ML20129F112

Insp Repts 50-295/96-10 & 50-304/96-10 on 960713-0829. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering,Plant Support & Security

ML20129F112
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/22/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129F025	List: ML20129F020 ML20129F032 ML20129F112
References
50-295-96-10, 50-304-96-10, NUDOCS 9610290030
Download: ML20129F112 (25)

See also: IR 05000295/1996010

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket Nos: 50-295, 50-304

License Nos: DPR-39, DPR-48

Report No: 50-295/96010, 50-314/96010

Licensee: Commonwealth Edison Company

Facility: Zion Nuclear Plant, Units 1 and 2

Location: Opus West III

1400 Opus West III '

Downers Grove, IL 60515

Dates: July 13 - August 29, 1996

Inspectors: R. A. Westberg, Senior Resident Inspector

D. R. Calhoun, Resident Inspector

D. M. Chyu, Resident Inspector

D. E. Jones, Reactor Engineer

S. K. Orth, Health Physics Specialist

J. L. Belanger, Security Specialist '

J. Yesinowski, Illinois Department of

Nuclear Safety (IDNS) Inspector

Approved by: Lewis F. Miller, Jr., Chief 4

Reactor Projects Branch 4

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9610290030 961022

PDR ADOCK 05000295

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PDR 0n

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l EXECUTIVE SupMARY

j Zion Nuclear Plant, Units 1 and 2

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NRC Inspection Reports 50-295/96010; 50-304/96010

l This integrated inspection included aspects of licensee operations,

! engineering, maintenance and plant support as a result of the routine

{ inspections by the resident inspectors, a regional radiation specialist, a

] regional security specialist, and a reactor engineer.

Operations

e The briefing for the Unit I startup was good (Section 01.2).

{ e There were a significant number of rod position indication system

! problems during the Unit 1 startup (Section 01.3).

{ e Licensed operators failed to include a valve in the partial clearing of

j an out-of-service on the auxiliary steam system which resulted in cross-

tying the auxiliary steam system with the service air system. (Section

j 01.4).

e A violation was identified for the second occurrence of overfilling the

i OB lake discharge tank due to non-licensed operator error (Section i

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l 01.5).

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j e A non-licensed operator misaligned a 2B diesel generator air regulation

isolation valve while performing a valve lineup verification. (Section

l 02.1).

! e A violation was identified when fuel handling personnel inadvertently  !

! dropped two new fuel assemblies during new fuel assembly receipt l

l inspection due to an inadequate procedure (Section 03.1).

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j e Rod position indication problems resulted in numerous individuals l

l clustering around the process computer terminal.  ;

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Maintenance

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e A violation was identified when inadequate corrective actions were

, implemented after scaffold interfering with the Unit I turbine stop

j valves was found on June 17. On August 5, the inspectors identified

i that a scaffold around the IB containment spray pump obstructed

l operation of the IB containment spray discharge valve (Section M1.2).

l e A violation was identified for the failure of maintenance personnel to

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properly document all as-found discrepant conditions of the IB

, centrifugal charging pump (CCP) shaft-driven oil pump during an

i inspection of the pump (Section M1.3).

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e The licensee identified that poor preventive maintenance had been

performed on the main steam isolation valve limit switches (Section

M1.4).

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Enoineerina

e Engineering personnel failed to include the necessary supporting

information in an operability assessment to justify the conclusion that

the IB charging pump was operable with a degraded shaft driven lube oil

pump (Section E2.2).

Plant Support

Radioloaical Protection and Chemistry

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e The licensee dedicated additional resources to improve as low as

reasonably achievable (ALARA) planning of work activities for the site

l construction staff. ALARA plans for site construction activities were

well prepared and contained good radiation protection hold points and

information. However, the ALARA plans were not formally incorporated by

, the licensee's procedures to ensure that significant RP requirements

l were reflected in radiation work permits (Section RI.1).

e Weaknesses were observed in the configuration of the portable air

samplers. Sample pump exhaust ports were expelling filtered air into

the sample pump intake (Section R2.1).

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e Radiological posting problems were observed in the Auxiliary Building

(Section R2.2).

e A violation was identified with ZRP 5820-12 "Out-of-Service

Surveillance for Radiation Monitor," for failure to specify actions to

meet the technical specification action statement requirement when

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containment high radiation monitor 2R-AR03 was inoperable (Section

R3.1).

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e Preparations for unloading new fuel were not well coordinated.

Personnel were cbserved loitering in the Auxiliary Building for l

excessive periods of time (Section R4.1). I

! Security

i e TI 2515/132, " Malevolent Use of Vehicles at Nuclear Power Plants," was

closed, as the licensee had adequately developed and implemented an

adequate Vehicle Barrier System as required (Section S1.1).

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Report Details

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Summary of Plant Status

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Unit I began this inspection report period at 100 percent power. However, the

unit tripped on August 18 due to low low level in the 10 steam generator as a

result of the closure of the ID main steam isolation valve (MSIV). The root

cause of the MSIV closure was determined to be a faulty limit switch on the

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MSIV. The unit reached criticality on August 21; however, the unit was taken

i off-line again on August 26 for an inoperable power operated relief valve.

Unit 2 began this inspection report period at 100 percent power and remained

there throughout the period.

I. Operations

01 Conduct of Operations

01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent

review of ongoing plant operations.

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01.2 Briefina for the Unit 1 Startuo

a. Inspection Scope (71707)

On August 20, the shift engineer and two nuclear engineers (NEs)

conducted an infrequent evolution briefing in preparation for a Unit I

startup. The inspectors attended the briefing and reviewed the

Reactivity Management Oversight (RMO) memorandum which was issued by the

operations manager.

b. Observations and Findjnqi

The shift engineer and the NEs demonstrated leadership and provided good

direction during the briefing. The briefing was thorough and

appropriate emphasis was given to maintaining the proper safety focus

during the startup activities. Clear communications and expectations

were provided to the Unit I nuclear station operators (NS0s) regarding

their roles and rMponsioilities for assuring safe reactor startup

operations. Operations management also attended the briefing and

reiterated many of the safe practices, consistent with the RM0's

memorandum.

c. Conclusion

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The inspectors considered that the briefing was well conducted and

appropriately focused of safety. In addition, proper management

oversight was provided as indicated by the plant manager's, the

operations manager's, and the Unit 1 operating engineer's attendance at

the briefing. j

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l 01.3 linit " Reactor Startuo Observation

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! a. Inspection Scone (71715)

On August 21, the inspectors observed the Unit 1 startup from pulling of ,

j the shutdown rods through criticality. l

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! b. Observations and Findinas l

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a Due to longstanding problems with the rod position indication (RPI)  !

j system, two Nuclear Engineers (NEs) were available to support the Unit 1

crew. One NE was dedicated solely to monitor rod position indication

j problems and the other was to provide technical support to the operators  ;

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as the qualified nuclear engineer (QNE). 1

The startup was well controlled and the operators closely monitored the I

panels; however, frequent RPI out-of-tolerance alarms were received. It

l appeared that there were more than the usual number of RPI alarms during

this startup. There were 35 alarms. In addition, the crew and the NEs

! were also hampered by the process computer failing during the startup,

! without any indication of failure. The process computer was being used

to provide another indicator of individual rod positions. The frequent

! RPI problems also strained command and control during the startup, since

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the crew, NEs, and observers tended to cluster around the computer

terminal when the RPI alarms were received.

c. Conclusion

) Control rcci: decorum was good. The operators were concentrating on the

i- control boards and calling out the annunciators.

j The control room was congested at times. When there were problems with

j the RPIs, everyone tended to cluster around the NE at the computer

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l The frequent RPI out-of-tolerances and failure of the process computer

were a significant distraction to the crew during the startup.

l 01.4 Auxiliary Steam Inadvertent 1v Cross-Tied to Service Air  ;

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l a, Inspection Scope (71707) '

I On August 15, the auxiliary steam system was inadvertently cross-tied to

i the service air (SA) system when a valve was overlooked during a partial

l removal of an out-of-service (005) on the auxiliary steam system. The 1

i inspectors interviewed operations and maintenance personnel reviewed the '

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00S and work request (WR) package, and parformed an inspection of the  ;

l 00S error. "

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b. Observations and Findinas

When the 00S was placed for the auxiliary boiler, the WR package

directed the mechanics to connect a hose from service air to valve,

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0AX321, " Auxiliary Steam Main Header Drain Valve," to facilitate cooling I

, down the system's piping. However, the WR failed to direct the removal

of the hose after the work was completed. l

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On August 15, operations personnel partially cleared the 00S of the l

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auxiliary boiler system to facilitate generation of boric acid for the I

upcoming Unit 1 outage. In preparation, operations personnel failed to

include valve OAX321. The inspectors noted that a contributing factor l

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for this error was that the valve was not identified on the print.  ;

However, the valve was listed on the original 00S as an open valve with i

, its end cap removed, and this valve did not require an 00S card i

according to the 00S. Subsequent to partially clearing the DOS and i

valving in the steam supply to the header, the control room was informed

that there was water in the SA system. An equipment operator (E0) was

dispatched and he identified that the hose was still connected be9een

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the two systems which allowed steam into the SA system. The E0 l

immediately removed the hose and the control room notified plant l

, personnel, via the paging system, not to use SA due to the cross-tie

error.

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The SA system low point drains were opened to remove any moisture;

approximately 55 gallons of water was drained from the SA system. >

Instrument air (IA) lines were checked for water; no water was found in

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any of the IA lines. However, it was later identified that radiation

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protection technicians while performing a filter changeout on radiation

i monitor 1RIA-PR49, the Unit 1 vent stack monitor, saturated the

radiation monitor with service water while purging the radiation monitor

with SA. The technicians believed that the SA system had been purged of

service water when it had not been purged. This error was due to

miscommunication. The radiation monitor was appropriately declared

inoperable by operations.

Additionally, corrective actions included:

1. Providing station direction to comply with the temporary

alteration program.

2. Adding valve, 0AX321, to the piping and instrumentation drawing

and station operating procedures.

3. Verifying labelling on 0AX321 is accurate.

4. Providing direction to the work analysts to obtain engineering's

input for the installation of a cross-tie between systems and

assuring that work instructions (including signatures for the

cross-tie installation and removal steps) or a temporary j

alteration is used for the installation of the cross-tie.

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c. Conclusion

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The inspectors concluded that the following items contributed to this

event: 1) operator error when partially clearing the 00S; 2) failure of

the work package to specify the hose's removal as required by station

procedures; and 3) miscommunications among radiation protection

personnel.

01-5 Overflow of the OB Lake Discharae Tank (LDT)

a. Inspection Scone (93702)

On August 16, an operator failed to close 0WD-0018, the "0B LDT Inlet

Isolation Valve," which resulted in another operator overflowing the OB

LDT. Approximately 7000 gallons of slightly contaminated water was

pumped onto the floor at the 542' level of the auxiliary building (AB).

The inspectors interviewed personnel involved in this event; walked down

the rad waste panel, the waste gas and boron recovery panel, and the

542' level of the AB; and inspected the LDT inlet isolation valve.

b. Observations and Findinas

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On the day of the event, both the OA and OB LDTs were already full. The

LDTs have a total capacity of 30,000 gallons with overflow alarms set at

the level corresponding to 27200 gallons. Because the LDTs were already

full, the overflow annunciators were in the alarm position for both

tanks. Therefore, adding additional water would not cause an alarm.

The radwaste department, knowing the tanks were full, had planned to

release the LDTs to the lake on Saturday morning, August 17.

In preparation for the release, the day shift operator had performed

S01-67F1, Section 5.2, " Recirculating for Sampling, " Step 1, which was

to verify that 0WD-0118, " Lake Discharge Tank Inlet Isolation Valve,"

was closed and locked. Procedure 501-67F1 is a mandatory, in-hand

procedure; however, the operator did section 5.2 from memory. When

interviewed the operator stated that he was sure he closed the valve

because the valve stem was down. Therefore, assuming the valve was

closed, the operator locked the valve.

On the next shift, a different operator (night shift) performed S01-36M,

" Discharge Blowdown Monitor Tanks to Holdup Tanks," Section 5.1, Step

10, which was " verify locked 0WD-0018." The night shift operator noted

that the inlet valve appeared closed by observing the stem position and

that there was a lock on the valve. The procedure did not require the

operator to physically verify the valve position.

The night shift operator started the OA radwaste pump to pump from the

blowdown monitor tanks to the hold up tanks (HUTS). However, valve 0WD-

18 was partially open, so two flow paths were created instead of one:

one flow path was from the BDT to the HUT, while the other flow path was

from the BDT to the LDT. The operator went to verify level on the HUT

level gauge, ILVS-190, located on the waste gas and boron recovery panel

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in Unit 2. When the operator returned to the rad waste panel, he j

received a call from another operator reporting water on the floor of '

the AB 542' level. The operator then secured pumping to the HUT.

The addition of water from the blowdown monitor tanks directly to the OB

LDT invalidated previous sampling of the 08 LDT by the chemistry

department, which had been required prior to the scheduled release.

Therefore, the operator re-performed S01-36M and found that the inlet

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isolation valve to the OB LDT was partially open. The operator

repositioned the valve End locked it closed.  !

c. Conclusion ,

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The inspectors concluded that this event was caused by inattention to

detail by non-licensed operators.

This event was of concern for two reasons. First, it was a repeat of a

previous event. On January 20, a non-licensed operator overflowed the

OB lake discharge tank and caused approximately 560 gallons of slightly

contaminated water to backup into various engineered safeguards pump

rooms and other auxiliary building spaces. That event was included as

an example of an apparent violation in inspection report 295/304-96007.

Therefore, corrective actions taken for the January 20 event appeared to

be ineffective. Secondly, an inappropriate practice was identified by

the licensee of operating with the LDT tank overflow annunciators in the

alarm position, which resulted in the second operator having no warning

that the tank was being overfilled.

Failure to verify OWD-0118, " Lake Discharge Tank Inlet Isolation Valve,"

was closed and locked in accordance with S01-67F1, Step 1, is a

violation of 10 CFR Part 50, Appendix B, Criterion V

(50-295/304-96010-01(DRP)).

An identical event was previously the subject of enforcement action, on

August 23, 1996; therefore, this event will be included as an additional

example of that violation. The inspectors observed that the response to

that violation discussed and adequately addressed the August 16

occurrence. Therefore, no separate response is required for this

violation.

02 Operational Status of Facilities and Equipment

02.1 2B Emeraency Diesel Generator (DG) Imoroner Independent Verification

a. Insoection ScoDe (93702)

On July 26, a maintenance engineer identified that the 2B DG air

regulator isolation valve to temperature control valve OTCV-SW186 was

taken out-of-service in the wrong position. The inspectors reviewed

applicable procedures; inspected the valve in the field; and interviewed

the assistant operations manager, shift engineer, equipment operators,

and the shift engineer responsible for preparing the 00S.

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f b. Observations and Findinas

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A maintenance engineer, performing a pre-job walkdown on the 2B DG,

identified that the air isolation valve to OTCV-SW186 was open instead

i of closed. The 00S, No. 960009314, had designated the isolation valve j

! as a closed valve that did not require an 005 card. The inspector's

review of the event revealed that the second operator performing  !

independent verification responsibilities did not follow the

requirements of procedure ZAP 300-06B, " Equipment Verification," 1

i Revision 9. The second operator opened the valve instead of checking it

closed as required. The second operator signed the independent

verification (IV) that the valve was 00S closed, even though he had not

actually performed the IV task.

The inspectors were informed by the second operator that he considered

that there was no difference whether he observed or signed the

independent verification as the first or second operator as long as he

observed the valve position. The inspectors also questioned additional

plant personnel on their understanding of ZAP 300-068. In particular,

the inspectors questioned if the operators understood the concept of

independent verification. The answers given indicated the concept of

independent verification was understood.

Corrective actions taken by the licensee included: 1) the operators were  !

instructed by optrations management personnel that independent

verification of 00Ss was to be done by the verifying operator after the

operator hanging the 00S had left the area; 2) shift management reviewed '

the independent verification procedure requirements (ZAP 300-06B,

" Equipment Verification") with operations personnel during the shift

briefing; and 3) a standing order was issued that stated that 00Ss

would normally be done with the original 00S copy in the field and

independent verification would be done with the original 00S copy after

the first person had returned to the control room after completing the

initial task for the 00S.

c. Conclusion

The inspectors concluded that the second operator did not understand ZAP

300-06B requirements for independent verification. The failure to

properly independently verify the air regulator isolation valve to valve

OTCV-SW186, as required by ZAP 300-06B is a violation of 10 CFR 50,

Appendix B, Criterion V. However, this violation was identified by the

licensee and could not have been reasonably prevented by the licensee's

corrective action for a previous violation or a previous licensee

finding that occurred within the past two years. Therefore, this

licensee-identified and corrected violation is being treated as a Non-

cited Violation, consistent with Section VII.B.1 of the NRC Enforcement

Policy (50-304-96010-02(DRP)).

The inspectors also concluded '. hat the maintenance engineer did a good

job in identifying the mispositioned valte when he performed a routine

walkdown of the 00S prior to the perforaance of scheduled work.

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03 Operations Procedures and Documentation

03.1 New Fuel Assembly Shinoina Container Drooped  !

a. Inspection Scope (93702)

While performing fuel assembly receipt inspection on July 30, the end of

a shipping container containing two new fuel assemblies was

inadvertently dropped approximately two inches. The inspectors

discussed the incident with the fuel handling supervisor, the nuclear .

material custodian (NMC), a RP technician, and Westinghouse's i

representative. The inspectors also observed use of a new procedure  !

step to lift the fuel assemblies after the incident and discussed the  !

process with various fuel handlers (FHs). .

b. Observations and Findina

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On July 30, FHs were using Fuel Handling Instruction, FHI-02, " Handling

of Shipping Containers and Site Removal of New Fuel Assemblies From

Shipping Containers and Inspection of New Fuel," Revision 2, to prepare

new fuel assemblies for receipt inspection. One end of a shipping ,

container, which held two new fuel assemblies, was being raised using a  :

nylon sling to allow the lateral lock tubes, at the one end of the shock

mounted frame, to be telescoped into their support housings to i

facilitate the raising of the shipping container to a vertical position.

The two inch wide nylon sling being used for the lift slipped off a

three inch wide edge on the shipping container which caused it to fall i

approximately two inches. The nuclear material custodian (NMC) >

immediately stopped the evolution. Accelerometers affixed to the new ,

fuel assemblies during transportation showed no excessive motion.  :

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Westinghouse personnel documented in Field Anomaly Report 0-8G-02 that

the two new fuel assemblies were not damaged. The licensee subsequently  ;

revised FHI-02 to require the use of two eyelets, located on the end of r

the shipping container, to attach the slings to the crane hook. Another  :

option given in the revised procedure was to use a hydraulic jack for

the lift.

Although there was no prior history of the occurrence of this type of

incident, the inspectors observed that the rigging method did not use ,

the readily available techniques that the revised procedure subsequently

included.

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Using the revised procedural rigging method, the shipping container was l

lifted by the attachment of slings to the two eyelets with shackles. '

Following the placement of the lateral lock tubes, the cradle was tilted ,

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upright from the other end, and the new fuel removed and placed over the

new fuel storage area for visual inspection. l

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c. Conclusion

The licensee concluded that the cause of the event was an inadequate

rigging step in the procedure. The licensee took immediate corrective

action by revising the procedure. The inspectors considered that these

actions were appropriate.

Fuel Handling Instruction, FHI-02, " Handling of Shipping Containers and

Site Removal of New Fuel Assemblies From Shipping Containers and

Inspection of New Fuel," Revision 2, Step 9, required that the fuel

handling crew lift the one end of the shock mounted frame slowly with

the overhead crane and a minimum rated two ton nylon sling, until the

lateral lock tubes slide into their support housing. Failure to have an

adequate rigging step in FHI-02, Step 9, that was not appropriate to the

circumstances, which resulted in fuel handling personnel inadvertently

dropping two new fuel assemblies is a violation of 10 CFR 50, Appendix

B, Criterion V (50-295/304-96010-03(DRP)).

The inspectors concluded that the NMC showed conservative decision

making when he stopped the evolution.

08 Miscellaneous Operations Issues

08.1 (00en) NUREG-0737. Item III.D.3.4. Control Room Habitability: This item

was discussed in inspection reports: 90013/90015, 91027, and 92004.

The licensee performed leakage testing in 1991 following modifications

to the ventilation system in response to a 1986 event. The testing

resulted in unacceptable inleakage (LER 91007-01) which prompted further

repairs and another leakage test in 1992. The licensee submitted a re-

analysis of control room habitability to the NRC in September 1993 using

these latest test results.

As of August 22, 1996, this analysis remains under NRR review. Pending

NRR's final review and approval of the latest 1992 reanalysis including

the control room inleakage testing frequency, this issue will be an

inspection follow-up item (50-295/304-96010-04(DRP)).

11. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

a. Inspection ScoDe (62703)

The inspectors observed portions of the work associated with WR 960063817, "DG IB Jacket Water Cooler Cleaning and Inspection;" WR 960063813, "DG 1B-1 Intake Air Intercooler Inspection;" and WR 960012091, "DG 18 Jacket Water M/U Isolation Valve Replacement."

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b. Observations and Findinas

The inspectors determined that the work request packages provided proper

instructions to perform the work and that craft personnel were knowl-

, edgeable of their assigned tasks.

c. Conclusion

i The inspectors observed that the above maintenance activities were

i properly performed.

2 M1.2 Scaffold Obstructina Operation of IB Containment Sorav (CS) Pumo

Discharae Valve ,

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a. Insoection Scope (62703)

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On August 5, the inspectors identified that a scaffold around the IB CS

pump was obstructing operation of valve CS0004, "1B CS discharge valve."

The inspectors interviewed the site construction superintendent and

reviewed the scaffold inspection procedure, ZAP 900-20, "Use of Scaf-

folding and Ladders" and form.

b. Observations and Findinas

On April 24, contractors erected a scaffold around the 18 CS pump in

preparation for valve testing. On August 5, the inspectors identified

that the scaffold was in the path of the handwheel of valve, CS0004.

The valve could not be manually operated due to the close proximity of

the scaffold.

The inspectors informed on-shift operations personnel of the scaffold

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deficiency; the licensee initiated timely and effective corrective

actions to remove the deficient condition by modifying the scaffold. In

addition, on August 6, the licensee and contractors stopped all scaffold

i erection and walked down all existing scaffolds in the plant. The

licensee identified five additional scaffolds which could interfere with

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the operation of non-safety related equipment.

On June 17, the licensee identified a scaffold deficiency around the

Unit I high pressure turbine stop valves. At that time, the licensee

informed the contractors of the scaffold interference issue and initiat-

ed a procedural revision to require an operations' review after the

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erection of scaffold. In addition, the licensee performed a cursory

j review of all the scaffold forms and identified no problems.

c. Conclusion  !

The inspectors concluded that the corrective actions for the June 17

event were inadequate which resulted in the identification of another

deficient scaffold on August 5. Failure to take effective corrective

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actions to prevent recurrence of a previous condition adverse to quality I

is a violation of 10 CFR 50, Appendix B, Criterion XVI (50-295-96010- .

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05(DRP)).

M1.3 Inadeauate Documentation of As-Found Condition of the IB Centrifuaal  :

Charaina Pu=a (CCP) Shaft Driven Oil Pumn -

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a. Inspection Scone (62703)

On August 16, the inspectors identified that the as-found condition of  !

the IB CCP shaft driven oil pump was not documented in the work package  !

as required by the work package. The inspector reviewed ZAP 400-02,

" Initiating and Processing Work Requests," Revision 8, WR 960036505 02,

which had been prepared to inspect and repair the IB CCP shaft driven

oil pump, and interviewed the involved maintenance engineer (ME).  !

b. Observations and Findinas

After reviewing the work pac.kage for WR 960036505 02, the inspectors

interviewed the ME who was present when the pump was inspected and ,

removed. The ME informed the inspectors that the shaft driven lube oil

pump had a missing bottom plate. The ME also commented that the  !

combination of the missing plate, which had orifices that provided a  ;

back pressure for the lube oil in the pump internals, and pump wear i

could have caused degraded performance of the IB CCP shaft driven pump.

However, the missing plate was not documented by maintenance personnel  ;

as part of the as-found condition of the work package. The documented i

as-found condition stated that "no problems were found during the

inspection." In addition, another undocumented as-found condition noted

during the inspection was that a flexible hose, which was connected to ,

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the lube oil reservoir, was only hand-tight instead of being properly

secured.

c. Conclusions l

Failure to adequately document the as-found condition of the IB CCP l+

shaft driven lube oil pump to furnish evidence of activities affecting

quality is a violation of 10 CFR 50, Appendix B, Criterion XVII, ,

" Quality Assurance Records."  !

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M1.4 1D Main Steam Isolation Valve (MSIV) Limit Switch Material Condition .,

a. Inspection Scope f62703)

On August 18, Unit I tripped on low low steam generator level when l

testing the ID MSIV. The ID MSIV intermediate limit switch failed to i

operate properly to prevent more than 10 percent valve closure from >

fully open. The inspectors responded to the trip and observed the trip

13

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t

. 1

'

i

. recovery and subsequent post trip review, reviewed the Problem Identifi-

cation Form (PIF) documenting the limit switch failure, reviewed a list  ;

i of all valves with similar limit switches in both units, and interviewed  ;

the responsible system and maintenance engineers.  ;

I

i b. Observations and Findinas I

. During performance of PT-3D, "lD MSIV Partial Stroke surveillance," the l

l 10 MSIV closed approximately 50-75 percent instead of the required 10 )

!

percent closed. As a result, steam generator level decreased to less

than its low-low steam generator water level setpoint of 10 percent,

which caused a reactor trip and a subsequent turbine trip. The cause of

the trip was determined by the licensee to be failure of the intermedi-

ate limit switch on the ID MSIV. The MSIV limit switches were not in

the Zion Preventative Maintenance (PM) program and subsequent inspection

indicated that the grease in the limit switch had hardened and that the

contact resistance was excessive. All four Unit 1 MSIV limit switches

were replaced with upgraded Namco switches, prior to Unit I startup.

The Unit I partial stroke surveillance was then successfully performed

on all 4 MSIVs.

The MSIV intermediate limit switches are non-safety related switches

that perform no safety function. However, the recently installed limit

switches have a different alloy material for the cover and 0-rings on -

the screws which should protect the switches in their hostile environ-

ment. Additional corrective actions included periodic switch replace-

r ent as part of the PM program. Further, a maintenance engineering

action plan activity identified a population of switches that have

critical control and/or safety functions in the plant; these switches

will then be replaced as part of the PM program. Per the action plan,

during the Z2R14 outage, Unit 2 MSIV limit switches and other applicable

Unit 2 switches will be inspected and or replaced.  ;

c. Conclusion

The inspectors concluded that the root cause of the limit switch failure

was insufficient preventive maintenance. The inspectors concluded that l

the licensee's corrective action plans'were adequate. i

M8 Miscellaneous Maintenance Activities

M8.1 (Closed) Unresolved Item (50-295/94017-01 (DRS)): Effect of corrective

actions from the April 1994 fire on the July 1994 fire. The inspectors

reviewed the corrective actions following the turbine building generator

bus duct fire in April and the effect of these actions on the July fire.

The April fire was caused by a cracked generator phase "C" bushing,

causing the escape of hydrogen and fire. The July fire was caused by

the improper installation and an insufficient number of bus duct ground

strap cables following the April fire. The inspectors reviewed the

.

'

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.

corrective actions taken as a result of the April fire and determined

that they constituted examples of inadequate corrective action as

addressed in the December 1994 violation in inspection report 94021.

This item is closed.

l l

'

III. Enaineerina

El Conduct of Engineering

'

During this inspection report period an engineering and technical

support inspection was also conducted (See inspection report

1 50-295/304-960ll(DRS)).

E2 Eng'neering Support of Facility end Equipment

-

E2.1 Inadeauate Operability Assessment Performed for Dearaded 18 Centrifuaal

'

Charaina (CCP) Shaft Driven Lube Oil Pumo

a. Inspection Scope (37551)

On April 5, an operability assessment, engineering request (ER) No.

9601784, was prepared to determine operability of the IB CCP Pump with a

degraded shaft driven lube oil pump. The inspectors reviewed the

operability assessment, and interviewed system and site quality verifi-

cation engineers.

b. Observations and Findinas

On April 5, the system engineer prepared an operability assessment to

determine the operability of the IB CCP because of a degraded shaft

driven lube oil pump. The shaft driven lube oil pump could not provide

its design lube oil pressure of 10-12 psig.

The operability assessment addressed this deficient condition by stating

that the IB CCP pump was operable provided its associated auxiliary lube

oil pump remained operable. The operability assessment action plan ad-

dressed the condition by specifying that a caution card be placed on the

IB CCP main control board control switch, to run the auxiliary lube oil

pump when running the IB CCP. On August 7, a site quality verification

(SQV) engineer identified a concern with the operability assessment.

The operability assessment failed to address that upon the occurrence of

a safety injection (SI) signal, that the auxiliary lube oil pump would '

start and remain running after the SI signal was reset. Upon resetting

the SI, the auxiliary lube oil pump would then continuously cycle on and

off depending on lube oil pressure. When the pump was off, the IB CCP

would not have adequate oil pressure. Therefore, the SQV engineer

considered the IB CCP inoperable.

15

3

I

,

. l

l

After this concern was raised, operations personnel initiated a new

caution card that stated to continuously run the IB CCP's auxiliary lube l

oil pump. On August 10, the IB CCP's shaft driven lube oil pump was j

replaced. The shaft driven oil pump is being evaluated to determine the i

root cause of the pump's inability to develop design oil pressure. l

,

Subsequently, after the inspector questioned the system engineer about

the actual capability of the degraded shaft driven lube oil pump, the I

system engineer contacted the vendor and was informed that a lube oil l

pressure of six psig would be sufficient to maintain the IB CCP's

operation. Also, the system engineer researched the auxiliary lube oil

pump breaker and determined that repeated cycling would not have tripped

off the oil pump breaker unless the cycling was more than three times in I

one minute. I

{

c. Conclusions

The inspectors agreed that the operability assessment was inadequate;

the assessment failed to address the impact of resetting the SI signal

on the IB CCP's auxiliary lube oil pump operation. The inspectors also

concluded that operating safety related equipment with degraded support

systems over a long period of time (April 5 to August 10) did not

demonstrate conservative operation of safety related equipment. Pending

further review of the licensee's level 3 root cause analysis, this is an

unresolved item (50-295/304-96010-07(DRP)).

E3 Review of UFSAR Commitments

A recent discovery of a licensee operating their facility in a manner

contrary to the Updated Final Safety Analysis Report (UFSAR) description

highlighted the need for a special focused review that compares plant

practices, procedures and/or parameters to the UFSAR descriptions.

While performing the inspections discussed in this report, the inspec-

tors reviewed the applicable portions of the UFSAR that relatad to the

areas inspected. The inspectors verified that the UFSAR woroing was

consistent with the observed plant practices, procedures and/or parame-

ters.

E8 Miscellaneous Engineering Activities

E8.1 (Onen) Violation 50-295/304-93009-02(DRP): Failure to use appropriate

acceptance criteria to ensure that: 1) the ECCS cubicles would be  !

maintained at a negative quarter-inch water pressure with respect to the i

main auxiliary building; and 2) the main building would be maintained at  :

a negative quarter-inch water pressure with respect to the outside. l

Previously, the licensee stated that these concerns would be addressed

in their improved technical specifications (TS). A review of their  ;

proposed TS indicated that the licensee addressed tho ECCS cubicles but

did not address the auxiliary building. Further review by the inspector

indicated that the licensee updated section 9.4.3 of the UFSAR and

deleted the ECCS cubicle and auxiliary building acceptance criteria

which provided for a negative quarter-inch water pressure. This was

16

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i

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!. accomplished by a safety evaluation that concluded the change would not j

{ constitute an unreviewed safety question. The evaluation did not +

provide the bases for determining that this change did not involve an  ;

unreviewed safety question. Failure to perform an adequate safety  ;

,

'

evaluation on this issue was the basis for a previous civil penalty

(Report Nos. 93009 and 93014). The current issue remains open pending ,

,

NRR review of the acceptability of the relaxed acceptance criteria. l

! .

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IV. Plant Suonort

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i  !

R1 Radiological Protection and Chemistry (RP&C) Controls i

1

'

Rl.1 Unit 2 Refuelina Outaae Plannina ,

!

a. J.nspection Scone (83750)

t

i The inspectors reviewed the licensee's planning for the Unit 2 refueling l

outage (Z2R14, September 14 - November 4, 11#96). The inspectors i

,

reviewed radiation work permits (RWPs), As Low As Reasonably Achievable  ;

j- (ALARA) plans, and dose estimates for several planned outage activities. l

In addition, the inspectors reviewed the licensee's progress in reducing

j the number of cobalt containing valves.  !

1 1

i b. Observations and Findinas

The licensee dedicated additional ALARA planners to the site construc- l

tion staff to prepare ALARA plans and to provide additional ALARA l

oversight. The ALARA planners were assembling job histories for the 35 ',

l construction jobs with the highest estimated dose and were preparing

.

ALARA plans fcr these tasks. The ALARA plans contained information from ,

1 industry experience and the station's historical performance informa-  !

] tion. The ALARA planners also stressed the use of training mockups and l

simulations to reduce worker exposures. In addition, the licensee had  !

! assured that the 12 cobalt containing valves which were planned to be  ;

'

worked on during the outage were rebuilt using non-cobalt containing

! components. ,

The inspectors reviewed the ALARA plan and RWPs for the construction of

i scaffolding in the auxiliary building (AB) and reactor containment. The  !

( ALARA plan was comprehensive, documenting good historic information, i

j good radiation protection (RP) practices, and RP hold points. However,

i '

the inspectors observed that the licensee's procedures and program did

not recognize the ALARA plan. The licensee did not have a formal

process to assure that information and RP requirements contained in the  ;

ALARA plan were included in RWPs. The health physics supervisor j

indicated that the ALARA plan was a program enhancement and that the  !

licensee planned to revise RWPs, as applicable, to contain significant

instructions developed in the ALARA plans.

The ALARA planners indicated that job history files had a number of

weaknesses. For example, lessons learned from previous outages (i.e.

17

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.

1995 Unit I refueling and 1996 Unit 1 maintenance outage) were not well ,

documented. The RP evaluations of the outage were informal. The ALARA

staff planned to improve the job history files via a computer based ap-

proach. The licensee expected ;his system to provide better accessi-

bility and more comprehensive job files. The licensee also planned to

use separate RWPs for emergent and re-work dose to better account for

the dose expended.

c. Conclusion

The licensee dedicated additional resources to improve RP ALARA planning

of work activities for the site construction staff. ALARA plans for

site construction activities were well prepared and contained good

radiation protection hold points and information. However, the ALARA

plans had not been _ incorporated in the licensee's procedures to ensure

that significant RP requirements were reflected in RWPs.

R2 Status of RP&C Facilities and Equipment

R2.1 Air Samplina Instrumentation

a. Inspection Scope (83750)

The inspectors toured the radiologically restricted area and reviewed

the licensee's use of portable air sampling equipment,

b. Observations and findinas

The inspectors verified that air samplers were calibrated to ensure that

flow measurements were accurate. However, the inspectors noted that the

exhaust port for the air sampler in the fuel handling building (FHB) was

located in close proximity to the sampler inlet. The inspectors

identified that exhausted, filtered air was cycling back into the inlet

and diluting the air sample. Subsequently, the licensee installed a

diffuser on the exhaust port to correct the problem and reviewed other

sampling equipment to ensure a similar situation did not exist.

Although the air samphr was not required by Technical Specifications

(TSs) nor the Offsite Dose Calculation Manual (0DCM), the licensee used

the sampler to monitor the contribution of radioactive particulates and

iodines from the FHB to the AB ventilation system.

c. Conclusion

The potential dilution of air samples indicated a weakness in the

identification of problems by the RP personnel, who are responsible for

establishing the air sampler, and the chemistry personnel, who are

responsible changing the filters.

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l R3 Radiological Protection and Control Prcesjures and Documentation

R3.1 Radiation Procedure Weakness for Assurina Surveillance Reauirements Are

t Mt:1

! a. Inspection Scone (83750)

i ,

} On July 26, a system engineer ginerated a station deficiency report for l

1 not meeting the TS, when a radiat%n monitor was inoperable. The I

l

'

inspectors interviewed system engineering, radiation protection, a.,d

regulatory assurance personnel. The inspectors also reviewed the TSs

l and other appropriate procedures.

! b. Observation and Findings )

i 1

l Radiation monitor, 2R-AR03, "High Containment Radiation," was taken out

of service to efftct repairs to inadequate wiring. The radiation

4 monitor is one of two containment high radiation monitors; the other

! redundant radiatio 7 monitor is 2R-AR02 and it was available. With 2R- l

l AR03 inoperable, T5 Table 3.14, " Radiation Monitoring Instrumentation",  !

Action Statement 31, required that an alternate method of monitoring

4- containment be initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Radiation protection proce-

dure, ZRP 5820-12, "Out of Service Surveillance for Radiation Monitors,"

Revision 5, was used to implement the requirements of the TS Table 3.14.

The procedure was inadequate in that it specified that no routine

surveillance was required. However, the redundant radiation monitor,

2R-AR03, was available and provided an alternate method of sampling

containment; therefore, the TS action staiement requirement was met.

During the exit meeting, the new radiation protection supervisor stated

that the raquirements of TS Table 3.14 were met by operability proce-

dure, ZODM-AP, " Area Radiation Monitoring," Revision 5. The inspectors

noted that Procedure ZODM-AR required for an inoperable monitor that an

alternate method of monitoring containment be accomplished within 72

hours; which is the same requirement as the TS. However, the ZODM does

not specify how to implement this action. Procedure, IAP 5820-12,

stated that the use of this procedure was to accomplish any applicable

requirements of the TS and offsite dose calculation manual, but did not

require containment monitoring within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable

radiation monitor. Therefore, as noted above ZAP 5820-12 and ZODM-AR

were inconsistent. J

c. Conclusion

The inspectors concluded that the TS action statement was met when 2R-

AR03 was inoperable; however, Procedure ZAP 5820-12 was inadequate in

that it incorrectly stated no action was required for the inoperability

of 2R-AR03. This is a violat. ion of 10 CFR 50 Appendix B, Criterion V

(50-295/304-96010-09(DRP)).

,

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l R4 Staff Knowledge and Performance in RP&C

I R4.1 RP Oversiaht of New Fuel Shioments

f a. Insoectjyp A ne (83750)

The inspectors observed preparation for the receipt of a shipment of new

fuel in the FHB.

b. Observation and Findinas

i All personnel were wearing the correct dosimetry as required by proce-

. dures. Additionally all personnel, including two radiation protection j

l technicians (RPTs), covering the evolution, were staged in low dose l

!. areas'of less than 1 arem/hr. However, the inspectors noted that )

i personnel were spending an excessive amount of time in the FHB, while

j waiting for support from operations' personnel. About one hour later,

j the individuals left the area and deterMned that operations' personnel

were working on a necessary procedure revision.

l

c. Conclusion

l Although the persons were waiting in a low dose area, the lack of

i coordination indicated poor planning and ccamiunications prior to

i entering the radiologically posted area.

3

'

l R8 Miscellaneous RP&C Issues

i  :

! R8.1 (Open) Violation 50-295/304-95018-01: failure to adequately don

protective clothing and to prevent the spread of contamination as

required by RP procedure ZRP 500-7, " Unescorted Access To and Conduct in

j Radiological Posted Areas."' The licensee reviewed the violation with RP  !

I and maintenance staff members to assure their understanding of proper l

3

radiation worker (radworker) practices. In addition,' the licensee's 1

e corrective actions included additional training of RP, maintenance, and l

i contractor personnel and revising RP procedure, ZRP 500-7. The inspec-  !

! tors reviewed the licensee's progress in completing the remaining j

j corrective actions:

l

0 The licensee had begun training first line RP and maintenance

l supervisors to improve their understanding of management expecta- .

'

tions and oversight skills. The licensee had all applicable

1 personnel scheduled for training through November 1996.

]

j o The inspectors also reviewed the enhanced radworker training

presented to maintenance personnel. The training was comprehen-

j sive and included both classroom and workshop instructions.

During this inspection, the licensee was in the process of expand-

ing its initial nuclear general employee training (NGET) to

e include the topics of the enhanced training, including contamina-

tion control techniques. The training staff indicated that the

20

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.

revised NGET would assure that contract personnel hired for Z2R14

would receive radworker training at the depth of the enhanced

training.

o The inspectors also reviewed a draft revision of ZRP 500-7, which i

provided instruction to personnel regarding removing items from '

contaminated areas and contamination control techniques. The

inspectors verified that the above training was consistent with

the licensee's RP procedures. Once personnel were trained on the

revision, the licensee planned to approve the procedure. l

This violation will remain open pending the completion of training, the

revision of ZRP 500-7, and the observations of radworker performance 1

during the 1996 Unit 2 re-fueling outage. I

S1. Conduct of Security and Safeguards Activities

S1.1 (CLOSED) Temoorary Instruction 2515/132. " Malevolent Use of Vehicles at

Nuclear Power Plants"

a. Insoection Scope (TI 2525/132)

The inspectors examined the licensee's provisions for land control

measures to protect against the malevolent use of a land vehicle to

determine compliance with regulatory and licensee comitments.

b. Observations and Findinas

(1) Vehicle Barrier System (VBS)

The inspector found that the features and structures that form the

VBS met the design characteristics established by the NRC. The

vehicle barrier components and the location of the barrier were as

described in the revised sumary description of the VBS submitted

by the licensee to the NRC in February 1996.

A visual walkdown performed by the inspector confirmed that the

general type of vehicle barrier described in the VBS sumary

description had been installed and that the barrier was continu-

ous.

(2) Bomb Blast Analysis

Inspector field observations of standoff distances were consistent

with those documented in the sumary description. The licensee

confirmed that calculation of minimum standoff distance was based

on NUREG/CR-6190 or an independent engineering analysis.

21

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(3) Procedural Controls

The licensee appropriately defined criteria for maintenance,

surveillance, and compensating for the VBS system in Corporate

Nuclear Security Guideline No. 4, " Operational Planning and

Maintaining Integrity of Vehicle Barrier Systems (VBS)," Revision

0, dated February 1996.

Discussions with security management confirmed that procedures

necessary to safely shutdown the units after a bomb blast were

reviewed and found adequate.

c. Conclusion

The licensee's provisions for land vehicle control measures met regula-

tory requirements and licensee commitments. The VBS program was

consistent with the summary description submitted to the NRC and

adequate procedures addressing VBS maintenance and compensatory proce-

dures were developed and implemented.

XI Exit Meeting Summary

The inspectors presented the inspection results to members of licensee I

management at the conclusion of the inspection on August 29, 1996. The l

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

identified.

i

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, PARTIAL LIST OF PERSONS CONTACTED

.I

Licensee

. G. Schwartz, Station Manager

i W. Stone, Regulatory Assurance Supervisor

B. Fitzpatrick, Operations Manager

i B. Giffin, Engineering Manager

'

K. Hansing, Site Quality Verification Director '

W. Strodl, Radiation Protection Supervisor

4 D. St. Clair, Work Control Manager

M. Weis, Services Director ,

4

i

. HEL ,

L. Miller, Chief, Reactor Projects Branch 4

j R. Westberg, Senior Resident Inspector

.

!

IDMS

J. Yesinowski

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List of Insnection Procedures Used

IP 37551 Engineering

IP 62703 Maintenance Observation

IP 71707 Plant Operations

IP 71715 Sustained Control Room Observation

IP 83750 Occupational Radiation Exposure

IP 93702 Prompt Onsite Response to Events at Operating Power Reactors

TI 2515/132 Malevolent Use of Vehicles at Nuclear Power Plants

.

List of Items Opened. Closed. and Discussed

!

4 Opened

50-295/304-96010-01(DRP) VIO failure to follow procedures which

resulted in overflowing the OB LDT. No

<

response required

, 50-304-96010-02(DRP) NCV failure to properly independently

verify DG air regulator isolation valve

, 50-295/304-96010-03(DRP) VIO failure to have an adequate procedure

for rigging of new fuel containers

50-295/304-96010-04(DRP) IFI testing of the control room ventila-

tion system

50-295-96010-05(DRP) VIO inadequate corrective actions taken

to assure procedures were followed for

scaffold interferences

50-295/304-96010-06(DRP) VIO failure to document all as-found

discrepancies during the inspection of the

IB CCP pump

-

'

50-295-96010-07(DRP) URI inadequate operability assessment for

IB CCP

50-295/304-96010-08(DRP) NCV failure to assure that radiological

postings were conspicuous in accordance

'

with 10 CFR 20.1902

50-295/304-96010-09(DRP) VIO Procedure ZAP 5820-12 was inadequate

in that it incorrectly stated no action

was required for the inoperability of 2R-

<

AR03.

-

Closed

50-295/304-96010-02(DRP) NCV failure to properly independently

verify DG air regulator isolation valve

50-295/304-96010-07(DRP) NCV failure to assure that radiological

postings were conspicuous in accordance ,

'

with 10 CFR 20.1902

50-295/94017-01(DRS) URI effects of corrective actions from )

April / July 1994 fire i

Discussed

50-295/304/93009(DRP) VIO failure to use appropriate acceptance

criteria

24

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O l

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List of Acronyms

l

AB Auxiliary Building

ALARA As Low As Reasonably Achievable

CCP Centrifugal Charging Pump

CS Containment Spray

CT Chemistry Technician

DG Diesel Generator

E0 Equipment Operator

ER Engineering Request

FH Fuel Handling

FHB Fuel Handling Building i

IFI Inspection Followup Item l

IP Inspection Procedure  !

IR Inspection Report ,

IV Independent Verification  !

LDT Lake Discharge Tank l

ME Maintenance Engineer i

MSIV Main Steam Isolation Valve

NCV Non-Cited Violation I

NE Nuclear Engineer l

NGET Nuclear General Employee Training l

NMC Nuclear Material Custodian

NRC Nuclear Regulatory Commission

NSO Nuclear Station Operator

ODCM Off-site Dose Calculation Manual l

00S Out of service  ;

PDR Public Document Room l

PIF Problem Identification Form  !

QNE Qualified Nuclear Engineer

RM0 Reactivity Management Oversight  :

RP Radiation Protection l

RP&C Radiological Protection and Chemistry  !

RPI Rod Position Indicator i

RPT Radiation Protection Technician i

RWP Radiation Work Permit

SA Service Air

SI Safety Injection

SQV Site Quality Verification

TS Technical Specification

UFSAR Updated Final Safety Analysis Report i

URI Unresolved Item

VBS Vehicle Barrier System

VIO Violation

WR Work Request

!

25

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