ML20151V373
| 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: |
| References | |
| NUDOCS 8808220256 | |
| Download: ML20151V373 (3) | |
See also: IR 05000295/1988003
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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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AUG 121988
Commonwealth Edison Company
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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
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SovMI reports and continue to exist at the Zd,on station.
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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
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modifications examined. This led to deficiencies in setpoint calculations,
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incomplete analyses, and improper definition of post-modification testing
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scope or acceptance criteria.
For example, the design analysis for a
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modification involving the auxiliar feedwater pump oil reservoir drains
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assumed a 2 inch valve, when a 1 inch valve was installed; and the
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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.
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Many examples we e found where p scedural steps had been overlooked or poorly
implemented in all phases of modification work.
Specific examples included
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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.
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Based on the findings throughout the report, it is apparent that your quality
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oversight activities have been marginally effective.
Completed ~ modification
packages were accepted by supervisors before required testing was performed;
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reviews of safety evaluations failed to identify deficient evaluations; and
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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
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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,
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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,
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as specified in the enclosed Notice. A written responte is required.
In addition, your response should also address the following:
(1) how you
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will improve your technical oversight of detailed design changes made by
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consultants; (2) your measures to increase the level of attention to detail
and adherence to procedural requirements by your staff and contractor
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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.
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Commonwealth Edison Company
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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
Jan Norris, Project Manager, NRR
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DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Richard Hubbard
J. W. McCaffrey, Chief, Public
Utilities Division
Mayor, City of Zion
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