ML20132D160
| ML20132D160 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/18/1985 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8507310228 | |
| Download: ML20132D160 (6) | |
See also: IR 05000304/1985006
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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July 18, 1985
MEMORANDUM FOR:
Charles E. Norelius, Director
Division of Reactor Projects
Region III
FROM:
Brian K. Grimes, Director
Division of Quality Assurance, Vendor
and Technical Training Center Programs
Office of Inspection and Enforcement
SUBJECT:
ZION STATION UNIT 2 INSPECTION REPORT N0. 50-304/85-06
Enclosed is the report (and attendant 766) of the special team inspection at
Zion Station Unit 2 to review the implementation of a program to meet the
requirements of 10 CFR 50.49. This inspection was conducted on January 14-18,
1985, at the offices of Comonwealth Edison Company and Sargent & Lundy Company
in Chicago, Illinois, and at Zion Station Unit 2, Zion, Illinois. The inspection
report contains four Potential Enforcement / Unresolved Items. We would charac-
terize these items at Severity level IV relative to implementation of a 10 CFR 50.49 program. The recommended severity level for these items has been concurred
in by the IE Enforcement Staff.
Enclosed are Potential Enforcement / Unresolved
Items 304/85-06-01, 05, 06, and 09.
In addition, five Open Items (304/85-06-02,
03, 04, 07, and 08) were identified that are being referred to you for appropriate
followup and resolution.
If you do not expect to issue a Notice of Violation
on the above items within the next month, please let me kncw.
If you have any questions concerning this inspection, please call V. Potapovs
(FTS 492-8030) or G. Zech (FTS 492-9663).
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Brian K. Grimes, Director
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and Technical Training Center Programs
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Office of Inspection and Enforcement
Enclosures:
See next page
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8507310228 850710
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Charles E. Norelius
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July 18, 1985
Enclosures:
1.
Inspection Report 304/85-06
2.
Inspector's Report (Forn 766)
3. -Potential Enforcement / Unresolved
~ Item 304/85-06-01
4. . Potential Enforcement / Unresolved
Item 304/85-06-05
5.
Potential Enforcement / Unresolved
Item 304/85-06-06
6.
Potential Enforcement / Unresolved
Item 304/85-06-09
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ENCLOSURE 3
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Potential Enforcement / Unresolved Item 304/85-06-01
Facility:
Zion Station Unit 2
Docket No.: 50-304
Area:
10 CFR 50.49 Implementation
Date: January 18, 1985
Team Leader:
G. T. Hubbard
As a result of the inspection at the Zion Station Unit 2 Nuclear Plant on
January 14-18, 1985, the following violation of an NRC requirement was
identified:
Paragraph (g) of 10 CFR 50.49 requires that each holder of an operating
license issued prior to February 22, 1983, shall by May 20, 1983, identify
the electric equipment important to safety within the scope of this section
already qualified and submit a schedule for either the qualification to
the provisions of this section or for the replacement of the remaining
electric equipment important to safety within the scope of this section.
This schedule must establish a goal of final environmental qualification
of the electric equipment within the scope of this section by the end of
the second refueling outage after March 31, 1982 or by March 31, 1985,
whichever is earlier.
Paragraph (b)(3) of 10 CFR 50.49 requires that certain post-accident
monitoring equipment be included as electric equipment important to
safety covered by 10 CFR 50.49.
Findings:
Contrary to the above, the licensee failed to establish
certain post-accident monitoring (Regulatory Guide 1.97) qualification of
equipment, included
on his May 1983 submittal of electric equipment important to safety within
the scope of 10 CFR 50.49, prior to Zion 2's second refueling outage after
March 31, 1982.
Examples of equipment included in the licensee's submittal
that had not had qualification established were Barton Model 763 and 764
pressure transmitters.
Recommended Severity Level:
IV
ENCLOSURE 4
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Potential Enforcement / Unresolved Item 304/85-06-05
Facility: Zion Station 2
Docket No.: 50-304
Area:
10 CFR 50.49 Implementation
Date: January 18, 1985
Team Leader:
G. T. Hubbard
As a result of the inspection at the Zion Station Unit 2 Nuclear Plant on
January 14-18, 1985, the following violation of an NRC requirement was
identified:
Paragraph (g) of 10 CFR 50.49 requires that each holder of an operating
license issued prior to February 22, 1983, shall by May 20, 1983, identify
the electric equipment important to safety within the scope of this section
already qualified and submit a schedule for either the qualification to the
provisions of this section or for the replacement of the remaining electric
equipment important to safety within the scope of this section. This
schedule must establish a goal of final environmental qualification of the
electric equipment within the scope of this section by the end of the second
refueling outage after March 31, 1982, or by March 31, 1985, whichever is
earlier.
Findings:
Contrary to the above, the licensee had not adequately demonstrated and/or
documented qualification of Marathon terminal blocks / top-entry junction boxes
used in electrical control circuits inside containment prior to the end of
Zion 2's second refueling outage after March 31, 1982.
Recommended Severity Level:
IV
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ENCLOSURE 5
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Potential Enforcement / Unresolved Item 304/85-06-06
Facility:
Zion Station Unit 2
Docket No.:
50-304
Area:
10 CFR 50.49 Implementation
Date:
January 18, 1985
Team Leader:
G. T. Hubbard
As a result of the inspection at the Zion Station Unit 2 Nuclear Plant on
January 14-18, 1985, the following violation of an NRC requirement was
identified:
Paragraph (f) of 10 CFR 50.49 requires that each item of electric equipment
important to safety must be qualified by one of the following methods:
(1) Testing an identical item of equipment under identical conditions or
under similar conditions with a supporting analysis to show that the equipment
to be qualified is acceptable.
(2) Testing a similar item of equipment with a supporting analysis to show
that the equipment to be qualified is acceptable.
Findings:
Contrary to the above, the licensee had installed qualified Limitorque valve
operators in Zion 2 in a configuration different from the configuration which
was qualified by testing and/or analysis. The licensee had installed the
valve operators without removing the plastic protective shipping caps from
the valve operator gear case grease relief valves, therefore, providing an
operator configuration different from the qualified configuration.
Recommended Severity Level:
IV
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ENCLOSURE 6
Potential Enforcement / Unresolved Item 304/85-06-09
Facility: Zion Station Unit 2
Docket No.:
50-304
Area:
10 CFR 50.49 Implementation
Date: January 18, 1985
Team Leader:
G. T. Hubbard
As a result of the inspection at the Zion Station Unit 2 Nuclear Plant on
January 14-18, 1985, the following violation of an NRC requirement was
identified:
Paragraph (e) of 10 CFR 50.49 requires that the electric equipment qualification
program must include and be based on the following:
(1) Temperature and Pressure. The time-dependent temperature and pressure at
the location of the electric equipment important to safety must be established
for the most severe design basis accident during or following which this
equipment is required to remain functional.
Paragraph (1) of 10 CFR 50.49 requires that replacement equipment must be
qualified in accordance wita the provisions of this section unless there are
sound reasons to the contrary.
Findings:
Contrary to the above, the licensee did not consider the most severe environment
accident profile (specifically Main Steam Line Break) when establishing the
qualification of replacement equipment (Conax seals, Namco limit switches, and
Raychem splices) installed inside containment in Zion 2.
Recommended Severity Level:
IV
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UNITED STxTES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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APR 15
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1985
Docket No. 50-304
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Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
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Vice President
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Post Office Box 767
Chicago, Illinois
60690
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Gentlemen:
SUBJECT:
INSPECTION N0'. 50-304/85-06
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Enclosed is the report of the special team inspection conducted by Mr. G. T.
Hubbard and other NRC representatives on January 14-18, 1985, at the offices of
Commonwealth Edison Company and Sargent & Lundy Company in Chicago, Illinois, and
at Zion Station Unit 2, Zion, Illinois, of activities authorized by NRC License
- a DPR-48.
The team's findings were discussed with you and members of your
e "ff at the conclusion of the inspection.
The inspection reviewed your imple-
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. ation of a program as required by 10 CFR 50.49 for establishing and maintaining
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tne qualification of electric equipment within the scope of 10 CFR 50.49.
The
inspection also included evaluations of the implementation of equipment quali-
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fication corrective action commitments made as a result of the December 14, 1982,
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Safety Evaluation Report (SER) and the June 18, 1982, Franklin Research Center
Technical Evaluation Report (TER).
Within this area, the inspection consisted
of selected examinations of procedures and representative records, interviews
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with personnel, and observations by the inspectors.
The inspection determined that you have implemented a program to meet the require-
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ments of 10 CFR 50.49 and your corrective action commitments relative to SER/TER
deficiencies; however, some deficiencies in your implementation of this program
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were identified.
Four deficiencies are classified as Potential Enforcement /
Unresolved Items and will be referred to the NRC Region III office for further
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action.
Five other identified deficiencies are classified as Open Items and your
corrective actions regarding them will be reviewed during a future NRC inspection.
Details of the above deficiencies are discussed in the enclosed inspection report.
We will gladly discuss any question you have concerning this inspection.
Sincerely,
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ary G. Zech,
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Vendor Program Branch
Division of Quality Assurance, Vendor,
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and Technical Training Progra,ms
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Office of Inspection and Enf.orcement
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Enclosure:
1.
Appendix A
2.
Inspection Report No. 50-304/85-06
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APPENDIX A
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Potential Enforcement / Unresolved Items
As a result of the special equipment qualification inspection of January 14-18,
1985, the following items have been referred to NRC Region III as Potential
Enforcement / Unresolved Items (paragraph references are to the detailed portion
of the inspection report).
1.
Contrary to paragraph (f) of 10 CFR 50.49, Commonwealth Edison Company
(CECO) had installed qualified Limitorque valve operators in Zion 2 in
a configuration different from the configuration which was qualified
by testing and/or analysis (Paragraph 4.C.(2)).
2.
Contrary to paragraph (g) of 10 CFR 50.49 CECO had not adequately
demonstrated and/or documented qualification of Marathon Terminal
blocks / junction boxes used in electrical control circuits inside
containment prior to the end of Zion 2's second refueling outage
after March 31, 1982, (Paragraph 4.C.(1)).
3.
Contrary to paragraphs (e) and (1) of 10 CFR 50.49, CECO did not
consider the most severe environment accident profile (specifically-
Main Steam Line Break) when establishing the qualification of
replacement equipment (Conax seals, Namco limit switches, and Raychem
splices) installed inside containment in Zion 2 (Paragraph 4.D.(3)).
4.
Contrary to paragraphs (b) and (g) of 10 CFR 50.49, CECO failed to
establish qualification of certain post-accident monitoring equipment,
identified on their May 1983 submitted list of electric equipment
important to safety, prior to the end of Zion 2's second refueling
outage date after March 31,1982 (Paragraph 4. A. (1)).
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No.:
50-304/85-06
Docket No.:
50-304
License No.:
OPR-48
Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, Illinois 60690
Facility Name:
Zion Station, Unit 2
Inspection At:
Chicago and Zion, Illinois
Inspection Conducted:
January 14-18, 1985
4//fM[
Inspector:
G. T. Hubbard, Equipment Qualification and
Date
Test Engineer
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Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, I&E
R. C. Wilson, Engineer, I&E
H. C. Garg, Engineer, NRR
R. O. Karsch, Reactor Engineer, NRR
R. A. Borgen, Consultant Engineer, Idaho National Engineering Laboratory
A. S. Gautam, Reactor Inspector, RIII
R. J. Smeenge,. Reactor Inspector, RIII
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Approved by:
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Gary G. Zech, Chief, Venda r Program Branch, I&E
Date
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' INSPECTION SUMMARY:
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Inspection on January 14-18, 1985 (Inspection Report No. 50-304/85-06)
Areas Inspected:
Special, announced inspection to review the licensee's
implementation of a program per the requirements of 10 CFR 50.49 for
establishing and maintaining the qualification of electric equipment within
the scope of 10 CFR 50.49.
The inspection also included evaluations of the
implementation of equipment qualification (EQ) corrective action commitments
made as a result of deficiencies identified in the December 14, 1982, Safety
Evaluation Report (SER) and the June 18, 1982, Franklin Research Center (FRC)
Technical Evaluation Report (TER).
The inspection involved 255 inspector
hours onsite.
Results:
The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed
below.
No deficiencies were found in the licensee's implementation of corrective
action commitments made as a result of SER/TER identified deficiencies.
Four Potential Enforcement / Unresolved Items were identified.
(1)
Installation of Limitorque valve operators in a configuration different
from the equipment configuration for which qualification was established -
paragraph 4.C.,(2).
(2) Failure to adequately demonstrate and/or document qualification relative to
leakage currents for the installed configuration of Marathon control circuit
terminal blocks / junction boxes
paragraph 4.C.(1).
(3)
Lack of specific quantitative evaluation of main steam line break (MSLB)
environmental profile inside containment for replacement equipment -
paragraph 4.D.(3).
(4) Failure to establish qualification of post accident monitoring [ Regulatory
Guide (R.G.) 1.97 - 10 CFR 50.49(b)(3)] equipment included on licensee's
May 1983 submitted list of electric equipment important to safety within
the scope of 10 CFR 50.49
paragraph 4. A. (1).
Five open items were identified:
(1)
Station procurement procedure 'or replacement equipment
paragraph
f
4.A.(2)(a)
(2) Verification of training program implementation
paragraph 4.A.(2)(b)
(3)
Incomplete maintenance procedures
paragraph 4.A.(4)(a)
(4)
Incomplete documentation packages
paragraph 4.D.(1)
(5) Deficiencies in documentation
paragraph 4.0.(2)
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Oetails
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PERSONS CONTACTED
1.1 Commonwealth Edison Company (Ceco)
- C. Reed, Vice President, Engineering
- R. Cascarano, Zion Licensing Administrator
- F. Lentine, Zion Project Engineering, Station Nuclear
Engineering Department (SNED)
- G. Plim1, Assistant Superintendent, Zion
- J. Abel, Manager, SNED
- 0. Lamken, SNED Electrical and Qualification Group
- G. Wagner, Power Operations Manager
- R. Rybak, Nuclear Licensing
- M. Bailey, Tech Staff Engr /EQ Coordinator, Zion
- G. Alexander, Nuclear Licensing Adminstrator
- S. Zunjic, SNED, Zion, Engineer
L. DelGeorge, Assistant Vice President, Engineering
D. Farrar, Director, Nuclear Licensing
K. Graesser; Station Superintendent, Zion
G. Dix, Electrical Maintenance, Zion
W. Kurth, Instrument Maintenance, Zion
L. Thorsen, Operations, Zion
C. Lawreys, Technical Staff, Zion
- J. Bieronski, SNED, LaSalle
M. Lesnet, Technical Staff, Zion
W. Stone, Technical Staff, Zion
1. 2 Ceco Contractors
- R. Hameetman, Project Manager, Sargent & Lundy (S&L)
- R. Mazza, Project Director, S&L
- M. Rauckhorst, Mechanical Engineer, S&L
- R. Raheja, Supervisor, Mecahnical Engineer, S&L'
B. Gogineni, Engineer, S&L
C. Schwartz, Engineer, S&L
0. Drankham, Engineer, S&L
A. Behera, Engineer, S&L
C. Crane, EQ Consultant; WESTEC Services, Inc.
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J. Bassett, Engineer, Westinghouse Electric Corporation
B. Tumblin, Engineer, Westinghouse Electric Corporation
- R. Ho, Consultant, EPM, representing Nuclear Utility Group on
Equipment Qualification (Observer)
1. 3 Nuclear Regulatory Commission
- G. Zech, Chief, Vendor Program Branch, I&E
- J. Norris, Project Manager, NRR
- 0enotes those present at the exit interview in Chicago on January 18, 1985
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2.
PURPOSE
The purpose of this inspection was to review the licensee's implementation
of the requirements of 10 CFR 50.49 and the implementation of committed
corrective actions for SER/TER identified deficiencies.
3.
BACKGROUND
On January 25 and 26, 1984, the NRC held a meeting with CECO officials to
discuss CECO's proposed methods to resolve the EQ deficiencies identified
in the December 14, 1982 SER and June 18, 1982, FRC TER.
Discussions also
included Ceco's general methodology for compliance with 10 CFR 50.49 and
justification for continued operation for those equipment items for which
environmental qualification was not completed.
The minutes of the meeting
and proposed method of resolution for each of the EQ deficiencies were
documented in April 10 and June 20, 1984, submittals from the licensee.
The TER and the April 10 and June 20 submittals were reviewed by the
inspection team members and were used to establish a status baseline for
the inspection.
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4.
FINDINGS
A.
EQ Program Compliance with 10 CFR 50.49
The NRC inspectors examined the licensee's program for establishing
the qualification of electric equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's
qualification documentation files, examination of procedures which
control the licensee's EQ efforts, verifying the adequacy and
accuracy of the licensee's 10 CFR 50.49 equipment list, and examin-
ation of the licensee's program for maintaining the qualified status
of the covered electrical equipment.
Based on the inspection findings,
which are discussed in more detail below, the inspection team deter-
mined that the licensee has implemented a program to meet the require-
ments of 10 CFR 50.49, although some deficiencies were identified.
The identified deficiencies relate to the implementation of specific
aspects of the program.
(1)- Qualification Files, General
The licensee's qualification files were arranged in the format
of a single binder titled, " Zion Environmental Qualification
Report" (EQR), Revision 4, dated January 10, 1985.
The EQR
was supplemented by individual equipment binders identified as
"EQ Documentation Packages."
The inspection team reviewed the
EQR and determined that it contained the master list of
qualified equipment; references to the EQ documentation
packages; summaries of plant environmental zone descriptions;
lists of action items such as deferred Three Mile Island (TMI)
related items; and similar information serving to define and
coordinate all of the plant environmental qualification
documentation.
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The NRC inspectors reviewed and evaluated EQ documentation
packages for 13 types of-equipment, three of which were
identified by CECO as being TMI related items.
Since Ceco's
TMI items have a deferred implementation schedule, these three
packages were incomplete and not finalized at the time of the
inspection.
Each EQ documentation package included such information as a
checklist comparing service and qualification conditions;
detailed identification of plant equipment and type test
specimens; pertinent type test reports; references to or
copies of purchase orders and other relevant supporting
documents; copies of applicable IE Information Notices (ins)/
Bulletins with definition of their impact on the equipment and
resolution of any concerns; and detailed definition of
maintenance and surveillance criteria necessary to maintain
qualification of the installed equipment.
Additional documentation such as plant modification packages
for installing qualified replacement equipment, supporting
seismic calculations, station maintenance / surveillance
procedures, and station instrument calibration procedures
were also referred to in support of the documentation file
reviews.
The inspection team's review and evaluation of the EQR and 13
documentation packages identified several minor deficiencies
in the files which are discussed in more detail later in this
report and one item classified as a Potential Enforcement /
Unresolved Item.
During the team's review of the licensee's
EQ documentation it became apparent that for some post-accident
monitoring [R.G. 1.97 - 10 CFR 50.49(b)(3)] equipment, establish-
ment of qualification would not be completed until the licensee
has completed his R.G. 1.97 review.
In the case of Zion Station,
CECO is scheduled to submit its final 1.97 review report to the
NRC in early 1987.
CECO has not requested an extension of the
qualification deadline for this' equipment.
10 CFR 50.49 requires that each holder of an operating license
issued prior to February 22, 1983,' identify by May 20, 1983, the
equipment important to safety within the scope of the rule and,
for such equipment not already qualified, submit a schedule of
qualification or replacement.
Final qualification of all
equipment is required to be established by the end of the second
refueling outage after March 31, 1982, or by March 31, 1985,
whichever is earlier unless an extension of the deadline has been
granted by the Director, NRR.
In their May 19, 1983 submittal to NRC, CECO identified certain
equipment items used for post-accident monitoring as falling
within the scope of 10 CFR 50.49, for example, Barton Model 763
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and 764 pressure transmitters.
These, as well as other post-
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accident monitoring items listed in the May 19, 1983 submittal
have subsequently been deleted from the CECO environmental
qualification review pending the completion of their final R.G.
1.97 review.
The failure to establish qualification of this equipment is
identified as a Potential Enforcement /Unresolvad Item since
any extension of qualification schedules for items identified
in the May 19, 1983 submittal beyond the 10 CFR 50.49 deadlines
must be processed in accordance with the provisions described in
the rule.
(304/85-06-01)
It is recognized, however, that the qualification schedule of
additional items identified as a result of R.G. 1.97 review
will depend on the R.G. review schedule and may extend beyond
the dates established in 10 CFR 50.49.
(2) EQ Program Procedures
The NRC inspectors reviewed the licensee's EQ program as described
in the EQR, which was prepared and is maintained current by S&L
for Ceco.
Additional program procedures reviewed for evaluating
the licensee's 10 CFR 50.49 program implementation included:
S&L Instruction PI-ZI-25, Rev. O, dated January 7, 1985,
" Procedure for the Documentation of Updates to the Zion EQR."
S&L Instruction PI-ZI-14, Rev. 2, dated January 7,1985,
" Review of Modifications for Potential Environmental
-Qualification Interface."
S&L Instruction PI-ZI-23, Rev. 1, dated January 7, 1985,
" Procedure for Preparation, Review, Control, Issuance, and
Maintenance of Environmental Qualification Documentation
Packages."
SNED Procedure Q.6, Rev. 9, dated January 14, 1985,'"Modifi-
cations Originated by Station Technical Staff."
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Station Quality Procedure (SQP) QP-4-51, dated December 12,
1984, " Procurement Document Control for Operations - Processing
Purchase Documents."
SQP QP-3-51, dated December 12, 1984, " Design Control for
Operations Modification."
SQP QP-3-52, dated November 21,1984, " Design Control for
Operation Plant Maintenance."
The licensee's program was reviewed to verify that adequate
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procedures and controls had been established by the licensee
to implement requirements of 10 CFR 50.49.
Areas of the
program reviewed included methods and their effectiveness for:
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(a) Requiring all equip 4ent that is located in harsh
environments and i', within the scope of 10 CFR 50.49
to be included or the list of equipment requiring
qualification.
(b) Controlling the generation, maintenance, and distribution
of the list of equipment requiring qualification.
(c) Defining and differentiating between mild and harsh
environments.
(d) Establishing harsh environmental conditions at the
location of equipment through engineering analysis and
evaluation.
(e) Establishing and maintaining a file of plant conditions.
(f) Establishing, evaluating, and maintaining EQ document-
ation.
(g) Training personnel in the environmental qualification of
equipment.
(h) Controlling plant modifications such as installation of
new and replacement equipment, and providing for updating
replacement equipment to 10 CFR 50.49 criteria.
As a part of the program review, the licensee's Quality Assurance
(QA) program was reviewed as it pertains to equipment qualification.
Interviews were conducted with the station supervisors of quality
assurance and electrical and mechanical maintenance.
These
interviews revealed that in place procedures are providing direction
for maintaining environmental qualification of the equipment
identified in the EQR.
The Work Request cover pages identify
when equipment with environmental qualification are involved in
maintenance activities.
The jackets of Work Request packages
were also noted to be stamped with l!s" letters "EQ."
For these
Work Requests identified as "EQ," QC is required to observe and
signoff on the Work Request verifying that all work is completed
and that the activities have been accomplished in accordance with
approved procedures.
Quality Assurance performs audits and surveil-
lances for site work activities affecting environmentally quali-
fied equipment and uses " HOLD POINTS" to assure witnessing of key
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activities.
See paragraph 4.A(4) for further discussion of
activities to preserve the qualified status of installed equipment
for the life of the plant.
Purchase orders reviewed were observed to be approp^iately
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identified with EQ requirements.
Receipt inspectica for EQ
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equipment and qualification data packages is performed by the
site QA/ Quality Control (QC) organization.
Accepted equipment
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is stored in a controlled area reserved for safety related
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The inspector determined that Ceco QA audits the activities
'
performed by S&L and vendors, including equipment qualification
laboratories.
The.1985 audit schedule planned two audits for
S&L and four audits for equipment qualification laboratories.
During the 10 CFR 50.49 programmatic review the inspection team
noted that Ceco's program is actually established, controlled,
and implemented through S&L procedures such as PI-ZI-14, 23, and
25, which are not referenced in CECO's SNED QC procedure or the
EQR.
Discussions were held with CECO personnel concerning the
'
possibility that Ceco's 10 CFR 50.49 program could be deficient
without the S&L procedures; therefore, some means of correlating
the SNED and S&L procedures might be appropriate to avoid possible
future program problem areas / deficiencies.
The inspection team
did determine that the S&L procedures are being followed and no
programmatic deficiencies were identified.
4
t
Certain documentation discrepancies, typographical errors, and
the like were identified during the programmatic review.
These
,
!
deficiencies are discussed in paragraph 4.D(2) below.
Two Open Items resulted from the EQ program review, as follows:
-
(a) CECO procurement procedures require involvement of the
headquarters SNED, which ensures that EQ procedures are
followed, unless a simple like-for-like component procure-
ment is involved, in which case the station can procure
directly.
Paragraph (1) of 10 CFR 50.49 requires that a
<
00R Guidelines plant such as Zion 2 must upgrade replacement
p
equipment to full rule conformance.
Station personnel are
aware of this requirement and indicated that they follow it;
no evidence to the contrary was observed.
Since station
i
'
procurement procedures do not require upgrading of environ-
mentally qualified replacement equipment, the NRC inspector
recommended that the licensee incorporate the requirement
into the procedure.
Verification of action on this concern
- ,
is considered to be an open item, pending further review
during a subsequent inspection.
(304/85-06-02)
(b) During review of the licensee's EQ training activities, it
'
was observed that a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> qualification maintenance train-
'
ing program had been prepared for CECO engineering and station
personnel.
At the time of this inspection, this training had
only been provided to 28 management personnel.
Only four
site personnel were identified as being trained.
Personnel
from QA/QC, engineering, purchasing, licensing and Quality
,
and Maintenance at CECO Headquarters and site personnel from
engineering, QA/QC, and stores were scheduled to receive
this training.
NRC interviews with licensee and contractor
personnel established a consistent awareness on the part of
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personnel that special requirements apply to environmentally
qualified equipment within the scope of 10 CFR 50.49.
Verifi-
cationLof implementation of the training program is considered
to be an open item, pending further review during a
subsequent inspection.
(304/85-06-03)
(3). 10 CFR 50.49 List
The licensee is required to maintain a list of the equipment
necessary to bring the plant to hot shutdown in case of an
accident.
The first master list of equipment required for
compliance with 10 CFR 50.49 was developed by the licensee in
response to IE Bulletin 79-018.
Between 1980 and 1982 the
licensee evolved a methodology (as described in the CECO submit-
tal to NRC dated April 10, 1984) by which an initial master list
was derived.
At this time Ceco maintains executive control of
the master list and its contractor, S&L, maintains physical
control of the list with the aid of a computerized system.
No
i
formal procedures have been written to document the development
of a master list; however, Ceco and S&L procedures are in place
for keeping the list current with regard to configuration changes
in the plant.
These include CECO procedure Q.42, Rev. 2, dated
January 14, 1985, "E.Q. Documentation Control and Acceptance,"
and several of the procedures listed in paragraph 4.A.(2).
The
reviewed procedures appear to be adequate for maintaining the
master list.
,
Seventeen items were used as the audit sample to verify the
completeness of the master list.
This sample included two items
from Appendix I, " Justification for Removal of Items from the
-
'
Master List," of the EQR as a test of the rationale for deleting
an item from the list.
The remaining fifteen items were selected
to verify that items required to be on the list are in fact on
,
the list, and that items not required to be on the list are in
- .
fact not on the list.
Additionally, a check was made to determine
that items which may be required in the future as part of the TMI
improvement program are not on the list now, but are earmarked for
future consideration.
These sample items were selected from examination of' piping and
instrumentation drawings, a review of the EQR, and from file
inspection items.
The audit verified that the master list was
accurate and complete for every item sampled, except for post-
accident monitoring equipment discussed in paragraph 4.A.(1).
(4) EQ Maintenance Program
The NRC inspectors reviewed the licensee's program for preserving
.
the qualified status of equipment through maintenance and surveil-
lance activities.
Each completed EQ documentation package contains
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a maintenance and surveillance section detailing criteria for
maintaining qualification.
Schedules, inspection checksheets,
and other information pertinent to the specific equipment type
are included.
Based on these criteria, the station prepares
Plant Maintenance / Surveillance Procedures specifying the
activities to be performed in the plant.
A typical procedure,
IMEQ-1 for Rosemount 1153D transmitters, was reviewed by the
inspector.
A typical plant modification package, M22-2-81-51
for installation of qualified transmitters, and the calibration
procedure for the transmitters were also reviewed, and procedural
implications were considered during the plant physical inspection.
The NRC inspectors found no deficiencies in the completed
maintenance and surveillance procedures.
Where EQ procedures
were not yet in effect, the inspectors found that the
normal plant maintenance procedures currently being used did
not compromise the environmental qualification of equipment
reviewed.
Since some of the EQ procedures are not yet completed,
the following open items were identified:
(a) Plant EQ Maintenance / Surveillance procedures have not been
completed for all environmentally qualified equipment, such
as 4 kv Westinghouse motors, Rosemount 176 KF temperature
elements, Conax temperature elements, and D.G. O'Brien
electrical penetration assemblies.
Procedures are being
updated for activities between outages such as lubrication
and bearing inspection.
Procedures are also not in place
to initiate annual review of EQ inspection result trends
and resultant scheduling of changes, modifications, and
i
checks.
The licensee informed the NRC inspectors that
all procedures currently in draft or under revision are
expected to be in place by March 31, 1985.
Verification
of full implementation of the EQ Maintenance procedures
at the station is considered to be an open item pending
further review during a subsequent inspection.
(304/85-06-04)
(b) During the plant physical inspection, the solenoid coil
housings on several non-EQ ASCO solenoid valves were found
to be loose to the touch.
Master List valve 2A0V-800001
was inspected, and the coil housing was not loose to the
touch.
Modification package M22-2-82-36, which covers
installation of environmentally qualified ASCO solenoid
valves, includes and properly invokes ASCO installation
bulletins specifying torque requirements for the solenoid
base subassembly.
Tightness is essential to qualification,
since it compresses two gaskets that prevent postulated
accident atmospheres from entering the coil housing.
Although no discrepancy was observed for the Master List
valve, the loose housings found on several unqualified
.
_ _ _ _ _ _
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9
valves indicate that Plant Maintenace/ Surveillance Procedure
E-024-01 should be reviewed by the licensee for adequacy
with respect to assuring housing tightness.
B.
SER/TER Commitments
The NRC inspectors evaluated the implementation of EQ corrective
action commitments made as a result of the SER/TER identified
deficiencies as stated in licensee submittals dated April 10 and
June 20, 1984.
These submittals stated that all equipment on the
EQ master list is qualified except (a) three component types for
which exemption requests were submitted and (b) certain post accident
monitoring equipment for which a separate, later schedule was
negotiated with the NRC.
Based on review of files whose selection specifically included
components for which the licensee had committed to replace unqualified
equipment,-and on review of the EQ master list, the NRC inspectors
identified no deficiencies in the licensee's implementation of SER/
TER commitments to date.
C.
Plant Physical Inspection
The NRC inspectors, with plant accessibility input from licensee
personnel, established a list of components for physical inspection
that were (1) of the same types for which file reviews were performed
and (2) accessible at the time of the inspection, dyring plant
operation.
Ten components were selected for examination of such
characteristics as mounting configuration, orientation, interfaces,
model number, ambient environment, and physical condition.
Two
concerns were identified during the physical inspection and both
are classified as Potential Enforcement / Unresolved Items.
Details
are as follows.
(1) One concern was identified during the inspection of Marathon
series 6000 and 1600 terminal blocks.
The NRC inspectors
observed that outside containment terminal blocks for control
circuits were locate _d in junction boxes which had top conduit
entries as opposed to the qualification tested configuration of
side or bottom conduit entries.
The inspectors determined from
discussions with licensee personnel that the licensee was
planning to replace all top entry junction boxes with boxes
using side or bottom entries.
However, this action had not
been completed, raising the question of whether or not the top
conduit. entry boxes / terminal block configurations are qualified,
especially for use on inside containment control circuits.
The
specific concern with the top conduit entry boxes is whether
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the cumulative effect of control circuits with terminal block
leakage currents will trip the associated power circuit breaker
itself and thus render all circuits from that breaker ineffective.
Since the licensee was unable to present any data during the
inspection that would demonstrate that this concern regarding the
qualification of top entry junction boxes did not exist, this is
identified as a Potential Enforcement / Unresolved Item.
(304/85-06-05)
(2)
Inspection of an outside containment Limitorque valve operator
.
revealed the presence of a plastic protective shipping cap
'
on the valve operator gear case grease relief valve.
Although
this is probably acceptable for outside containment uses, the
j.
question was asked whether shipping caps also were installed
on operators inside containment.
As a result of this question,
Ceco sent personnel inside Unit 2 containment on the morning of
Friday, January 18, 1985.
These personnel found and removed
the covers from two operators, plant ID numbers 2-MOV-RC-8000A
'
and B.
This action was reported to the NRC during the exit
meeting.
The presence of shipping caps on valve operator gear
case' grease relief valves created a situation where the
installed equipment configuration was different from the
equipment configuration for which qualification had been
,
'
established.
Since the above described difference in equipment
,
i
i
configuration raises questions regarding the qualification of
'
the installed equipment prior to the removal of the shipping
caps, this deficiency is identified as a Potential Enforcement /
i
Unresolved Item.
(304/85-06-06)
'
- 0.
Detailed Review of Qualification Files
The NRC inspectors examined selected Zion EQ documentation
packages and supporting documents to verify the qualified status of
equipment within the scope of 10 CFR 50.49.
In addition to comparing
plant service conditions with qualification test conditions and verifying
the bases for these conditions, the inspectors reviewed such things as
,
required post accident operating time compared to the duration of time
the. equipment has been demonstrated to be qualified, similarity of
tested equipment to that installed in the plant (e.g., insulation
!
class, materials of components of the equipment, tested configuration
compared to installed configuration, and documentation of both),
evaluation of adequacy of test conditions, aging calculations for
t'
qualified life and reple. cement interval determination, effects of
decreases in insulation resistance on equipment performance, adequacy
of demonstrated accuracy, evaluation of test anomalies, and applica-
bility of EQ problems reported in IE ins / Bulletins and their resolution.
The Zion EQ packages reviewed by the NRC inspectors were generally in
'
conformance to 10 CFR 50.49 except for the following deficiencies.
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(1) Incomplete documentation packages - Some of the EQ documentation
packages were not complete and issued to the station at the time
of inspection.
The following concerns were noted:
(a)
Package EQ-ZN039 for Rosemount resistance temperature
detectors (RTDs) was not fully assembled.
Test report
WCAP-9157, references identifying plant equipment,
maintenance and surveillance requirements, and the like
were missing.
(b) "Open Items Lists" at the front of some packages identified
missing information.
For example, in EQ-ZN035 for Rosemount
transmitters, documentation of installed plant equipment and
a study demonstrating the acceptability of a reduced operating
time were not yet included.
(c) Package EQ-ZN011 was being expanded to include information
on Marathon 1600 series terminal blocks, as well as 6000
series, but the expansion was not completed.
Although no technical deficiencies were observed because of this
incompleteness, the issuance of the remaining Zion EQ Packages is
considered to be an open item pending verification during a
subsequent inspection.
(304/85-06-07)
(2) Deficiencies in documentation - Several minor errors in the form
of discrepancies, omissions, typographical errors, and the like
i
were noted by the NRC inspectors, including the following:
(a)
SNED procedure Q6, Rev. 9, Exhibit I, section 4.0(e) defines
harsh environment as radiation exceeding 5 x 10E4 rads,
with no mention of other parameters.
The EQR, section 4.2
pp 26-7, defines harsh environment as exceeding 1 x 10E4
rads, atmospheric pressure and 90% humidity.
(b) Definition of "long, mid, and short term" operating times
was not provided in Rev. 4 of the EQR.
The licensee
indicated that,Rev. 3 had contained definitions inadvertantly
omitted from Rev. 4.
(c) For charging pump motors the zone description specified
3 psig environment, while the EQ package stated " unknown"
plant pressure and 0 psig qualified pressure.
The licensee
indicated that the discrepancy is simply a documentation
error.
!
(d) The type test documentation for the charging pump motors is
l
not clear in identifying whetner the same stator was subjected
l
to all type tests.
In response to questions the licensee
indicated that the same stator was used throughout testing,
'
[
and initiated action to obtain documentation from Westinghouse
'
to clarify the files.
,
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(e)
In lists and tabulations in the EQR the following deficiencies
were identified.
[1]
Limit switch A0V-DT 9170 was listed on the qualified
status list in Appendix L when in fact it should have
been deleted per the list of Appendix I.
[2] Typographical errors in the main steam isolation valve
listings of Appendix K were identified.
4
[3] Remote shutdown panels were identified in Appendix I
for Unit 2 when in fact they should have been deleted
as were the panels for Unit 1.
(f) The review checklist form in package EQ-ZN011 omitted
reference to terminal block orientation, which is necessary
to establish qualification.
Verification of correction of these deficiencies in documenta-
tion is considered an open item, pending further review during
a subsequent inspection.
(304/85-06-08)
(3)
Lack of specific quantitative treatment of MSLB environmental
profile inside containment for replacement equipment - The hRC
inspector's review of the EQ documentation packages revealed
that replacement equipment was being procurred to the same
severe accident environmental criteria used for evaluation of
original plant equipment.
The Ceco evaluation considered only
the LOCA profile for in-containment equipment and not the in-
containment MSLB profile, which could be more severe.
However,
i
for replacement equipment paragraphs (e) and (1) of 10 CFR 50.49
l
require qualification to be established for the most severe
i
design basis accident during or following which the equipment
l
is required to remain functional.
CECO identified that the following types of replacement equip-
ment have been ordered since the effective date of 10 CFR 50.49,
installed in the plant, and considered qualified without
addressing a specific in-containment MSLB profilo:
Conax seals,
Namco limit switches, and Raychem splices.
Ceco stated that,
although a specific MSLB profile was not considered in the
l
qualification review of this equipment, actual qualification
l
test conditions would probably exceed the plant conditions.
CECO
!
stated that it had not considered MSLB environmental profiles
!
when establishing qualification for replacement parts due to past
correspondence with the NRC regarding qualification environmental
profiles and its interpretation of the upgrading requirements of
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CECO was advised that the upgrading requirements of 10 CFR 50.49
do require reevaluation or recalculation of environmental para-
meters for replacement equipment within the scope of 10 CFR 50.49;
therefore, this deficiency is identified as a Potential
Enforcement / Unresolved Item.
(304/85-06-09)
E.
The NRC inspectors reviewed and evaluated Ceco's activities relative
to the review of EQ related IE ins / Bulletins.
The inspectors' review
included examination of CECO's procedures and EQ documentation packages
relative to 12 ins and one Bulletin.
The review determined that CECO
does have a system for distributing, reviewing, and evaluating ins /
Bulletins relative to qualf'fied safety related equipment within the
scope of 10 CFR 50.49.
Dur'ng the review of individual.EQ document-
ation packages, which include copies of applicable ins / Bulletins with
definition of each's impact on equipment and resolution of any concerns,
the NRC inspectors evaluated the actions taken by CECO relative to
the applicable ins / Bulletins for that package.
No concerns were
identified during this review of Ceco's activities.
.
!
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