IR 05000295/1993023
| ML20059H123 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/14/1994 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059H111 | List: |
| References | |
| 50-295-93-23, 50-304-93-23, NUDOCS 9401260273 | |
| Download: ML20059H123 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Report Nos. 50-295/93023(DRP); 50-304/93023(DRP)
Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Executive Towers West III 1400 Opus Place - Suite 300 Downers Grove, IL 60515 Facilv Name:
Zion Nuclear Power Station, Units 1 and 2 Ins; a At:
Zion, IL Inspection Conducted: November 24, 1993, through January 6, 1994 Inspectors:
J. D. Smith
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M. J. Miller V. P. Lougheed S. G. DuPont e j
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W Appioved By: mBruce orgensen, Chief
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F Reactor Projects Section lA Date
Inspection Summary Inspection from November 24. 1993 to January 6. 1994 (Report Nos.
50-295/304-93023(DRP))
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Areas Inspected: This was a routine, resident inspection of licensee action on previous inspection findings; outage activities and events; operational safety; maintenance and surveillance; engineering and technical support; safety assessment and quality verification; licensee event reports (LERs); and management changes.
Results: One violation was identified and is discussed in section 6.
The violation involved a failure to incorporate appropriate acceptance criteria in a test procedure. Two non-cited violations were identified concerning a failure to perform a surveillance and a failure to perform an offsite review of a safety evaluation. Both of these items are discussed in section 8.
One inspection followup item was identified concerning foreign material fcund in the reactor vessel (section 7a).
9401260273 940119 PDR ADOCK 05000295 G
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Operations Operations made a prompt and sound operability call on the emergency diesel-generators when the under-frequency relays were found cracked. Also r
noteworthy was the prompt inspection of other non-safety relays for cracking.
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Maintenance i
The improved in-house capability to replace large valves, which will reduce
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dependence on contractor assistance, is considered a positive effort by the j
licensee.
i Engineering
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Management was not proactive in the application of resources to determine the
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root cause and correct the IC containment spray pump's slow starting problem.
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However, good engineering support by the system and site engineering groups
have helped the station maintain an aggressive schedule with major
modifications being made.
i Plant Support'
i The station's total person-rem for the outage was slightly lower than
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projected for this stage of the outage. The radiation protection department i
has done ar axcellent job of keeping exposures ALARA considering the higher i
source terras on Unit 1.
j Safety Assessment And Quality Verification
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Management attention was inadequate to prevent foreign materials from getting
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into the reactor vessel and other systems. However, Tggressive corrective
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actions were being taken by management to correct the foreign material t
intrusion problems. On the positive side, good outage management enabled the
outage to stay on schedule with only minor problems that were quickly i
resolved.
q The quality verification group's increase in staff size will enable them to t
provide broader coverage for the station.
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DETAILS
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1.
Persons Contacted
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R. Tuetken, Vice President, Zion Station J
- A. Broccolo, Station. Manager-
- M. Lohmann, Site Engineer & Construction Manager
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- S. Kaplan, Regulatory Assurance Supervisor
- P. LeBlond, Executive Assistant to the Vice President
- D. Wozniak, Operations Manager
- L. Simor., Maintenance Supervisor J. LaFontaine, Outage Management Manger
- T. Printz, Assistant Superintendent of Operations
- R. Cascarano, Services Director
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W. Stone, Performance Improvement Director l
- R. Budole, Site Quality Verification
- J. Tiemann, Technical Staff
- K. Moser, Unit 0 Operating Engineer
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- K. Dickerson, Regulatory Assurance - NRC Coordinator
- Indicates persons present at the exit interview on January 6, 1994.
The inspectors also contacted other licensee personnel including members of the operating, maintenance, security, and engineering staffs.
2.
Licensee Actions on Previous Inspection Findings (92701, 92702)
a.
(Closed) Inspection Followup Item 295/304-90030-25(DRP):
" Ineffective Implementation of Corrective Actions." To resolve
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this issue, the licensee reviewed steps taken in closing corrective actions to the electrical distribution system functional inspection (EDSFI). As a result of this review, 12
items were re-opened and further corrective actions were taken.
- i The licensee also improved various tracking systems and implemented a problem identification form (PIF) system. The-inspectors, over a number of inspection periods,.have reviewed the effectiveness of the tracking systems, and found them to be acceptable.
This item is closed.
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(Closed) Open Item 295/304-90035-03(DRP):
"Several Improper Wiring Determinations were Identified in Safeguards Cabinets."
There were no operability concerns with'this issue. Grooming of Unit I cabinets has been completed and Unit 2 cabinets will be groomed in January of 1994. This item is closed.
c.
(Closed) Inspection Followup Item 295/91012-01-(DRP):
" Loose Part
in Number 1 Component Cooling Heat Exchanger." An inspection of
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the service water. inlet channel head for the heat exchanger-revealed five three-by-one inch tapered pins. Additionally, several loose mechanical tube plugs were found. No damage to the tube sheet was caused by the foreign material. Corrective actions
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I to strengthen the foreign material exclusion (FME) program were
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being implemented. This item is closed.
d.
(Closed) Unresolved item 304-92014-01(DRP):
" Operational Analysis f
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Department Personnel Opened a Wrong Interlock Knife Switch Which Resulted in the Loss of DC Control Power to an Emergency Diesel
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Generator that was Out-of-Service." Corrective actions included a j
new procedure to provide better control during testing and several
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knife switches were relabeled. The inspectors have no further concerns. This item is closed.
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(Closed) Inspection Followup Item 295-930ll-01(DRP): " Recurrent
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Diesel Containment Spray Pump Starting Failures." During this
t inspection period, the inspectors reviewed the licensee's actions to correct the recurrent IC containment spray (CS) pump failures i
to start.
Based on the results of the review, as discussed -in section 6, this item is closed.
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No violations or deviations were identified.
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3.
Outage Activities a.
Status
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During this inspection period, the dual unit outage continued.
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Both units remained defeled and spent fuel pit cooling was i
supplied by the temporcey service water system.
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The extensive service water (SW) work.and emergency diesel
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generator (EDG) modifications were ahead of schedule; however, i
motor operated valve (MOV) testing progress, including completion
of paper work, continued to be a concern.
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The Unit 2 ten-year reactor vessel inservice inspection was completed successfully and the lower internals were reinstalled.
Inservice inspection of steam generator girth welds for both: units
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was completed and final evaluation was in progress.
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The two low pressure turbine rotor inspections (IA and 2A) were
completed and the turbines reassembled. The erosion-corrosion i
inspection for Unit I was completed on 60 components with'no i
significant problems being identified.
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Enhanced maintenance of the rod. control system for Unit I was completed by the vendor and final system testing was completed-l satisfactorily.
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b.
Events
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Unit 0 component cooling water heat exchanger: On December 15, eddy current testing of the component cooling water heat-I exchangers was completed. On the Unit 0 heat exchanger, there J
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were a number of indications which exceeded the licensee's.40%
through wall criteria, indicating a need to plug the tube.
However, if all the tubes with the indications were plugged, then the cooler would no longer meet its original design requirements.
The plugging criteria has been changed from 40% to 60% through wall criteria. The new criteria provides a 15% margin from the code allowable wall thickness.
In addition, the tube plugging limit was a function of heat exchanger cleanliness. The cleanliness factor was raised from 50% to 54% to increase the allowable number of plugged tubes. ' The cleanliness change was.
still conservative.
Station support engineering recommended that the tube bundle for the Unit 0 component cooling heat exchanger be replaced during the January 1995 outage.
Forebay cleaning: On December 9, divers inspected and cleaned the 2C intake bay.
Extensive zebra mussel fouling was found, with the trash collectors in the forebay being completely covered. The licensee expanded the mussel removal scope to include complete cleaning of the forebay and intake structures during the dual. unit outage.
The licensee plans to thermally shock the service water and circulating water systems in the spring to prevent zebra mussel reinfestation.
No violations or deviations were identified.
4.
Operational Safety Verification (71707)
The inspectors verified that the facility was being operated in conformance with the licenses and regulatory requirements and that the licensee's management control system was effectively carrying out its responsibilities for safe operation.. During tours of accessible areas of the plant, the inspectors made note of general plant and equipment conditions, including control of activities in progress.
On a sampling basis the inspectors observed control room staffing and.
coordination of plant activities; observed operator adherence with-procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was available and observed the frequency of plant and control room visits by station managers. The inspectors also reviewed various administrative and operating records, a.
Areas of Inspection Radiation Protection Controls The inspectors verified that workers were following health physics procedures and randomly examined radiation protection instrumentation for operability and calibration.
By the end of the inspection period, the dual unit outage was approximately half way through, with the actual dose accumulated being slightly lower than projected for this stage of the outage. The source term in
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the Unit 1 containment is approximately 70 percent higher than seen in previous outages. The radiation protection department was actively monitoring the accumulated dose in order to maintain dose as low as reasonably achievable (ALARA); and believed that the 600 rem projected dose was still achievable.
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.i Security During the inspection period, the inspectors monitored the
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licensee's security program to ensure that observed actions were
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being implemented according to their approved security plan.
Housekeeping and Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matter.
Foreign material exclusion is discussed further in section 7a. Despite the large
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scope of the dual unit outage, good housekeeping was observed in removing construction debris, disposing of old' valve components, and maintaining general cleanliness.
Emergency Diesel Generator Relay Defect: During testing of the under-frequency relay for the
"0" EDG, the operational analysis
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department (OAD) found a small plastic part on the test cart.
The part could not be readily identified as belonging to the relay and the relay passed the testing.
On December 3, it was determined that the part belonged.to the "0" EDG relay. The remaining four under-frequency relays for the EDGs
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were inspected and cracking, to different degrees, was identified on each relay. While the
"0" EDG relay was able to pass the testing with the part broken off, continued normal operation could not be assured.
The four remaining relays had the potential for
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the part (or the spring it retained) to fall into the contact
mechanism and prevent the contacts from closing. The contacts
complete a permissive logic which allows the EDG output breaker to close automatically or manually from the control room.
Even if
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the contacts for this permissive logic could not close, the output
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breaker could still be closed manually at the breaker.
Due to both cores being off loaded into the spent fuel pit, the.
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ability to close the output breakers locally was sufficient to supply power for fuel pool cooling in the event all offsite power was lost.
The station revised the dual unit outage procedures to address this scenario. An-inspection of other non-safety relays, that use the same contact assembly, identified additional cracking problems.
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A lessons learned initial notification was issued and the information was placed on the nuclear network.
A 10 CFR Part 21
review was started. Repair parts for the contact were obtained
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and qualified. The licensee is in the process of making the necessary repairs.
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Assessment The prompt and sound diesel operability determination, and the prompt inspection of other non-safety relays for cracking were considered noteworthy. ALARA results have been good despite a higher Unit I source term.
No violations or deviations were identified.
5.
Monthly Maintenance and Surveillance (62703 and 61726)
Routinely, station maintenance and surveillance activities were observed
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and reviewed to verify that they were conducted in accordance with all
regulations. Also considered during the observation and review were:
that proper approvals were obtained; that operabil.ity requirements were met; that appropriate functional testing and calibrations were performed; that any discrepancies identified were resolved;.that quality control records were maintained; and that all activities were accomplished by qualified personnel.
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Maintenance / Surveillance Related Activities Outage Work Schedule Review: The residents reviewed the dual unit outage scheduled and deferred work. The review included deferred work re-added to the outage, work missed in initial work scope, and emerging work.
This review did not reveal any work on safety systems and systems
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important to safety that requires completion during this outage,
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but has been deferred.
Breaker Problems due to Grease Hardening: A follow-up of Zion's maintenance program for 4kV ITE breakers was done after LaSalle Station had breaker failures from grease hardening.
LaSalle had
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t borrowed spare operating mechanisms from Zion that had hardened grease. Machinery history indicated that the grease had not been
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changed in the spare breaker operating mechanisms sent to LaSalle.
The maintenance history showed that all installed breakers had the
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operating mechanisms overhauled with new grease added in response to a 10 CFR Part 21 notice.
There have been no grease related l
breaker failures since the overhauls.
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Mechanical Maintenance Valve Replacement: The-mechanical
maintenance department has been performing a significant number of valve replacements this outage.
The planned scope includes valves
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which range from small steam traps to the IC heater drain suction -
isolation valve, a 24 inch valve. The maintenance department l
performed the valve removal by either machining or torch cut,
rigging, end preparation of the pipe, fit-up of the valve,- and I
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welding. The experience gained during this outage will greatly
improve proficiency of mechanical maintenance in valve replacemen;
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and reduce the station's dependence on contractor assistance, j
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Assessment of Maintenance and Surveillance
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will reduce dependence on contractor assistance, is considered a
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positive effort by the licensee.
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No violations of deviations were identified.
6.
Engineering and Technical Support (37828)
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The inspectors evaluated the extent to which engineering principles and evaluations were integrated into daily plant act.vities. This was accomplished by assessing the technical staff involvement in non-routine events, outage-related activities, and assigned TS surveillances; observing on-going maintenance work and troubleshooting; and reviewing deviation investigations and root cause determinations.
a.
Engineering and Technical Activities Erosion Corrosion Program:
In implementing the erosion corrosion program, 60 components on Unit I consisting of approximately 150 segments of pipe were inspected.
Two of the segments inspected required further evaluation from corporate engineering. One pipe did not have an actual code minimum and the other was above the
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i code minimum but there was uncertainty as to how long it would '
take before the pipe reached the code minimum. Corporate
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engineering has evaluated the two items. A code minimum was calculated for the first item and the second item (a pipe tee)
will require replacement during the next Unit I refueling outage.
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An earlier problem, a small steam leak in 'a cross under pipe elbow (see IR 295/304-93011), was resolved by a stainlee steel weld clad repair to the inside of the pipe.
This is cte idered a permanent repair.
The external temporary repair patch was removed and any indications caused by the patch were repaired.
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Rod Control Enhanced Maintenance: The vendor completed the enhanced maintenance program for the Unit I rod control. This
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maintenance program was performed on Unit 2 in 1990, and improved rod control performance was attributed to this program. The maintenance includes removal of all circuit boards, cleaning of
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the cabinets and circuit cards, visual inspections, individual testing (and repair if necessary) of each circuit card,_ and
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finally system testing once the circuit cards were reinstalled.
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The inspection identified a 43 percent failure rate for the visual inspection of the circuit cards. The majority of these failures were cold solder joints and printed circuit conductor problems.
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These items had the potential of causing future problems and were repaired. The individual circuit card testing identified failures in six percent of the cards.
These cards were still capable of
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performing their function and would not have been identified by
normal licensee maintenance. The cards were repaired and tested-
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successfully.
t Cabinet inspection revealed several loose connections, low voltage supplies out of tolerance, and overvoltage protectors out of tolerance.
These items were minor in nature and were corrected.
The system was reassembled and passed the final testing.
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Motor Operated Valve Testing: The scope of the MOV testing for the dual unit outage included 100 static tests and 32 differential
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pressure tests.
Progress in completing the tests has been slowed due to smaller thrust windows (as the result of using higher stem friction factors), an additional requirement to use a torque
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cartridge (connected to the spring pack), and the loss of pretension on previously installed sensors.
Testing of the newly installed service water (SW) valves has gone well, as the valves were preset in the warehouse prier to:
g installation into the SW system. However, some of the valves,
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tested in previous outages, have presented significant challenges
in adjusting the torque switches to remain within the smaller i
thrust windows. The station applied additional resources to improve productivity and the operators were becoming more familiar with the new constraints on testing. At the end of this reporting period 50 static and 2 differential pressure tests had been
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completed. Only 23 package closures for both the static and the differential pressure tests had been completed. The original dual
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unit outage schedule did not identify M0V testing as being part of the critical path work; however, the testing has become a critical path for completion of the outage.
Containment Spray (CS) Pump Operability Review: During the final Zion Review Team (ZRT) visit, the team reviewed the licensee's efforts to resolve the recurrent starting problems with the i
diesel-driven 1C CS pump. The team concluded that the licensee's
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corrective actions were acceptable, but noted that the intensive
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overhaul scheduled for the outage might resolve the problems without identifying the cause.
The licensee committed to resolve
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the pump starting problems before startup from the refueling
outage.
t The ZRT questioned the licensee's failure to perform an onsite review of the July 28 slow start, especially since the analysis of record assumed that the pumps would reach full speed within_a few
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seconds of receiving the pump start sequence.. For the July 28
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test, the pump ran for approximately 14 seconds, shut itself down, cranked for 30 seconds, was secured and then restarted by the
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nuclear station operator, cranked for another 14 seconds and then
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i started. The ZRT also noted that the procedure being used to monitor the degraded pump starts (PT-6C-ST " Containment Spray C Pump Systm Tests and Checks") 'did not contain any requirement to
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monitor pump start times, nor any acceptance criteria relating to pump start times. This led to only one of the pumps starts actually being timed.
On November 24, the licensee completed an onsite review of the delayed start occurring July 28. As part of the onsite review, the licensee identified that the IB EDG sequence timer was part of the IC CS pump's start logic.
Previously, the licensee had
believed that the pump started directly on receipt of a r
containment spray hi-hi signal. The licensee also determined that the 122 second starting time, contained in the analysis of record, was not entirely available for pump cranking time, although the earlier onsite reviews made that assumption.
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incorporated this information into the onsite review, and a
concluded that the pump was operable because full flow out of the spray header would have occurred within 120 seconds, which was
within the 122 seconds contained in the analysis of record.
I The inspectors reviewed the calculation done to support the operability review, and noted that the licensee used the 44 second CS pump start time, the IB EDG start and sequencing times.from a l
July 1992 survetilance, and a header fill time which credited
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valve opening characteristics.
Finally, some of the header backpressure conservatism was removed in order to ensure that the
122 second time limit was not exceeded.
The inspectors discussed the above assumptions with the licensee, and accepted the licensee's operability argument. However, the licensee
acknowledged that these assumptions would not have been apparent
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to the system engineer in July when the operability call was made.
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demonstrated that there is continued need to ensure that design basis information is recaptured, documented,.and disseminated,
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especially to the system engineers who have responsibility for
maintaining that design basis.
Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XI " Test Control" requires, in part, that
tests be performed in accordance with test procedures which incorporate the requirements and acceptance limits contained in.
i applicable design documents.
It further requires that test results be evaluated to ensure that test requirements are
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satisfied. Contrary to the above, the procedure chosen to monitor
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the degradation in pump starting times did not contain any-i requirement to monitor pump start times, nor any acceptance i
criteria, such as those contained in the analysis of record, for
evaluating the effect of pump starting time delays on pump
operability. Additionally, for the July 28 test, the test results
were not evaluated to ensure that pump start time requirements,-
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such as contained in the analysis of record, were satisfied before
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'f declaring the pump operable. This is considered a violation I
(295/92023-01).
10 CFR 50.59 Review:
Four 10 CFR 50.59 safety evaluations were reviewed for correctness and agreement to the regulation. All of
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the safety evaluations were determined to be correct and in agreement with regulations.
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The safety evaluations for modifications M22-0-91-026A (Component
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Cooling Water) and E22-1(2)-93-026A (Turbine Driven Auxiliary feedwater Pumps) were. thorough in detail. The evaluations provided adequate justification of the conclusions.
t However, the safety evaluations and addendum for modification...
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M22-1(2)-91-025 and its supplement (Emergency Diesel Generator 0 Breaker Logic) were not thorough in detail.
The details provided to verify that an unreviewed safety question
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did not exist were not in all cases thorough. This required
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reviews of additional evaluations, documents, and prints to
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determine the adequacy of the safety evaluation.
The. safety evaluations required verification that the consequences of a
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malfunction of equipment impcriant to safety may not increase.
The evaluations usually contained discussions of the likelihood of a malfunction occurring, instead of the consequences.
In most cases, this masked the legitimate verification contained within
the evaluations.
- These examples demonstrated a need for improvement in the documentation of safety evaluations. Although adequate information could be reviewed to demonstrate agreement with
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10 CFR 50.59, in some cases, the process required extensive searches through numerous documents and evaluations to satisfy.
compliance.
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Assessment of Engineering and Technical Support Management was not proactive in the application of resources to determine the root cause and correct the IC containment spray pumps slow starting problem.
However, good engineering support by
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the system and site engineering groups have helped the station
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maintain an aggressive schedule with major modifications being
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made.
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One violation and no deviations were identified.
7.
Safety Assessment and Quality Verification (40500)
The effectiveness of management controls, verification and <
rsight activities in the conduct of jobs observed during this inspemion were
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evaluated. Management and supervisory meetings involving plant. status
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were attended to observe the coordination between departments.
The
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results of licensee's corrective action programs were routinely
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monitored by attendance at meetings, discussion with the plant staff, review of deviation reports, and root cause evaluation reports.
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a.
SAQV Related Events Part 21 Notification: A 10 CFR Part 21 notification was issued concerning a manufacturing defect in the auxiliary' feedwater (AFW)
pump oil coolers used at Zion. The defect appeared to be due to
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excessive deformation of the tube roll joint at the tube sheet.
The defect was identified when oil and water were observed coming out of the 2B AFW lube oil cooler reservoir. The failure was attributed to inadequate process control by the manufacturer and inadequate inspection requirements at the station.
A corporate review of all six nuclear stations identified that the coolers were only used at Zion.
The coolers in stores have been inspected and the coolers in service will be inspected prior to
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the completion of the dual-unit outage.
Foreign Material Exclusion (FME) Program:
Foreign material was found in and retrieved from the reactor vessel, reacter cavity,.
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and in the service watcr side of the component heat exchangers.
The use of a submarine to inspect the reactor vessel improved the licensee's ability to find and retrieve material. The licensee has not determined if the material recovered from the reactor vessels was due to previous outages or the present outage.
Foreign material was consistently being found around the reactor
cavities and spent fuel pit. The cause for the materials in and around the reactor cavity and spent fuel pit was an inadequate FME program for work control and zone control.
i Contributors to the FME program deficiencies were a lack of ownership of the program by the workers, weak training, a confusing FME procedure, and inadequate conveyance of senior
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management expectations by supervisors to the workers.
A Level II investigation, which requires upper management involvement, on the FME program was being conducted and a Zion Management. Action Plan (ZMAP) was assigned for the program.'
Corrective actions to strengthen the FME program included procedure revisions, training, coaching, RWP revisions to include
. FME zone requirements, and more in-the-field. time by supervisors-
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and managers. Senior management also addressed groups receiving FME training to communicate their expectations. The inspectors will continue to follow the evaluation concerning the material
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removed from the reactor vessels and consider the results of the l
evaluation an inspection followup item (295/304-93023-02(DRP)).
l The evaluation will be completed during the next inspection period.
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r Quality Verification Self-Assessment:
The site quality verification (SQV) director met with the resident staff to discuss recent changes in the SQV organization.
The changes were prompted by completion of a study by a management consultant which identified several issues facing SQV at the six nuclear stations.
as well as the corporate office. The station reviewed the study and performed a self-assessment of the weaknesses and strengths within the Zion SQV organization.
As a result of the self-assessment, the SQV director identified five areas needing improvement to be addressed during 1994:
increase the SQV staff by seven additional people along with career path development; improvement of trending capabilities; reinforcement of-the Quality Vision, including better definition of SQV roles; improvement of data collection and analysis capabilities; and improvement of communication between SQV and the corporate office and between SQV and onsite departments. The inspectors regarded the SQV self-assessment as having identified the key weaknesses in the organization. The residents will monitor the licensee's progress in remedying these weaknesses.
b.
Assessment of 3AQV Management attention needed to prevent foreign materials from getting into the reactor vessel and other systems was inadequate.
However, aggressive corrective actions were being taken by management to correct the foreign material intrusion problems. On the positive side, good outage management enabled the outage to stay on schedule with only minor problems that were quickly resolved.
The quality verification groups increase in staff size will enable-them to provide broader coverage for the station.
No violations or deviations were identified.
One inspection followup item was identified.
8.
Licensee Event Reports (LERs) Followup (92700)
Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications. The LERs discussed below are considered closed.
LER 295/93009:
Failure to Perform Off-Site Review of a 10 CFR 50.59 Safety Evaluation While responding to a Notice of Violation concerning the auxiliary building missile doors, the licensee identified that the safety evaluation performed on the doors had not been reviewed by the offsite
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review organization, as required by Technical Specification 6.1.7.A.I.a.
The licensee promptly sent the safety evaluation to the offsite review group.
To prevent recurrence, the licensee revised Zion administrative procedure ZAP 100-06, " Safety Review and Approval", and the safety evaluatics 100 to provide better tracking of the transmission of safety evaluations to the offsite group. The inspectors reviewed these actions and found them to be acceptable.
The failure to perform an offsite review of the safety evaluation is a violation of technical specification requirements. However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.2 of the " General Statement of Policy and Procedures for the NRC Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C), were satisfied.
LER 295/93010:
"Autostart of the 1A Residual Heat Removal Pump" This LER documented the automatic start of the 1A residual heat removal (RHR) pump. This event was discussed in Inspection Report 92023.
The licansce committed to issuinha supplemental LER by mid-summer 1994 in order to document the root cause and corrective actions.
The inspectors will review the supplemental report when it is issued.
LER 304/93001:
" Failure to Meet 'As Found' Requirement for Total Type B and C Leak Rate" This LER documented local leak rate test (LLRT) failures of check. valve RC8047 on both units. The root cause and final corrective actions were still under investigation at the end of the inspection period.
The licensee committed to issue a supplemental report shortly after the end of the dual unit outage, and the root cause and adequacy of the corrective actions will be reviewed at that time.
LER 304/93002:
" Missed Surveillance on the Containment Vent and Purge Radiation Monitors Prior to Core Alterations Which Violated Technical Specification 3.14.3.C" This LER documented a failure to perform a surveillance on the containment vent and purge system. The failure occurred for two reasons:
(1) Appendix E-2 to periodic test PT-0 had not been updated to reflect that periodic test procedure PT-17 had been subdivided into three new procedures, PT-17A, PT-17B, and PT-17C; and (2) The PT chosen by the unit operator was not the correct one for the plant conditions.
The licensee's corrective actions to this event were to update PT-0, Appendix E-2, and to verify that all other pts referenced in Appendix E-2 were correct. The event was also discussed with the individuals involved. The inspectors reviewed the licensee's corrective actions and found them to be acceptable. The failure to perform a required surveillance is a violation of NRC requirements. However, the licensee
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identified this violation and it' is n)t being cited because the criteria i
specified in Section VII.B.2 of the " General Statement of Policy and.
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Procedures for the NRC Enforcement Actions," (Enforcement Policy, 10 CFR l
Part 2, Appendix C), were satisfied.
In addition, the inspectors reviewed problem identification forms (PIFs), and resultant investigations, to ensure that they were generated
appropriately and dispositioned in a manner consistent with the i
applicable procedures and the quality assurance manual.
The following
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completed PIFs were reviewed:
295-180-93-012 Failure of Type C Test on Unit 1 Valve RC8047 295-200-93-CAT 3-165 Failure to Perform Off-Site Review of a 50.59
Safety Evaluation
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295-201-93-CAT 4-1192 Fuel Handlers Working in the U-l Cavity w/o Proper Coverage 304-180-93-002 Type C Leak Rate Test Failure of 2RC8047 304-180-93-003 Possible Missed Surveillance l
Two non-cited violations were identified.
,j 9.
Inspection Followup Items Inspection followup items are matters which have been discussed with the licensee which will be reviewed further by the inspector and which
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involve some action on the part of the NRC or licensee or both. One inspection followup item disclosed during this inspection is discussed-in section 7a.
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10.
Management Changes
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On December 13, 1993, Mr. David Wozniak was named as the new Operations Manager.'
In addition, Mr. Wozniak will continue to act as Technical Services Superintendent until a replacement can be selected.
11.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in section 1)
throughout the inspection period and at the conclusion of the inspection on January 6, 1994, to summarize the scope.and findings of the inspection activities. The licensee acknowledged the inspectors'
comments. The inspectors also discussed the likely informational
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content of the inspection report with regard to documents or processes i
reviewed by the inspectors during the inspection.
The licensee did not
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identify any such documents or processes as proprietary.
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