IR 05000295/1985028
| ML20135E965 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/13/1985 |
| From: | Suermann J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135E948 | List: |
| References | |
| TASK-1.A.1.1, TASK-1.A.1.3, TASK-TM 50-295-85-28, 50-304-85-29, NUDOCS 8509170109 | |
| Download: ML20135E965 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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Reports No. 50-295/85028(DRP); 50-304/85029(DRP)
Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, IL Inspection Conducted: August 6 through September 3, 1985 Inspectors:
M. M. Holzmer L. E. Kanter J. N. Kish b
a Approved By:
J. F.
ermann, Acting Chief
<7//3/B S'
Reactor Projects Section 2A Date'
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Inspection Summary Inspection on August 6 through September 3,1985 (Reports No. 50-295/85028(DRP);
50-304/85029(ORP)
Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; Westinghouse review of station surveillance program; diesel driven containment spray and fire pump starting battery quali-fications; Unit 2 blowdown isolation valve actuation; operational safety and Engineered Safety Feature walkdown; surveillance; maintenance; licensee event reports; and TMI item closeout. The inspection involved a total of 288 inspector-hours onsite including 64 inspector-hours onsite during off-shifts.
Results: Of the nine areas inspected, no violations or deviations were identified.
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-1 DETAILS 1.
Persons Contacted
- K. Graesser, Station Manager
- G. Plim1, Superintendent, Production
- T. Rieck, Superintendent, Services
.E. Fuerst, Assistant Station Superintendent, Operations K. Kofron, Assistant Station Superintendent, Maintenance R. Budowle, Unit 1 Operating Engineer J. Gilmore, Unit 2 Operating Engineer
.L. Pruett, Rad Waste Operating Engineer
- W. Kurth, Assistant Superintendent M. Carnahan, Training Supervisor
- R. Cascarano, Technical Staff Supervisor A. Ockert, Assistant Technical Staff Supervisor C. Schultz, Assistant Technical Staff Supervisor R. Aker, Station Health Physicist
- J. Ballard, Quality Control Supervisor D. Kaley, Quality Control Engineer
- W. Stone, Quality Assurance Supervisor D. McHenamin, Quality Assurance Engineer
- M. Rauckhorst, Staff Engineer, Sargent and Lundy
- A. Bless, Staff Engineer, Technical Staff
- A. Amoroso, Electrical Group Leader
- D. Wozniak, Senior Engineer, SNED
- Indicates persons present at exit interview.
2.
Licensee Actions on Previous Inspection Findings (Closed) Open (295/78-23-03;304/78-23-03):
Limitorque motor operated valves (MOVs) were not staked per manufacturer's Limitorque Instruction
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and Maintenance Manual.
The licensee had planned to conduct an inspection program to verify and document the staking of the limitorque operators.
The. program was initiated and an inspection was conducted for Unit 1 in 1978. The inspection for Unit 2 was planned at the time the NRC inspec-tion report was written.
The licensee was unable to produce a record documenting the inspection of Unit 2 limitorque MOVs subsequent to 1978.
Since that time, an inspection program of limitorque MOVs was initiated as part of the Environmental Qualification (EQ) program. This program was performed during the 1984 Unit 2 and 1985 Unit i refueling outages. As a result of these inspections, the licensee disassembled and repaired 35 limitorque MOVs, none of which were found to have improperly staked stem nut locking nuts. The licensee has also included the manufacturer's staking requirements in the EQ and non-EQ valve disassembly and reassembly procedures.
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(Closed) Noncompliance (295/84-12-03;304/84-12-06):
Failure to prepare and utilize written procedures for conduct of maintenance on nuclear instrumentation. This item was correctly closed in NRC Inspection Reports
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No. 295/85-04; 304/85-04 on the basis of NRC's review of procedure IMP-NR-9. The report incorrectly stated that the procedure was in draft form and awaited NRC review. The procedure was in fact issued in final form, reviewed and found acceptable by NRC prior to closeout. This over-sight is considered corrected.
(Closed) Violation (295/84-25-01):
Unit 1 exceeded the axial power distribution monitoring system (APDMS) turn-on power. A discussion was held with the operator to remind him to be more attentive.
Future core loadings will probably not have power fractions less than one due to an increased F limit which resulted from a new LOCA analysis, obviating the g
need to use APDMS or to use the APDMS turn-on power in lieu of licensed power limits.
(Closed) Violation (295/85012-03A):
Failure to implement corrective action. The licensee discussed the importance of properly performing QC hold point inspections and reviewed this event with all QC inspectors.
(Closed) Violation (295/85012-038):
Failure to determine the root cause of an inoperable safety-related snubber. The licensee re-opened the inves-tigation and determined the root cause to be uncontrolled removal of the snubber to permit easier removal of the containment equipment hatch.
The procedure for removal of the equipment hatch has been changed to record and replace any snubbers rendered inoperable during hatch removal.
Furthermore, all department heads were informed of the event and reminded to have their personnel cooperate fully with persons conducting investiga-tions in accordance with the corrective action system.
(Closed) Open Item (304/85008-01):
Revision to ZED 3, ground checking procedure. The procedure was revised on July 25, 1985 to include instruc-tions to contact Operational Analysis Department (OAD) when ground checking activities involved 0AD equipment.
(Closed) Open Item (304/85011-02):
Inoperability of Unit 2 hydrogen purge fans. This item was held open pending a modification to prevent recurrence of simultaneous inoperability of both fans. On March 14, 1985 a change to the Technical Specifications eliminated the need to have the hydrogen purge fans operable. This item is therefore considered closed.
(Closed) Violation (295/85012-01; 304/85013-01): Movement of heavy load over spent fuel pit. The licensee's corrective actions included revising control of the crane interlock bypass key to require Master Mechanic or Fuel Handling Foreman approval prior to bypassing crane interlocks for lifts involving movement of heavy loads over safety related equipment.
The licensee also developed a site specific crane training course which included precautions for movement of loads over safety related equipment.
This training was provided to all crane operators.
Persons supervising such lifts have received training on safe load paths.
No violations or deviations were identified.
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3.
Summary of Operations Unit 1 Unit 1 operated at power levels up to 99% throughout the inspection period.
On August 3, 1985, the unit ramped down to 50 percent power for approxi-mately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> for condensate pump strainer cleaning. On August 27, 1985, the unit ramped down to approximately 60 % power for two days to minimize hot spot problems in the main generator.
No trips or unplanned shutdowns occurred.
Unit 2 Unit 2 operated at power levels up to 55% and continued to coastdown in preparation for the September 5 refueling outage. No trips or unplanned shutdowns occurred.
4.
Review of Surveillance Program by Westinghouse In mid-1984, as a result of NRC concerns at the LaSalle County Station, the licensee independently requested that two contract Westinghouse engineers conduct a review of their Technical Specifications (TS) and surveillance procedures to determine whether all TS surveillance require-ments were covered by plant procedures. Approximately 28 findings were reported to the licensee as discrepancies.
Eleven of these apparent discrepancies were determined by the licensee to be satisfactorily covered by plant procedures with which the reviewers were not familiar. Four additional items were found to require TS revisions because station practice was determined by the licensee to meet the intent although the surveillances were not performed as one test, but piecemeal in several different procedures.
Thirteen other discrepancies involved procedural revisions to ensure that surveillances (especially situational requirements)
were properly covered.
Of that group of thirteen deficiencies, four were reported to the resident inspectors on August 8, 1985 as being potential missed surveillances.
After discussion with the office of Nuclear Reactor Regulation (NRR),
the licensee determined that they had not violated the intent of the TS surveillance requirements and that these items were not reportable pursuant to 10 CFR 50.73. The licensee has nevertheless initiated procedure changes to correct the minor deficiencies identified.
Review of these items for compliance with TS requirements by the resident inspector office is considered an Open Item (295/85028-01:304/85029-01).
No violations or deviations were identified.
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5.
Qualifications of Diesel Driven Containment Spray and Fire pump Cranking Batteries During a tour of the auxiliary building, the resident inspector identified that the diesel driven containment spray pump cranking batteries did not appear to be seismically mounted. The batteries were located in angle iron racks and had gaps of several inches (4" to 6" total) between the ends of the batteries and between the batteries and the racks.
The inspector requested that the licensee perform an evaluation to deter-mine whether the gaps violated the seismic design requirements of the racks.
The licensee also noted to the inspector that the batteries were not purchased to seismic requirements, and that to their knowledge, no diesel cranking batteries were available on the market which were designed to withstand a seismic event. The licensee stated that they would attempt to determine whether the tests to which the batteries were subjected by the manufacturer would satisfy seismic design requirements.
In addition, they would also attempt to determine whether the batteries installed at the station were successfully tested by the manufacturer.
In addition to the foregoing, the inspector asked that these questions be extended to the diesel driven fire pump cranking batteries, since they are identical to those used for the containment spray pump. This is considered an Open Item pending receipt of the appropriate information from the licensee and review of the same by Region III specialists (295/
85028-02; 304/85029-02).
No violations or deviations were identified.
6.
Review of Inadvertent Closure of Unit 2 Blowdown Isolation Valves On May 27, 1985, while performing PT-10, " Safeguard Actuation Test", a NRC red phone call was made concerning an inadvertent closure of the Blowdown Isolation Valves. Both a Deviation Report (DVR), and Work Request (WR)
form were written in regard to this event. However, investigation by the licensee showed an apparent misreading of the procedure by the operator
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which ultimately led to cancellation of the DVR and WR.
This is considered an Unresolved Item pending review by the NRC to determine whether the event should have been reported pursuant to 10 CFR 50.73 (304/85029-03).
No violations or deviations were identified.
7.
Operational Safety Verification and Engineered Safety Features System Walkdown The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from August 6, 1985 through September 3, 1985. During these discussions and observations, the inspectors ascertained that the operators were alert, fully cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and
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turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenance.
The inspectors, by observation and direct interview, verified that the physical security activities were being implemented in accordance with the station security plan.
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the period August 6 to September 3,1985, the inspectors walked down the accessible portions of the auxiliary feedwater, service water, and component cooling systems to verify operability. The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.
These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications,10 CFR and administrative procedures.
No violations or deviations were identified.
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Monthly Surveillance Observation The inspector observed Technical Specifications required surveillance testing on the auxiliary feedwater, diesel generator, reactor protection logic, containment spray, and accident monitoring systems and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for opera-tion were met, that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specifica-tions and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
The inspector also witnessed portions of the following test activities:
PT-7A Starting Procedure for Motor Driven Auxiliary Feedwater Pump Lube Oil Pumps PT-11 Diesel Generator Loading Test for IA Diesel Generator PT-5B Reactor Protection Logic Tests, Reactor Normal PT-6 Containment Spray Tests and Checks PT-2G Accident Monitoring Instrumentation Channel Check Test No violations or deviations were identified.
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9.
Monthly Maintenance Observation Station maintenance activities on safety related systems and components listed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, and in conformance with Technical Specifi-cations.
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The following items were considered during this review:
the limiting j
conditions for operation were met while components or systems were
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removed from service; approvals were obtained prior to initiating the
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work; activities were accomplished using approved procedures and were
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inspected as applicable; functional testing and/or calibrations were
performed prior to returning components or systems to service; quality i
control records were maintained; activities were accomplished by qualified
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personnel; parts and materials used were properly certified; radiological
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controls were implemented; and fire prevention controls were implemented.
Work requests were reviewed to determine status of outstanding jobs and i
to assure that priority is assigned to safety related equipment mainte-nance which may affect system performance.
The following maintenance activities were observed or reviewed:
Reactor Coolant Pump No.1 Seal Runner Maintenance j
IC Service Water Pump Maintenance
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No violations or deviations were identified, i
10.
Licensee Event Reports (LER) Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had
been accomplished in accordance with Technical Specifications. The LERs l
listed below are considered closed:
UNIT 1
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LER NO.
DESCRIPTION
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85-26 Missed Surveillance of Containment Isolation Valves UNIT 2
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LER NO.
DESCRIPTION 85-12 Closure of Unit 2 Purge Valves From a High Radiation i
Signal
85-13 Automatic Closure of Containment Isolation Valves
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o Concerning LER 295/85-26, this item is considered a licensee identified violation for which no citation will be given (295/85028-05).
The licen-see intends to perform a modification to restore penetration pressuriza-tion air to the affected valves. A review of the licensee's modification program revealed that current procedures are adequate. This is considered an Open Item pending a review of the licensee's long term corrective actions (295/85028-03).
With regard to LER 304/85-12, " Closure of Unit 2 Purge Valves From a High Radiation Signal," this is considered an Open Item pending licensee imple-mentation of corrective action (304/85029-04).
With regard to LER 304/85-13, " Automatic Closure of Blowdown Containment Isolation Valves," the LER will be closed, however an Open Item will be issued pending licensee submittal of a revised LER. (304/85029-05).
One violation (not cited, as described above) and no deviations were identified.
11. TMI Item Closecut I.A.1.3 Shift Manning - Overtime Limits Inspection Reports 295/81-09 and 304/81-05 noted three variances between NRC guidelines and Ceco policies and procedures:
(1) CECO guidelines only apply to NRC licensed individuals on shift work who have the control room as their duty station.
(2) The existing union collective bargaining agreement conflicts with the NRC overtime limits.
(3) The station disagrees with the guidelines requiring a break of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> between work periods.
The inspector reviewed ZAP 10-52-3, " Shift Manning Relief and Turnover,"
and noted that the overtime requirements contained therein apply to all operating personnel. With respect to the second item, the union contract still contains no prohibitions on overtime in excess of the NRC guide-lines; however, ZAP 10-52-3 does contain overtime restrictions which are in agreement with NRC guidelines.
The union contract applies to all CECO employees (not just operating personnel at nuclear stations). With respect to the third item. ZAP 10-52-3 requires a break of at least eight hours between work periods, which is consistent with Generic Letter 82-08 that revised the break time between work periods from 12 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This item is considered closed.
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I.A.1.1.3.b STA Training The licensee's program for Shift Technical Advisors (STAS) was reviewed and approved by the NRC as documented in a letter from S. A. Varga to L. O. De1 George dated January 11, 1982.
The licensee's program calls for the STA function to be met by the use of a degreed, STA trained, SRO qualified position in the line function of the shift, called Shift Control Room Engineer (SCRE).
In addition, other individuals would also be trained and qualified to function as STAS but would not hold licenses, and these individuals do not routinely fulfill the STA function. NRC also approved the licensee's plans for training STA/SCREs.
Training records for selected STA/SCRE individuals were reviewed by the inspector to determine whether. the licensee's commitments for SCRE training were met.
In general, all individuals appeared qualified to meet the STA/SCRE requirements; however, the licensee had difficulty producing objective evidence to show successful completion of a few portions of the training, or waivers where the individuals were otherwise trained or qualified. The licensee agreed to perform a review to upgrade the STA/SCRE training records to provide objective evidence of training received or waived for all portions of STA/SCRE training. This is con-sidered an Open Item pending NRC review of the upgraded training records (295/85028-04; 304/85029-06).
No violations or deviations were identified.
12. Open Items Open Items are matters which have been discussed with the licensee which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or both.
Six Open Items disclosed during this inspection are discussed in Paragraphs 4, 5,10, and 11.
13. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or devia-tions. One Unresolved Item disclosed during this inspection is discussed
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in Paragraph 6.
14. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
throughout the inspection period and at the conclusion of the inspection on September 3, 1985 to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely informational content of the inspec-tion report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
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