ML20151V383

Notice of Violation from Insp on 880329-0602.Violation Noted:Procedure Zap 3-51-4 Inappropriate to Circumstances for Listed Reasons & Inadequate Design Control Measures

ML20151V383
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:
Shared Package
ML20151V376	List: IR 05000295/1988003 ML20151V373 ML20151V383
References
50-295-88-03, 50-295-88-3, NUDOCS 8808220262
Download: ML20151V383 (5)

Text

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, , r NOTICE Or 10LATION Commonwealth Edison Company Docket No. 50-295 As a result of the inspection conducted on March 29 through J :ne 2,1988, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1987), the following violations were identified:

1. 10 CFR Part 50, Appendix B, Criterior. V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the ci-cumstances and shall be accomplished in accordance with these instrc.* s, procedures, or drawings. Instructions, procedures, or dr..s.ngs shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Zion Administrative Procedure ZAP 3-51-4, Revision 23, "Frocedure Governing the Use of Temporary Jumper Cables, the Lifting of Terminated Wires, the Bypassing of Alarms, or the Installation of Mechanical Blocks or Bypasses," was issued to specify the procedural requiremer.ts for performing each of the titled activities.

Contrary to the above, the procedure, ZAP 3-51-4, was inappropriate to the circumstances for the following reasons: (1) it failed to provide adequate procedural guidance to ensure that safety evaluations were performed prior to the performance of these safety-related and nonsafety-related temporary alterations involving components described in the FSAR, and rep::rted to the NRC on an annual basis, as required by 10 CFR 50.59;

) (2) it failed to describe the electrical power system issues which should be addressed prior to performing the alteration for using jumpers or lifting terminated wires such as power source capability, availability of circuit protection, cable characteristics, and cable routing.

This is a Severity level IV violation (Supplement I).

2. 10 CFR Part 50, Appendix B, Criterion III, requires that measures shall be established to assure that applicable regulatory requirements and the design basis for safety-related components and systems are correctly translated into specifications, drawings, procedures, and instructions.

Measures shall also be established for the selection and review for  ;

suitability of application of materials, parts, equipment, and processes i that are essential to the safety-related functions of the systems and components. Design control measures shall be applied to items such as l

the following: reactor physics, stress, thermal, hydraulic, and accident I analyses; compatibility of materials; accassibility for inservice inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.

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O 8 Notice of Violation 2 Contrary to the above, design control measures did not ensure that the design basis for systems and components were correctly translated into specifications, drawings, procedures, and instructions nor did they ensure that the suitability of application of the equipment and processes that are essential to the safety-related functions of the systems and components were met. Specifically:

A. Modification M22-1-86-33 contained assumptions in the design uncertainty calculation related to temperature rise of 50 degrees F, value for accuracy of measuring and test equipment, and value of station calibration tolerances; however, there was no justification to support the suitability of these assumptions. In addition, the assumption that the drift period was 12 months was inappropriate since the calibration frequency was 15 to 18 months rather than 12.

B. Modification M22-1-86-09 contained calculations for the pressure switch setpoint which failed to incorporate the accuracy of the instrumentation and the accuracy of the measuring and test equil. ment, which would be necessary in determining an accurate setpoint value.

C. Modification M22-1-86-37 failed to appropriately consider the accumulator relief valve thrust in the analysis of the relief-line piping.

D. Modification M22-1-85-20 involved zhe possibility of installing longer limit switch actuating arms; however, no design calculations had been performed to determine their seismic qualification.

E. Modification M22-1-87-05 for the auxiliary feedwater pump oil reservoir drains qualification analysis made inappropriate use of the result of a seismic analysis to qualify the equipment for steady-state vibration, and failed to consider vibration information obtained by measurements.

This is a Severity Level IV violation (Supplement I).

3. 10 CFR Part 50, Appendix B, Criterion XI, requires that a test program shall be established to assure that all testing required to demonstrate that structures, .ystems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.

Notice of Violation 3 Centrary to the above, the test program did not demonstrate that systems or components would perform satisf actorily, was not performed in accordance with written test procedures, did not incorporate the requirements and acceptance limits contained in applicable design documents, and did not include provisions for assuring that all prerequisites for the given test had been met. Specifically:

A. Although Modification M22-1-86-23 involved the disconnecting and reconnecting of various relay contacts, limit-switch contacts of Class 1E motor-operated valves, and output contacts of various Class 1E instruments; the specified post-modification testing did not include testing of any of these components to ensure that they would continue to perform satisfactorily.

B. The testing requirements in ModificaticiM22-1-87-03 failed to incorporate specific nondestructive examination criteria, although Section XI of the ASME Code requires such examination, failed to utilize design tables providing design and operating pressures and temperatures for the component, and failed to specify a tolerance or upper limit for the "greater than 50 psig" test pressure.

C. Although the design modification approval letter for Modification M22-1-87-05 stated that the post-modification test was to be performed with the reservoir full and with the pump running, the test procedure was written for the test only to be performed with the pump off. In addition, the test procedure failed to identify three screwed joints that were to be verified leak tight, and the test procedure did not contain any acceptance criteria.

D. The post-modification test for Modification M22-1-86-37 was performed without any written test procedures or instructions directing testing activities or establishing acceptance criteria.

As a result, key test parameters such as test pressure and valve lineup during the test were not identified or recorded.

This is a Severity Level IV violation (Supplement I).

4. 10 CFR 50.59(b)(1) requires that the licensee shall maintain records of changes in the facility made to the extent that these changes constitute changes in the facility as described in the safety analysis report.

These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. .

Notice of Violation 4 Contrary to the above, no safety evaluations were performed for temporary modifications B-7030, "Modify IC Feedwater Pump Recirculation Valve,"

L-960, "Lif t Lead on Pressurizer Heater," or L-Irff, "Lif t Leads on Pressurizer Heaters."

This is Severity Level IV violation (Supplement I).

5. Technical Specification 6.1.7.A.1.(a) requires that the Offsite Review and Investigative Function shall review the safety evaluations for changes to equipment or systems as described in the safety analysis report completed under the provisions of 10 CFR Section 50.59 to verify that such actions did not constitute an unreviewed safety question.

Contrary to the above, although safety evaluations were written for some temporary modifications performed, these evaluations were not reviewed by the Offsite Review and Investigative Function.

This is a Severity Level IV violation (Supplement I).

6. 10 CFR Part 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality, such as failures, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken to preclude repetition shall be documented and reported to appropriate levels of management.

Contrary to the above, established measures failed to assure that the cause of significant conditions adverse to quality was determined and corrective action taken to preclude repetition. Specifically:

A. Modifications M22-1-86-35 and M22-1-86-38 contained numerous Speed ers documenting plant deficiencies; however, there was no .

Oce that these deficiencies had been reviewed to determine l cause of the deficier.cy, the impact on plant systems or proper  ;

fur, tioning of affected circuits, or the specific corrective action '

to be taken to preclude repetition of the deficiencies. l B. A general work request was issued as a result of NRC-identified cable tray deficiencies which resuited in a number of cables being '

placed back into trays without determining the significance of these safety-related cables not being in accordance with plant design requirements, the cause of the associated deficiencies, or the appropriate corrective actions to ensure that the cable was not damaged and was reinstalled in the correct tray segment.

This is a Severity Level IV violation (Supplement I).

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Notice of Violation 5 Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each. violation: ,(1) corrective action -

taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration m.sy be given to extending your response time fer good cause shown.

AUG 121988 Dated Huber(s0. Miller, Director Division of Reactor Safety

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