IR 05000295/1996017
| ML20134H103 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/03/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20134H066 | List: |
| References | |
| 50-295-96-17, 50-304-96-17, NUDOCS 9702110148 | |
| Download: ML20134H103 (31) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III i i
l Docket Nos: 50-295, 50-304 i License Nos: DPR-39, DPR-48 Report No: 50-295/96-17, 50-304/96-17 Licensee: Commonwealth Edison Company Facility: Zion Nuclear Plant, Units 1 and 2 Location: Opus West III 1400 Opus West III Downers Grove IL 60515 -
Dates: October 12 through December 6, 1996 Inspectors: R. A. Westberg, Acting Senior Resident Inspector D. R. Calhoun, Resident Inspector E. W. Cobey, Resident Inspector M. E. Parker, Senior Resident Inspector, Palisades A. Vegel, Senior Resident Inspector, Fermi J. Yesinowski, Illinois Department of Nuclear Safety Inspector Approved by: Marc L. Dapas, Chief Reactor Projects Branch 2 9702110148 970203 5 DR ADOCK 0500
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EXECUTIVE SUMMARY Zion Nuclear Plant, Units 1 and 2 c NRC Inspection Reports 50-295/96 17; 50-304/96 17 This inspection included aspects of licensee operations, maintenance, and engineering. The report covers an eight-week period of inspection activities by the resident staf Licensee performance during this inspection period was characterized by recurrent events caused by personnel errors, lack of a questioning attitud the failure to follow procedures, and inadequate procedures. Of particular concern was the identification by NRC inspectors of several instances where the licensee's evaluation of degraded plant conditions was untimel :
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Operations
. Inappropriate operator response to a material condition problem with the valve position indication for a residual heat removal system valve resulted in a 400 gallon water spill and a violation for failing to
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l follow equipment control procedure (Section 01.1) '
. The inspectors identified several material condition deficiencies on safety-related components that were indicative of poor attention to detail during post-maintenance restoration and system engineering walkdown (Section 02.1)
. Operators unknowingly caused the common unit emergency diesel generator (EDG) to be inoperable for approximately two days. Operator training deficiencies and the initial failure of operators to question if an
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i operating procedure was correct when the procedure was in conflict with requirements in the Zion Operability Determination Manual contributed to the error. As a result. Technical Specification action requirements for an inoperable EDG were not followed, resulting in a violatio (Section 04.1)
. The inspectors identified a violation involving the failure to implement corrective actions for insufficient monitoring of the 011 125 Volt- battery exhaust ventilation system. The licensee's practice of not tracking level 4 problem identification form actions to completion contributed to this error. (Section 07.1)
Maintenance
. The inspectors identified a violation regarding the licensee's failure to address operability of a safety-related battery when surveillance test acceptance criteria were exceeded on several occasions. The inspectors identified another violation involving the incorrect determination of average cell voltage during a battery surveillanc (Section M1.1)
. The inspectors identified two examples of inconsistencies between the condition of structures, systems, or components described in completed
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work documentation and the actual plant configuratio (Section M1.2) !
. . The inspectors identified a violation involving a compressed gas cylinder that was improperly secured to a seismically qualified .
scaffold. (Section M1.3) I
. Five protective trips of the 2A emergency diesel generator occurred j during post-maintenance testing due to poor work practices and i inadequate maintenance procedures. Two examples of a violation for l inadequate procedures were identified for the associated maintenance activitie (Section M3.1) !
. A violation was identified involving an inadequate maintenance 3rocedure l which resulted in damage to the 1A auxiliary feedwater pump tur)ine '
inboard bearing during post-maintenance testing. (Section M3.2) i Engineering
. The inspectors identified three examples of a violation involving the failure to address operability of degraded safety-related piping ;
supports in a timely manner. (Section El.1) l
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Report Details
- Summary of Plant Status i
Unit 1 operated at or near 100 percent power during the inspection perio '
Unit 2 remained shut down during the inspection period in support of the 14th refueling outag Licensee performance continued to be characterized by recurrent events caused by personnel errors, lack of a questioning attitude, the failure to follow procedures, and inadequate procedure Of particular concern was the identification by NRC inspectors of several instances where the licensee's evaluation of degraded plant conditions was untimely. Although the licensee identified the violation pertaining to the inoperable emergency diesel generator, some examples of the failure to follow procedures, and examples of inadequate procedures, these licensee identified issues are included in the cited violations because they stem from previously identified performance problems which the licensee has not yet effectively addresse I. Ooerations 01 Conduct of Operations 01.1 Doeration of Out-of-Service (00S) Component Resulted in a Soill of 1 Anoroximately 400 Gallons of Water Insoection Scope (71707)
On November 3 during the fill and vent of the 2B train of the residual heat removal (RHR) system, the licensee spilled approximately 400 gallons of water in the Unit 2 letdown heat exchanger room. The inspectors interviewed operations department personnel, reviewed '
applicable procedures, and reviewed the results of the licensee's !
investigatio Observations and Findinas On November 3. during the performance of System 0)erating Instruction (S0I) 5F " Filling and Venting RHR Train B with tle Unit Defueled Using the RWST [ refueling water storage tank]." Revision 4. the licensee identified water flowing from the partially disassembled Unit 2 letdown heat exchanger to the Auxiliary Building sump. Radiological consequences were minimal since contamination levels were not significantly above the levels in the room before the spill. Based on the results of the licensee's investigation of this event, the licensee l concluded that the spill resulted from operation of an 00S valv !
On November 1, an operator closed RHR system heat exchanger "A" discharge to letdown heat exchanger valve 2RH-8734A and placed an 00S tag on the valve to indicate that it was part of the isolation boundary
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for maintenance on the Unit 2 letdown heat exchanger. The operator identified that the valve position indicator (VPI) on the reach rod
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c)erator incorrectly indicated that valve 2RH-8734A was in mid-positio T1e shift engineer directed the operator to first verify the valve's
)osition locally at the valve and then to hang the 00S tag on the valve
)od However, no action was taken by the licensee to disable the reach rod operator or to identify that the valve needed to be operated locally due to the material condition deficiency with the VP On November 2 during the 3erformance of S01-5E. " Filling and Venting RHR Train A with the Unit )efueled Using the RWST," the operator conducting the evolution did not recognize that valve 2RH-8734A was an 00S component, due to the location of the DOS tag. Consequently, when the operator opened valve 2RH-8734A with the reach rod operator, a flow path was created which resulted in the s)ill. In addition, when valve 2RH-873A was repositioned open, the reac1 rod VPI broke. The operator did not identify the broken VPI as a condition which required verification of valve position locally and no action was taken to correct the deficient conditio Conclusions Inappropriate operator response to the identification of a material condition problem resulted in a spill when another operator re)ositioned a valve that had been tagged 00S. When an operator tasked wit 1 performing an OOS, identified that the indicated valve position on the reach rod VPI was incorrect, no action was taken by the licensee to disable the reach rod operator or to identify that the valve needed to be operated locally due to this material condition deficienc Similarly, after the reach rod VPI pin broke during valve operation, the operator manipulating the valve did not verify the valve position locally or initiate action to resolve the deficienc Zion Administrative Procedure (ZAP) 300-06. "Out-of-Service Process,"
Revision 9, Section E.6 requires, in part. that once an 00S is in place, physical operation of an 00S component is prohibited. The operation of valve 2RH-8734A. which was an 00S component, is considered a violation of TS 6.2.1.a. as described in the attached Notice of Violation (50-304/96017-01).
01.2 Licensed Steadv State Thermal Power Insoection Scope (71707)
On October 23 the inspectors identified that average nuclear power instrumentation was indicating greater than 100% power. The inspectors interviewed operations personnel and reviewed applicable documentatio . - . - . - . - - - - . - - . - - - . - - - . - _ . _ . ~ . - -
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. Observations and Findinos !
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During a routine review of control room activities, the inspectors !
identified that average nuclear power instrumentation was indicating !
greater than 100% power, specifically 100.2%. Further review of the 1
" Power History Log, PT-0 Revision 12 Appendix P, indicated that ;
actual power as determined by an hourly secondary calorimetric, was -less i than 100% power, specifically 99.8%. However, the inspectors noted that I-the hourly calorimetric readings recorded in the log for 4:00 a.m. and 5:00 a.m. indicated that reactor power was at 100.1%.
l The inspectors determined that reactor power did not exceed the j licensee's administrative limits specified in procedure PT-0, which :
! stated- When o)erating at full power, reactor power should be maintained such tlat the 60 minute calorimetric indicates an average power level of less than or equal to 100.0% power.
l E any 60 minute calorimetric is greater than 100.0% power, THEN l l
a)propriate action and/or monitoring should be performed to ensure '
l tie next 60 minute calorimetric is LESS THAN or EQUAL to 100.0% :
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t E the 60 minute calorimetric is greater than 100.0% power for two I consecutive readings in a row, THEN immediately reduce power to i less than or equal to 100.0% power to restore the next 60 minute l
. calorimetric to less than or equal to 100.0% power. (NRC letter t l from E. L. Jordan dated 8/22/80, Tech Spec Interpretation 94-03). i
! E either a 10 minute or 60 minute calorimetric indicates greater than 100.5% power, THEN immediately take action to reduce reactor ,
power until a 10 minute calorimetric indicates less than or equal
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l to 100.0% powe i l The licensee maintained that the reactor could be operated above 100% !
power, up to 100.5%, with a 1.5% uncertainty, and still be within the l appropriate design basis (102%). A review of the uncertainty analyses
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confirmed that the instrument uncertainties were within 2 percent (actual 1.47%). The ins)ector's initial review to determine if the licensee had operated the Jnit I reactor above 100% power using this operating 3ractice identified several other instances, in which, reactor r power had )een above 100% for periods of time u) to three hours before action was taken to reduce reactor power to witlin licensed thermal power limit The inspectors reviewed Ap)endix P of PT-0 in evaluating tile licensee's position on this issue wit 1 respect to information in design basis documents, including Appendix K to 10 CFR Part 50 and the Updated Final i' Safety Analysis Report (UFSAR). Aopendix K "ECCS [ emergency core cooling system] Evaluation Models " assumes that the reactor has been
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licensed power level to allow for such uncertainties as instrumentation l error. Also Section 14.1.3 of the UFSAR, " Analysis Performed at
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3250 MWt." states that the initial conditioris for transient analysis are based on steady-state operations at 3250 MWt with a reactor power uncertainty of 2 percent applied to ensure conservative analysis. The licensee's operating procedure (PT-0. Appendix P) allowed reactor power l to reach 100.5%. before requiring immediate action to reduce reactor l powe This issue is considered an Unresolved Item (50-295/96017-02) pending ,
further NRC review of the licensee's practice against other pertinent '
licensing documents such as the Zion Facility Operating Licens c. Conclusions j After the inspectors discussed this issue with the licensee, additional operating instructions were provided to licensed operators. These instructions required operators to maintain reactor power at or below 3250 MWt (licensed thermal limits) at all times, and to take immediate l action to reduce reactor power if any 60 minute calorimetric indicated greater than 100% powe The licensee's response to this issue was timely. The licensee had taken prompt action, upon identification by the inspectors, to ]rohibit further operation above licensed thermal power limits. Althoug1 the licensee's corrective action was timely, the inspectors expressed concern with non-conservative past operating practice Operational Status of Facilities and Equipment 02.1 Enaineered Safety Feature System Walkdowns a. Insoection Scone (71707)
The inspectors conducted walkdowns of accessible portions of the following safety systems:
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Emergency Diesel Generators (EDGs) 1A, 1B. O, 2A, 2B
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Unit 1 Containment Spray System
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Shared Unit 1 and 2 Service Water System b. Observations and Findinos During the system walkdowns, the inspectors identified numerous discrepancies. Specifically:
. On October 14, the inspectors identified that the 1A EDG supply i fan was missing one of six support rod vibration isolators. The l licensee corrected the problem on the same day and performed an o)erability assessment. The licensee subsequently determined that l t1e fan was operable even though the support was missin l
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. On October 15. the inspectors identified that the 2A service water pump motor was leaking water at a rate of approximately
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20-30 drops per minute. After engineering condition and declared the pump inoperabl personnel the pump evaluated the was taken out-of-service. The licensee determined that the leak was from the oil cooler supply line. The line was repaired and the pump was returned to servic . On November 20, the inspectors identified numerous valve packing leaks on the Unit 1 containment spray system. The inspectors informed engineering personnel of the discrepancies and the licensee initiated appropriate corrective action c. Conclusions In addition to the above observations, the inspectors identified numerous other discrepancies, including oil leaks and missing fasteners on the EDGs. Additional material condition discrepancies and the licensee's response to them are discussed in sections M1.2 and El.1 of this report. The failure of the licensee's staff to identify these material condition problems was indicative of poor attention to detail during post-maintenance restoration and system engineering walkdown Operator Knowledge and Performance 04.1 Missed Technical Specification (TS) Action Reauirements for an InoDerable EDG a. Inspection Scope (71707)
On October 28. the licensee identified that the 0 EDG had been inoperable for approximately two days and that required TS actions had not been performed. The inspectors interviewed operations and engineering department personnel and reviewed operations department training, applicable procedures, and the results of the licensee's root cause investigation, b. Observations and Findinas On October 28. during shift turnover, the Unit 2 nuclear station operator noticed that the Unit 2 control switch for the 0 EDG was in the pull-to-lock (PTL) position. After further review of the diesel starting logic and control circuit design by system engineering personnel, the licensee determined that the 0 EDG is rendered inoperable whenever the Unit 1 or Unit 2 control switch for the 0 EDG is in the PTL position. With the 0 EDG inoperable. TS 3.15.2.C requires that the two remaining Unit 1 EDGs be demonstrated operable and that the availability of two sources of off-site power be demonstrated. However, since the l licensee did not recognize that the 0 EDG was inoperable, the TS requirements were not me The licensee determined that the Unit 2 control switch for the 0 EDG was
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, placed in the PTL Josition on October 26, during performance of S01-63G, 4 "Deenergizing 4KV ESF [ Engineered Safety Feature] Buses," Revision 1.
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This S0I was conducted to de-energize bus 247 to support a scheduled bus i outage. The licensee determined during a follow-u) investigation that !
the S0I requirement to place the EDG control switc1 in the PTL position j was not necessary to support the bus outage.
j The licensee determined that with the Unit 2 (Unit 1) control switch in i
the PTL position, the 0 EDG could not be manually started with the Unit ;
1 (Unit 2) control switch. However, the 0 EDG would start in response i
condition signal, and would run until the SI signal is manually reset or l
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the UV condition cleared. Once the emergency start signal had cleared, i
the 0 EDG would initiate a 15 minute cooldown cycle and then shut down since the seal-in circuit would be bypassed with the control switch in
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scenario. The most risk significant scenario involves a UV condition.
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The 0 EDG would start on undervoltage and power the loads secuenced onto the associated unit safeguards bus. Once the EDG was alignec to the bus, the UV signal would clear and the diesel would initiate a 15 minute
- cooldown cycle. At the end of the cooldown cycle, the diesel would i coast down under load until the bus voltage reached the undervoltage 4 setpoint, at which time the 0 EDG would receive another emergency start i i
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signal on undervoltage. The load sequencer would strip the bus loads l and then sequence loads onto the bus. The 0 EDG would then enter
- another cooldown cycle. The degraded voltage condition on the i safeguards bus resulting from coastdown of the EDG at the end of the ,
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cooldown cycle, could adversely affect the operation of equipment 1 powered by the bus.
- The inspectors determined through several interviews that control room
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operators did not understand how the position of the 0 EDG unit specific i' control switches affected the ability of the 0 EDG to perform its l l intended safety function. Most operators knew that the EDG would start {
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! all of the operators interviewed understood the general operability requirements contained in the Zion Operability Determination Manual (ZODM), including the specific recuirement that equipment listed in the Technical Specifications be consicered inoperable when the respective control switch was in the PTL position. However, during performance of S01-63G on October 26 the operators placed the 0 EDG control switch in PTL without recognizing or questioning the impact of their actions on the operating uni The inspectors reviewed licensed operator training records pertaining to coeration of the 0 EDG control circuit. Initial licensed operator t' raining included operation of the control circuit per lesson plan LO-PSC-31. This lesson plan covered both the normal and emergency start sequences. However, operation of the unit specific control switches was not specifically addressed, with the exception of one
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l instructor's note which indicated that the emergency start of the 0 EDG ;
was not affected by the control switch being in PTL. This not l
. however, did not discuss the ability of the EDG to perform its intended ~
safety function with either unit control switch in PT In addition, the inspectors reviewed the training conducted for )
modification M22-0-88-09 which installed controls for the 0 EDG on the i Unit 2 control board in September 1989. The training consisted of a i brief description of the scope of the modification, however, it did not l include any discussion of the impact of the modification on EDG control i circuit operation. This training was promulgated to the licensed I operators in the form of a required reading packag Conclusions i i
Operators unknowingly rendered the 0 EDG inoperable for approximately two days. Operator training deficiencies and the failure of operators 1 to question if an operating procedure was correct when the 3rocedure was i in conflict with requirements in the ZODM, contributed to t1e erro '
Technical Specification 3.15.2.C permits reactor operation with the ,
0 EDG inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, provided that the two remaining EDGs for i the associated unit are demonstrated to be operable and that two sources i of off-site lower are demonstrated to be available. The failure to :
demonstrate )oth the operability of the two remaining Unit 1 EDGs and the availability of two sources of off-site power is considered a i violation of TS 3.15.2.C (50-295/96017-03: 50-304/96017-03), as described in the attached Notice of Violatio Quality Assurance in Operations 07.1 Failure to Imolement Corrective Actions for Inocerable Batterv Exhaust Ventilation System a. Insoection Scooe (40500) .
On October 15, the inspectors reviewed the licensee's~ corrective actions i for high ambient temperature in the 011 125 Volt-D.C. battery roo l This issue was previously documented in NRC Inspection Report :
50-295/96014: 50-304/96014. The inspectors interviewed operations and j regulatory assurance department personnel and reviewed applicable '
documentation, including Problem Identification Form (PIF) 240 b. Observations and Findinas While conducting followup inspection activities for high ambient temperature in the 011 125 Volt-D.C. battery room (refer to Section E8.2), the inspectors identified that PIF-2402 had been closed l without completion of the specified corrective actions and with no other tracking mechanism in place to ensure their completion. Problem Identification Form 2402 recommended that the Unit 2 Equipment Operator Checklist, Appendix S of PT-0, be changed to require verification of air
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1 flow in the battery room. Past practice had been to verify that the i exhaust fan was energized, however, this did not ensure that the battery '
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exhaust ventilation system was operable. In response to the inspectors' I concerns, the licensee re-opened the PIF and implemented the recommended corrective actions, j Conclusions
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i Based on interviews with regulatory assurance personnel, the inspectors l concluded that corrective actions for deficiencies identified in PIFs
l and categorized as significance level 4 were not required to be formally
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! tracked through completion, and as a result, the actions were not always completed. The failure to implement corrective actions for an
identified condition adverse to quality, specifically, insufficient monitoring of the battery exhaust ventilation system, is considered a
violation of 10 CFR Part 50, Appendix B, Criterion XVI (50-295/96017-04:
- 50-304/96017-04), as described in the attached Notice of Violatio .2 Lack of Overtime Control l Insoection Scoce (40500)
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! On November 14, the Site Quality Verification (SOV) Audit Group
! identified a significant recurring deficiency with the control of
- overtime. The inspectors interviewed station management SOV and staff
. personnel, reviewed applicable procedures, and evaluated available data on overtime deviations.
j Observations and Findinas a
. During the period of November 21 through December 16, 1994, SOV i personnel performed an audit in the area'of operations and radwaste i packaging and transport. The audit team identified that 305 overtime l
? deviations occurred between January 1 and November 30, 1994. As a '
i result, the licensee initiated a Level III corrective action record j (CAR) for overtime control (CAR 22-94-067). !
! During a followup review of CAR 22-94-067 S0V identified that overtime control continued to be a problem, as evidenced by 225 overtime i deviations for 38 personnel during the period from July 17 to October 25, 1996, of which only five deviations had been approved. In
- response to this finding, S0V initiated a Level II CAP. for overtime
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control (CAR 22-96-053) and the licensee subsequently implemented some a near term corrective actions. During a followup review to evaluate the effectiveness of these actions, the licensee identified that
- unauthorized overtime deviations were continuing, i The inspectors noted that the issue with control of overtime has been
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addressed by the NRC on several occasions, both on a generic basis and i specifically with the licensee. Generic Letter (GL) 82-12, Ruclear
- Power Plant Staff Working Hours," and GL 83-14. " Definition of Key i Maintenance Personnel (Clarification of Generic Letter 82-12)," provided i 11 L
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j licensees with guidance on the control of overtime. In addition NRC
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Inspection Report 50-295/88017: 50-305/88017 identified that sufficient '
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measures were not in place to ensure that safety-related work was not jeopardized by personnel working too many hours. In the licensee's response to this inspection report, dated October 4, 1989, the licensee committed to establish a corporate policy governing safety-related work 3 at Commonwealth Edison nuclear stations by April 30, 1990, in accordance with the guidelines contained in GLs 82-12 and 83-1 Additionally, the Diagnostic Evaluation Team (DET) inspection conducted during June 1990 identified that overtime was not being managed or controlled. In the licensee's response to the DET report dated November 2, 1990, the licensee committed to control overtime through additional staffing, improved work planning, and strict adherence to overtime guideline Conclusions At the conclusion of this inspection period the licensee was in the process of conducting a root cause evaluation for the identified I overtime deviations. This issue is considered an Unresolved Item (50-295/96017-05: 50-304/96017-05) pending further NRC review of i licensee actions implemented in response to NRC concerns with the '
control of overtime to determine if licensee commitments in this area were me Os Miscellaneous Operations Issues 0 (Closed) LER 50-295/96026: Exhaust air flow from the fuel handling 4 building bypassed the auxiliary building charcoal exhaust filters. This issue is discussed in Section E2.1 of this repor l 08.2 (Closed) LER 50-295/96024: Missed TS surveillances for ino)erable i common diesel generator caused by management deficiency. T1is issue is
' discussed in Section 04.1 of this repor .3 (00en) LER 50-304/96010: Inadvertent engineered safety features (ESF)
actuation. On November 20 a Unit 2 ESF actuation and containment isolation inadvertently occurred during testing. The inspectors interviewed operations and engineering personnel and reviewed applicable test procedure While performing Technical Staff Surveillance Procedure 079-96,
" Response Time Test of Reactor Protection and Engineered Safeguards Features Logic," Revision 7G a system engineer inadvertently shorted l test leads. The leads were connected across a relay's contact which resulted in a containment isolation actuation. Reactor coolant drain tank isolation valve 2A0V-DT1003 and containment radiation monitor isolation valve 2FCV-PR24A close In addition, five valves associated i with the isolation valve seal water system opened. The licensee 1 immediately suspended testing activities and verified that all of the i required components had properly operated during the ESF actuatio !
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The inspectors concluded that the licensee's immediate corrective actions to stop testing and investigate the causes for the event were
. appropriate. However, the inspectors noted that the licensee was slow to verify that all components operated properly as a result of the ESF actuation. The licensee did not have a full understanding that all components operated as required until November 22. At the end of the inspection period, the licensee was in the process of developing corrective actions to prevent recurrence. This item will remain open pending NRC review of the licensee's long-term corrective action II. Maintenance M1 Conduct of Haintenance M1.1 Failure to Address 00erability for Surveillance Tests with Parameters Outside Accentance Criteria a. Inspection Scone (61726)
The inspectors reviewed the results of the November 1996 monthly surveillance test and all four 1996 quarterly surveillance tests for the 011 125 Volt-D.C. station battery. The inspectors also interviewed several licensed operators, system engineers, and electrical maintenance personne b. Observations and Findings The inspectors identified that the licensee failed to recognize operability concerns and take appropriate actions for abnormal specific gravity readings obtained during surveillance tests for the 011 125 Volt-D.C. station battery. The tests were conducted in accordance with Electrical Maintenance Surveillance Procedure (EMSP) 01. " Station Battery Monthly and Quarterly Surveillance," Revision 1, which implements the requirements of TS 4.15.1.E.2. This surveillance procedure s)ecifies an acceptance criteria for corrected s)ecific gravity of )etween 1.205 and 1.225. The Zion Operability Jetermination Manual (ZODM) requires that equipment which does not meet acceptance criteria specified in procedures be considered inoperable. The inspectors identified the following instances where the licensee did not evaluate the operability of either the battery or individual battery cells when specific gravity was not within test acceptance criteria.
l . On April 1.1996, the quarterly surveillance test results indicated that the corrected specific gravity of one cell was less than 1.205. As a result, the licensee initiated an equalizing charge on April .
. On October 7, the quarterly surveillance test results indicated that the corrected specific gravity for four cells was less than
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1.205. As a result, the licensee initiated an equalizing charge on October 10. On October 26. the licensee completed a partial surveillance test on the four cells. The s)ecific gravity for three of these cells was still outside of t1e acceptance rang . On November 4, the monthly surveillance test results indiccted that the corrected specific gravity for the pilot cell was 109 with a value of 1.199. The licensee did not initiate an equalizing charg Licensee evaluation of the surveillance test results and battery conditions consisted of an informal review by a system engineer who recommended the actions described above. Based on interviews with the involved system engineer and the electrical group lead, the inspectors determined that the system engineer did not consider acceptance criteria specified in the surveillance test to be criteria for operabilit '
On November 11, after several discussions with various personnel in the operations and engineering departments about whether an operability assessment was required for low specific gravity, the inspectors raised l the issue to the attention of the plant manager. Subsequently, on l November 15, the licensee completed an operability assessment -
(No. ER9606326) and determined that the 011 125 Volt-D.C. station i battery was operable. The inspectors reviewed the operability assessment and had no concern The inspectors noted that licensed operators were not required to review the monthly and quarterly station battery surveillance test results unless electrical maintenance personnel specified that an equalizing i charge was needed. The licensee has imposed less stringent requirements for the review of battery surveillance test results relative to other TS-required surveillance tests which must be reviewed by licensed I operator In addition, the inspectors identified an error in the performance of !
the quarterly station battery surveillance test conducted per EMSP-01 on July 1. Due to an error in the calculation of average individual cell voltage, the licensee did not identify that an equalizing charge needed to be performed. The inspectors determined through interviews with system engineering and electrical maintenance department personnel that each group thought that the other was going to verify the accuracy of the calculations and consequently, no independent verification of the calculations was performe c. Conclusions l The inspectors concluded that: (1) operability of the 011 125 Volt- station battery was not evaluated on several occasions when surveillance test results indicated that specific gravity was outside of prescribed ;
acceptance limits. (2) battery surveillance test results were subject to '
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less stringent operational reviews than other TS-required surveillance tests, and (3) due to the failure to independently verify the accuracy
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of calculations performed for the quarterly surveillance test, the licensee did not identify that calculational errors existed which prevented the licensee from determining that an equalizing battery charge needed to be conducte Section 5.1.B of ZODM-0, " Operability Determination Program,"
Revision 8, requires that a system, subsystem, train, component, or device that fails to meet acceptance criteria specified in governing and a) proved 3rocedures, be considered inoperable. The failure to address t1e opera]ility of the 011 125 Volt-D.C. station battery in accordance with ZODM-0 when specific gravity was outside the acceptance criteria specified in surveillance procedure EMSP-01 on April 1, October 7 and 26. and November 4. is considered an example of a violation of 10 CFR Part 50, Appendix B Criterion V (50-295/9G017-06a: 50-304/96017-06a),
as described in the attached Notice of Violatio <
Step 3.14 of EMSP-01 requires that average cell voltage be calculated '
and recorded. The failure to correctly calculate and record average cell voltage in accordance with EMSP-01 on July 1 is considered an example of a violation of 10 CFR Part 50 Appendix B Criterion V (50-295/96017-06b: 50-304/96017-06b), as described in the attached Notice of Violatio M1.2 Inconsistencies Between Completed Work Documentation and Actual Plant Configuration >
' Insoection Stone (62707)
The inspectors identified two examples where station personnel inappropriately signed off that work package criteria had been met. The inspectors reviewed applicable documentation and interviewed operations and engineering department personne Observations and Findinas i
On November 4. the inspectors identified that fasteners on several ;
conduit supports did not meet minimum thread engagement criteria. These
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supports had been installed in January 1996 for ID steam generator feedwater isolation valve IMOV-FW0019 in accordance with Work Package No. 950020050-01. Instructions in the work package specified minimum thread engagement criteria and required cuality control (OC)
verification of salected work steps per buclear Station Work Procedure E-03. The inspectors noted that the electrician and the OC inspector involved in the work activity had each signed off that the minimum thread engagement criteria had been met.
i On November 27, the inspectors identified a loose environmental
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qualification (EO) union for containment air H monitor loop D isolation valve 2A0V-PR250. TheEQunionwaslooseattfieconnectiontothevalve
- bod The loose union was required to be torqued to between 45 and
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55 ft-lbs as specified in Work Package No. 930028776-01. In
, February 1995, the involved electrician and OC inspector both
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signed off that the union had been torqued to 50 ft-lb Conclusions
, The inspectors concluded that the safety consequences of the ;
i installation deficiencies were minimal. However, as described in NRC l Inspection Report 50-295/96006-04: 50-304/96006-04, dated May 17, 1996, ,
' a violation was issued for the difference between the condition of a structure, system, or component (SSC) as described in completed work '
documentation and the actual plant configuration. In the case of the
- two examples identified during this inspection period, the work
activities during which the problem originated were conducted before the violation was issued. As a result, a violation is not being cited for
"
these example However, the inspectors were concerned with the identification of additional examples of inconsistencies between the condition of SSCs described in completed work documentation and the actual )lant configuration. These inconsistencies indicate a lack of
thoroug1 ness on the part of maintenance workers and OC personnel in
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verifying that work package criteria for safety-related equipment has l
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been met before signing off the work package.
l M1.3 Gas Cylinder Imoronerly Secured to Scaffold
!
- Insnection Scone (62707)
j On November 6, the inspectors identified that a compressed gas cylinder was secured to a seismic scaffold. The inspectors interviewed the night
, shift scaffold supervisor, a regulatory assurance engineer, and a member of the corporate safety oversight office.
' Observations and Findinas
- During an inspection of the fuel Handling Building, the inspectors identified that a compressed gas cylinder was secured to a seismic
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scaffold. The questionable scaffold configuration was associated with Scaffold Log Nos. A-617-096 and A-617-17 The inspectors were concerned that the seismic scaffold evaluation was invalidated by i increased loading from the gas cylinde ; The licensee initially informed the ins)ectors that it was acceptable to l secure a gas cylinder to a scaffold. T1e ins)ectors asked the licensee if the seismic evaluation had accounted for t1e additional weight of the gas cylinder. The licensee subsequently determined that the evaluation did not account for any external loads, such as gas cylinders, and concluded that the gas cylinder should not have been attached to the scaffold. The inspectors were also concerned that maintenance personnel did not understand the requirements of Zion Administrative Procedure (ZAP) 900-06, " Compressed Gas Cylinder Control," Revision 1, which did not allow gas cylinders to be secured to scaffolding. In followup to the inspectors concerns, corporate safety personnel identified
,
additional examples where gas cylinders had been improperly secured to
, scaffold .
c. Conclusions Maintenance personnel did not understand site gas cylinder control requirements. In addition, the licensee's staff was slow to recognize the impact of gas cylinders secured to a scaffold on the seismic qualification of that scaffold. The failure to control gas cylinders, :
as required by ZAP 900-06, which resulted in gas cylinders being secured to a seismic scaffold, is considered a violation of 10 CFR Part 50, Appendix B, Criterien V (50-295/96017-06c: 50-304/96017-06c), as described in the attached Notice of Violatio l M3 Maintenance Procedures and Documentation ;
I M3.1 Poor Work Practices and Inadeauate Maintenance Procedures Resulted in Five Protective Trios of the 2A EDG 1 a. Insoection Stone (62707) l
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On October 14. the 2A EDG was removed from service for replacement of the generator and modification of the diesel governor. During post-maintenance testing, the 2A EDG experienced five protective trip The inspectors observed selected portions of the maintenance, interviewed engineering and maintenance department personnel, and reviewed applicable maintenance procedures, j b. Observations and Findinas During a followup inspection of the EDG trips, the inspectors noted the following maintenance and manufacturing errors:
Generator Leads Wired Backwards On October 31, during startup of the 2A EDG in accordance with S01-11A,
" Local Operator Setup of Diesel Generator," Revision 5, and S01-11C,
" Local Starting of Diesel Generator," Revision 6, in preparation for Technical Staff Surveillance Procedure (TSSP) 82-94, the EDG trip)ed on generator phase differential a) proximately two seconds after the EDG had been started. The licensee su)sequently identified that the generator leads from the current transformers (CT) and potential transformers (PT)
had been wired incorrectly. The improperly landed leads resulted in the output of the PT being connected to one of the inputs for the differential current protection circuit, which normally received input from the CT. Consequently, when the field flashed on startup, the differential current protection circuit sensed a differential input which caused a trip signal to be generate The generator leads from the CT and PT were disconnected and reconnected per Work Request No. 950117181-01 which governed the generator'
replacement work. However, the wire numbering for the new generator was
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l i- different from the wire numbering for the original generator. Upon !
I o identifying this discrepancy, maintenance workers involved in the !
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generator re)lacement activity informed their supervisor. The-
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supervisor,10 wever, directed the workers to connect the leads using the
{ wire numbering scheme for the new generator without properly resolving i
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the issue. As a result, the leads were installed incorrectly. This i issue is considered an Unresolved Item (50-304/96017-07) pending NRC l
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i review of the results of the licensee *s investigation of the quality l
+
assurance requirements associated with the purchase order and the i vendor's quality assurance program, to determine the root causes for the ;
improperly configured wiring harnes !
l Imoronerly Disconnected Generator Neutral Ground Lead i i
During troubleshooting activities following the generator phase 1 differential trip, the licensee identified that the generator neutral i ground lead was improperly disconnected. With this lead lifted, single i phase ground faults could not be identified and cleared before the ground caused damage due to excessive heatin i Although the neutral ground lead had to be disconnected for removal of the generator, work instructions in Work Request No. 950117181-01 did i not specify that the subject lead be disconnected. Consequently, '
disconnection of the lead was not documented on a lifted lead data l sheet. During subsequent reassembly of the generator, the involved !
electrical maintenance (EM) technician identified that the generator ,l neutral ground lead was disconnected. The EM technician reconnected the lead, completed his work tasks, and then informed the maintenance i supervisor that he had reconnected the lead upon discovery that it was disconnected.. The supervisor informed the EM technician that the ,
neutral ground lead needed to be disconnected to support i post-maintenance generator inspections, and as a result, the EM :
technician disconnected the lead. The inspectors noted that the work !
activities involving lifting and re-landing the generator neutral ground i lead were conducted without any work control During the subsequent generator inspections, conducted in accordance i with P/E009-2N, " Diesel Generator Inspection and Maintenance " !
Revision 17, the licensee did not identify that the generator neutral !
ground lead was disconnecte In reviewing 3rocedure P/E009-2N in ;
preparation for the generator inspections, t1e work analyst deleted the ;
steps which specified that the lead be disconnected since the lead had l already been lifted. The maintenance supervisor who also reviewed i P/E009-2N, deleted the procedure steps for reconnecting the lead since i the work analyst had previously deleted the steps for disconnecting i ;
Machinina Imoerfection in Governor Actuator ,
On November 2 during the initial loading of the 2A EDG to support l TSSP 82-94, the EDG immediately tripped on reverse powe Based on indications, the licensee suspected that the newly installed governor '
actuator was causing excessive hunting resulting in a reverse power
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trip. After consulting with a vendor representative, the licensee !
. adjusted the governor response and then attempted to load the EDG. The !
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EDG tripped again on reverse power. The licensee readjusted the !
governor response, started the EDG, and attem)ted to load it. The EDG
'
tripped for a third time on reverse )ower. Tie licensee then directed that testing be stopped until a trou)leshooting plan had been developed and approve l The licensee determined that due to a machining imperfection, the governor actuator was not sitting flush with its baseplate. When the ;
maintenance technician had originally installed the governor actuator, he did not question the existence of this condition. As a result, when the maintenance technician secured the governor actuator to the base ,
plate, the misalignment caused mechanical binding of the governor I actuator, resulting in the observed reverse power trips. The licensee i l
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decided to replace the governor actuator since the licensee could not l determine if the actuator had been damaged by the bindin l Hisalioned Governor Actuator i On November 4. the licensee installed a new governor actuator per a field change to Work Request No. 940029891-01. The work instructions in this field change consisted of the statement " Install new governor."
The instructions did not address correctly positioning the terminal lever on the terminal shaft, and as a result, the governor actuator was misaligned. When the licensee attempted to start the EDG, it tripped on overspeed because excessive fuel was supplied to the engine due to the misaligned actuato Conclusions The inspectors concluded that: (1) lack of a questioning attitude and i
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failure to address identified discrepancies resulted in missed l opportunities to prevent each of the EDG trips: (2) inadequate work '
instructions for the generator replacement. and the practice of not documenting the disconnection of all leads, contributed to the failure to reconnect the generator neutral ground lead: and (3) inadecuate work I
instructions for the governor actuator replacement contributec to the .
overspeed trip of the 2A EDG. The inspectors also concluded that !
, safety-related equipment was unnecessarily challenged due to poor l l maintenance practices and inadequate maintenance procedure l The failure of Work Request No. 950117181-01 to provide appropriate guidance to control the configuration of the generator neutral ground lead, and the failure of the field change to Work Request N to provide appropriate guidance to control the alignment of the governor actuator, are considered two examples of a violation of 10 CFR Part 50. Appendix B. Criterion V (50-304/96017-08a and >
50-304/96017-08b, respectively), as described in the attached Notice of
.
Violatio M3.2 Inadeouate Maintenance Procedure Resulted in Damaae to the 1A Auxiliarv
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Feedwater (AFW) Pumo Turbine Inboard Bearina
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a. Insoection Scone (62707) '
The insf.ectors observed selected portions of maintenance activities
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related to the 1A AFW pump. The inspectors interviewed mechanical !
maintenance, operations, and engineering department personnel: reviewed
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i selected maintenance procedures: and inspected the 1A AFW pump, ;
including the turbine inboard bearing assembl ,
b. Observations and Findings
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i The inspectors evaluated the following issues with respect to the AFW l pump work:
AFW Pumn Turbine Bearina Water Intrusion
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i On November 25 the 1A AFW pump was removed from service for scheduled
- maintenance. While replacing the oil in the turbine inboard bearing, the licensee identified approximately one-half gallon of water in the '
turbine inboard bearing oil reservoir, which has a capacity of five and one-half quarts. Based on an investigation by system engineering personnel, the licensee identified three possible sources of water: the ;
l installed oil cooler, turbine steam migrating to the bearing along the
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shaft, and leakage from the oil cooler that was in service before December 1995. Based on the results of a hydrostatic test of the installed cooler and inspection of the pump turbine, the licensee concluded that the source of the water was most likely from the cooler in service before December 199 System engineering personnel concluded that the water had been present in the oil reservoir before the cooler was installed in December 1995 -
and had not been detected due to improper performance of the oil change i preventive maintenance (PM) task. System engineering personnel maintained that the fuel handlers who performed this PM activity had drained oil from the reservoir via the sightglass instead of the drain plug, resulting in the removal of approximately one quart of oil from the upper portion of the reservoir. This practice resulted in the majority of the oil and whatever water was present, remaining in the reservoi i l
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However, the inspe tors noted that the explanation by system engineering personnel of why the presence of water in the oil reservoir had not been detected, conflicted with statements by the fuel handlers responsible '
! for performing the PM activity. When the inspectors discussed this issue with operations management and a fuel handling supervisor responsible for completing the oil change PM, these individuals informed the inspectors that the oil change had always been conducted using the drain plug. This information did not support the conclusion by system engineering personnel that the source of the water was from the oil cooler in service before cooler replacement in December 1995. This issue is considered an Unresolved Item (50-295/96017-09) pending NRC
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review of the licensee's evaluation of the source of the water and the !
adequacy of the oil change PM tas !
AFW Pumo Turbine Bearina Damaae ,
i As a result of water beina identified in the bearing reservoir, the - .
licensee expanded the scope of the scheduled maintenance to include an l inspection of the turbine inboard bearing assembly. During this ,
inspection, the licensee discovered that the bearing was wiped. Because i bearing damage was limited to a discrete portion of the bearing surface, the licensee concluded that the damage was not the result of water ;
intrusion. The licensee's investigation to determine the root cause for the bearing damage was still in progress at the end of the inspection i perio .
Incorrect Installation of AFW Pumo Turbine Bearina Slinaer Rinas
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On November 28. the licensee replaced the turbine inboard bearing in accordance Work Request No. 960110430-01, Revision No guidance on installation of the oil slinger rings was provided in the work instructions associated with this work request. During installation of the new bearing, the maintenance staff incorrectly installed the slinger rings. Consequently, on November 29. during post-maintenance testing of the 1A AFW pump, elevated turbine inboard bearing temperature necessitated tripping the pump. The 11ensee identified significant bearing damage during an inspection of the bearing and attributed this damage to inadequate lubrication caused by the improperly installed oil .
slinger rings. The licensee replaced the damaged bearing and satisfactorily retested the AFW pump. The inspectors noted that the work activity involving installation of the oil slinger rings was observed by a mechanical maintenance superviso c. Conclusions The inspectors concluded that the work instructions used to install the 1A AFW pum) turbine inboard bearing were not appropriate for the skill level of t1e mechanics performing the maintenance activity. The failure to provide sufficient work instructions for installation of the turbine bearing is considered an example of a violation of 10 CFR Part 50, Appendix B Criterion V (50-295/96017-08c), as described in the attached Notice of Violatio _
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III. Enaineerina El Conduct of Engineering El.1 Failure to Address Operability for Deficiencies in Safety-Related Pioino l
Suonorts in a Timely Manner a. Insoection Scone (37551)
The licensee did not evaluate three NRC identified safety-related piping support deficiencies in a timely manner. The inspectors interviewed operations and engineering personnel and evaluated the licensee's resolution of the degraded pipe support condition j b. Observations and Findings On October 25. the inspectors identified that a "U" bolt style piping support was missing on both the 1A and the 0 EDGs. The licensee documented this condition on Problem Identification Form (PIF) 96-3713 and initiated an operability assessment per Appendix A. " Initial Operability Assessment " of the Zion 0)erability Determination Manual (ZODM) 0. Based on this initial opera)ility determination, which was
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completed on October 26, the licensee concluded that the EDGs were operable. The licensee is also required to perform an operability evaluation per Appendix B. " Operability Issue Form." of ZODM-0. whenever an operability issue has been identified. The licensee completed the Appendix B evaluation on November 8, which specified that a detailed calculation be completed by November 15 to determine if the jacket water cooling system remained seismically qualified. On November 8, the engineering supervisor responsible for approving the Appendix B l evaluation identified that the timeliness requirements specified in the i ZODM-0 had not been me ;
On November 7. the inspectors notified engineering personnel that a l
" trapeze" style piping support for eight service water lines in the
, Unit 1 containment spray room was partially disassembled. in that, one l
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of two support rods was not attached. An engineer did not inspect the support until November 14. After inspecting the support, the engineer
,
initiated a PIF (96-4217), and an operability assessment )er Appendix A of the ZODM-0 was completed. Based on this initial opera)ility determination, the licensee concluded that the affected equipment was operable. The required Appendix B operability evaluation was completed l on November 15.
l On October 16, the inspectors informed a system engineer that a pi]e support was missing on high pressure N2 backup pressure control va ve
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IPCV-NT10. The system engineer informed the inspectors that the missing support had been identified three years ago and that there was not an operability concern based on an evaluation performed at that time. The
engineer, however, could not produce the documented evaluation. In response to the inspectors concerns, the licensee performed an operability assessment for the missing pipe support on November 27 and 22 _ . _ _ . - . . . . _ . _ . . -
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. concluded that the valve IPCV-NT10 was inoperable.
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- c. Conclusions The inspectors concluded that engineering personnel did not evaluate '
safety-related material condition deficiencies for operability in a timely manner. The failures to: (1) complete Appendix B of ZODM-0 within the required time limit specified in ZODM-0 for missing jacket water cooling system pipe supports on the 1A and 0 EDGs: (2) complete operability assessments for a partially disassembled service water ,
piping support )er Appendix A and B of ZODM-0 within the time limits specified in Z0)M-0: and (3) complete Appendix A within the required time limits of ZODM-0 for a missing pipe support on valve IPCV-NT10: are considered three examples of a violation of 10 CFR Part 50 Appendix B, Criterion V (50-295/96017-06d: 50-304/96017-06d. 50-295/96017-06e, and 50-295/96017-06f respectively), as described in the attached Notice of Violatio E2 Engineering Support of Facilities and Equipment E2.1 Exhaust Air Flow From the Fuel Handlino Buildino (FHB) Bvoassed the Auxiliary Buildino (AB) Charcoal Exhaust Filters a. InsDeCtion SCODe (71707 and 37551)
On November 7, the licensee identified that the plant may have operated in a condition outside of the plant's design basis as described in the Updated Final Safety Analysis Report (UFSAR). The condition pertained to a design basis fuel handling accident. The inspectors interviewed system engineer personnel and reviewed ap)licable documentation, including the Technical Specifications, t1e UFSAR, and a fuel building ventilation system safety evaluation (50.59/0213/96).
b. Observations and Findinos Section 9.4.3.1 of the UFSAR assumes that for a fuel handling accident, ,
all of the exhaust air from the FHB is routed through the AB charcoal i exhaust filters. To facilitate the movement of large equipment into and I out of containment during the Unit 2 refueling outage, the licensee i removed a shield block wall between the containment and FH This created a ventilation exhaust path through a vertical pipe chase and !
pipe tunnel which bypassed charcoal filters in the AB ventilation i syste In response.to a high radiation condition during a fuel handling accident, radiation monitors in the pi)e tunnel (2RT-PR07A and B) should actuate, realigning the ventilation ex1aust path through charcoal filters. However, per the Technical Specifications, the radiation monitors are not required to be operable in Mode 6 (refueling).
Consequently, there was no assurance that the monitors would have been available to realign the pipe tunnel exhaust through charcoal filter The licensee concluded that this condition could have resulted in
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significant increases in offsite dos To address this issue, the licensee initiated the following corrective actions:
. Periodic Test 19. " Auxiliary Building / Fuel Building Ventilation Test," Revision 5, was revised to configure the pipe tunnel exhaust through charcoal filters during fuel handling and crane movements over the spent fuel poo . Engineering requests were issued to perform a modification to -
install' duct work between the pipe tunnel opening and the AB to prevent FHB exhaust air from bypassing charcoal filters . Conclusions !
Upon identification, the licensee initiated prompt corrective actio As of the end of this inspection period, the licensee was still in the J 3rocess of evaluating this-issue. This issue is considered an Jnresolved Item (50-295/96017-10: 50-304/96017-10) pending further NRC review to determine if this condition existed during actual fuel movements in the FHB and what previous opportunities existed for the ,
licensee to identify the ventilation system concer I E2.2 Fuel Assembly Clearances Durina Fuel Moves i Insoection Scoce (71707)
On November 24 the licensee identified a discrepancy between the actual '
plant configuration and the UFSAR description ~of the clearance between the bottom of a fuel assembly and the weir gate and the distance between the surface of the spent fuel pool' (SFP) and the top of a fuel assembly during fuel moves. The inspectors interviewed engineering and licensing department personnel and reviewed applicable documentatio Observations and Findinas Section 12.3.2.2.3.1. " Spent Fuel Pool," of the UFSAR states that,
"Using a clearance of six inches between the bottom of a spent fuel assembly and the base seal of the gate, a 10-foot 3 inch water shield is i provided above the active length of the assembly during transfer." The licensee identified that the six inch clearance and water shield requirements were not met during fuel moves. The maximum clearance of a fuel assembly from the weir gate base was 2," and the SFP level would have to have been above the overflow value of 615' 5" in order to have maintained 10' 3" of water above the fuel assembly during fuel ;
transfers. The licensee's corrective actions in response to this issue i included suspension of all fuel moves and the initiation of a change to I the UFSA l
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c. Conclusions
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The licensee appropriately suspended fuel movement upon identification of this issue. The licensee was still in the process of evaluating the reason for and the significance of this UFSAR discre)ancy at the end of the inspection period. This issue is considered an lnresolved Item
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(50-295/96017-11: 50-304/96017-11) pending NRC review of the results of l the licensee's evaluatio E3 Engineering Procedures and Documentation l
E3.1 Review of UFSAR Commitments
- The discovery of a licensee operating its facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR descriptions. The inspectors reviewed the applicable portions 2 of the UFSAR that related to the areas inspected. The following inconsistencies were noted between the wording of the UFSAR and the plant practices, procedures, and/or parameter a. Fuel Handlina Accident Defined in UFSAR Incorrect On November 7, the licensee identified that the fuel handling accident, as described in UFSAR Section 9.4.3.1, was incorrect. This issue is discussed in Section E2.1 of this repor b. Fuel Assembly Clearances Durino Fuel Transfer Not Consistent With UFSAR On November 24, the licensee identified a discrepancy between the actual plant configuration and the UFSAR description of the clearance between the bottom of a fuel assembly and the weir gate and the distance between the surface of the SFP and the top of a fuel assembly during fuel move This issue is discussed in Section E E8 Miscellaneous Engineering Issues E8.1 (Closed) IFI 50-295 304/96014-07: Safety-related pi)ing support anchor
)lates exceeded the specified gap criteria between tie plate and the Juilding structures i l
The inspectors reviewed the licensee's operability assessment l (No. ER9604805) and supporting engineering calculations and determined '
that the licensee's conclusions regarding operability of the analyzed pipe supports were adequately justified. However, since the licensee's operability assessment was based on an inspection of a limited number of supports, of which approximately 50 percent exceeded the gap criteria, the inspectors determined that the licensee's conclusion that all large bore piping supports with excessive gaps were capable of performing their intended safety function, lacked a technical basis. In res)onse to the inspectors concern, the licensee informed the inspectors tlat in the future when deviations from the specified gap criteria were
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identified, the licensee would either demonstrate that the condition is
. bounded by operability assessment No. ER9604805, or perform an
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additional evaluation of the condition. The inspectors had no further concerns with this issue and this item is close j E8.2 (Closed) IFI 50-295:304/96014-08: High ambient temperature in the 011 l 125 Volt-D.C. battery roo ;
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Per guidance in the Zion Operability Determination Manual, the licensee :
considers the 011 125 Volt-D.C. battery to be operable for up to five l days without the battery room exhaust ventilation system in operation, i based on the calculated time for hydrogen concentration to exceed two percent without ventilation flow. The 3rojected time for hydrogen concentration to reach two percent was Jased on calculation N NED-MSD-H-7. The inspectors reviewed this calculation and did not l identify any concern The inspectors also reviewed the licensee's basis for allowing operation of the 125 Volt-D.C. batteries in an elevated ambient temperature environment. As documented in licensee internal correspondence (Chron iiu. 115671) dated May 5,1992. the licensee concluded that continued operation of the batteries in an elevated temperature environment would result in reducing the battery service life by approximately 25 percent. However, the reduced service life of the batteries would not increase the number of expected battery replacements before the expiration of the plant license. The licensee therefore,
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concluded that a modification to the battery ventilation system to lower I ambient temperatures was not justified based on economic consideration l The inspectors had no further safety concerns with this issue and this '
item is closed, l l
E8.3 (Closed) Unresolved item 50-295/304-96006-09 Unit 1 safety injection '
(SI) pump suction pi)ing pressurized due to freezing of the recirculation line w1ere it traversed the containment purge supply duc l At the time of the event Unit I was in Mode 5 (cold shutdown). The SI i system is not required to be operable in this plant condition. The
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inspectors reviewed operating records for the past five years to determine if the SI system recirculation piping was susceptible to freezing due to plant conditions at a time when the SI system was required to be operable. The susceptibility of the recirculation pi)ing to freezing was dependent upon the outside ambient temperature, whetler the containment purge system was in service, and the accumulation of water in the recirculation line due to running of the SI pump during a previous surveillance test. The inspectors did not identify the existence of the recuired plant conditions during the past five year The inspectors notec that the licensee completed a similar review on November 27, 1996, with the same result The licensee addressed this equipment vulnerability concern during the current refueling outage by rerouting the Unit 2 SI system recirculation I piping away from the containment purge supply ducting. The exposed 1
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piping in the vicinity of the Unit 1 containment purge supply ducting
. was heat-traced and the licensee implemented a standing order to check
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temperatures-in the purge room each shift. The inspectors concludej that the licensee's corrective actions were adequate. This item is close IV. Plant Suocort F2 Status of Fire Protection Facilities and Equipment F2.1 Unaualified Fire Barriers On November 8, the licensee identified that "Cerifiber" fire seals installed in the plant did not conform to approved fire test report The licensee initiated an investigation to determine the fire seals'
qualification, which was still in progress at the end of this inspection perio In the interim, the licensee established compensatory measures including hourly fire watch tours of the affected areas. This is considered an Unresolved Item (50-295/96017-12: 50-304/96017-12) pending NRC review of the licensee's investigation result V. Manaaement Meetinas X1 Exit Heeting Summary The inspectors 3 resented the inspection results to members of licensee management at tie conclusion of the inspection on December 6, 1996. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie X3 Hanagement Heeting Summary NRC and Commonwealth Edison management met at the NRC Region III offices on November 19, 1996, to discuss the licensee's initiative to have an independent scfety assessment (ISA) of LaSalle County Station and Zion Station conducted by a contractor. At this meeting, the licensee described the purpose of each ISA, organization and staffing of the ISA team, the scope of each assessment, and the proposed schedule. The licensee stated that the ISA would consist of a comprehensive review of historical performance at each facility to determine why previous improvement initiatives had not been successful and to ensure the licensee was focusing resources on appropriate issue !
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee J. Mueller, Site Vice President G. Schwartz, Station Manager G. VanderHayden, Operations Manager W. Stone, Regulatory Assurance Supervisor B. Fitzpatrick, Operations Manager B. Giffin Engineering Manager K. Hansing, Site Quality Verification Director W. Strodl, Radiation Protection Supervisor M. Weis, Services Director NRC M. Dapas. Chief, Reactor Projects Branch 2 M. Parker Senior Resident Inspector, Palisades A. Vegel, Senior Resident Inspector Fermi R. Westberg, Senior Resident Inspector
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l List of Insoection Procedures Used
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L- IP.37551 Onsite Engineerin {
IP 40500 Effectiveness of Licensee Controls in Identifying. Resolving, and
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Preventing Problems IP 61726 Surveillance Observations >
l IP 62707 Maintenance Observation l I
IP 71707 Plant Operatione 1 i
l List of Items 00ened. Closed. and Discussed
00ened i
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j 50-304-96017-01 VIO Operation of an 00S component which resulted in
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a spill of approximately 400 gallons of water l 50-295-96017-02 URI Practice of allowing reactor power to knowingly exceed licensed thermal )ower limit 50-295/304-96017-03 VIO Failure to demonstrate tie operability of the two remaining EDGs and the availability of two sources of off-site power within one hour and at
! least once per every eight hours thereafter
! while the 0 EDG was inoperable 50-295/304-96017-04 VIO Failure to implement corrective actions for an identified significant condition adverse to i
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quality 50-295/304-96017-05 URI Control of overtime 50-295/304-96017-06a VIO Failure to address operability of equipment when I a TS required surveillance test discovered equipment parameters outside the acceptance criteria specified in the test 50-295/304-96017-06b VIO Failure to correctly calculate average cell voltage during a battery surveillance 50-295/304-96017-06c VIO Improperly attached gas cylinders to seismic scaffold which invalidated the seismic evaluation 50-295/304-96017-06d VIO Failure to com)lete appropriate operability
- assessment witlin five days of discovery of i missing piping supports on the 1A and 0 EDGs 50-295/304-96017-06e VIO Failure to complete the appropriate operability assessments within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and five days for a partially disassembled service water piping support 50-295/304-96017-06f VIO Failure to com)lete a)propriate operability assessment wit 11n 24 lours for a N 2backup pressure control valve 50-304-96017-07 URI Review of purchase order and vendor quality assurance program to determine cause of the improperly configured wiring harness on new generator 50-304/96017-08a VIO Inadequate maintenance procedure resulted in the r loss of configuration control for the generator i l neutral ground lead !
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29 l
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I 50-304-96017-08b VIO Inadequate maintenance procedure resulted in the 1
. misalignment of the 2A EDG governor actuator
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50-295-96017-08c VIO Inadequate maintenance instructions resulted in the improper assembly of the 1A AFW turbine inboard bearing 50-295-96017-09 URI Review evaluation of source d adequacy of oil change PM or turbine inboard bearing 50-295/304-96017-10 URI Review evaluatiori a . Dypass flow 50-295/304-96017-11 URI Review evaluation 0, anbly clearances during fuel ...
50-295/304-96017-12 URI Review fire barrier quali1 aon documentation
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Closed 50-295/304-96006-09 URI SI pump recirculation line freezing 50-295/304-96014-07 IFI Operability assessment and su) porting engineering calculations for .)aseplate gaps 50-295/304-96014-08 IFI Basis for 125 Volt battery operability without battery room exhaust ventilation 50-295-96024 LER Missed TS surveillances for inoperable common EDG caused by manageiaent deficiency 50-304-96026 LER FHB ventilation exhaust air flow bypassed the AB charcoal exhaust filters i
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List of Acronyms
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AB Auxiliary Building AFW Auxiliary Feedwater CAR Corrective Action Record CT Current Transformer DET Diagnostic Evaluation Team EDG Emergency Diesel Generator ECCS Emergency Core Cooling System EM Electrical Maintenance EMSP Electrical Maintenance Surveillance Procedure E0 Environmental Qualification ESF Engineered Safety Features FHB Fuel Handling Building GL Generic Letter IFI Inspection Follow-up Item IP Inspection Procedure LER Licensee Event Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission 00S Out-of-Service PDR Public Document Room PIF Problem Identification Form PM Preventive Maintenance PT Potential Transformer PTL Pull-to-Lock OC Quality control RHR Residual Heat Removal RWST Refueling Water Storage Tank SI Safety Injection SFP Spent Fuel Pool SOI System Operating Instruction SOV Site Quality verification TS Technical Specification TSSP Technical Staff Surveillance Procedure UFSAR Updated Final Safety Analysis Report URI Unresolved Item UV Undervoltage VIO Violation VPI Valves Position Indicator ZAP Zion Administrative Procedure ZODM Zion Operability Determination Manual 31