IR 05000295/1997016
| ML20216C494 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/28/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216C445 | List: |
| References | |
| 50-295-97-16, 50-304-97-16, NUDOCS 9709090068 | |
| Download: ML20216C494 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli l
l Docket Nos:
50 295, 50 304 i
License Nos:
50 295/97016: 50 304/97016 Liceitsee:
Commonwealth Edison Company
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Facility:
Zion Nuclear Plant, Units 1 and 2 Location:
101 Shiloh Boulevard Zion, IL 60099 Dates:
May 30 through July 18,1997 Inspectors:
A. Vegel, Senior Resident inspector E. Cobey, Resident inspector
P. Cataldo, Operator _ Licensing Examiner J. Yesinowski, Illinois Department of Nuclear Safety inspector Approved by:
Melanie A. Galloway, Acting Chief Reactor Projects Branch 2 r
1 9709090068 970828 PDR ADOCK 05000295 g
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l EXECUTIVE SUMMARY Zion Nuclear Plant, Units 1 and 2
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NRC Inspection Reports 50 295/97016; 50 304/97016
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This inspection included aspects of licensee operations, maintenance, ud engineering.
The report covers a se.ven-week period of inspecticn activities by the resident staff.
Licensee performance during this inspection period wes characterized by numerous
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deficiencies in the control of the configuration of plant systems and equipment. However, neither operations department personnel nor your staff's use of the corrective action
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process identified that an adverse trend had developed, inspector identification of the
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- numerous material condition deficiencies in the control room called into question the effectiveness of the previous system walkdowns conducted to assess the material readiness of Unit 2 for restart.
_Ocerations
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The inspectors concluded that the licensee's implementation of the Operational
Readiness Demonstration Program was adversely impacted by inadequate planning and inconsistent implementation of the Zion Operations Department Standards.
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(Section 01.1)
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The inspectors identified an adverse trend in the licensee's control of the
configuration of plant systems and equipment.. (Section 01.2)
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A violation was identified involving the failure to follow an operating special
procedure for the 2A emergency diesel generator (EDG). (Section 01.2)
j Maintenance
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A violation was identified for the failure to provide appropriate guidance for setting
the droop potentiometer prior to loading the O EDG. (Section M3.1)
J The inspectors identified a violation pertaining to the failure of a quality control
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inspection to verify conformance with work instructions for the O EDG governor modification. (Section M7.1)
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Enoineerina
The inspectors concluded that the pre-evolution briefing for an isolation valve seal
j water system test was effective at identifying and resolving potential problems.
(Section E2.1)
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The inspectors identified numerous material condition deficiencies in the control room. Of particular concem was the failure of the licensee to identify these j
problems during recent system affirmations on the control room ventilation system.
(Section E2.2)
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Report Details Summarv of Plant Status During this inspection period, the licensee maintained Unit 1 in a defueled status, and Unit 2 in a cold shutdown, depressurized condition pending completion of restart actions delineated in the Zion Recovery Plan.
1. Operations
Conduct of Operations 01.1 Operational Readiness Demonstration Proaram imolementation a.
insoection Scone (71707)
The inspectors observed licensee implementation of the Operational Readiness Demonstration Program (ORDP). The inspectors observed control room activities, attended ORDP daily debriefs, interviewed operators, and reviewed applicable documentation, b.
Observations and Findinas On July 7,1997, the licensee initiated the ORDP to assure the effectiveness of the corrective actions taken to resolve the fundamental operator performance issues resulting from the February 21,1997, reactivity management event. The purpose of the ORDP was to verify that the operators and shift crews could implement management's expectations for plant operations and verify management support of operations through day to day plant activities. The ORDP consirted of a series of operating tasks that were selected to validate plant and operator readiness prior to returning the plant to power operations. The operating tasks selected for observation included routine and infrequent surveillance activities and off-normal evolutions. The observations of the ORDP activities were conducted by operations line and shift management, industry peers, and site and corporate independent oversight groups. The expected time period to complete the ORDP was approximately four weeks, with changes being anticipated as a result of management's assessment of performance.
During the first week of the ORDP impleme7tation, the licensee focused its efforts on developing and refining the processes supporting the ORDP. - For example, the ORDP guidance document which included expectations, performance measures, and observation guidelines was not issued by the licensee until July 9, two days af ter the ORDP commenced. During the second week of the ORDP implementation, the number and quality of observations conducted significantly increased. However, only one of four special activities planned for the ORDP was actually conducted due to work planning and scheduling problems.
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The inspectors attended several ORDP daily meetings and observed that numerous observations (approximately 20-30 por day) of control room and in plant activities were being conducted. The inspectors noted that the majority of the documented licensee observations provided meaningfulinsights on various aspects of operator performance including log keeping, control room decorum, communications, effectiveness of turnovers, and effectiveness of non-licensed operator rounds.
However, the inspectors observed that the standards applied during the observations were not always consistent with the Zion Operations Department Standards. For example, confusion existed between a management observer and an operator regarding expectations on the technique to identify a component before operating it.
c.
Conclusion The inspectors concluded that the effectiveness of the first two weeks of the ORDP was mixed. Positive attributes of the ORDP included the numerous observations performed, which resulted in good insights on operator performance. However, the implementation of the program was marred by inadequate planning and inconsistent application of the Zion Operations Department Standards.
01.2 Adverse Trend in Confiauration Control of Plant Svstems and Eauinment a.
insoection Scone (71707)
The inspectors identified an adverse trend in the control of the configuration of plant systems and equipment. The inspectors interviewed operations, maintenance, and radiation protection personnel, and reviewed applicable procedures and documentation including the completed apparent cause evaluations.
b.
Observations and Findinas During this inspection period, the inspectors noted six examples of inadequate configuration control. During follow-up inspection activities, the inspectors identified that the licensee was slow to investigate the circumstances surrounding these occurrences; and, the licensee failed to recognize that an adverse trend had developed. Specifically:
2A Emergencv Diesel Generator (EDG) 3L Kiene Valve Out of-Position Ooen On June 8.,1997, during performance of periodic test (PT) 11 DG2A, "2A Diesel Generator Loading Test," a non-licensed operator heard an abnormal noise and determined that the 3L Kiene valve (cylinder test valve) was open. The operator subsequently tripped the 2A EDG and initiated Problem Identification Form (PIF) Z1997-00107. The operating shift's immediate corrective actions included repositioning the 3L Kiene valve closed and verifying that all of the remaining Kiene valves on each EDG were closed.
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The licensee assigned the PlF to the mechanical maintenance department for investigation. The department personnel completed the cause evaluation on June 18,1997, and concluded that during the last performance of Operating Special Procedure (OSP)97-012, "2A D!esel Generator Liner Test," Revision 1, on May 10, the valve was not closed as retiuired in Section 5.58.
The inspet, tors' review of this occurrence identified several contributors that were not discussed in the apparent cause evaluation including: the peer evaluation for this step was not completed by an individual with equivalent qualification; the peer evaluator observed the mechanic' actions and did not verify that the valve was actually closed; and all 16 action m the step were completed before any sign-offs were made for the individual actions. As a result, maintenance management promulgated to the maintenance department the expectations for performing peer evaluations and for documenting multiple tasks within a single step.
As previously documented in NRC inspection Reports 50 295/96014; 50-304/96014,50-295/96017; 50-304/96017, and 50-295/97013; 50-304/97013, the failure of maintenance personnel to follow procedures continues to be an area of concem. The failure to close the 3L Klene valve on the 2A EDG as required by OSP 97-012, Section 5.58, it, considered a violaticn of 10 CFR Part 50, Appendix B, Criterion V, (50-304/97016-01), as described in the attached Notice of Violation.
011 125 Volt-D C. Batterv Vent.ilation Found Secured
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On June 11,1997, a non-licensed operator identified that the 011 battery room ventilation system was secured when the system should have been in operation.
The operating shift subsequently reenergized the system and initiated PlF Z1 bis 7-00165.
The licensee assigned the PlF to the electrical maintenance department for investigation. Based on the results of this evaluation, the licensee concluded that the cause of the occurrence was unknown since electrical maintenance had no reason to secure the system, and there was no way of knowing why or when the ventilation was secured. The inspectors were concemed that the evaluation was completed and approved, and the respective Nuclear Tracking System item was closed without any involvement by the operations department. The inspectors'
concern was based on the fact that the operations department had operational authority for all plant systems and equipment, but in this case was not involved in determining why a safety-related battery ventilation system was not in its expected configuration.
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Ayxiliarv Feedwater (AFW) Low Suction Pressure Transmitter Found Isolated
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On June 16,1997, a Unit 2 Nuclear Station Operator noted that the Auxiliary Feedwater Purap Suction Pressure Low annunciator had not cleared as expacted following the final clearance of an AFW out-of service (OOS) instruction.
Investigation by a non-licensed operator idenafied that We :oot valve for the
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pressure transmitter was closed. The operating shift repositioned the valve open and initiated Fib Z1997 00256. On July 25,in response to the inspectors'
questions and requests for information, the licensee determined thu ree PlF had i
never been screened by the event screening committee and that no further investigation had been initiated.
1B EDG Switches Found Out-of-Position Durino an OOS Indeoendent Verification On July 16,1997, during the performance of independent verification for the 1B EDG OOS 970007285, a non-licensed operator identified that two control switches were out of position. Both of the control switches for the 1B EDG train B starting air compressor and the 1B EDG 1BW diesel oil transfer pump were in the " auto" instead of "off" position. The operator repositioned the control switches, and the licensee completed a subsequent independent verification. In response to this occurrence, the Unit Supervisor initiated PlF Z1997-00720. At the end of the inspection period, the licensee's investigation was in progress.
Containment Radiation Monitor Deeneraized Without Authorization Resultina in a Containment Ventilation isolction Sional l
On July 14,1997, Unit 2 received an unexpected containment ventilation isolation actuation signal as a result of a radiation protection technician (RPT) performing troubleshooting activities on the containment air sampling monitor, 2RIA 'R40.
The RPT was investigating a problem with the monitor involving the failure of two channels to reset from the maintenance mode. The RPT informed Unit 2 control room operators of this condition and that an action request would be generated to correct the problem. The RPT subsequently notified the Unit 1 control room operators of his intent to deenegize the monitor for troubleshooting: however, the Unit 1 operators failed to inform the Unit 2 operators. When the monitor was subsequently deenergized, an unexpected Unit 2 containment isolation actuation signal for the closure of the containment ventilation valves resulted. Since the containment ventilation valves were already closed, no actual valve movement occurred.
The inspectors were concemed that this event occurred as the result of poor communications and a lack of command and control of plant activities by control room operators. Specifically, the Unit 1 operators failed to inform the Unit 2 operators that a Unit 2 compones was going to be deenergized, and the control room staff failed to eveluate the expected plant response prior to the radiation monitor being deonergized. The less-than-adequate operator performance combined with an RPT performing troubleshooting without a clear understanding of the implications, was considered to be another example of inadequate configuration control. Additional inspector review of this event was documented in NRC Inspection Report No. 50-295/97020; 50 304/97020.
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Fire Protection Valve Found Out-of Position Closed On July 17,1997, during the performance of System Operating Instruction CS, Appendix A, Part II, " Fire Protection System Essential Valve Line-Up," operations department personnel found the Unit 0 fire protection area 0 AF alarm valve OFPO494 alarm inlet isolation valve, OFP0760, out-of-position closed. The licensee subsequently repositioned the valve open and initiated PlF Z1997 00736.
During a subsequent walkdown raf the equipment, the Fire Marshall determined that the flow switch for the fire protection header, which this valve isolated, was not electrically connected. Consequently, the Fire Marshall concluded that the valve being out of position did not affect system operation. However, the inspectors identified that the fire protection system drawing, M-43, indicated that the flow switch was in-service. The licenseo's development of corrective action was in progress at the close of the inspection period, c.
Conclusions The inspectors concluded that even though the operations department had operational authority over all plant systems and compone u, operations department pert onnel were only involved in investigating the circumstances surrounding the 1B EDG OOS error. Furthermore, neither operations department personnel or staff use of the corrective action process identified that an adverse trend was developing with the control of the configuration of plant systems and equipmen'.
In response to the inspectors' identificatica of the adverse trend in configuration control, the licensee initiated PlF 21997-00893 and a formal root Lause investigation. This issue is considered an Unresolved Itom 60-295/97016-02; 50-304/97016 02) pending NRC review of the licensee", root cause investigation for configuration control deficiencies including: (1) the secved 011 battery ventilation, (2) the isolated AFW low suction pressure tra 1smitter, (3) the out-of-position 1B EDG switchas, and (4) the out-of-position fire protection valve OFP0760.
O3 Operations Procedures and Documer'tation 03.1 Overator Resnonss to Steam Generator (SG) Tube Ruoture Based on the observations of three operating crews during simulator scenarios, the licensee identified that operator response time to a SG tube rupture event was longer than assumed in the Updated Final Safety Analysis Report (UFSAR). During the performance of several simulator scenarios involving SG tube rugtures, tha licensee staff noted that three operating crews required 34,39, and 41 minutes, respectively, to stop the leak. The UFSAR assumes that operators can isolate and stop the leak from a ruptured SG within 30 m'.Jtes of accident initiation.
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Specifically, UFSAR Section 15.6.3.1 states:
" Consideration of the indications provided at the control board.
- together with the magnitude of the break flow, leads to the conclusion that the isolation procedure can be completed -
within 30 minutes of accident initiation."
In addition, UFSAR Section 15.6.3A states that in determining the mass transfer through the broken tube to celculate the estimated dose at the site boundary, the following assumption is made:
"The operator identifies the accident type and terminates break flow to the faulty steam generator within 30 minutes of accident initiation."
Following the identification of this discrepancy with the UFSAR requirements, the licensee initiated PlF Z1997-00565. This issue is considered an Unresolved item (50-295/97016-03; 50-304/97016-03) pending NRC review of the licensee's actions to resolve the discrepancy between UFSAR assumptions and observed operator response time to a SG tube rupture simulator scenario.
11. Maintenance M1 Conduct of Maintenance M1.1 2A Safety iniection (SI) Pumo Testinq j
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Insoection Scoos (61726)
The inspectors reviewed the circumstances related to a failed 2A Si pump surveillance. The inspectors reviewed PT-2A-RT, " Safety injection Tests During Refueling," PlFs Z1997 00130 and Z1997_00131, and applicable documentation.
The inspectors also interviewed operators and the Si system engineer.
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Observations and Findinas On June 9,1997, during the licensee's performance of PT-2A RT, the 2A SI pump failed the surveillance due to the pump head being higher than the set value range.
Based on the measured pump discharge pressure, the licensee determined the calculated pump head to be 3,392.2 feet. The pump head set value prescribed by the procedure was 3 249 to 3,381 feet. The licensee initiated PlF Z1997-00131 to document this dio vepancy and track corrective action:,
in additicn, during this test, the licensee flushed the 2A SI pump recirculation line strainer and found three pieces of debris. As a result, the licensee initiated PlF Z1997-00130 to track the investigation of the foreign materialin the Si system.
As previously documented in NRC Inspection Report 50-295/95-03: 50-304/95 03,
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Si pump recirculation line orifice plugging due to debris has been a long-standing problem. Consequently, the licensee recently installed the strainers in the 31 pump recirculation lines to prevent the clogging of the Si orifices.- The inspectors were concerned that the cause for the introduction of foreign materialinto the Si system has not been effectively resolved, c.
Conclusions This issue is considered an Unresolved item (50 295/97016-04; 50-304/97016 04) pending NRC review of the licensee's evaluation of the 2A Si pump head being above the set value range and the debris found during the flush of the 2A Si pump recirculation line strainer.
M3 Maintenance Procedures and Documentation M3.1 Inadeauste Procedural Guidance Resulted in Imoroner Settina of the O EDG Governor I
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Insoection Scoos (62707 and 37551)
During post maintenance testing, the O EDG began self-loading following closure of the output breaker. At a load of approximately 1.5 MW and increasing, the Nuclear
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l Station Operator (NSO) manually opened the output breaker, which prevented potential overload of the EDG. The inspectors observed selected portions of the maintenance, interviewed engineering and maintenance department personnel, and reviewed applicable maintenance and testing procedures.
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ObservationtLand Findinas f
On June 26,1997, during the performance of Technical Staff Surveillance Procedure (TSSP) 008-97, " Diesel Generator 0 Governor Test Fast and Slow Starting Modes Construction Test," Section 31, " Paralleling the Dies 61 Generator with the Grid (Remote, Fast Start, Droop Mode, Generator Loading)," the O EDG began self loading after the operator closed the output breaker. The NSO manually opened the output breaker when load was approximately 1.5 MW t.nd increasing.
The licensae shut down the O EDG and developed a troubleshooting plan. While completing the troubleshooting plan, the licensee identified that the electronic-governor droop potentiometer, which serves to regulate dieselloading when paralleling to the grid, was set at zero. This setting caused the governor to act as if it was in the isochronous mode, i.e., maintaining a set frequency. As a result, without operator action, the EDG could have been overloaded when paralleled to
' the grid in the isochronous mode.
The licensee determined that the Instrument Maintenance Procedure OS-DG86,
"O DG [ Diesel Generator] Engine RPM [ Revolutions per Minutel Governor Control,"
which satisfied prerequisite B.1.1 of TSSP 008 97, set the droop potentiometer at zero in step 5.15.1. The engineers who wrote the test assumed that the droop potentiometer was set at mid scale in conflict with the prerequisite Step B.1.1.
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Also, several places in TSSP-008 97, the statement, "At the direction of the Test F.ngineer, PERFORM ADJUSTMENTS as necessary to optimize OSC DG86
[govarnor)," existed. However, there was no specific guidance in the test procedure to set the droop potentiomoter at mid-scale.
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Conclaiang The inspectors concluded that due to a lack of guidance in TSSP-008-97 for setting the droop potentiometer, the electronic governor was set incorrectly. As a result, the EDG could have been overloaded when paralleled to the grid in the isochronous mode. As previously documented in NRC Inspection Reports 50-295/96014; 50-304/96014 and 50 295/96017; 50 304/96017, the failure to provide appropriate precedures for maintenance activities continues to be an area of concern. The failure of TSSP-008 97 to provide appropriate guidance for setting the droop potentiometer prior to loading the O EDG is considered an examp!e of a violation of 10 CFR Part 50, Appendix B, Criterion V (50-295/97016-05;
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50-304/97016-05), as described in the attached Notice of Violation.
M7 Quality Assurance in Maintenance Activities l
M7.1 Inadeouate Quality Control (OC) Insoection Durino O EDG Governor Modification
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Installation a.
Insoection Scooe (62707 and 37551)
During post-maintenance testing, the O EDG tripped due to the failure of both #1 and #2 magnetic pickup units (MPUs). The inspectors observed selected portions of the maintenance; interviewed engineering, construction, and OC personnel; and reviewed the applicable maintenance and QC instructions, b.
Observations and Findinos On June 25,1997, during the performance of Technical Staff Surveillance Procedure (TSSP) 008-97, " Diesel Generator 0 Governor Test Fast and Slow Starting Modes Construction Test," Section 26, " Diesel Generator Start with Electronic Governor OSC-DG86 (Local, Fast Start, Droop Control, No Loading)," the O EDG tripped immediately on starting. The initialindication of the cause of the trip
was the failure of both the #1 and #2 MPUs. During troubleshooting, the licensee identified that a loose strand of wire was discovered in the amphenol connector at the governor actuator. The strand caused a ground which degraded the MPU signals and resulted in the trip signal being generated. The licensee subsequently repaired the connection, and initiated PlF Z1997-00455.
The licensee installed this connector in accordance with the work instructions provided in Work Package No. 950069039-01, "O D/G [ Diesel Generator] Governor Outago - Electrical," Step 38, which references several documents including Document #101, " Soldering Procedure for Electrical Components," and Document #50, " Instrument / Control Cable Termination Checklist." However,
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during the installation, the electrician apparently did not notice tnat a strand of the conductor was loose and not properly soldered.
i The inspectors identified that this connection had received a OC inspection which J
was not adequate to identify the loose conductor strand. The inspectors also identified several contributors including: Document #50, " Instrument / Control Cable
- Termination Checklist," the checklist utilized for the QC inspection, did not provide guidance on the verification of solder connections; and Document #101, " Soldering Procedure for Electrical Components," Section 4.0, which contained specific guidance for the OC inspection of solder connections, was not referenced.
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Conclusions
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The inspectors concluded that the QC inspection of the amphenol connector at the governor actuator was not adequate to identify the loose conductor strand, which subsequently resulted in the protective trip of the O EDG during post-maintenance testing.
The failure of the OC inspection to verify conformance with the documented l
instructions for installing the amphenol connector is considered a violation of 10 CFR Part 50, Appendix B, Criterion X (50-295/97016-06; 50-304/97016-06), as described in the attached Notice of Violation.
M8 Miscellaneous Maintenance issues M8.1 (Closed) IFl 50 295/304-95003-05: Foreign material in the 1B SI pump recirculation line orifice. This issue is closed to Unresolved item 50-295/97016-04; 50-304/97016-04 (see Section M1.1).
til. Enoineerina E2 Engineering Support of Facilities and Equipment E2.1 Isolation Valve Seal Water Testina a.
insoection Scone (61726 and 37551)
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The inspectors evaluated the licensee's conduct of the isolation valve seal water (IVSW) system testing. The inspectors observed the testing, reviewed test procedure TSSP 15.6.88, " Isolation Valve Seal Water System Operability Test,"
Revision 18, and interviewed operators and the system engineer.
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Observations and Findinas On June 20,1997, the licensee commenced IVSW testing in accordance with TSSP 15.6.88. Prior to the conduct of the evolution, operators walked
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down the procedure, and the system engineer led a pre-test briefing. The briefing was attended by licensed and non-licensed operators involved in the test, including operations shift supervision. The briefing included a detailed discussion of the purpose of the test, test precautions and limitations, and a review of the test procedure. The inspectors observed that operators actively participated in the briefing which resulted in test performance enhancements. For example, the operators identified that the radwaste operator needed to be contacted prior to test performance to ensure that sufficient tank capacity was available to receive the water that was to be drained during the test. The system engineer evaluated the operator's concems and implemented procedure changes as necessary prior to the test performance.
Once the concerns raised during the pre-evolution briefing were resolved, the licensee commenced performance of the test. Shortly after the test was started, the licensee stopped the test because it found a valve, which was assumed to be
open as an initial condition for TSSP 15.6.88, closed. Specifically, the licensee-
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found the " Tank Emergency Service Water Isolation, Upstream of Regulator,"
21WO174, closed. The licensee stopped the test and initiated a procedure revision, and subsequently completed two-thirds of the test satisfactorily. The licensee then put the test on hold pending completion of reactor coolant pump (RCP) testing.
- Following the completion of RCP testing, the licensee recommenced preparations to complete TSSP 15.6.88. On June 25, during the pre-test walkdown, the system engineer identified that a temporary pressure gauge, which was installed to support TSSP 15.6.88, was over-ranged. The licensee determined that the test gauge (0-100 lb) was damaged during RCP testing when it was exposed to approximately 350 lbs. of reactor coolant system pressure. The licensee replaced the test gauge, and completed the test. However, the licensee also found the secund temporary pressure gauge over-ranged. The licensee initiated PlF Z1997-00609 to document over-ranging of the test gauges. At the.snd of this inspection period, the licensee's investigation was in progress, c.
Conclusions The inspectors concluded that the IVSW system testing pre-brief conducted on June 20, was effective. Contributing significantly to the effectiveness of the briefing was the open dialogue between operators and engineering personnel which resulted in the identification and resolution of potential problems. However, the inspectors were concerned with the adequacy of the pre-evolution walkdown and the licensee's control of system configuration, as reflected in valve 21W-0174 being found out of ds expected TSSP 15.6.88 position. in addition, the over-ranging of the test gauge twice provided further indication that there were potential deficiencies in the licensee's control of plant configuration during testing.
This issue is considered an Unresolved item (50-304/97016-07) pending NRC review of the licensee's investigation of IVSW testing deficiencies including: (1)
the cause and corrective actions associated with valve 21W-0174 being out of the expected position specified by TSSP 15.6.88, including adequacy of pre-evolution
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walkdowns, and (2) the cause and corrective actions for the over ranging of the temporary pressure gauges.
E2.2.Dearaded Material Condition of the Control Room a.
Insnection Scone (71707 and 37551)
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The inspectors identified numerous material condition deficiencies in the control room while inspecting the accessible portions of the control room overhead and areas that were made accessible due to the installation of scaffolding. The inspectors discussed the deficiencies with engineering and maintenance personnel, reviewed the licensee's corrective actions, ar.d reviewed applicable documentation, b.
Observations and Findinas On June 13,1997, during an inspection of the control room overhead while accompanied by licensee engineering personnel, the inspectors identified numerous material condition deficiencies including:
a significant amount of miscellaneous debris located throughout the control
room overhead several missing cable tray covers
numerous improperly secured wireway covers e
cables improperly pla::ed in trays
numerous missing covers on conduit junction boxes
missing covers for openings in the top of the control panels
several dead weight supports disconnected
three exhaust ventilation ducts missing or improperly connected
in response to the walkdown conducted by the inspectors, the licensee performed further walkdowns to determine the scope of the problems and identified similar additional examples. Consequently, the licensee initiated four action requests (each with multiple tasks), three engineering requests, and seven PIFs to resolve the identified deficiencies. On July 17, following completion of the maintenance activities to correct the above deficiencies, the inspectors performed a follow-up inspection of the Unit 2 control room overhead and identified similar additional deficiencies. As a result, the licensee initiated another action request to correct these problems.
In response to the inspectors' concerns, the ventilation system engineer identified an additional 11 exhaust ventilation ducts that had never been installed as specified in the drawing (M-315, " Control Room HVAC [ Heating, Ventilation, anu Air Conditioningl System El. 642'-0") and 3 ducts that were not described in the drawing. As a result, the licensee initiated an engineering request, ER9703730, to determine whether the as-built configuration of the control room ventilation system met the design requirements. The licensee subsequently determined that this issue needed to be resolved prior to restart of Unit 2. This issue is considered an Unresolved item (50-295/97016-08; 50-304/97016-08) pending NRC review of the
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licensee's evaluation of the as-built configuration of the control room ventilation system and its ability to fulfill the required safety functions.
The control room ventilation system was one of twelve systems that the licensee reviewed as part of the system readiness assessments and affirmations conducted in January 1997 to support the Unit 2 restart. This system was also one of the 16 systems reviewed as part of the Zion Recovery Program System Readiness Review conducted in April 1997. The objective of these reviews was to assure that all system deficiencies were identified, documented, and evaluated for their effect on operability. The inspectors were concerned with the effectiveness of these system readiness reviews given the type and number of deficiencies identified by the NRC following the licensee's completion of these reviews. At the end of the inspection period, the licensee was in the process of evaluating the effectiveness of the system affirmations, c.
Conclusions The inspectors concluded that a lack of a questioning attitude and low standards by licensee personnel contributed to the failure of the licensee to identify the degraded material condition of the equipment in the control room. in addition, the system walkdowns to support the control room ventilation system affirmations conducted to support Unit 2 restart did not include all accessible portions of the system and did not include verification that the system was installed as designed.
E8 Miscellaneous Engineering issues E8.1 Non-Conservative Power Ranae Rate Trio Setooint Tolerances On July 15,1997, the licensee identified that the current instrument maintenance (IM) procedure acceptance criteria for the nuclear instrumentation power range rate trip setpoint was not conservative. Specifically, IM procedures N-41 through N-44,
" Power Range Nuclear instrumentation," required that the power range rate trip be calibrated to trip at 5 percent of rated neutron flux in 2 seconds with an allowable tolerance of + 1 percent. Technical Specifications Section 2.1.1.C and Table 3.1-1, required that the trip be set at less than or eaual to 5 percent of rated neutron flux in 2 seconds. Upon identification of this non-conservative calibration of multiple channels of safety system instrumentation, the licensee initiated PlF Z1997-00683 and reported the condition to the NRC in accordance with 10 CFR Part 50.72.
At the end of this inspection period, the licensee's investigation of this problem was in progress. This issue is considered an Unresolved item (50-295/97016-09; 50-304/97016-09) pending the licengee's completion of its investigation of the power range rate trip tolerance discrepancy including (1) the cause of the discrepancy, (2) its safety significance, and (3) the appropriate corrective actions.
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l E8.2 Teflon used in Containment Hatch Seals On July 17,1997; the licensee identified that the seals utilized on containment escape hatch shafts may potentially not be qualified for the postulated maximum post-accident radiation fields. The teflon seats were identified as being susceptible to break down when exposed to a high radiation field which could have resulted in a direct leak path from the containment atmosphere to the environment. The licensee initiated PlF Z1997-00696 to document the potential problem and track corrective actions. The licensee notified the NRC of the problem in accordance with 10 CFR Part 50.72. This issue is considered an Unresolved item (50 295/97016-10; 50 304/97016-10) pending NRC review of licensee actions to resolve the containment escape hatch shaft seal qualification concern.
V. Manantment Meetinas j.
X1 Exit Meeting Summary l
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The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 30,1997. 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
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Partial List of Persons Contacted Licensee R. Starkey, Plant General Manager T. O'Connor, Restart Manager R. Godley, Regulatory Assurance Manager E. Katzman, Radiation Protection Manager T. Kerwin, Work Control / Outage Manager T. Luke, Engineering Manager M. Schimrnel, Unit 2 Maintenance Manager M. Weis, Business Manager C. Winters, Shift Operating Supervisor J. Brandes, Assistant Shift Operating Supervisor K. Dickerson, Executive Assistant to Site V.P.
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l M. Weis, Business Manager W. Stone, Regulatory Assurance
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D. Beutel, Regulatory Assurance F. Jones, Regulatory Assurance NEC G. Grant, Director, Division of Reactor Projects M. Galloway, Acting Chief, Reactor Projects Branch 2 l
A. Vegel, Senior Resident inspector I
E. Cobey, Resident inspector Z. Falevits, Reactor inspector IDNS J. Yesinowski
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I List of insoection Procedures Used l
lP 37551 Engineering IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 71707 Plant Operations List of items Ooened. Closed, and Discussed Ooened 50 304/97016-01 VIO Failure to close the 3L Klene valve on the 2A EDG as required by OSP 97-012 50-295/304-97016-02 URI Review of the root cause investigation for configuration control deficiencies including: (1) the 011 battery ventilation being secured; (2) the isolation of the AFW low suction pressure transmitter; (3) the 1B EDG switches being found out-of-position during an OOS independent verification; and (4) the fire protection valve OFP0760 being out-of-position closed, 50-295/304-97016-03 URI Review of the licensee's actions to resolve the discrepancy between UFSAR assumptions and observed operator response time to a SG tube rupture simulator t
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scenario 50-295/304-97016-04 URI Review of the licensee's evaluation of the 2A Si pump
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head being above the set value range and the debris found during the flush of the 2A Si pump recirculation line strainer
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50-295/304 97016-05 VIO Failure to provide appropriate guidance for setting the droop pt ;.tiometer prior to loading the 0 emergency diesel generator 50-295/304-97016-06 VIO Failure of a quality control inspection to verify conformance with work instructions for the 0 emergency diesel generator governor modification 50-304/97016-07 URI Review of the licensee's investigation of the IVSW testing deficiencies 50-295/304-97016-08 URI Review of the licensee's evaluation of the as-built configuration of the control room ventilation system and its ability to fulfill the required safety functions 50-295/304-97016-09 URI Review of licensee actions to resolve the power range rate trip tolerance discrepancy 50-295/304-97016-10 URI Review of licensee actions to resolve the containment escape hatch shaft seal qualification concern Closed 50-295/304-95003-05 IFi Review the foreign materialin the 1B SI pump recirculation line orifice
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List of Acronyms
--AFW Auxiliary Feedwater
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EDG Emergency Diesel Generator.
' IFl Inspector Follow up Item IM instrume it Maintenance IP inspaction Procedure IVSW lsolation Valve Seal Water MPU-Magnetic Pickup Unit NRC Nuclear Regulatory Commission NSO Nuclear Station Operator OOS Out-of Service ORDP Operational Readiness Demonstration Program OSP Operations Special Procedure PDR Public Document Room PlF Problem identification Form PT Periodic Test OC Quality Control RCP Reactor Coolant Pump-RPT Radiation Protection Technician SG Steam Generator SI Safety injection TSSP Technical Staff Surveillance Procedure UFSAR
- Updated Final Safety Analysis Report URI Unresolved item
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VIO Violation
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