ML20125C684
| ML20125C684 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/03/1992 |
| From: | Burgess B, Gleaves W, Lerch R, Salehi K, Shembarger K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20125C660 | List: |
| References | |
| 50-295-92-23, 50-304-92-23, NUDOCS 9212140035 | |
| Download: ML20125C684 (13) | |
See also: IR 05000295/1992023
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U.S. NUCLEAR REGULATORY COMMISSION'
REGION III
Reports No. 50-295/92023(DRS); NO. 50-304 / 92023 (DRS)
Docket Hos. 50-295; 50-304
Licensees Commonwealth Edison Company
Opus West III
1400 Opus Place - Suite 300-
Downers Grove, IL
60515
Facility Namet
Zion Nuclear Generating Station, Units 1 and 2
Inspection Att
Zion, Illinois
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Inspection conducted:
October 5 - 29, 1992
Inspectors:
R? }$, ///%*tW
_ / 2 - / - 12
R. H. Lerch
Date
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8,A1. baw
r.rt?,
t-t
1 - 9 1
K. Shembarger
Date
_
f.' A b x<yt rint
t: -2-12
K.
Salehi
Date
f.' Af, fc/?e g
s?rr
r*-2~92
W. Gleaves
Date
/5 s 0
-Approved By:
t'[bN-[.Ilua; ~ ._
/J /?/72.
B. L. Burgess,/ Chief
Date
Operational Programs Section
Insoection Summary-
Inspection conducted from October 6 - 29, 1992 (Recorts
No. 50-293/92023fDRSir No. 50-304/92023(DRS))
Ar.p_gg Insoected:
Announced, routine, safety inspection of
modifications and design changes (MC 37700) including engineering
and technical support.
Resulta
Engineering performance was-good.
The__ review of
modification packages found them to be thorough and correct.
-Management actions to increase engineering involvement in the-
site was a strength.- A licensee initiative, the Integrated
Reporting Program included.a look for engineering performance
9212140035 921204
ADOCK 05000295
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trends.
Some areas of weakness were noted including the
temporary alteration program and post-maintenance testing.
A violation was written for an inadequate 20 CFR 50.59 safety
evaluation of a temporary alteration (paragraph 3.2).
A violation was written for lack of a post-maintenance test
(paragraph 3.4.a).
Other findings were a lack of trending of
component performance data (paragraph 4.1), failed safety rollef
valve tests not reported (unresolved item - paragraph 3.4.b),-and
inadequate procedural guidance for performing materials
engineering technical evaluations and alternate replacement parts
evaluatione (open item - paragraph 3.3).
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REPORT DETAILS
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1.
Commonwealth Edison Comoany
+R.
Tuetken, General Manager
+T. Joyce, Station Manager
+K.
Ainger, Site Engineering Supervisor
+S. Bakhtiari, Design Engineering Supervisor, Mechanical
+G. Beale, OPEN Administrator
+R. Chrzanowski, Technical Staff Supervisor
+T.
Cromeans, Technical Staff Engineer
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+K.
Dickerson, NRC Coordinator
+P.
Donavin, Nuclear Engineering Supervisor,
Mechanical / Structural
+C.
Grasser, Quality Verification Staff
+D.
Plauck, Technical Staff Engineer
+G.
Ponce, Quality Control Staff
+B.
Scharping, Technical Staff Engineer
+S.
Stimac, Nuclear Licensing Administrator
+W.
Stono, Performance Improvement Director
+D. Wozniak, Technical Superintendent
U.S. Nuclear Reculatory Commission
+B.
Burgess, Chief, operational Programs Section
+J.
D. Smith, Senior Resident Inspector
+ Denotes those present at the exit meeting on
October 22, 1992.
Other persons were contacted as a matter of course during
the inspection.
2.
Licensee Action on Previous InsDection Findinas
2.1
(Closed) Unresolved Item 295/90030-23:
Inadequate
engineering evaluations of modifications.
The Diagnostic
Evaluation Team (DET) questioned the validity of engineering
evaluations performed for modifications after 1989.
There
were-two modifications needing additional review of the
design _ change process.
One-case was related to wrong
orifice plates being installed in the 2B emergency diesel
generator-(EDG) lube oil and jacket water cooler.
The other
was related to a maintenance valve installed in the reactor
containment fan cooling (RCFC) isolation return header,
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The EDG cooler orifice was a fabrication error which was
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detected and corrected by the licenseo prior to installation
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and was not a design error.
The RCFC maintenance valve
was installed prior to 1989 and therefore was outside the
time period in question.
A review of the modification
package and station procedures showed that the DET concern
for a single failure Nas evaluated and appropriate
administrative contrc s were in place.
Thlu item was
closed.
2.2
focen) Violg$lon 295/91014-01
Inadequate technical input
for procurement specifications of modifications.
The
response and corrective actions to this violation were
reviewed.
Part of the licensee's response to this violation
referenced their Eng?7ecring Assurance program Assessment.
This program was self-initiated and examined the licensee's
overall procurement process with special emphasis on
technical input into procurement documents.
The Engineering
Assurance Program Assessment report, number EA-91-04,
documented six deficiencies regarding the inadequacy of
providing and reviewing technical input in the procurement
process including generation of procurement specifications.
This report specifically requested that designated design
superintendents develop procedures (QE-83 and QE-51H) to
minimize these six deficiencies.
The inspectors review of the generated procedures, QE-83
(approved in 1991) arid QE-51H (currently in the approval
process), showed that the procedures did not address the six
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deficiencies.
The author of the QE-83 procedure, the main
procedure to address these concerns, had not been aware of
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the EA-91-04 report, and therefore did not specifically
address the six deficiencies.
The inspectors discussed
these concerns with the licensee staff and they stated that
they would review and modify those precedures as appropriate
for the response to the EA-91-04 findings.
This item
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remained open.
3.
The Ouality of the Enaineerina A9tivities
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The quality of E&TS management and staff activities was good
with some weaknesses.
Modification packages, and
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evaluations of deviations were typically thorough and
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correct.
Weaknesses were found with temporary alterations,
a lack of evaluation of component performance data, and
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replacement parts evaluations.
This was based on
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inspector's reviews, observations, and interviews regarding
routine and reactive engineering functions.
Areas reviewed
included modifications, temporary alterations, system
engineer activities, deficiency reports, licensee event
reports, and others.
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3.1
110A1f.1.qit1Rn Packngan
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Modification packages and design engineering performance
were good.
Twelve modification packages weto reviewed for
such items as design assumptions, supporting calculations,
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safety evaluations, post-modification testing, and
unroviewed safety questions.
No significant concerns were
identified with the modification packages reviewed.
a.
The inspectors examined the licensee's modification
package, M-22-2-30-555A/B, replacing Grinnel hydraulic
anubbers with Lisega snuhtars.
The inspectors
ovaluated the licensee's snubber reduction program
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developed and coordinated by the Mechanical and
Structural Support (M&S) organization in the corporate
Nuclear Engineering Department.
The review identified
a thorough and active involvement by the licensee's M&S
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organization in the snubber reduction program including
performance of the design analysis for two systems.
The inspectors found the extent and quality of the
licensne's effort in this activity to be excellent,
b.
The inspectors identified a concern with modification
M22-2-80-47.
This modification replaced the starting
air compressors for the emergency diesel generators.
The concern was that local humidity levels were not
clearly specified as part of the environmental
considerations in the procurement specifications.
This
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omission contributed to the vendor delivering
equipment, that during operation, allowed moisture to
condense in the compressor and drain into the crankcase
oil.
Tainted oil E-1s observed by the licenseo
maintenance personnel who took immediate action to
determine the cause of the contamination and to replace
the oil.
Licensee technical personnel, with the
support of the vendor,. analyzed the problem, took
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appropriate interim measures, and planned for long term
fixes.
Water in the compressor oil did not have an
immediate impact on its operability.
The lack of humidity requirements in the procurement
specification was an example of an inadequate
specification for which violation 295/91014-01 Vas
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previously 1scued (See paragraph 2.2).
Since
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corrective actions for the violation were not fully
implemented to prevent this reoccurrence, a violation
is not being issued.
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c.
Tne modifications examined in this inspection were as
follows:
M22-2-87-02C, Increase Steam Generator Blowdown
capacity
M22-1-88-47C, Replace Diesel Generator Starting
Air Compressor
M22-2-89-029, Replacing Fuel Transfer Switches
M22-1-90-09, Replace SI 9012 Cneck Valve with
Different Valve
M22-2-90-555A and B,
Hydraulic Snubbers
Replacement
M22-1-90-557, Replacing Valve Trim of PCV VC131
M22-90-559, Cable Tray Siderails Support
Enhancement
M22-0-90-568C, Heat Exchanger Vent and Drains
P22-1-91-09A, RC Containment Isolation
M22-1-91-00VB and C,
Containment Isolation Valves
for ILRT
M22-1-91-576 A,
B, or C, MOV Repairs per Generic Letter 89-10
M22-1-92-508, Replacing the MCC Cubicle for PP Air
Compressor
No violations or deviations were identified in this area.
3.2
Temporary Alterations (TA)
The inspectors found the temporary alteration (TA) program
adequate with several weak areas.
Although training in the
completion of safety evaluations was increased in 1991, the
safety and technical evaluations from 1991 and 1992 were of
inconsistent quality with varying degrees of detail.
Individual TAs were installed that were minor design
modifications and were not given the more detailed review of
the modification process.
The age of many TAs and the total
number of active TAs exceeded the goals of the TA program.
Although the TA program was well defined by procedure and
trended by the monthly report, the licensee did not make
progress towards achieving the TA program goals,
a.
The inspectors reviewed the temporary alteration
program as outlined in Zion Administrative Procedure
(ZAP) 3-51-4 dated November 14, 1991, titled " Temporary
Alteration Program".
The inspectors also reviewed the
September 1992 monthly TA status report, ZAP 2-54-5,
Rev.
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dated Auguot 20, 1992 titled " Safety Review and
Approval", and 14 TAs dated from February 1989 to
July 1992.
Individual TAs were reviewed for their
adherence to programmatic and regulatory requirements.
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b.
The inspectors reviewed TA 90-053 " CIT Outlet Valve
Leakage Reroute To RCDT" dated June 9,
1990, that had a
possible unreviewed safety question.
The TA instalied
a lesh off line to route wator leaking past valves
2MOV-SI-8801A(B) to the reactor coolant drain tank
rather that thermally cycling the cold leg injection
The rafety evaluation acknowledged a
potential for water hammer, however, it failed to
evaluate a failure of the relief valve on the leak-orf
line draining a portion of the high head injection
(HHI) lines.
The temporary leak-off drain was in a low
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point in the system and an approximate 0.11
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gallons / hour was leaking through the relief valve body.
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A portion of the HHI line could drain between the
monthly PT-20 stJoke test of the MOV-8801 valves which
might have resulted in a water hammer affecting all
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four injection lines.
The inadequacy of t: 1 safety
evaluation was a violation of the requirements of 10 CFR 50.59 (295/92G23-01(DRS)),
An engineering
evaluation performed by the licensee on or about
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October 21, 1992, determined that an unreviewed sefety
question did not exist.
3ased on pipe temperatures,
the licensee concluded that the relief valve Icakage
came from the MOV-8801 valves.
That leakage was judged
sufficient to keep the injection lines full.
c.
Fourteen TAs reviewed were:
(1)88-119
Unit "0V & PV Systen Felief Dampers"
(2)89-005
Unit 1 "1C FWP Recirc Valve 1 FCV-FW20"
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(3)89-074
Unit 2 "2A Aux FW Pump Lube Oil Cooling
Line"
(4)90-053
Unit 2 " Bit Outlet Valve Leakage Reroute
to Root"
(5)90-056
Unit 2 "2A charging Pump Shaft
Mcnitoring"
(6)91-059
Unit 0 " Alternate Make-up System"
(7)92-001
Unit 1 "4KV Bus Voltage Less than 2990"
(8)92-007
Unit 1 " Install Blower with New Oil
Sight Glass"
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(9)
92-0016
Unit 0 " Door Alarm for Laundry Trailer"
(10)92-065
Unit 0 " Replace Aux. Bldg. Sump Pump OC"
(11) 92-0071
Unit 2 " Jumper Out Aircraft Crash Damper
Contacts for 2B D/G
(12)92-072
Unit 1 " Disable HX Cooling Water Low
Pressure Trip for Reactor Coolant Sample
Shut Off Valves in #1 Rad Sample System"
(13) 92-0073
Unit 2 "2B RCP Standpipe Low Level Alarm
Lead Lift"
(14)92-076
Unit 1 " Lift Incore Thermocouple R-05
Leads in 1CB116"
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As stated in paragraph 3.2.b,
one violation was identified
in this area.
3.3
Parts Assessmenig
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A brief review of parts evaluations and the parts evaluation
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process was performed.
Although an overall assessment of
the parts evaluation program was not made, the following two
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concerns were identified:
a.
The review and approval process for downgrading parts
from safety-related to nonsafety-related did not
require review from licensed operations personnel or
system engineers.
Without including the system experts
and individuals with an operations background in the
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parts classification process, the adequacy of the
review to determine the safety function (s) of the
part's parent component within a system may be lacking.
b.
The inspectors' identified that the lack of a
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definition for the terms interface, interchangeability,
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safety, fit, form, and function introduced
inconsistencies in their use.
This was evident in
technical evaluation Z-90-06-1243-00 for a valve in the
diesel generator system.
The technical evaluation
indicated that the part fit, form, or function had not
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changed when w stiffer spring was being used in the
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valve supplied by the vendor.
Initial discussions with
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several pacts evaluators revealed that changing the
spring stiffness was not considered a change to the
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form or fit of the spring.
However, further discussion
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with the evaluators on the definition of the terms
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revealed that eithar the form or fit, or both must have
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been changed.
The adequacy of procedural guidance for
performing material engineering technical evaluations
and alternate replacement parts evaluations is
considered an open item. (295/304/92023-02(DRS))
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One open item was identified in this area.
3.4
Correctino De(igiencies and Adverse Trends
In general, the corrective action of engineering
deficiencieu and adverse trends was good.
Weakness was
identified in that root causes determinations, and
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coordination between system engineers and specialty groups
within the technical staff were not always adequate.
The
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inspectors reviewed numerous Deviation Reports (DVR),
Discrepancy Records (DR) and Problem Identification Forms
(PIF) to evaluate the level and quality of engineering
involvement in correcting drficiencies.
Based on the
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review, several concerns were identified.
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a.
DVR 22-1-91-142 was written as a result of an interlock
failure identified on December 28, 1991, during the
performance of PT-2C-D-ST, "ECCS Valve Stroke and
Interlock Test (Heatup)".
Valve 1MOV-SI8804A
(discharge valve from RHR pumps to charging pumps)
failed to open with 1MOV-RH8701 (suction valve from RCS
to RHR pumps) closed.
The DVR evaluation concluded
that inadequate maintenance on 1MOV-RH8701 was the root
cause.
Electricians failed to recognize the
requirement to adjust the rotor with the interlock
contacts.
The inspectors identified that an additional
contributor was inadequate testing following
maintenance performed on 1MOV-RH8701 in March, 1991.
Specifically, PT-2C-D-ST was not performed as part of
the post-maintenance testing.
The failure to perform
adequate post-maintenance testing is a violation of
Criterion XI-
(295/92023-03(DRS)).
The inspector identified three
additional factors which contributed to the
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significance of this violation.
First, the DVR
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evaluation failed to identify inadequate post-
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maintenance testing as leading to the failure.
Second,
review of subsequent maintenance performed on the RHR
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pump suction valves revealed that in July, 1992, limit
switch maintenance was once again performed on one of
the valves without the requirement for the interlock
test.
Finally, with the interlock inoperable, the ECCS
was degraded for nine months in its ability to be lined
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up for cold leg recirculation.
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b.
DVR 22-1-92-039 and DR 92-0045D were generated when two
of three pressurizer safety valves set pressures were
outside the Technical Specifications allowable band.
The DVR evaluation indicated that a root cause analysis
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of the valve failures could not be performed since the
technical staff was not notified of the failure until
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after the valves received maintenance.
The corrective
action established to ensure a root cause analysis
could be performed in the future was to add a step in
the valve testing procedure to notify the technical
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staff if problems were encountered during testing.
Since a step already existed to notify the inservice
inspection (ISI) group within the technical staff, the
corrective action tracking item was closed out without
action.
During review of the event, the inspector
determined that the ISI group was properly notified,
but fie information was only documented in a log and
was r et analyzed, trended, or communicated to the
prima , systems group within the technical staff.
As
a result, the inspector concluded that the corrective
actions taken to prevent recurrence were inadequate.
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The inspectors questioned whether this event was
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reportable to1the NRC.
The two relief valves-lifted
during testing more:than 5% below the specified set.
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point.
This was at or close to the set point-for the
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power-operated relief valves with a potential for'
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simultaneous _ lifting.
A revi'ew of the reporting
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guidance provided in NUREG 1022, Rev 1, was not-
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conclusive as to the reportability of relief valves.
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found out of. tolerance when a plant is shut down.
This
matter was reviewed with the licensee staff who
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acknowledged that their reportability guidelines did
not address relief valves being significantly out of
tolerance.
This concern is an unresolved item under-
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review by the NRC (295/92023-04(DRS)).
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c.
PIF 304-554-91-CAT 4-150 was generated when the 2B SI-
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pump suction valve failed to stroke open on October-31,
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1991, during performance test FT-2A, " Safety Injection
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system Tests".
During trouble shooting,
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3 strip charts indicated abnormally high current during
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valve closure, before the torque switch contacts
opened.
The 1991 PIF evaluation noted that a strip
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chart from July, 1990 also showed an abnormally high
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rise in current prior to torque switch-trip, but failed
to recognize this as unacceptable.- Rather, it-
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characterized the chart as a trend.
The procedure for
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evaluating strip charts was re"iewed.and found to lack
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detailed guidance.
Procedural guidance:and train 4.ng-
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relating to MOV strip charts is considered an open-
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item. (304/92023-05(DRS))
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One violation, one unresolved. item, and one oran item were
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identified in this area.
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4.
Extent of Encinegrina Involvement
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Through interviews with operations, maintenance, design
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engineering,;and technical staff personnel, and review of
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various technical staff. engineering positions, the-
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inspectors concluded that, overall, the extent of
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engineering involvement in support of the station was good.
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Technical Staff
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Involvement by the technical staff was good with respect to
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knowledge.of assigned systems, system walkdowns and daily
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-plant status.
However, the following weaknesses were
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identified:
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a.
Component trending performed by the-technical staff was
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minimal.
Although component. failures were logged, in
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the= cases of the out-of-tolerance rellaf valves and
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the Mov motor currents, an analysis of information was
not performed that could have been used to improve
component reliability.
b.
System engineer involvement in' correcting deficiencies
for components within their system was lacking when
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specialty groups (such as the MOV and ISI groups)
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within the technical staff were ultimately responsible
for the review.
As a result, system engineers were-not
always aware of component problems within their system,
c.
Improvement was noted by operations and maintenance
personnel in the system engineers' understanding of
system-related procedures.
Interviews indicated,
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however that lack of comprehensive system knowledge
places some system engineers at a disadvantage when
dealing with operations and maintenance.
4.2
Site Engineering
Site engineering was established on site in 1992 with
technical staff engineers and design engineers relocated
from the corporate office in Downers Grove, Illinois.
Interviews with site design engineers indicated that the
engineers were finding the proximity to the site and other
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station engineering groups beneficial for resolving issues.
4.3
Encineerino Manacement
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Jngineering management involvement was evident.
Significant
changes had been made to improve engineering functions,
however, two areas inspected were weak.
The initiatives and
weaknesses are discussed below.
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a.
The reorganization of the engineering groups included
relocating personnel to the site and establishing a
site engineering organization.
It also separated
responsibilities for most modifications from the
technical staff and gave them to specific engineering
groups.
b.
Management had increased its expectation that engineers
review the products of engineering contractors.
The
design engineering staff members interviewed were aware
of this expectation and were performing these reviews.
As a result, substantive comments were being
transmitted to the contractors.
This is significant
and positive since the licensee is transferring its
primary engineering services contract from Sargent
and Lundy to ABB Impell.
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c.
The temporary alteration (TA) program had several
indicators of weak performance.
As discussed in
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paragraph 3.2,
the station was not meeting its goals
for either the total number of TAs (approximately 60
were active) or age (17 were over 2 years old).
The
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safety and technical reviews were not always rigorous
enough to support the potential impact an alteration
might have.
Also, periodic reviews of TAs appeared to
provide little or no enhancement of TA safety or
reliability.
This area was discussed with the licensee
managers who stated that specific plans would be
developed for the elimination of each TA and that the
evaluation and review programs for TAs would also be
examined.
The licensee is also developing a procedure
for " exempt modifications" which will provide a more
efficient process for minor modifications.
This may
alleviate the motivation to use TAs for design changes.
d.
The licensee formed a performance monitoring group in
the technical staff.
This group will correlate
equipment performance data from all station departments
and issue periodic reports on trends.
This group will
also be responsible for implementing trending to meet
the maintenance rule which will be based on reliability
studies.
These studies were not completed and it will
be a couple years before this program is working.
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Based on the weaknesses observed by inspectors with
equipment trending for relief valves and MOVs, the
licensee missed opportunities to avoid equipment
failures by not performing more evaluation of equipment
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performance data.
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e.
The licensee had initiated an " Integrated Reporting
Program" consolidating most of the stations problem
reports.
The program created a single problem report
mechanism using a " Problem Identification Form (PIF)."
The data in this program allowed the licensee to
identify some specific performance indicators for
different organizations.
The indicators for
engineering were newly established, but the program
demonstrated the ability to identify trends which may
lead to problems in areas such as foreign material
exclusion and radiological controls.
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No violations or deviations were identified in this area.
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5.
Unresgived Items
Unresolved items are matters about which more information is'
required in order to ascertain whether they are acceptable
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items, violations, or deviations.
An unresolved item
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disclosed during the inspection is discussed in
Paragraph 3.4.b.
6.
Qpg1 Items
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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
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licensee or both.
Open items disclosed during the
inspection are discussed in Paragraphs 3.3.b.
and 3.4.c.
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7.
Exit Meetina
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The inspectors met with the licensee representatives (see
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Paragraph 1) on October 29, 1992, to conclude the
inspection.
The inspectors summarized the inspection
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purposa, scope, and findings.
The licensee acknowledged the
information and did not identify any information as
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proprietary.
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i
13
.
-
~