ML20151V373

Forwards Safety Insp Rept 50-295/88-03 on 880329-0402,11-15 & 18-29 & Notice of Violation.Item Dealing W/Inconsistent Design Process,Preparation of Sers,Lack of Attention to Detail & Inadequate Quality Oversight Noted in Insp Rept

ML20151V373
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	08/12/1988
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML20151V376	List: IR 05000295/1988003 ML20151V373 ML20151V383
References
NUDOCS 8808220256
Download: ML20151V373 (3)

See also: IR 05000295/1988003

Text

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AUG 121988

Docket No. 50-295

Commonwealth Edison Company

ATTN: Mr. Cordell Reed

Senior Vice President

Post Office Box 767

Chicago, IL 60690

Gentlemen:

SUBJECT: SAFETY SYSTEMS OUTAGE MODIFICATIONS INSPECTION

This letter forwards the results and conclusions of the Safety Systems

Outage Modification Inspection (SSOMI) of Unit I at the Zion Nuclear

Generating Station. The objective of this SSCMI was to assess the degree

of success you have achieved in your corrective actions responding to the

findings of an NRC SSOMI conducted at the Dresden Nuclear Generating Station

between December 1985 and July 1986. The inspection team was composed of

NRC personnel and consultants, The inspection was divided into two parts

with the design portion being conducted on March 29 through April 2 and

April 11-15, 1938, and the installation and testing portion being conducted

on April 18-29, 1988. Followup inspections were conducted on May 16-18, and

May 31 through June 2,1988. A management exit meeting was held at the site

on April 29, 1938; a subsequent management exit meeting was held on July 6,

1988, to review followup inspection findings and potential enforcement items.

The purpose of the design portio'1 of the SSOMI was to determine, through an

examination of specific work packages, that design and engineering activities

were adequate to support modifications, and to determine whether services or

products acquired to support the outage were in accordance with your

commitments and regulatory requirements.

The purpose of the installation and test portior, of the SSOMI was to determine,

through an examination of specific work packages, that implementation of the

selected modifications conformed to design and installation requirements,

and to verify that the repaired or modified components and systems have the

requirca or:erating configurations and have been adequately tested to ensure

that they are capable of performing their intended functions,

The number and scope of modifications completed during the outage and examined

by the inspection team were limited, and therefore the sampling base was

considered to be small. While at the conclusion of the inspection,

optrability concerns for these modifications had bean resolved, a large number

of deficiencies were found in these modification packages. This indicates

that corrective actions responding to the 550MI findings at Dresden have been

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Commonwealth Edison Company 2

AUG 121988

only marginally effe ' 7. For example, items dealing with inconsistent

design processes, preparation of safety evaluation reports, lack of attention

to detail, and inadequate quality oversight were identified in the Dresden '

'

SovMI reports and continue to exist at the Zd,on station.

he observed a lack of adequate direction to the Architect-Engineers performing

the work and a lack of adequate review of the A-E's product in many of the t

modifications examined. This led to deficiencies in setpoint calculations,  ?

incomplete analyses, and improper definition of post-modification testing +

scope or acceptance criteria. For example, the design analysis for a ,

modification involving the auxiliar feedwater pump oil reservoir drains

'

assumed a 2 inch valve, when a 1 inch valve was installed; and the  !

setpcint calculation for a modification involving the addition of a flow

transmitter utilized a 12 month drift when the calibration frequency was  :

15-18 months.

,

Many examples we e found where p scedural steps had been overlooked or poorly

implemented in all phases of modification work. Specific examples included i

failure co document work performed, failure to perform post-modification

tests in accordance with procedures, and failure to review safety evaluatiens

required by technical specifications. These examples lad the team to conclude  ;

that an attitude existed at Zion that resulted in a lack of attention to

detail in assuring procedural compliance. had the design changes been

properly implemented and the planned work procedures foilowed, the team

believes that the overall modification program would have been adequate. ,

Based on the findings throughout the report, it is apparent that your quality [

oversight activities have been marginally effective. Completed ~ modification

packages were accepted by supervisors before required testing was performed; i

reviews of safety evaluations failed to identify deficient evaluations; and -

quality control inspected and accepted work that contained nonconformances and

deficiencies. One example involved the replacement of wide-range pressure

transmitters. The work instruction indicated that a horizontal run sloping <

downward one inch per fcot was to be installed; however, the accepted

installation consisted of twisted tubing with many upward and downward  ;

direction changes. For this modification, neither the installer's walkdown, ,

contractor's QC signoff on the work traveler, CECO technical staff engineer's  ;

signoff on the work traveler, or CECO QC staff signoffs on the traveler  ;

identified this deficient condition.

Many of the above concerns appear to be in violation of NRC requirements, '

as specified in the enclosed Notice. A written responte is required.

In addition, your response should also address the following: (1) how you '

,

will improve your technical oversight of detailed design changes made by l

consultants; (2) your measures to increase the level of attention to detail l

and adherence to procedural requirements by your staff and contractor i

personnel; and (3) the measures you have taken or plan to take to improve the

effectiveness of your quality oversight activities to ensure that deficiencies ,

and nonconformances are identified and resolved. l

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, ,

Commonwealth Edison Company 3 AUG 121988

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter and your response to this letter will be placed in the NRC Public

Document Room.

The r anses directed by this letter and the accompanying Notice of Violation

are ...t subject to the clearance procedures of th Office of Management and

Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

.

Sincerely,

. galclHM SIGNED BY. IlVBERT J. MILLER

Hubert J. Miller, Director

Division of Reactor Safety

Enclosure: Inspection Report

No. 50-295/88003(DRS)

,

cc w/ enclosure:

T. J. Maiman, Vice President,

PWR Operations

H. Bliss, Nuclear *

Licensing M a ager

G. J. Plim1, Station Manager l

Jan Norris, Project Manager, NRR I

DCD/DCB (RIDS)

Licensing Fee Management Branch

Resident Inspector, RIII

Richard Hubbard

J. W. McCaffrey, Chief, Public

Utilities Division

Mayor, City of Zion I

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