ML20040A082
| ML20040A082 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, Zion  |
| Issue date: | 11/17/1981 |
| From: | Hayes D, Kohler J, Waters J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20040A078 | List: |
| References | |
| 50-295-81-23, NUDOCS 8201200316 | |
| Download: ML20040A082 (6) | |
See also: IR 05000295/1981023
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Report No.:
50-295/81-23, 50-304/81-19
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Docket No.:
50-295, 50-304
License No.:
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Licensee:
Commonwealth Edison Company
P. O. Box 767
Chicago, IL 60690
Facility Name:
Zion Nuclear Power Station, Units 1 & 2
Inspection at:
Zion, IL
Inspection Conducted:
August 1-October 30, 1981
1
J.E. Kohler
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Inspector (s):
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Approved By:
D. hayes, Citief Re/ tor Projects
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Section IB
Inspection Summary
Inspection on August 1-October 30, 1981 (Reports No. 5.0-295/81-23, 50-304/81-19).
Areas Inspected: Special announced inspection of possible enforcement items
identified in Performance Appraisal Inspection Report 50-295/81-04. The inspec-
tion involved 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> onsite by two NRC inspectors with no hours on the back
shift.
Results: Of the areas inspected, one item of noncompliance was identified
(using uncalibrated torque wrench multipliers in a safety related application).
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1.
Persons Contacted
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- K
Graesser, Station Superintendent
E. Fuerst, Assistant Station Superintendent-Operations
- G. Plim1, Assistant Station Superintendent-Administrative
and Support Services
K. Kofron, Assistant Superintendent for Maintenance
- B. Harl, Quality Assurance Engineer
P. LeBlond, Assistant Technical Staff Supervisor
T. Lukens, Quality Control Supervisor
- M. Krysiak, Quality Control Engineer
- Denotes those present at exit meeting.
2.
Follow-up Review of PAS Enforcement Items
During the inspection interval, the Resident Inspector's Office reviewed
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the possible items of enforcement described in NRC Performance Appraisal
System Inspection Report 50-295/81-04 dated August 11, 1981. As a result
of this review an item of noncompliance against NRC commitments was identified.
This is described in the Appendix (Notice of Violation).
The following is a
restatement of the item that was determined to be enforceable. Procedures
or facilities determined by the licensee to be necessary to fulfill regulatory
commitments tut not as yet in place are identified as open items:
Failure to Have a Procedure for Calibration of Torque Wrench Multipliers as
Required by 10CFR50 Appendix B
The inspector conducted a follow-up inspection of noncalibrated torque wrench
multipliers to determine if the licensee had failed to comply with requirements
of 10CFR50 Appendix B, Criterion XII. The licensee routinely adds 10% to all
specified torque wrench multiplier values to compensate for drift, although
there was no procedure to document this activity. The licensee took the
position that torque wrench multipliers do not fall under Section XII,
10CFR50 Appendix B, Control of Test and Measurement Equipment, since a torque
multiplier is not a test and measurement device.
PAS inspectors determined that torque wrench multipliers onsite were used
as tools during implementation of modification required by IEB-79-0 2.
Checks
of torque wrench multipliers onsite provided an approximate 12% lower torque
than required.
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The NRC has taken the position at other sites that a torque wrench multiplier
used in safety related applications is a test and measurement device and
does fall under the requirements of 10CFR50 Appendix B, Section XII.
Therefore,
this item is classified an item of noncompliance and is designated open item
50-295/81-23-01; 50-304/81-19-01.
In a response to this item of noncompliance please provide your assessment
of the effect of using an uncalibrated torque wrench multiplier on work
performed under IEB 79-02.
We are mainly concerned with your assessment
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of any possible under torque conditions and the effects on installed base
plates taking into account that the base plates may be overdesigned.
Also, it is to be noted that torque wrench multipliers need not be placed
in a regular calibration program with calibrations performed at a given
frequency.
The only control required is that they be calibrated prior to
use in a safety related application.
3.
Follow-up Review of PAS Items Which are Not Enforceable
Several of the items identified by PAS were not enforceable.
items is described below:
Each of these
Failure to Follow Zion Station Administrative Procedurc 3-51-4 for
a.
Jumper and Lifted Lead Log
The inspector conducted a follow-up inspection in order to determine
whether the licensee had violated ZAP 3-51-4.
After discussion with
the licensee about the intent of the procedure, it was determined that
it was acceptable for the Shift Engineer (S.E.) to sign for the Shift
Foreman (S.F.) since the S.F.'s portion could be done by eitter S.F.
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or S.E. depending on availability.
The intent of the procedure, as reviewed by PAS, was not to provide
double verification, but to free the S.E. from performing certain
administrative and clerical functions.
The S.E. still maintained the
responsibility for overall authorization for the temporary jumper or
lifted lead.
Subsequent to the PAS finding, the licensee issued a standing order to
provide for independent verifications of jumper and lif ted leads.
No items of noncompliance were identified.
b.
Failure to Comply with ANSI 45.2.2
Section 6.3.3. Regarding Storage
of Hazardous Materials
The inspector conducted a follow-up inspection to determine whether the
licensee had failed to comply with the commitments of ANSI 45.2.2
6Property "ANSI code" (as page type) with input value "ANSI 45.2.2</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3.3. as well as Regulatory Guide 1.38.
Section
It was determined that the
licensee made the following changes based on PAS concern:
(1)
Penetrant materials noted by PAS were moved to a fire retardant
cabinet.
(2)
Weld ends were protected by placing cardboard interlacing between
them and the shelving of the next layer.
(3)
ZAP 13-52-1 was revised to state no smoking was permitted in the
storage area.
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(4) The storage area for station batteries is planned to be moved to
a new facility pending authorization of construction funds.
In reviewing the significance of the items identified by PAS, review of
the referenced documents, as well as discussions with the licensee,
the inspector concluded that they were collectively insignificant.
The findings did not represent a threat to any important nuclear plant
items, (as referenced in Regislatory Guide 1.38), since these findings
were made In a storage area some distance from the Zion Nuclear Station.
The inspector also based his decision on several other factors as iden-
tified by the licensee:
(1) The storage area is the permanent location of several employees
so eating and smoking would be understandable.
(2) Any damage to threaded fittings or weld end preparations because
of lack of caps would be detected by QA or QC upon selection of
that material for use.
(3) Regulatory Guide 1.38 states that the requirements of ANSI 45.2.2-1972
pertains to the construction phase of light water reactors, but
is to be applied to the operations phase where applicable. The
inspector considers the PAS findings to be more applicable to a
plant under construction rather than an operating plant such as
Zion.
In view of the above, the inspector judges none of the items noted by
PAS as discrepant (in Section 9. Procurement PAS Report 295/81-04) to
be enforceable.
No items of noncompliance were identified.
c.
Failure to Store Single Copy Active Records in NFPA Class A Four Hour
Minimum Rated Facility
The inspector conducted a follow-up inspection in order to determine
whether the licensee had deviated from his commitment to ANSI N45.2-1974,
Section 5.6.
The requirement is to provide a fire secure area for quality
records. However, the PAS inspection discovered single copy technical staff
files in nonfire secure files.
The licensee has taken the position that the technical staff files do
not constitute quality records as defined by the standard since:
Files in question are not of significant value to safe
operation and other documentation exists in log books to
demonstrate that current tests were performed. Past testing
is routinely sent to central files and put on microfilm. The
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microfilm is stored in a fire secure area.
However, in consideration of the PAS comments, the licensee has issued
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an administrative procedure directing all technical staff engineers to
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have their single copy active files duplicated on microfilm as
often as every six months. With expedited microfilming, the
station does not consider the possible loss of any technical
staff files to significantly affect any aspect of plant performance.
The inspector found no items of noncompliance.
d.
Failure to Have ZIAP 5-51-12 Approved by Onsite Review
The inspector conducted a follow-up inspection in order to determine
whether the referenced procedure had received a review consistant
with established plant procedures for review and approval by the onsite
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review committee.
It was determined that the referenced procedure
received an onsite review after the PAS inspection noted that no onsite
review had been performed.
The inspector determined that the lack of an onsite review was an
oversight which had very little regulatory significance since almost
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all activities referenced in ZIAP are backed up by written approved
procedures. The few specific activities references that do not have
written procedures as a back-up have been determined by Zion Station
to be within craft capability and require no written procedures.
The inspector also determined that the past review of the referenced
ZIAP resulted in no changes to the document or any station activities.
In view of the large number of procedures reviewed by PAS, the inspector
concludes that one discrepant procedure lacking timely signatures by
the appropriate reviewing body constitutes a positive finding indicating ^
a licensee strength in carrying out station activities according to
approved procedures.
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No items of noncompliance were identified.
ZAP 6-52-2 Specified the Maximum Retention Period for Lifetime Records
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to One Year
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PAS found that some technical staff active files reviewed contained
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records from 1979. This was thought to be in violation of ZAP 6-52-2
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which specifies a maximum retention period of one year.
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The inspector reviewed ZAP 6-52-2 and determined that the PAS ins'pector
misinterpreted its requirements. ZAP 6-52-2 requires that the length
of time a file remains active is determined by the office of record.
In most cases, this is normally at least one year. However, the ZAP
is being revised to include more frequent microfilming of single copy
active records in response to a PAS concern raised in section 3.C of
this report.
f.
ZAP 3-51-4 Did Not Address Independent Verificat_ ion Requirements for
the Use of Bypass Lines
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PAS references ANSI N18.7-1971 Section 5.2.6 as requiring independent
verification of temporary modifications such as bypass lines. The
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inspector determined that ANSI N18.7-1972 does not contain this
requirement; ANSI N18.7-1976 contains the requirement, however,
the licensee is not committed to the 1976 edition of ANSI N18.7.
In consideration of the PAS comments, the licensee has revised
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ZAP 3-51-4 to include independent verification requirements for
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bypass lines. Also, the licensee performs an independent veri-
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fication program that is in full compliance with all Three Mile
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Island Lessons Learned requirements.
h.
Lack of a Corrective Action Procedure for Significant Recurring
Deficiencies in the Design Process
The inspector conducted a followup inspection b3 reviewing rele-
vant portions of the QA manual. From this review it was deter-
mined that there is adequate written guidance to satisfy the PAS
concern.
Sections of the QA manual reviewed were Q.R.16.0,
Q.P.16.1.
4.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph
1) at the conclusion of the inspection on October 30, 1981 and summarized
the scope and findings of the inspection activities.
The licensee acknowledged the inspector's comments.
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