicting statements on the i
appropriate power connection kits and grommets for humidity protection.
During the inspection, licensee personnel contacted the vendor, Raychem,-
I who confirmed the suitability of the components used.
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o Calculation No. 22S-0-Il0M-022, SFP Time to Boil and Makeup Water Requirements, Rev. O, 10/13/92.
The inspectors noted some discrepancies between this calculation and i
I calculation no. 225-0-110M-001 regarding the mass of water and mass of
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metal.
The masses of water and metal were approximately 10% higher in calculation 022. The values used in this calculation appeared more realistic and were acceptable. This issue was not known to licensee personnel until the question was raised by the inspectors.
3.4.1.6 lemporary Spent Fuel Pool Coolina Modification M22-1-92-002, required the design and installation of a temporary service. water system and a temporary spent fuel pool (SFP) cooling system.
This modification was required because modification and repairs of the service water systems during the dual unit outage would require draining both the existing service water and component cooling water systems. The temporary SFP was to be cooled by the temporary service water system. This modification was classified as non-safety related.
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In reviewing the SFP portion of this modification, the inspectors had a number of concerns.
These concerns involved the possible loss of cooling for the temporary SFP.
If this loss occurred it would most probably be due to the loss of the non-safety related temporary service water.
The concerns are as follows:
o Time to Boil -- Licensee calculation No. 22S-0-110M-022, "SFP Time to Boil and Makeup Water Requirements" indicated that, on a loss of the temporary SFP cooling, the minimum time to boil would be 8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
All actions required to prevent boiling must be accomplished within this time interval. The main procedure which addressed this accident was DU0-801 " Loss of Spent Fuel Pit Cooling." This procedure contained no guidance to assure that the required actions could be completed in this minimum time. Contingency plans had not been tested to ensure timely completion of required actions. The Site Quality Verification Shutdown Outage Assessment Group had recommended that contingency plans for loss of cooling to the SFP should be tested.
Incorrect Temperature Range for Temperature Indicators -- The inspectors o
noted that Appendix X of dual unit outage Procedure PT-0, "DU0 Auxiliary Building Equipment Attendant Checklist," Revision 0, stated that the temperature range for instruments ITI-TF02 #1 and 2TI-TF02 #2 at the temporary SFP heat exchanger outlet was60-120 F.
The inspectors noted that this range was too high at the upper end, since the temperature of the water exiting the SFP heat exchanger should be much lower than 120 F.
The maximum SFP temperature (inlet to the heat exchanger) was to be 120 F, including the temperature rise due to the decay heat. A procedure change request was submitted by the licensee to modify the instrument range to 50-80 degrees F.
incorrect Decay Heat and Time to Boil -- The inspectors reviewed o
procedure DU0-801, " Loss of Spent Fuel Pit Cooling," which addressed the loss of SFP cooling, and noted that figures 1 and 2 were incorrect.
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Licensee personnel stated that figure 1, " Decay Heat Load versus Time"
and Figure 2, " Time to Reach Saturation versus Decay Heat Load" were l
taken from the corresponding plant procedure A0P-6.4.
These figures
.i were not appropriate for the dual unit outage since both cores would be
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off loaded into the SFP. The decay heat load and time to boil have been
calculated and documented in calculations 22S-0-110M-004 and 22S-0-110M-
022 respectively. A procedure change request was generated during the inspection to correct the error.
O Lack of Cross-Referencing Procedures -- Procedure DU0-801, addressed
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using demineralized water as the source of makeup water if SFP boiling
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occurred. Additional sources of makeup water were addressed in DU0-204,
" Spent fuel Pit Makeup " There were no instructions in DU0-801 to refer'
i the operators to DU0-204, in case demineralized water was not available to the pool. The team recommended that these instructions be incorporated in DU0-801 to expedite required actions during boiling.
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O Boron Dilution -- Loss of Temporary Service Water flow to SFP heat exchanger might require feed and bleed of the SFP, as described in Appendix B of procedure DU0-801, by providing demineralized water to the pit.
This method.of pool cooling might be used until normal temporary service water or fire protection water was reestablished. Step'10.c of the procedure required that the boron concentration be maintained at a level greater than 2400 ppm.
However, no analyses had been performed to assess the effect of feed and bleed on boron depletion. A rough estimate performed by the licensee during the inspection indicated that-the boron concentration, assuming that the hold up tanks were full, would be 986 ppm. The Technical Specification Limit was 500 ppm.
The team recommended that the licensee finalize this calculation.
O Increase In Personnel Exposure with Increasing Spent Fuel Pool Temperature -- Since radiation levels increase as the pool temperature increases, the inspectors asked if the increased dose rates had been addressed to minimize personnel exposures during pool heat up following a loss of SFP cooling or for the increased heat load associated with two full cores in the pool.
Such an increased exposure could hamper workers efforts to re-establish pool cocling.
Licensee personnel indicated that the analysis had not been done but that the dose levels would not be much different than the ones associated with the design basis load of the pool.
The team recommended that such analyses be performed.
The inspectors concluded that additional studies, evaluations and assessments should have been completed to ensure that the impact of a loss of SFP cooling could be mitigated.
3.4.2 Temocrary Alterations The inspectors reviewed the methods used to control Temporary Alterations (TAs).
The methods were described in procedure ZAP 510-05, " Temporary Alteration Program", Revision 2.
The scope of the procedure was well defined; the procedure was comprehensive and provided clear directions for implementation.
The inspr ctors reviewed a list of temporary alterations and noted that the number of temporary alterations was high. Although management's goal was that TAs be installed for less than two years, some of the TAs had been installed for several years.
The TA listing indicated that many of the safety related TAs were written on the service water system.
Discussions with licensee personnel indicated that the service water TAs as well as many others would be removed during the daal unit outage as work proceeded to completion.
The number of TAs open af ter the dual unit outage was projected to be less than one third of the current level.
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No significant problems were noted in the review of temporary alteration packages.
Based on the review of the temporary alteration packages, the inspectors considered the methods used by the licensee to control temporary alterations to be thorough and provide adequate control.
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The inspectors selected eleven temporary alteration packages for review to
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verify proper control of temporary alterations. The packages reviewed are listed below
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O TA 90-0060 -- Replace Service Water Strainer Backwash Discharge Valve
TA 91-0070 -- Remove the spool piece for the RHR heat exchanger i
auxiliary steam connection and install a blind flange to isolate the
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auxiliary steam from RHR
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o TA 92-0001 -- 4kV bus voltage less than 3990 o
TA 92-0012 -- Hydraulically locked open control room ventilation emergency makeup filter discharge damper until actuator repair parts
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TA 92-0046 - Install New Pump for Radiation Monitor ORT-PR13.
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O TA 92-0089 -- Eliminating Low Lube Oil Pressure Trip for the Auxiliary Feedwater Lube Oil Pump.
Documentation in the TA package indicated that approval of this alteration by the members of the onsite review committee was by separate-i
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telephone calls.
Two references concerning drawing and procedural changes contained in the technical evaluation form were omitted.
The inspectors did not consider either of these two omissions as safety significant; however, tne method used for onsite review might have
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contributed to this omission.
Based on discussions with licensee personnel,-the inspectors determined
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that the alteration sas discussed thoroughly in a number of meetings, and had a more intensive review than the documentation indicated.
O TA 93-0028 -- Install EPROMs in Protection Set III o
TA 93-0040 -- Fail 0FCV-CVllA Open, Lower Damper Actuator Located Outside Duct (Damper is Internal).
o TA 93-0047 -- Replace the valve stem of the inlet isolation valve for the IB Charging Pump Oil Cooler, valve ICC0363, with a plug to eliminate excessive water leakage.
o TA 93-0056 - Install IC core spray (CS) diesel fuel line sight glass to obtain data for correcting diesel starting hesitation
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4.0 Self Assessment of Enaineerina Activities
Self assessment of engineering activities at the Zion Station consisted of
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audits, and field monitoring of plant modifications.and engineering support.
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Overall, the various assessments covered the spectrum of engineering support
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activities.
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4.1 Audits and Field Performance Monitorina
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The inspectors reviewed recent Quality Assurance (QA) audit and field j
performance monitoring records and interviewed personnel to determine the
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effectiveness of the licensee's self assessment of engineering activities.
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The QA audits and field performance monitoring records indicated that these
activities were performance based, effective in finding engineering l
weaknesses, and adequately covered engineering activities.
Field performance
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monitoring activities complemented the audit program in an appropriate manner.
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Findings and recommendations noted were significant and appropriate.
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t 4.1.1 Ouality Assurance Audits
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Comprehensive audits of the engineering group were normally conducted yearly I
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with additional audits of supplemental engineering activities conducted as
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needed.
Records of four QA audits of engineering or engineering related
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activities were reviewed. These records were:
o QAA 22-92-02: Maintenance Audit
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QAA 22-92-07:
ISI Audit of Zion Technical Staff.and Contractors.
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o QAA 22-92-10:
Site Support Audit of Zion ENC and Contractors.
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o QAA 22-93-02: Site QV Technical Audit of Zion.
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The 1993 Onsite and Offsite Quality Verification Audit Schedule and Plans were
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also reviewed. The audit schedule showed a total of six scheduled audits of l
engineering activities.
4.1.2 Field Performance Monitorina
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Field performance monitoring was used by QA to supplement audits in the assessment of engineering performance. The inspectors reviewed the
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engineering related field performance monitoring reports issued since early 1991.
These reports indicated that the field performance monitoring program, complemented the audit program in an appropriate manner.
The program was'
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strongly performance-based and broad in scope but was focused on suspected or potential problem areas. Monitoring activities often involved observing work-
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in-progress.
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i 4.2 Special Assessments of Enaineerina
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Corporate QA was primarily responsible for special assessments of engineering.
- No overall assessments of engineering had been performed by this group in the last two years.
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i 4.2.1 Comparative Audits The inspectors reviewed records for two corporate QA comparative audits which h
covered some engineering functions. One of these audits had been completed
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and the other was in progress and was expected to be. completed before December 31, 1993. Comparative audits were conducted by corporate QA at all
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Ceco plants to compare the good and bad points of all the Ceco plants in.the specific audit area. Both of the audits reviewed covered limited engineering functions.
O Comparative Audit No. CE-00-92-Il on " Lessons Learned and Corrective
Action" had been completed and the report was issued in December 1992.
l The audit was limited to corrective action. The report covered all plants, and included Zion.
O The audit plan for audit QVA CE-93-15, " Technical Support Comparative
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Audit Plan" was reviewed and the audit was discussed with licensee
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personnel.
This was a corporate audit which compared technical support, including engineering, at the six CECO nuclear power stations.
Twenty i
general activities were audited in eight different functional areas,
including systems and site engineering effectiveness.
This audit was scheduled to be completed in December 1993.
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Based on the review of these documents the inspectors concluded that the comparative audits did not provide a good overall assessment of engineering activities and were of limited value in this area.
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4.3 Trendino and Correctis s Action The inspectors reviewed the methods used by engineering to trend equipment problems, investigate for cause,and provide adequate corrective action.
Significant problems or failures were documented on PIFs, used as a mechanism for investigation to determine root causes and initiate actions to prevent recurrence.
l Management involvement in the tracking and resolution of deficiencies and corrective actions had not been completely effective in the past.
Problems
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with trending and corrective action had resulted in several violations in this
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area during past NRC inspections To correct these problems, the licensee's i
root cause analysis methods were extensively revised. Tne revised methods
relied upon identifying, trending, evaluating and correcting problems.
Trending and corrective action are discussed separately in the following
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sections.
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4.3.1 Trendina
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The inspectors reviewed the methods used to track problems, detect repetitive equipment failures and trend hardware and other quality related problems.
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tracking system had been developed to track, sort and allow oversight of equipment failures and other potential problems. The tracking system used a matrix to collect and sort information into functional groups. Because of
.past problems with inadequate trending, an oversight of this system was provided by the root cause committee.
l In most cases, the system engineer was responsible for-monitoring failure information to detect trends on the assigned systems. Discussions with system engineers indicated that they were knowledgeable of repeat failures which had
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occurred in the assigned systems. The tracking system, noted above, provided a better method for detecting repetitive hardware failure and problem trends.
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The inspectors noted that, in one case, corrective actions, based upon trending information, had resulted in a revision to an operating procedure to monitor flow through service water heat exchangers to determine blockage i
caused by zebra mussels.
Another trending method used was the Component Failure Analysis Report (CFAR),
which utilized information from the nuclear plant reliability data system (NPRDS). This system allowed a review of industry failure and trending information on selected plant components. Discussions with licensee personnel indicated that, in some cases, failure rates were above the industry average for the specific components. These areas were referred to the appropriate system engineer for investigation and possible action.
Based on the review of trending documents and discussions with licensee personnel, the inspectors concluded that component trending was effective and that the trending program was acceptable.
4.3.2 Corrective Action
The inspectors reviewed the methods used for root cause investigation and
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corrective action on hardware and other quality related problems.
Significant problems or failures, requiring a review for cause of failure, were documented on PIFs to track the problems for cause investigations and resolutions.
Systems engineers were normally assigned follow up action for PIFs written on their assigned systems.
In order to improve the corrective system, the threshold level for writing PIFs had been reduced.
In addition, a root cause
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committee had been developed. This committee met each workday to discuss items requiring root cause investigation and possible corrective action.
The inspectors attended several of these daily meetings and concluded that the use of the root cause committee was an effective method for implementing the root cause program, t
The inspectors reviewed selected PIFs to evaluate cause investigation and
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corrective action and no examples of inadequate corrective action were noted.
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Based on the review of the corrective action program, the review of selected PIFs, attendance at several root cause committee meetings and discussions with licensee personnel, the inspectors concluded that actions taken to improve root cause investigations and corrective actions had been effective and that the corrective action program was acceptable.
In most cases, PIFs were written, properly processed, evaluated for cause and the actions taken were appropriate and timely.
Improvements in the corrective action program were evident.
5.0 Exit Meetina The inspectors met at the Zion Nuclear Power Station with licensee representatives (denoted in Section 1) on October 29, 1993, to summarize the purpose, scope, and findings of the inspection. The inspectors discussed the likely informational content of the inspection report with regard to documents
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or processes reviewed by the inspectors during the inspection, noting that two documents were identified as proprietary during the inspection.
Neither of these documents are discussed in this report.
Licensee personnel were asked to identify any proprietary information or material discussed during the exit meeting. The licensee did not identify any such documents or processes as proprietary.
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