IR 05000295/1988003

Safety Sys Outage Mod Insp Rept 50-295/88-03 on 880329-0602. Violations Noted.Major Areas Inspected:Design,Installation & Testing of Several Mods to Be Performed During Outage & Util Corrective Action Program

ML20151V388
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	08/12/1988
From:	Athavale S, Bongiovanni A, Dunlop A, Hasse R, Mendez R, Phillips M, Stasek S, Vandenburgh C, Wright G, Yin I 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 8808220266
Download: ML20151V388 (57)

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V.S. NUCLEAR REGULATORY COMMISSION-REGION'III h

Report No. 50-295/88003(DRS)

Docket No. 50-295 License No. OPR-39 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Unit 1 Inspection At: Zion Site, Zion, Illinoi ,

Sargent and Lundy Engineers, Chicago, Illinois Cygna Corporation, Chicago, Illinois Inspection Conducted: March 29 through April 2, 1988 April 11-15 and 18-29, 1988 Followup Inspection Conducted: May 16-18, 1988 May 31 through June 2, 1988 Team Members: /. / _r -

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1. Mr Date Consultants: J. Houghton, E. Willhaus, J. Haller, M. Good, D. Ford, R. Compton, and R. Jacobstein Reviewed By: 7 Mo6te P. Phillips, Chief Date Operational Programs Section Approved By: a y /2 s Date Gebffr69tC]BranchWright, Operations Chief Inspection Summary Inspection on March 29 through June 2,1988 (Report No. 50-295/88003(DRS))

Areas Inspected: Announced Special Safety System Outage Modification Inspection (SS0MI) to evaluate the design, installation, and testing of several modifications performed during the Unit 1 outage. The objective of the inspection was to assess the degree of success within the licensee's corrective action program in 'esponse to the findings identified during an SSOMI conducted at the Dresden Station between December 1985 and July 198 Results: Based on the inspection, the inspectors reached the following conclusions:

The control of temporary alterations was inadequate, especially in the areas involving performance of 10 CFR 50.59 safety evaluations, offsite review of safety evaluations, and control over how long alterations existed in a temporary status.

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The corrective actions to be implemented as a result of the findings of the Dresden SSOMI had not been fully implemented, especially in the installation and testing area ,

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The quality oversight activities performed were often ineffectiv Completed modification packages were accepted by supervivors before required testing was performed; reviews of safety evaluations performed i failed to identify the missing references to Technical Specifications or '

the FSAR; Quality Control inspected and accepted work that contained nonconformances and deficiencies; and Quality Assuranue had act ensured that deficiencies and violations identified during the Dresden SS0MI had been identified and corrected at the Zion statio '

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i The design process applied to modifications was inconsistent due to a "

lack of adequate. direction to the~ Architect-Engineers performing.the -l work and a lack of' adequate review of the A-E's product. This led to >

inconsistencies in setpoint calculations, incomplete analyses, and improper definition of post-modification testing scope or acceptance criteri *-

There were numerous examples of lack of attention to-detail ' involving virtually all aspects of work performed as evidenced by procedural steps which had been overlookea or poorly implemente i

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At the conclusion of the inspection, operability concerns for the modifications which were inspected had been resolve ,

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Violations identified during this inspection are discussed in Paragraphs 2.1.2.1, 2.2.2.2, 2.2.2.3, 2.3.2.3, 2.4.2.1, 2.4.2.2, 2.4.2.4, 2.4.3, 2.5.2.1.1, 2.5.2.1.2, 3.1.2.2, 3.3, 3.5.2.2, an .5.2.6.

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Unresolved items identified during this inspection are discussed in Paragraphs 2.2.2.1 and 3.1.2.1 .

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SUMMARY 1.1 Introduction A trial NRC SSOMI involving inspection and evaluation of design, procurement, installation, and testing for some safety system modifications was conducted at the Dresden Nuclear Generating Station between December 1985 and July 1986. [See NRC Inspection Reports 50-249/86009 (Design) and 50-249/86012 (Installation and

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Test) for details.] The SSOMI identified licensee program weaknesses in design change control, equipment installation, procedures, quality assurance / quality control (QA/QC) overview, corrective action implementation, and testing control. Since then, the Commonwealth Edison Company (CECO) had initiated and completed extensive corrective actions, including development of improved procedures, verification of additional modification packages, performance of in-depth system functionality reviews, and improvements in personnel trainin The SSOMI, conducted between March 29 and June 2, 1988, at the Zion Nuclear Generating Station, consisted of both design and, installation and testing inspections, and was performed to assess the effectiveness of CECO corrective actions for the Dresden inspection finding >

The purpose of the design portion of inspection was to determine, tt ough an examination of specific work packages, that the detailed design and engineering work was adequate, in accordance with licensee commitments and regulatory requiremerts, to support the safety-related modification Tnis included the review and evaluation of Ceco corporate and site engineering, contractor engineering, and the effectiveness of Ceco ,

oversight of contractor performanc There were two purposes of the installation and testing portion of the inspection. The first was to gain added assurance, through an examination of specific work packages, that the licensee's design, design control, and work control systems were properly implemented to ensure that installed equipment was in conformance with design and installation requirement The second purpose was to determine whether the repaired, modified, or newly installed components and systems had required operating configurations and had been tested to ensure that they were capable of safely performing their intended function l 1.2 Overall Conclusions The team concluded that weaknesses exist in the licensee's upgraded plant modification program. This was partially due to the fact that not all facets of the upgraded modification program developed in response to the SSOMI findings at Oresden had been implemente Furthermore, a number of problems identified during this inspection were generic and not program related, such as the lack of attention to details and the bypassing of i corporate-established measures for identifying and correcting deficiencie !

By the end of the inspection, all operability concerns had been resolved '

and the inspectors concluded that the modified systems were capable of j safely performing their intended function j

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The modifications made by the licensee during the refueling outage were limited in number, scope, and complexity; nonetheless, the team was able

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to identify the following significant program weaknesses: The control of temporary alterations was_ inadequate. Safety evaluations required for these alternations were not prepared in many cases, especially for nonsafety-related alternations of systems described in the FSAR, and those evaluations which were prepared were not reviewed by the Offsite Review Function as required by the Technical Specifications. In addition, there was no control on how long an alteration could remain '! temporary."

Some of the temporary alterations had remained unanalyzed for year '

This latter concern had also been identified in a recent INP0 audit. The licensee had initiated actions to correct the safety evaluations concern by the conclusion of the inspectio . The design process applied to modifications was inctnsistent due to a lack of adequate direction to the Architect-Engineers performing the work and a lack of adequate review of the A-E's product. This led to inconsistencies in satpoint calculations, incomplete analyses, and improper definition of post-modification testing scope or test acceptance criteri . Preparation, review, and approval of safety evaluations for compliance wit h 10 CFR 50.59 was weak evidenced by lack of ieference to the FSAR or technical specification . "he post-modification test procedures and acceptance criteria needed to meet design criteria were not clearly delineated, and in one case, the testing was performed without any procedure or acceptance criteri . t!umerous examples were found where procedural step, had been overlooked or poorly implemented in all phases of modification work, i.e., design, installation, and testin These examples lead the team to conclude that an attitude existed at the Zion station that resulted in a lack of attention to detail in assuring procedural complianc The team also noted during followup inspections that the licensee had initiated actions to correct this weaknes . The quality oversight activities performed were often ineffectiv Completed modification work packages were accepted by supervisors before required testing was performed or when improper testing was performe Reviews of safety evaluations performed failed to identify the missing references to Technical Specification or the FSAR. Quality Control inspected and accepted work that contained nonconformances and deficiencie Corrective actions to be implemented as a result of the findings of the NRC's SSOMI at Dresden in 1986 had not been fully implemented. In addition, many of the findings of this inspection were identical to those found at Dresden in 198 For example, the items dealing with inconsistent design processes (2); preparation, review and approval of safety

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evaluations (3); lack of attention to detail (4); and inadequate quality oversight (6) were all identified in the Dresden reports and continued at the Zion statio . The use of Speed Letters to identify deficiencies without logging and cortrolled followup bypassed the fundamental princioles of quslity assurance, which are to ensure effective deficiency idertification, evaluation, disposition, trend analysis, corrective measures which address the root causes of the conditions, and prevention of problem . The control and evaluation of . load additions to a given safety-related power bus was done in such an informal manner that the margins of safety were uncertain. The licensee had earlier identified this problem and was in the process of developing an Electrical Loads-Management System (ELM), which is scheduled for implementation at the Zion station in September 198 . Numerous examples of electrical separation issues were identified involving configurations that did not meet FSAR commitments for independence, cables outside raceway systems, cables pulled very tight, cable trays missing covers, and mixing of divisional and non-divisional cables. The licensee had recently identified these same concerns and was in the process of evaluating the problem to determine appropriate corrective action . It was the team's perception that, in some instances, some technical personnel faced excessive workloads. -The team was unable to determine whether this was the result of staffing inadequacies, imbalance, inadequate pre-outage planning, or the impact of the inspection team on outage activitie .0 DESIGN INSPECTION 2.1 Electrical Power Modifications 2. Scope The electrical portion of the design inspection consisted of a detailed review of selected plant modifications, associated work packages, and procedures. The modification packages were reviewed for completeness, technical accuracy, and proper evaluations and approvals. The inspection included a technical evaluation of modification project plans, safety evaluations, calculations, drawings, test criteria, work packages, and associated procedure The team also interviewed cognizant design and station personne The design inspection also included a review of maintenance work requests and lifted lead logs dealing with the electrical power syste _ - - _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ __ _ _ _ - - _ _ .

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2. Discussion The inspection identified findings in one of the seven modifications and in one procedure involving the electrical power system.- These findings are discussed in the following paragraphs. The maintenance work requests and lifted lead logs that were reviewed were found to be acceptabl .1. Procedur Q P 3-51-4 ZAP 3-51-4, is part of the CECO temporary alterations procedure and called for "Onsite Review and Approval" of a temporary power feeder for either safety-related (Class 1E) or nonsafety-related electrical power systems prior to installation. The procedure does not, however, specifically state the electrical power system issues which should be addressed. In order to comply with General Design Criterion 17, which is included in Appendix A to 10 CFR Part 50, the licensee needs to consider the following electrical system issues in order to demonstrate that the addition of a temporary power feeder will not result in the degradation of the capacity or capability of a Class 1E electrical power source or circui . power source capability and capacity to provide the temporary feeder required, availability of circuit protection and coordination, appropriate temporary power feeder cable characteristics, and proper temporary power feeder cable routin Criterion V of 10 CFR Part 50, Appendix B requires that work be accomplished in accordance with written procedures which are !

appropriate to the circumstances. By failing to address the above ,

concerns, ZAP 3-51-4 was not appropriate to ensure that Class 1E l electrical power source or circuits would not be degraded on '

installation of a temporary power feeder. This is a violation ;

(295/88003-01). i 2.1.2.2 Modification M22-1-86-11 Modification M22-1-86-11 consisted of replacement of the core exit thermocouple and the subcooling margin monitor with new instrumentation. The project plan for this plant modification stated, in Section 3.2.1.3, Electrical Requirements, that there would be an insignificant load increase on the Class 1E power i sources as a result of the addition of the new instrumentatio '

The statement that the load increase would be insignificant was not demonstrated in the design package by calculations or references to the base line bus-loading information and actual magnitude of the load addition. With regard to design modifications that result in electrical load additions to Class 1E buses, the same electrical issues and potential degradation of power sources as for temporary alterations (Paragraph 2.1.2.1 above) appl .. .

2.1. Electrical Load Management System (ELMS)

During the review of the licensee's' undocumented / informal procedure for considering loading additions to Class 1E electrical systems, the

. team.noted that considerable dependence is placed on.the original electrical system design of Sargent & Lundy-Engineers (S&L). S&L procedure ESI-163 (Revision 2-1-85), "Electrical Engineerin Instructions for Preparation and Maintenance of the Tabulation of Loads on Station Aniliary Power Systems," was used for developing the auxiliary electrical system loading data at the Zion statio This procedure is acceptable and sufficient if_S&L is cognizant of-all changes' to the auxiliary electrical systems made by the . licensee and other design agents. As the present load management effort doesi not have the benefit of input from recent plant walkdowns, the additions to the base line design reflected in S&L's "Tabulation of Loads" may not be all inclusiv To alleviate this concern and that of future ioad additions to the Class 1E medium- and low-voltage AC power systems and to the Class 1E DC power system, CECO has set a target date of September 1, 1988, for the implementation of an ELMS developed by S&L. 'The ELMS was developed based on the licensee's determination that load addition concerns existed. It is understood that the ELMS ,

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will determine the power source (transformer, bus, cable, etc.)

loading, fault duty, and voltage profile for various plant operating conditions resulting from Class 1E bus load addition A short demonstration of the system by S&L using fictitious input data was observed by the inspection team. The team reviewed the system and have no negative comment . Conclusion

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The significant finding in design change control fer the electrical '

power systems area dealt with the addition of electrical loads to Class 1E electrical buses resulting from either temporary alterations or design modifications to the plant. General Design Criterion 17 of Appendix A to 10 CFR Part 50 implies that electrical power systems shall have sufficient capacity and capability to assure operation of the plant's safety systems; therefore, the . licensee needs to demonstrate, by calculations or otherwise, that potentia?

loading additions, either temporary or permanent, will not degrade the Class IE systems. This should be accomplished through the implementation of the ELMS program, which was developed based.on the licensee's determination of the same proble .2 Instrumentation and Control Modifications

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l The inspection team's review included evaluation of design data, safety evaluation of the modifications, calculations, drawings, test instructions, and applicable procedures. The team also reviewed work orders, Ceco'. program for temporary alterations

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of plant configuration, and CECO's preve'ntive maintenance program related to this inspection. As a part of the design evaluation process, the team conducted interviews with plant and engineering /

design personne . Discussion The team reviewed the following modification packages, work orders, calibration packages, and plant procedure .2. Modification M22-1-86-11 Modification M22-1-86-11 consisted of replacing the original core exit thermocouple and subcooling margin monitor (SMM) instruments configuration of thermocouples, heatea reference junction box, and an indicator with a new reference junction microprocessor-based temperature-averaging module and a display. In addition, old nonqualified wires and cables were replaced with qualified wires and cable The thermocouple loop monitors and averages the temperature of the water in the subcooling area of the reactor vessel. The instrument strings are divided in two redundant trains.

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Microprocessors and displays for both trains were located in free-standing cabinet CB-116 in the main control roo The two train components in this cabinet were connected by fiber !

optic cables through which data between redundant trains was transmitted back and forth. This cabinet also contained redundant Class 1E power supplies, digital transducers, and new cable connections betwcen Class 1E reactor coolant system (RCS) pressure signal transmitters PT-403 and PT-40 During the design review of this modification, the inspection team noted that the designers did not perform a single-failure analysis, although many new components had been added to the existing instrument loop. The team was informed by the designers that a single-failure analysis was not required. The team reviewed physical layout of the components (shown on Drawings 22E-1-4566E Revision A and 22E-1-4566F Revision B) and noted that train A components were located in the upper cabinet compartment and train B components were loct.ted in the lower compartment. A partial metal barrier was installed between them, but there were spaces around the barrier. In this arrangement, had a fire occurred in the lower half of the cabinet, the temperature could rise in the upper compartment and disable the microprocessor units of the redundant trai Similarly, had smoke been generated due to a fault in the train B power supply, it could have also damaged and disabled the train A microprocessor and other solid-state electronic component The licensee engineers responded to the team's concern by stating that the design of this modification was reviewed by NRC in 1986 and an exemption to the requirement for a single-failure analysis had been granted. The team reviewed the correspondence, CECO letter to Mr. H. Denton, dated February 19, 1986, and NRC letter from

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Mr. S. A. Varga to CECO, dated August 18, 1986, and noted that the NRC review was based on a conceptual block diagram submitted by CEC Detailed drawings showing the physical arrangement were. not submitted for NRC review. The inspection team subsequently discu'ssed this situation with'the NRR Reactor Systems Branch and learned that the exemption granted to CECO was restricted to the reactor head area and was not a blanket exemption. CECO maintained its position that smoke will never be generated due to any kind of fault in the power supplies; and even if both trains of-the subcooling margin monitoring system were disabled, it still would not create any misrepresentation of reactor core temperature information. The team found that the-statement "no harm done even if both trains of SMM systems are lost" was incorrect, based on Attachment 3 to the "Emergency Operatin Procedures," dated February 19, 1986,' which. stated in Section FR-P.1, Step 4, that a caution statement was added to alert the operator that the required indication of the reactor vessel level indicating system (RVLIS) might not be attainable under some circumstance The caution statement also informed the operator that the subcooling margin monitor could provide additional information. This change increased the reliance on the subcooling margin monitor. The inspection team's finding was that the SMM system is important and required by Section II.F.2 of NUREG-0737. Therefore, this instrument is subject to the single failure criteria of Appendix A to 10 CFR Part 5 An additional evaluation performed by S&L concluded that there was no problem. The S&L evaluation will be reviewed by NRC. This is an unresolved item (295/88003-02).

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2,2.2.2 Modification M22-1-86-33 Modification M22-1-86-33 consisted of installing a safety-related flow transmitter to measure and control the containment spray system eductor flo The transmitter was required to be mounted on a seismically aualified instrument rack in the auxiliary buildin This transmitter feeds the flow signal to two loops. The team reviewed uncertainty calculations for one loop consisting of a transmitter, a square-root extractor, and an indicator. The inspection team had the following concerns: 1 J The instrument loop is safety related but the calculation was marked "non safety-related." There was no documented justification for the various assumptions used in this calculation, such as: a temperature rise of 50 F, the value for accuracy of '

the measuring and test (M&TE) equipment, and the value of the station calibration tolerance.

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are calibrated once every 15 to 18 months; therefore, the i calculation should have been performed using 15 to 18 months

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drif Instead, only 12 months drift was evaluate . .

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S&L calculation CI-87-CS-01 was revised based on this longer drift period, and the error in flow measurement was found to be insignifican . In another calculation reviewed by the team for ModificEtion M22-1-87-03, calculations CJ-87-RV-04 and 05, which were made to determine the loop setpoint for the reactor vessel narrow-and wide-range level transmitters, the design stated that,

"Effects of tap points for high and low pressure sides of the transmitter measurement range versus transmitter location and pressure changes if any are not addressed in this calculatio These items should be compensated for during the calibration of the transmitter." CECO stated that sensing line head tap locations, transmitter locations, and other data are provided to the station along with setpoint values and served as input for preparing the station calibration procedur The team interviewed plant personnel responsible for calibration and post-modification testing, and found, that instrument setpoint and loop uncertainty values furnished by engineering / design personnel were applied "as is." The team reviewed the pressure switch setpoint calculation for the residual heat removal (RHR) system's suction line in Modification M22-1-86-09. This calculation was performed by Nutech, Inc. The team noted that the calculation lacked many required details; for example, the accuracy of the instrument was not accounted for, the accuracy of the M&TE was not considered, and the calculation had many unverified assumption Subsequently, Nutech revised the calculation and satisfied the inspection team's concern The team was informed that CECO plans to install a comprehensive corporate-level setpoint calculation program that will provide consistent design methodology and data upgrades for all safety-related instrumentation (initial phase). The scheduled completion of this program for the Zion, LaSalle, and Quad Cities Nuclear Generating Stations is December 31, U8 Concerns 2 and 5 above constituto examples where the licensee failed to determine that the assumptions used were suitable in calculating the uncertainties in the flow signal or pressure setpoint,  !

respectively. Concern 3 is an example where the assumption used was unsuitable in calculating the flow signal uncertainty. Errors in setpoint or flow uncertainties can affect the operation of the safety system. Failure to adequately account for correct drift allowance, accuracies of M&TE used, temperature / density compensations, and correct values of calibration tolerances may create a situation where the measured variable may be in texcess l of its allowable safe value without being detected. Criterion III of 10 CFR Part 50 requires, in part, that measures be established for the selection and review for suitability of application of processes that are essential to the safey-related function of the syste However, concerns 2, 3, and 5 above are all examples where

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the suitability of application of the assumptions made were not determined or improperly determine This is a viciation (295/88003-03A).

2.2.2.3 Modification M22-1-86-23

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Modification M22-1-f>6-23 consisted of removing all unneeded annunciator lights from the bypass and permissive (B&P) annunciator panel in the Unit 1 control room, including disconnecting 34 annunciator lights and rearranging the remaining lights -so that all the connected lights are "on" only when the monitored conditions are abnormal. The test requirements and test acceptance criteri described in Section III.5 of the final project plan (reference S&L letter No. Z192 dated December 22,1987) stated that "The Bypass and Permissive status panel indicating lights should be checked for proper operation after this modification is installed. The. system test will be deseloped by the station. The station will define the ,

acceptance criteria for modified indicating lights." The team reviewed _the post-modification testing record and noted that the .

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scope of the testing was limited to testing the remaining connected

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lights and their associated logic; it did not include testing ~of all :

the Class 1E equipment where the signals to the lights were either disconnected or modified. This equipment was givea only a visual check as part of the physical verification of the modification on March 22, 1988, which was part of plant procedure _19 for control circuit The team determined that the scope of the post-modification testing was not adequate, since the modification

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involved disconnecting and/or reconnecting various relay contacts, limit-switch contacts of Class 1E motor-operated _ valves, and output ;

contacts of various Class 1E instrument ,

Criterion XI of 10 CFR Part 50 requires that a test projram shall be established to demonstrate that systems will perform satisfactorily and perform in accordance with written test procedures. However, by failing to test all of the components involved in this modification, the specified post-modification testing was incdequate to demonstrate that the systems would perform satisfactorily. This is a violation (295/88003-04A).

2.2.2.4 Modification M22-1-86-09

Modification M22-1-86-09 consisted of installing a small-diameter line and a pressure switch in the suction header of the RHR pump The team reviewed the safety evaluation for this modificacion i l

required by 10 CFR 50.59. A small break in the instrument sensing I line was assumed for this evaluation, and it was concluded that the resulting leak would not deplete the RCS coolant inventory. The team determined that the safety evaluation could not have been conclusive unless the following factors had also been considered: effects of the postulated size of the leak during normal plant operation,

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. . effects of released effluents on environmental qualification of the electrical and instrumentation and control (I&C) components located in the affected area, and response time for the leak dete-tion system, which could affect total loss of RCS inventory and probability of growth of a small leak into a large brea The team's evaluation of CECO safety evaluation program for permanent modification is documented in Paragraph 2.5.2.2 of this repor .2.2.5 Temporary Alteration Program The team reviewed the CECO Temocrary Alteration Program for the Zion station by reviewing the following procedures: ZAP-3-51-4, "Temporary Alterations," Revision 2 . ZAP 3-51-4, "Procedure Governing the Use of Temporary Jumper Cables, the Lifting of Terminated Wires, the Bypassing of Alarms, or the Installation of Mechanical Blocks or Bypasses."

[ Note: Both of these two different titled procedures had the same procedure number.] Station Nuclear Engineering Department (SNED) Procedure Q.6, Revision 0, dated March 11, 198 The team had the following concerns: Immediate installation of temporary alterations was allowed without performing the required 10 CFR 50.59 safety e valuation Prior to the conclusion of this inspection, CECO issued a directive to correct this violatio . Section 7, of ZAP 3-51-4, "Temporary Alternations," stated I that, "All safety-related temporary alterations not installed 1 as part of an approved procedure or technical specification ,

action requirement require an onsite PWR engineering technical '

review. The onsite PWR engineering technical review is a post- ,

installation review and shall be completed within 60 days after '

the installation date. Temporary alterations restored to the original design condition within 30 days after installation date do nct require an onsite PWR engineering technical review."

These statements raised two concerns. First, safety-related temporary alterations could be made that were not in accordance with approved procedures and were without technical assessmen Second, for the temporary alterations that were returned to their original conditions within 30 days, the synergistic effects of the alteration on the plant's safety systems and any possible permanent damage would not have been determine . The team noted that the Zion station did not have effective tracking of the temporary alterations; the only tracking

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system was a manually kept log. The procedures were ntt clear and contained contradictory statements. One procedure stated "if the alteration is not closed in one year consider it permanent." Other procedural steps required alterations be reviewed once every six months to determine whether te cancel or make them permanen The team was informed by CECc that the recent INPC audit of the same area identified similar concern The team reviewed portions of the INP0 report and noted that'

some of the temporary alterations had remained unanalyzed and temporary for years.

- The team found no method for annotating the essential control room drawings to reflect the temporary alterations. The procedure had a step that directed the reviewer to verify whether drawing changes were involved (Step h, technical evaluation, Part I, Page 48 of ZAP 3-51-4),'but it did not require markup of the control room drawings in a timely manner. The team was concerned that the control room drawings, which are normally used by the plant operators, might not be fully dependabl During a followup inspection, the team reviewed ZAP 3-51-4,

"Procedure Governing the Use of Temporary Jumper Cables, the Lifting of Terminated Wires, the Bypassing of Alarms, or the Installation of Mechanical Blocks or Bypasses," Revision 24, dated May 6, 1988, and had no adverse comment The Region III office will follow up on procedure implementatio .2.2.6 Design Modification Control Procedure The team reviewed CECO directive NS00-M14, Revision 0, for design '

modifications at the Zion station. The directive required the station staff to establish detailed acceptance criteria for the post-modification test The team commented that the establishment of post-modification test acceptance criteria might more appropriately be the engineering / design groups responsibility, as they are knowledgeable of the related design parameter '

2.2.2.7 Preventive Maintenance Program t The team evaluated the preventive maintenance program for the safety-related equipment. The evaluation included review of printouts of computer data base and maintenance procedures and interviews with program planners and I&C and station electrical staff. The review involved the following:  ;

, Work Request Z65532 involving an environmental qualification-related inspection of the motor and replacement of parts for containment fan cooler unit 1BRCFC in accordance with procedure E031-1, Revision . Work Request Z65410 involving EQ-related inspection of the motor and replacement of parts for limitorque MOV in accordance with procedure E022-1, Revision . . Work Request 200157 involving cerformance of calibration and inspection of reactor coolant flow transmitter 1FT-414 in-accordance with instruction IF-414T, Revision Preventative Maintenance Package IF-414E, involving performance of inspection and calibration of all instruments-(except the transtitter) shown on Drawing 22E-1-4945A, Revision '

The team noted that the program at the Zion station was based on a computerized data base system and that two separate data bases had been established. The team reviewed new data input for equipment added to the system during this outage per modification M22-1-86-11, and they noted that all the required data, such as frequency, next due date, and present status, had been entered in the computer data base properly. The team found that CECO had effective procedures to control these addition . Conclusion The team reviewed instrumentation and control design modifications performed by various A-Es in accordance with CECO's old and new design control programs. The team observed that the design processes applied to these modifications were inconsistent; that is, some were adequate, others were not. The team considered that the Pressurized Water Reactor Engineering Department (PWRE) did not provide adequate direction to its A-Es or review of the A-Es'

design processes. As a result, there were inconsistencies in

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setpoint calculations, and there were calculational errors, incomplete analyses, and insufficient design input data, as well as improper definition of testing scope and establishment of acceptance criteri .3 Mechanical Systems Modifications 2. _ Scope The team reviewed the modification packages generated under the old plant modification procedure and those generated under the new plant modification procedure. The packages were reviewed for completeness ;

ano conformance to licensee procedures, the licensing design basis ,

as described in the Updated Final Safety Analysis Report (UFSAR),

and national codes and standards, l Review of modification plans, detailed work packages, temporary alterations, and the Zion station administrative procedures (ZAPS)

were included in the scope of the inspection, as well as limited reviews of calculations, specific deviation reports, and specific Zion station letters applicable to the outage modifications.

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Testing Requirements and criteria developed by engineering personnel and their interface and translation into plant review and implementation documents were reviewed by the team for both safety-related and nonsafety-related portions of outage modifications, with emphasis on differentiation between testing requirement ..m - ., , -. , _ . _ , . , - . . - . -_, ~ , _ .,

._ .

. .

Specific reviews were performed by the. inspectors of outage modification safety evaluation The team also examined the methods of approval, by the onsite review function, of safety evaluations. The inspection team reviewed the block bypass logs (temporary alterations), and compared the' plant design basis codes with subsequently issued codes, code conditions /

~

addenda and other plant design basis documents and licensing commitments to ensure FSAR commitments were me . Discussion 2.3.2.1 Use of National Codes Issued Later Than the FSAR All Zion station seismic Class I piping was designed to comply with the requirements of ANSI B31.1-1967, "Power Piping Code," as identified in the FSAR Amendment response to NRC questions 4.64, 4.65, and 4.66 and in the UFSAR Section 1.10.4.2. Use of a later Code, Code Edition / Addenda, and Code Cases mest therefore be reconciled with the plant design basis code, ANSI B37 1-196 The S&L review plan for modifications includes the following statement: "Code requirements are implicitly a part of every review process... The Codes and Standards applicable to Zion systems and components can be found in the FSAR."

The team review of modifications M22-1-87-05, -07, -08, and 86-07 :

indicated that the piping was designed to ANSI B31.1-1967, but the seismic Class I piping stress analysis was performed using the computer program PIPSYS based on ASME Boiler and Pressure Vessel

, Code,Section III,1977 Edition through Winter 1978 Addenda (NC-3600). The ANSI B31.1-1967 Code was included in he modification plan, while the ASME Code,Section III, wes identified ,

in S&L piping analysis reports. S&L also stated that toe ASME Code,Section III, may be used for calculations NC-3652 since "it is more conservative than ANSI B31.1-1967."

When questioned as to the use of the ASME Code,Section III, without reconciliation with the design basis Code, ANSI B31.1, and its inclusion in the FSAR, S&L generated a comparison of the two Codes, calculation EMD-062763, with specific stress analysis details, and concluded that ASME Code,Section III, 1977 Edition through Winter 1978 Addenda "is either equivalent to, or more conscevative than, ANSI B31.1-1967, and as such can be used for analysis on the i Zion Power Plant." No evidence was found by the team that the ASME l Code,Section III in any Edition or Addenda was included in the FSAR or in any FSAR Amendments or the Updated FSAR transmitted to the NRC for review and approva In addition, the team found no evidence that any later Codes, Code Edition / Addenda, or Code Cases cove recent than the Winter 1987 Addenda had been compared to l'

ANSI B31.1-1967 to ensure that 831.1-1967 specifications were always met.

,

I j

.

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The followup inspection conducted by the team revealed no safety concern CECO has made a commitment to be more cautious when usinc the later codes and providing any necessary documented reconciliation.

,

2.3. Use of Regulatory Guides Not Committed To in FSAR FSAR Appendix IB provides the . licensing . basis for "Compliance to AEC Safety Guides." Only those Regulatory Guides (formerly-Safety Guides). included in the FSAR or those included in FSAR Amendments or ,

the Updated FSAR are considered to be applicable to the Zion station, unless shown to be acceptable in plant design basis document The team review of modification M22-1-87-05, -07, and -M showed ;

that Regulatory Guide 1.29, "Seismic Classification of 5 vuctures Components, and Systems," was invoked in the S&L Review plan for seismic classification, while the FSAR commitment is to Safety Guide 29. The design ir-luded in the referenced modifications ;

did not reflect the spec,r'c seismic Class I boundaries for proper application to the ater Regulatory Guide 1.29. No evidence was provided or found by the team to indicate reconciliation with

,

.

Regulatory Guide 1.29 or how the Regulatory Guide was apolied at the !

Zion statio The followup inspection conducted by the team revealed no safet concern CECO has made e commitment to be more cautious when using Regulatory Guides not documented in the FSA .3. Modification Test Requirements

The Zion station modification program ZAP 3-51-1B requires identification of testing requirements and accaptance criteria, including adequate information, as applicable, for plant testing ,

to ensure compliance with the FSAR design basis and licensing commitment 'l In modification M22-1-86-37, the testing requirements excluded inservice inspection for 1-in. and smaller piping in accordance with the S&L interpretation of the ASME Code,Section XI, but did require visual examination of welds based on S&L's interpretation !

of ANSI B31,1, Article 136. S&L also required that a "snoop" test ;

be performed at normal operating pressure. No differentiation was made by S&L for high pressure safety-related piping (ASME CodesSection XI, jurisdiction) and low pressure, nonsafety-related piping (ANSI B31.1 jurisdiction).

In modification M22-1-87-03, the testing requirements specified th the low pressure, consafety-related portions of the piping (pipin Design Table G) be tested to "a pressure greater than 50 psig" an that a visual inspection be performed during hnt :hutdown in accordance with ASME Code,Section XI,1980 Edition through Winter 1980 Addenda. No specific differentiation was made between safety-related piping and nonsafety-related piping for test pressure, and l

_ - _ _--_- --- - -_

. .

no tolerance or upper limit was identified for the "greater than 50 psig test pressure." No reference was made to the plant design basis ASME Code,Section XI Program; no specifie nondestructive examination (NDE) was identified, whereas the plant modification package attachment for the ASME Code,Section XI, repair / replacement program requires surface examination by liquid penetrant r' hods for all 1-in, welds in ASME Code,Section XI jurisdiction; and design /

installation specifications were listed as "whichever is applicable at the time of the inspection." Although the Zion station piping design tables provided design and operating pressures and temperatures, the testing requirements and criteria for the modification should have identified the speci'ic applicable portions of these tables to assure technical revi u and applicabilit CFR Part 50, Appendix B, Criterion XI requires that a test program shall be establi:hed to demonstra,e that systems will perform satisfactorily and perform in accordance with written test procedures, which incorporate the requirements and acceptance limits contained in applicable design documents. The failure to specify an upper pressure limit; failure to incorporate requirement from the plant design basis ASME Code,Section XI Program; and failure to identify the applicable portions of the design and operating pressures and temperat.!res are examples where the post-modification test did not incorporate the requirements and acceptance limits co-tained in applicable design documents. This is a violation (Do/88003-04B) .

2.3.2.4 Reference ASME Section XI ASMd Code,Section XI, 1980 Edition through Winter 1981, IWA-7220, requires review by the owner and inclusion of an evaluation report in the acomentation (IWA-7520) of a review for suitability of replacement ZAP 3-51-6, Revision o, dated December 22, 1987, did not include requirements to assure that documentation evaluating suitability of replacements for santy-related pressure retaining components and subcomponents used as replacements, renewal parts, or modifications were included in the ASME Code,Section XI, program records as required by the Code, nor does it reference the Code, i CECO has made a commitment to upgrade the procedur No specific safety problems were rev.aled after documentation searc .3.2.5 Onsite Reviews and 10 CFR 50.59 Evaluation Administrative Procedure ZAP 2-54-1 describes the purpose and scope l of the onsite Review and Investigative Function. This function serves the same basic purpose as the onsite Revi6w committees more ;

commonly used at other nuclear power plants. Procedure ZAP 2*54-1 requires that this function (hereafter referred to as onsite review) ;

be discharged in a:cordance with Technical Specification 6.1. "Onsite Review and Investigative Function," and Quality Procedures 3-51, 10-53, and 15-52,

. .

The onsite review must be applied to all proposed changes or modifications to plant systems or equipment that affect nuclear safety prior to installation and must be documente The inspection-team had two concerns in this area: (a) Zion procedure zap 3-52-1 l'

requires the Technical Staff Supervisor to review setpoint change This does not meet the requirement for c site review in that it is not mult1 disciplinary, (b) Zion procedure ZAP 3-51-4, which governs temporary modifications, contains a form for documenting the onsite review. This form requires a response to each of the three criteria from 10 CFR 50.59 for determining if an unreviewed safety questio,. is-involved. Thus, this form is in essence a 10 CFR 50.59 evaluation, although it is not identified as such. The form does not meet the requirements for an onsite review in that a multidisciplinary review is not guaranteed. The program evaluation conducted by the inspection team is described in Paragraph 2.5 of this report.

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2.3. Modification Approval Letter CECO's Nuclear Safety Department Directive NSDD-M14 and ZAP 3-51-1B, required that the safety evaluation, required by 10 CFR 50.59, and the modification approval letter be included in the modification package by SNED (later PWRE).

The team's review of modification M22-1-86-09, "RHR Pumps-Low Suction Pressure Alarm," identified inadequate assessment of each of the 10 CFR 50.59 questions and inadequate justification in the modification description portion of the modification approval '

letter, as follows: The question 1 response included statements that "... and any leak would be small in compariso with system leakage,"

and "...so any potential for leak is low." These statements did not address the previous FSAR evaluatio . The question 2 respease stated "minor leak," "flow is small in comparison with system flow," and "this type of accident has been analyzed." No specific bounding cases were reference . The question 3 response did not specifically refer to related Technical Specifications to justify the statement "not evaluated in Technical Specifications." The safety evaluation did not address single-failure criteria or make reference to any specific FSAR section relative to FSAR analysis for allowable leakage in the reactor coolant boundar When the team interviewed the Chairman of the onsite review

,

staff (Technical Staff Supervisor) regarding the acceptability of this specific safety evaluation, he recalled having a problem with it, discussing it with the preparer, but act t ag

,

t it without revision. When questioned as to how the safet;  !

evaluation was accepted by the onsite review staff, he '

indicated that onsite review approval of the modification package constituted approval of the safety evaluation, i J l

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_. . - _ - - - _ _ . _ _ _ _ _ _ _ - - - - _ _ _ _ _ . _ - _ . - - _ _ _ - - _ . _ _ - _ - . _ _ _ . - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - - . . _ - . - _ . . _ _ - - . . . _ _ _ . _ _ _ - _ _ _ . - _ - - _ _ _ _ _ - _ _ - - - . - - - _ - . - _ - _ _ - _ . - - _ - _ _ _ _ _ _ _ _ . - _ _ _

. _ _ _ _ _ _ _ -

o .

During this discussion period, a proposed draft procedure ZAP 2-54-5 was provided to the inspection team for informatio The team noted in its review of this document that proper assessment of the 10 CFR 50.59 evaluation criteria was included in the proposed draft procedur . The modification described the maximum pressure and design pressure as "switch overpressure rating is 150 psig." The description implied, however, that credit would be taken for higher pressures than allowed by the design by stating:

"The switch burst pressure is greater than 600 psig so that the RHR System prassure boundary integrity is maintained in the event of a valving error." No single-failure or other analysis relative to protection of RCS or RHR inventory was included in the package. No evidence was provided by the Zion station staff or the A-E (Nutech) during a team interview to substantiate the allowance for pressures higher than 150 psi The inspection team's program review is discussed in Paragraph of this report. No safety concerns were identified regarding this specific modification.

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2.3.2.7 Control of Block / Bypass The Block / Bypass Log form in procedure ZAP 3-51-4 provides for a description and disposition of the block / bypass, including modification number or drawing change request (DCR) numbe The inspection team review of the block / bypass (Log No. 6-033)

made to "block line between IB RHR pump and valve 1RH0002" found that a safety eval v tion was performed and approved by an onsite I

review. The "temporary alteration" was identified in the technical staff review as "fabricate a spool piece." The initial Block / Bypass Log entry did rat identify any addition of hardware although that is what actually occurred, ar.d was prepared and approved more than 18 months prior to the technical staff review. The log was never updated to indicate that a modification or DCR would be made, nor any indication that a "spn1 piece" was eve installed; however,

.

the Zion station letter regarding the onsite review (OSR/066/87)

of this issue indicated that it would be resoved by performing modification M22-1-87-38, which was awaiting SNED approva This is an example of poor contre. of a temporary alteratio i l

2. Conclusion

)

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The most significant weakness in the mechancial systems modification area at the Zion station is in the preparation, review, and approval of safety evaluations for compliance with 10 CFR 50.59. This has been evident in the lack of reference to and address of the Zion station FSAR and Technical Specifications. A second weakness is the lack of adequate test requirements and criteria in the plant modification packages. A third weakness is the lack of reconciliation between the Zion plant design batis Code and documents and the use of later Codes, Code edition / addenda

_ _ _ _ _ _ _ _ _ _

. .

and other documents, such as Regulatory Guides. A fourth weakness is the control of "temporary alterations."

2.4 Mechanical Components Design Modifications 2. Scope The team reviewed a number of modification packages for technical acceptability, adherence to procedures, fulfillment of license commitments and meeting of regulatory requirement CECO and contractor personnel were-interviewe '

2. Discussion 2.4. Modification M22-1-86-37 Modification M22-1-86-37 consisted of reorienting the existing inplace Unit 1 accumulator tank relief valves and modification of the connecting piping. The modification was initiated because the individual relief valve inlet centerlines were located in the horizontal plane, and it was believed that this position caused erratic valve operations due to the settling of crud in the valve

,

> eating are All accumulator tank relief valves are safety-related up to their discharge connections and, accordingly, analysis of piping and supports must be performed and documented. Small-bore piping ,

as-built drawings were prepared to support the analysis of the new

valve orientation and pipe routing. The team's review identified the following uficiencies: ,

t The reaction forces (thrust due to blowdown) resulting from relief valve actuation were not appropriately considere The Power Piping Code ANSI B31.1-1967 requires, in Paragraph 101.5.1, that "impact forces caused by all internal conditions be considered." This concern was brought to the attention of S&L, and their response was that it had been considered, but because the valve was a relief valve rather than a safety valve the thrust loading was deemed to be too .

low to conside l

' The loadings on supports found by the analyses of various

conditinns were not checked against the support allowable ,

loads given in Supplement 60-3 to Piping Specification X-2242, i

!

Containment Piping Systems, dated February 9, 1973, and, !

in many instances, were in excess of those allowabl !

S&L suggested that the allowable loads were excessively low because of the high factor of safety inherent in hanger i standard components design and applications. They also said i that the fact that the supports had undergone a number of i operation cycles and were still in place indicated that the loads were acceptabl l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _

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c .

-2.4.2.2 Modification M22-1-85-20 Modification M22-1-85-20 consisted of modifying the containment vent and purge valves to allow no more than 50 percent opening during plant operation. The modification was not intended to preclude the ability to fully open the valves'during an outage. To accomplish this, the valve's limit switches had to be modifie If repositioning the limit switches as far as they could be moved did not accomplish the specified valve position indication, the limit switch actuating arm was to be replaced by a new and longer arm. Whether the existing arm or a longer arm would be used was to be determined in the field. The team's review identified the following deficiencies: The new and longer arm was not seismically qualifie . The component with the new 1r nger arm was not seismically qualified.

Since this component and its parts are seismic Class 1,'the lack of seismic qualifications means that the FSAR commitments have not been me Subsequent to the team's identification of these deficiencies, the licensee submitted the Cygna . Corporation reanalysi This ;

analysis was found to be acceptable by the tea .

2.4. Modification M22-1-86-34 Modification M22-1-86-34 consisted of modifying the containment -

spray system diesel control panel cabinet by adding acrylic straps held down by wing nuts to prevent disengagement of relays (ILP-30 for Unit 1, and 2LP-30 for Unit 2) due to vibratio The team disagreed with the licensee that only parts of the modification were safety related. The modification was intended

to maintain functionability of the relays; therefore, the complete l

>

device, as designed, should be considered to be safety relate The team also considered that because of the vibratory environment, hand tightening of the wing nuts as specified could not assure that' 1 the wing nuts would not back off. The team also found that no I seismic analysis was performed for the seismic Class 1 relay installatio Subsequent to the team's review, the licensee submitted a number of analyses to address the team's concerns. Also, the wing nuts were replaced with regular nuts and proper torquing was applie .4. Modification M22-1-87-05 l Modification M22-1-87-05 consisted of modifying the auxiliary

feedwater pump oil reservoir drains by adding piping and valves to make obtaining oil samples easier with less oil loss. The drain l l

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19 )

l

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y

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i line included a vertical-to-horizontal run to the valve, a maximum of 26.5 or 21.5 inches, depending on the pumps, but the actual lengths were to be determined in the field, The team found the enveloping seismic analysis acceptable; however, results of the seismic analysis were used to qualify the design for steady-state vibratio S&L's seismic analysis yielded the first two frequencies at abcut 8 Hz, and the next two at about 97 H ,

The remaining frequencies were higher. S&L assumed that the natural '

vibration frequency of the pump was 60 Hz based on a 3580-rpm rotating speed. S&L concluded that because 60 Hz is remote from either 8 Hz or 97 Hz there would be no significant dynamic response due to steady-state vibration and that no additional steady-state vibration analysis was require The inspection team determined that the weight of the valve used in the modification was 1 lb (not the 2 lb used in the enveloping seismic analysis) and that the length of the pipe in the horizontal run might be less than 21.5 inches. In addition, the team noted that the assumption that 60 Hz was the only driving frequency present in the purro was not realistic. A subsequent interview with site personnel yielded dita, available in-the field, which showed that other frequencies were presen S&L ran two new analyses with a 1 lb valve, instead of 2 lbs; one with a 26.5 inches horizontal leg length, and one with a 21.5 inch horizontal leg length. The shorter-leg-length model yieldeo low frequencies at about 30 Hz. This indicated that the actual vibration may be-close to the 60 Hz value if the horizontal run is less than 21.5 inches. As a result, the licensee will watch for any excessive line vibrations during operatio .4.3 Conclusion r

Deficiencies identified during the review included the following: Accumulator relief valve thrust was not appropriately considered in the analysis of the relief-line piping and the restraints on the relief-line pip:ng might not be adequat . Containment vent and purge valves, which may require new, l longer limit switch actuating arms, were not seismically qualifie . The containment spray diesel relay control panel acrylic straps ,

were not identified as safety-related and were not seismically I analyze I

\ The auxiliary feedwater pump oil reservoir drains qualification analysis made inappropriate use of the result of a seismic analysis to qualify for study-state vibration and failed to !

consider vibration information obtained by measurements, j l

. _ _ _ , ._ . . .-= -

ap ..

" '

The many discrepancies identified above pointed to the fact that Ceco design control was inadequate, which may have been attributed to a lack of attention to details when documenting design '

justi'ication ,

10 CFR Part 50, Appendix B, Criterion III requires that measures

'

-shall bc escablished to assure that applicable regulatory requirements and the design basis are correctly translated-into '

,

specifications, drawings, procedures, and insouctions. General Design Criterion (GDC) 2 requires components be designed to .

withstand the effects of earthquake Similarly, GDC 4 requires #

components and systems be designed to accommodate the effects of environmental conditions associated with normal operations and postulated accidents. These components shall be appropriately protected from dynamic effects, including the effect of pipe whippin The above four modification analyses constitute examples where the '

applicable regulatory requirements were not correctly translated into specification, drawings, procedures, and instructions because  ;

the analyses were incomplete. This is a violation (295/88003-038),

2.5 10 CFR 50.59 Safety Evaluations

"

2. Scope

>

The team reviewed the safety evaluations and applicability ,

determinations pursuant to 10 CFR 50.59 conducted by the licensee ,

!

for 12 temporary alterations and 15 modifications during this inspection. This is a followup design review made in conjunction with the discussions documented in Paragraph 2.3.2.5 of this repor . Discussion

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2.5. Temporary Alterations 2.5.2.1.1 Onsite Review i

The follow'ng temporary alterations were reviewed to determine I whether 10 CFR 50.59 safety evaluations were performed when i s required and whether those performed were adequate:

B-6033 Block RHR Pump Seal Flush Line i B-7030 Modify IC Feedwater Pump Recirculation Valve

, J-218 Modify DG Test Circuitry L-932 Disable 1C Feedwater Pump Thrust Bearing Trips J L-960 Lift Lead on Pressarizer Heater i L-1069 Lift Leads on Pressurizer Heaters I L-1092 Relocate Mimic Bus 111 l L-2050 Adjust Thrust Bearing Probe During DG Feedwater {

Pump Operation.to Avoid Trip  !

L-3018 Disable Containment Evacuation Alarm on High i i Flux at Shutdown .

1 L-6035 Modify DG Test Contact

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1

_ _ - - _ - - _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ - - - _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ - - _ _ _ - - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ - - _ _ _ _ - - _ - _ _ _ _ _ _ . _ - _ _ _ _ _ _ - _ _ _ . - - _ _ - -

r

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L-6070 Modify DG Circuitry to Allow Undervoltage Trip

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Jon Specified Breakers When DG is Running-L-7019 Ensure Condensate Booster Pump >Re ire Path on Unit Tri ,

The licensee failed to perform the safety evaluations required by 10 CFR 50.59 for modifications B-7030,'L-960, and L-1069. . The regulation requires that a safety evaluation' be performed for changes to the facility as described in the FSAR:to determin whether an unreviewed safety question would be created. Temporary modification B-7030 consisted of modifying the recirculation valve on feodwater pump IC to allow only 50*, opening (apparently due to vibration problems). The feedwater pumps are described in '

Section 10.4.3 of the FSAR. The description includes a discussion of the recirculation function. Further,-the importance of the feedwater syste- to plant safety is attested to by the fact that two of the accidents evaluated in the FSAR involve feedwater malfunctions (Section 14.1.8, "Loss of Feedwater" and Section 1441.?,

"Excessive Heat Removal Due to Feedvater Malfunction"). Thus, the requirement for a safety evaluation of this modification is clea Similarly, temporary alterations L-960 and L-1069 consisted of removing Unit 2 pressurizer heaters from service by lifting loads (this was an out-of-service situation since the heaters had burned -

out). The total pressurizer heater capacity is described in FSAR Table 4.1.4-2 (1800 kw). Technical Specification 3.3.10 specifies the minimum capacity for operation (150 kw) to support natural circulation cooling if needed. These modifications removed 46 kw of heating capacity from service. Based on the original 1800-kw capacity and the minim m requirement of 150 kw, no immediate safety problem existed. @ese evaluation should have-bean made however, through the 10 CFR 50.59 evaluation process. The failure to perform these safety evaluations was due, ir part, to a programmatic deficiency. These are examples of a violation of 10 CFR 50.59 requirements (295/88003-05).

Three programmatic deficiencles were identified by the team as follows: The safety evaluations for temporary modifications were performed as part of the onsite revie The procedure l controlling temporary modifications (ZAP-3-51-4) did not l require an onsite review of temporary modifications made j to non safety-related equipment or systems. This effectively caused the licensee to fail to perform the required evaluation for any FSAR nonsafety-related system (see above), i The onsite review of temporary modifications could be performed'

as much as 11 days after the modification was completed. Th'. s .

an unreviewed safety question would be indeterminant for this period of tim . Temporary modifications that were subject to'the 10 CFR 50;59 evaluation process were not being reported to NRC as required '

by 10 CFR 50.59(b)(2). l

. .

10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstance However, the above three concerns constitute examples where ZAP 3-51-4 was inappropriate in assuring that the requirements of 10 CFR 50.59, as applied to temporary modifications, were implemente There are further examples of th: violation discussed in Paragraph 2.1.2.1 of this report (295/88003-01).

By the end of the inspection, the licensee had initiated action to address these deficiencies, including immediate implementation of a requirement to perform a 10 CFR 50.59 applicability check and safety evaluation prior to making c temporary modificatio The team's followup review of ZAP 3-51-4 for Temporary Alterations concluded that the revised procedure was acceptable. (See Paragraph 2.2.2.5 of this report).

2.5.2.1.2 Offsite Review The team identified a deficiency with respect to Technical Specification 6.1.7.A.1(a). The specification requires offsite review of the safety evaluations for changes made to equipment or systems described in the FSAR to verify that such actions did not create an unreviewed safety question. Although safety evaluations were written for some temporary modifications, discussion with offsite review personnel indicated that these evaluations were not reviewed by the offiste review group, in violation of Technical Specification 6.1.7. A.1.(a) (295/88003-06).

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2.5. Permanent Modifications Of the 15 permanent modification safety evaluations reviewed, two of the initial evaluations contained conclusions not supported by design analyses. The evaluation for Modification M22-1-86-11 concluded that the effect of adding new instrumentation to the electrical bus was insignificant; however, the bases for this conclusion was not demonstrated in design package by calculations or reference to the base line bus-loading information ar.d magnitude of load additio The evaluation for modification M22-1-86-09, had several deficiencies: ' The evaluation stated that any leakage of the new system would be small and was bounded by existing analyses in the FSA It failed +.o reference the existing analysis and assess its applicability with respect to leakage impact on electrical

,

and I&C components in the ate j The evaluation stated that this type of accident (system leakage)

was not evaluated in the Technical Specifications. It did not l reference the Technical Specifications based on LOCA protection l and assess the maximum leakage against these base j l

!

1

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4 The evaluation did not address single. failure consequence [ Although the design pressure for the modification was 150 psig, the evaluation appeared to.take credit for a switch burst pressure in excess of 600 psig without supporting documentatio During the inspection, a new draft' procedure was provided to the

'

inspection team for information. The team determined in its review of this draft procedure that proper assessment of the 10 CFR 50.59 t evaluation criteria.was included in this procedur '

2. Conclusion -

The licensee had a major programmatic deficiency with respect to the 10 CFR 50.59 evaluation procass for temporary modifications. This led to the failure to perform safety cvaluatioas when' required, j perform safety evaluations'after modifications were made, and failure to report modifications that were-subject to-the 10 CFR 50.59 evaluation process. In addition, technical specification requirements -t were not being met in that no o'fsite-reviews of safety evaluations were performed for temporary modifications.

-

With respect to permanent modifications, inadequacits in design

' analysis and a deficiency in load control for Class 1E buses led '

to the potential for having inadequate information tc perform a thorough safety evaluation. In addition, the safety evaluation

'

did not always document the bases for the conclusions reache However, the licensee had identified this latter concern and

, developed a new procedure which the inspection team determined !

should result in proper 50.59 evaluation !

1 3.0 INSTALLATION AND TESTING INSPECTION I

3.1 Electrical and Instrumentation Modifications Installation  :

3. ,

Scope

i In the electrical and instrumentation area, the team reviewed ten safety-related modifications. Modification packages were reviewed and discussed with Technical Staff engineers and appropriate craft personnel. Field inspections were conducted to verify that

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modifications were made in accordance with installation drawings and

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modification work instructions. Completed modification documentation was reviewed for proper signatures, QC/QA witness points, bill of materials, supervisory review and other requirements specified by the Zion station modification procedures.

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3. Discussion

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3.1. Modification M22-1-86-34 Modification M22-1-86-34 consisted of installation of holddown straps to prevent relays in the containment spray diesel control i

,

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panel cabinet from becoming disengaged. The relays involved in this modification were part'of the diesel starting-sensing circuit, which provided control for the diesel-driven containment spray pump.~

This control system contained a voltage-sensing circuit for each of the two 125VOC battery bank Upon sensing a voltage level below the prescribec limit, a ratchet relay would automatically switch starter supply to the other batter In 1986, the plant encountered the following relay operation problems: On February 24, 1986, the Unit I diesel driven containment

. spray pump was configured for a local start condition in order to fulfill the requirements of plant electrical maintenance procedure P/E 006-5N. The diesel ftiled to start both locally

'

and from the control room, regardless of which battery was selecte . On August 23, 1986, the battery operability lights on the containment spray control panel-were found not lit. This indicated that battery No. 2 was not operable. The iiesel--

driven containment spray pump was then lined up for testing.

'

The pump started locally from tiie No. 2 battery, but when switched to the "AVT0" position, did not start remctely from the control room.

'

Investigation of these events by plant personnel disclosed that .

the ratchet relays described above had become loose or partially disengaged. As a result, there was inadequate contact with the starting circuit, A subsequent evaluation showed that this

condition was a result of the force exerted by the weight of the relay, which is not supported by any means other than the socket into which it is plugged. To correct this problem, modification M22-1-86-34 was initiated to provide for installation of clear acrylic b8Ps and angle iron supports as restraints for the relays

.

. '

in the containment spray control panel The team examined these components and found that installation activities had been accomplished as required by the modification packag The acrylic bars appeared to provide sufficient restraint to prohibit disengagement af the horizontally mounted control relay ,

!

The team questioned whether this installation could adversely impact the functioning of the relays due to the additional forces exerted by the restraining bars. A review of the analysis of this design indicated that the restraining bars do not provide a holding

, force and will not adversely affect relay operatio During review of this modification the team raised concerns regarding the generic impact of similar relay failures upon plant systems at the Zion station and other commercial nuclear facilitie Since disengagement of these relays was determined to be the result of forces exerted exclusively by component weight, the adequacy of

their application in other plant systems and nuclear facilities-was questionabl _

e 'O

?

Discussions with licensee personnel disclosed that the relays and panels in question had been manufactured by Master Control Systems, ,

Inc. Notification of component defect pursuant to 10 CFR,'Part 21 had not been initiated for these components. For the Zion station-FSAR, only two operable containment spray pumps are' assumed in the accident analysis. The relay failures identified affected only one of three pumps; therefore, they did not pose a "Substantial Safety Hazard" as defined in 10 CFR Part 21. While this determination appeared to be prudent given the unique application of the relays in this system, similar relays may serve more vital functions at other facilities. Consequently, the licensee made a commitment to notify the industry via INP0's Nuclear Networ .1. Modification M22-1-86-35 .

Modification M22-1-86-35 consisted of rerouting breaker n relay

"

contact closures for manual actuation of safety injection, safe shutdown, and diesel generator load test circuitry to the plant j process computer. Examination of activities associated with this *

4 modification consisted of a visual inspection of affected 1 components, including switchgear, test switches, and field wirin '

'

Modification package documentation was also reviewe The team concluded that this modification had been accomplished in !

accrrdance with all applicable requirements. Test switches for '

simulated safety-injection actuation and simulated blackout were :

installed as shown on approved design documents. The switches *

were of the key-lock type to prevent inadvertent actuation and were further isolated by mounting within the switchgear cabinet, i Wiring associated with these devices exhibited the configuration shown on approved design documents. The scope of this modification was extensive in that it required the installation of a number of- ,

new safety-related cables. These cables were to provide signal

information from the centrifugal charging and residual heat removal l pumps to the process computer in support of periodic testing

activitie Since cable pull activities were accomplished prior to -

this inspection, review of these activities consisted of an evaluation 4 of cable pull data sheets and inspection records. No deficiencies were observed, i

During the review of work activities and documentation associated I i

with this modification, the team noted that numemus plant l

-

deficiencies had been documented and evaluated by informal l processes. As an example, this modification package contained a '

i number of Speed Letters that gave details of deficiencies in plant wiring. Specifically, the letters stated that field conditions

did not match the details shown on approved design documents. The i

<

1etters were initiated by substation construction personnel and l forwarded to the technical staff for resolution. In response, the

.,

technical staff indicated that S&L would inspect the affected wiring

<

and make recommendations for resolution of the problem. There was i

no evidence, however, that this activity had been accomplished, and j documentation could not be provided to assure that these deficiencies i

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,

, - < . , ,,

, .-

had been reviewed in the interim as to impact upon plant systems or ' !

the proper functioning of affected circuits. Additionally, the use -

of Speed Letters for documenting deficiencies was not in accordance with the requirements of CECO Quality Assuranca Manual Quality Requirement 15.0, in that it provided no tracking, documentation of technical evaluation, or resolution of the identified deficiencies, ,

An additionaliexample of this' concern was also identified relative to this modification. The modification package contained a letter from S&L to CEto transmitting the drawings and specifications required for making the modification. The letter detailed a plant deficiency (a

~

missing tray support member) which was identified during an engineering department walkdown. This deficiency was brought to the attention of CECO by telephone, and S&L was instructed to replace the missing component as part of the. modification. No repair documentation or evaluation of the deficiency was availabl The examples cited here indicate a weakness in the Zion station implementation of a corrective action program to formally document, a resolve, and track / trend deficiencie CFR Part 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality, such as deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and correcte In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The above weaknesses constitute examples -

of where the cause of the conditions were never determined, nor were corrective actions taken. This is a violation (295/88003-07A).

3.1.2.3 Modification M22-1-86-11 Modification M22-1-86-11 consisted of replacement of core exit thermocouple and subcooling margin monitor instruments. Examination !

of this modification consisted of a review of package documentation *

and inspection of the new microprocessor display loop. No concerns were identified, j

,

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3.1.2.4 Modification M22-1-85-20 Modification M22-1-85-20 consisted of modifying the containment vent and purge valves to allow a maximum 50*4 opening. The inspoction team reviewed the modification package document.ation and inspected the completed work. The work activities appeared to have been accomplished in accordance with the modification traveler, work request, and design requirement ,

3.1.2.5 Modification M22-1-86-16

'

Modification M22-1-86-16 consisted of making permanent a temporary change that had disabled a redundant set of diesel generator automatic starting contacts that were used only during test conditinns. The team reviewed the completed modification package, which had been reviewed and signed by quality control and quality ,

assurance personnel, and noted the following: >

.

. .

' Work requests 250104 and Z50105 did not list or reference

, work instructions in block 33. ZAP 3-51-1, "Origination and

'

Routing of Work Requests," provided inadequate guidance for what to include in block 33 when station procedures existed to do the work. Block 33 of the work requests were inconsistently filled out for the reviewed modification Some were blank, some referenced only QC and QA holdpoir.t The work request procedures were not consisten ' Work requests Z50104 and 250105 did not list the procedures for doing the work in block 38 as required by ZAP 3-51- , The work request traveler for work requests 250104 and Z50105

'

stated "these steps are not sequential after step No. 1."

Leads were removed in Steps 2, and step 3 consisted of construction tests and visual verificatio Steps 2 and 3 should have been required to be performed in sequence. The instructio t chat "These steps are not sequential after step i No. 1" was inappropriate and technically incorrect. This appeared to be a standard statement added to numerous Zion station travelers, without proper consideration for correctnes ' Step 2 of the traveler for work requests Z50104 and Z50105 stated "Remove leads to contacts per drawings." The step l did not provide adequate instructions to craft personnel in that it did not specify what leads, what contacts, or i what drawings should be referred to.for the required actio ,

a The required visual walkdowns were not specified on the work request, maintenance / modification procedures, or station travelers. The specification of walKdown steps on the station travelers was inconsistent within work package . The "work performed" block (block 51) of work request 250107 had an inadequate description of the work performed. It stated only "removed wires." ZAP 3-51-1 requires that the workman's

'

job notes be reviewed and the actual work be recorded. Work request 250106 was filled out in a similar manne .1.2.6 Modification M22-1-86-33

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Modification M22-1-86-33 consisted of replacing three Fischer-Porter containment spray transmitters with Rosemount 1152 model Transmitters IFT-CS01A, IFT-CS02A, and 1FT-CS03A were replace The transmitters were replaced because Fischer-Porter transmitters were no longer being manufactured, and spare parts were difficult to obtain. In addition, the transmitters were exhibiting excessive i

drift. The replacement transmitters were mounted in the same location and in the same manner as the original. The team reviewed the modification package and supporting documentation, conducted a field inspection of the installation, and noted the following:

, 28

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l 1. Conduit hangers ICSRS1112 and ICSRS1113 for the containment spray flow transmitters had bolts missing. The visuc1 checklist specified an inspection fcr loose, missing and/or

,

broken parts and had been completed prior to the team's field inspection. No guidance as to the scope of the verification inspection was provided; therefore, the subject bolts, which ,

.

'

were not directly affected by the transmitter changeout, were !

not detected. When this was brought to the licensee's attention, work requests 270016 and 270017 were written for repairing the hangers, t 2. The instrument cable conduit to transmitter 1FT-CS02A was mounted with one all-thread hanger supported from a spring bolt in a Unistrut above. The hanger supported the rigid

'

conduit and the Flextite to the transmitter. The inspectors questioned the seismic qualification of the installation and l the Zion staff could not locate a drawing for installation details or seismic data to support the installatio . The screw cover on the transmitter 1FT-CS03B auxiliary connection box was loose. A visual inspection checklist completed prior to the team inspection failed to identify this deficienc . A QC holdpoint on the traveler for work request Z53365 had been signed off and then backdated to the date ti;e step was performe A copy of the traveler given to the team on April 18, 1988, showed the holdpoint signoff associated with step 3 of the traveler to be missing. The work was completed on March 18, 1938, and subsequent steps of the traveler were signed off on March 19, 1988. The team reviewed the field copy of the traveler

,

on April 26, 1988, and noted that the holdpoint had been signed off and backdated to March 18, 1988. The reason for backdating the step was not documented and could not be ascertained through l discussions with the QC inspector and the QC supervisor.

l 5. Work step 5 of the traveler on Work Request Z53365 was signed

! 11 days after the step was completed. The work, which involved l calibration of three containment spray flow transmitters, was '

! signed as being completed on March 29, 1988. The calibration procedures were completed and reviswed on March 18, 198 .

6. Repair of safety-related wiring was conducted outside the scope ;

of work request 253365 and condoned by a QC inspector who i witnessed the work. The work request only authorized connecting l the transmitter to existing wiring. Damaged wiring was cut l back and stripped, and terminal lugs were crimped on two wires, j This was not specified in the work instructions or authorized i in the work request. Discussions with the QC supervisor, the !

QC inspector and modification personnel indicated that this !

was normal practice and was not really outside the scope of l

,

the work request. This philosophy could adversely affect !

l the proper performance of maintenance and modifications on j l safety-related equipment if the scope of work is allowed to !

l change without proper approval and procedural control l l

i i

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3.1.2.7 Modification M22-1-86-38 Modification M22-1-86-38 consisted of replacing the existing wide-range reactor coolant system pressure transmitters IPT-403 and IPT-405. The transmitters were being replaced to increase accurac The new transmitters were Rosemount model 1154, which are more accurate and reliable than those replaced. The new transmitters were to be located in approximately the same locations as the old ones using the same mounting. The team reviewed the modification package and conducted field inspections of the actual installatio The following were noted: Step 2 of the traveler for work request Z54994_ stated:

"Install Conax seal kits to -RCS pressure transmitters per tech staff." This appeared to be an exemple of an inadequate work instruction in that the step did not reference the procedure or detail on how to accomplish the actio . The procedure documentation block (block 38) of work request Z54994 did not list procedures as required by ZAP 3-51-1,

"Origination and Routing of Work Requests." The station traveler for work request Z54994 and work request 266741 did not specify a QC witness /holdpoint for makeup of the Conax seal assemblies. The torque / timing sequence for this Conax seal was to involve the application of two different tor;;ue values separated by a specified time. Additionally, the second torque value was required to be held foe a specified time period. It appears that these critical quality attributes should have required a witness point or should have documentation of such in the modification package for each Conax seal assembl . During a review of procedure QCAA-7, "Witness and Holdpoints,"

it was noted that the procedure addressed only the mechanical discipline For the mechanical area, the procedure discusse4 examples of the types of activities for which hold points would be appropriate, the quality attributes that should be inspected, and information on how to inspect those attribute The electrical discipline was not addressed. Inspectors discussed this instruction with the Quality Control Supervisor and confirmed that it did not cover the electrical area. This ,

appeared to be an inconsistent application of the Quality '

Assurance program to maintenance and modification activitie . Revision S of installation drawing 22E-1-4755 did not reflect the correct field configuration for wiring to transmitter IPT-403.

'

The drawing showed Raychem splices in a junction box betweer the containment penetration and the transmitter. When the splices were questioned by the team, CECO substation constructica personnel indicated that the splices had previously been removed I ar.d the drawing should have been updated. Substation construction '

personnel indicated a drawing change request (DCR) would be l written to delete the splices on the drawin l J

l l

4

,. . Modification work requests 254994 and Z66741 contained inadequate guidance to complete the modification. During installation, the substation construction foreman sent a Speed Letter to the technical staff noting that in order "to accommodate Conax connector we have to add LB fitting and to accommodate splice we have to add 'c' fitting." The modification work request and travelers had inadequate detail to specify the~

material to be '.: sed or instructions to acccmplish this tas The reply to the Speed Letter was that this was standard methodology and to install it accordingly. The use of a Speed Letter violates the requirements of ZAP 3-51-1B, Plant Modification Program," which specifics that a field change request (FCR) is needed to make changes to safety-related modification The use of Speed Letter for this application constitutes another example of the violation described in Paragraph 2.1. of this repor > The work instruction block (block 51) of wod request Z66741 did not contain or reference any work instructions. The work request station traveler contained work instructions; however, i leaving block 51 blank did not fulfill the intent of ZAP 3-51-1,

,

"Origination and Routing of Work Requests." The traveler for work request Z66741 listed required electrical l visual inspection steps 3 and 16. Visual inspection steps 1, 7, and 9 were not listed or, the travele The Zion station ,

staff indicated that these steps had been complete Documentation of completion of visual verification was not proceduralized or consistent throughout the modification package P The traveler for work request Z66751 contained the statement

"These steps are not sequential after step No.1," but step 2 of the traveler had to be completed before step 3. Permission to deviate from the intended sequence of a safety-related work instruction requires adequate review and approval; but in this ,

case, the station traveler permitted steps to be performed in

an incorrect sequence, which would have resulted in unsatisfactory accomplishment of the task.

'l

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10. The bill of material for this modification package, 00070, asser.iated with work request Z54994 indicated an incorrect count for the number of terminal lugs that were used during the installation. This was also true of work request Z6674 . The QA material tag for the Raychem splice kit used in work request Z54994 showed an incorrect working range of the Raychem tubing. The working range of the tubing was shown as 0.163 to 29 inches rather than 0.163 to 0.29 inches. This appeared more significant than just a minor typographical error in that verification of the Raychem working range and QA tag are

_ _ _ _ - - _ _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

. .

critical parts of the receipt inspection process, which should note and correct any discrepancies before the material reaches the field, 12. The associated maintenance / modification procedure and traveler for work request Z54991 had no instructions or referenced procedures for the termination of wires between the Conax seal and the transmitter. The work activities that were not covered by instructions included wire cutting, stripping, crimping on new thermal lugs, and terminating the wires on the correct '

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terminal .1.2.8 Modification M22-1-87-03 Modification M22-1-87-03 consisted of installation of an electronic system for indication-of reactor vessel level during refuelin This modification involved relocation of the level-sensing line connection to increase the level-indicating range and to minimize dynamic effects on the level indication. All flexible plastic hose was replaced with pipe or tubing, and a new transmitter and a new control room indicator were installed. The team reviewed the modification package and supporting documentation and conducted field inspections of the installation The following were noted: , The station traveler associated with work request Z66876 stated: "steps do not have to done in order." Step 1 was to rewire loop IL-RC-22 and step 2 was to calibrate loop 1L-RC-22. These steps had to be completed in the ssquence listed. The statement allowing step performance in any order may allow or cause ;mproper performanc . The partial modification approval record and the station traveler

'

associated with work request Z66876 allowed "troubleshooting as required," but the modification package did not specify work that would have required troubleshooting. If troubleshooting

was required, ZAP 3-51-1 would haue required a modification package revision or an FCR, depending on whether the change

was major or minor. The blanket allowance for troubleshooting >

by a modification package work request is considered

, inappropriate for specifying and controlling work activities on a system important to safety, i

, The attached documentation requirements block (block 38) in work requests Z66876 and Z66877 did not list applicable

>

procedures, as required by zap 3-51-1.

. The work instruction block (block 51) in work request Z66877 did not contain or reference any work instruction . Step 7 of the station traveler for work request Z66877 was considered to be too broad to adequately direct proper

"

installation activities. The step stated: "Install splice, junction boxes, relay panels and associated wiring per mod

'i

!

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drawings." In addition to the broad range of coverage, quality attributes such as splicing had no QC witness or holdpoint assignments. Use of blanket instructions, such as "install per mod drawings," is not sufficient to adequately control quality attributes, such as wire stripping, cutback, crimping, bend radius, and torquin . Step 12 of the station traveler for work request Z66877 stated:

"Welding if required in accordance with SSC weld procedure." ,

At the time the traveler was written, walkdown and preplanning should have identified the welding requirements. The required welding, if any, should have been specifically identified and approved as a part of the formal modification approval proces . During inspection of the reactor vessel level indicator in the rear of the control room main control boards, numerous wires '

were noted to be kinked and bent tightly back with the loop tie '

wrapped. Further inspection in control board 1C806 and adjacent

,

boards found similar conditions in all panels in the rear control board area. Bend radii of 1/16 and 1/8 inch were common for the

14- and 12-awg wiring in the panels. These radii appeared to be *

much less than the general industry standard and/or the 5 X OD rule that many plants utilize. No damage to these single-wire conductors was observed, and no damage was identified by the 1 licensee to dat . During the field inspection of the reactor vessel level indicator in the rear of the main control boards, inspectors also noted bare, disconnected terminal lugs, which were not identified. Similar disconnected terminal lugs were also noted in the nonessential switchgear room during field inspection of another modificatio Four specific instances i

of bare terminal lugs were noted and identified to Zion station staff and management for their investigation. Initial

, indications from the Zicn station staff was that the

'

unconnected terminal lugs were spares. A review of the specification for electrical installation work (X2329) and standard EA-205, indicated, however, that all spare conductors were to be attached to spare terminals. If spare terminals were not available, the ends of the loose conductors were to be taped and bent out of the wa Me team's followup inspection in the concerned areas in Units 1 and 2 identified no bare terminals, indicating that corrective action had been implemente .1.2.9 Modification M22-1-86-09 Modification M22-1-86-09 consisted of installing pressure switches to the suction side of the two residual heat removal (RHR) pumps and adding two annunciators and asso 'ated cable, conduit, and conduit

'

supports. The pressure switches annunciate an alarm in the control room when low suction pressure is sense a

. w 3.1.2.9.1 personnel Training

.

The modification packages required QC irspection of the installatio The team reviewed Substation Constructi e Department procedure 14,

"Qualification Classification and Training of. Inspection Persnnnel,"

Revision 0, which establishes the method for qualifying the QC .

personnel who perform inspections and-examinations. Section 5.2.2 of the procedure, states, in part: "Certification'shall be based upon documented successful completion of related technical and specialized indoctrination ... capability demonstration and substation  ;

construction site specific instructions / procedures per specific qualification." Section 5.2.3 states that certification shall be documente Section 4.2 states that QC coordinators shall be certified in the following specific areas: Cable pan and hanger inspections

, Conduit and hanger inspections Equipment / material receiving inspections  :

i Cabie pulling / termination inspections Vi nal weld inspections 3  :

The team reviewed the certification records of the QC coordinator  !

who performed the above specified inspections for the modification and found that he was only certifiad to perform visual weld .

inspection i On April 28, 1988, the Substation Construction Department supervisor i issued a letter to the station stating that the QC inspector was ,

certified to perform only visual weld inspections and dimensional  !

verifications. The letter further stated that other training and certification was ongoing in accordance with the procedur '

3.1.2.9.2 Torque Wrench Calibration ,

substation construction quality procedure SSC-22-8 establishes acceptance criteria for the installation of concrete expansion '

,

anchors and sections 3.3.3.a and 4.3.1 of the procedure require  ;

that torque wrenches be calibrated once a month. In addition, Section 3.1.1 states: "In cases of conflict, the requirements of this form shall govern." Substation construction procedure 12 and substation construction quality procedure SSC-22-6 did not conform to the standard by establishing a six-month calibration frequency for torque wrenches usec' in the installation of conduit

, hanger .

The inspection team found that torque wrenches A-110 (used in this modification), 5469, and 5676 did not neet the calibration i requirement established in procedure TSC-22-8 due to misapplication '

of procedure SSC-22- !

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_____ _. . _ _ _ _ _ _ _ _ _ _ _ ._ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -_ _ _ . _ _ _ ______-_____-____________--_a

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3.1.2.10 Modification M22-1-86-23 .

Modification M22-1-86-23 required elimination of unneeded annunciators

on the Unit 1 control board bypass and permissive annunciator-pane '

'

The bypass permissive status panels located on the main control :

board consist o7 52 indicating lights which are activated by specific plant conditions. The modification made 34 of the r indicating lights inactive and the remaining 18 active-indicating lights-conform to the "dark board" concept.

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During a walkdown of the modification, the team observed that three conductors were landed on terminal point 4 inside the reactor protection logic panel Channel 2, terminal block TB4S10. This was not in accordance with wiring diagram 22E-1-4593. Similar situations wore found on Channel 4, terminal block TB2S12, and termination points 2 and 4 The licensee had also identified a

similar discrepancy on terminal block TB2S12. The wiring specification C-2325, "W! ring Standards - Switchboard, Switchgear and Miscellaneous Equipment Shop and Field Installation," states,

"

in Section IV.12, that not more than two wires shall be connected to any one stud or terminal point; however, the licensee stated that

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under certain conditions, the landing of three lugs on one termination a point can be justifled. The team's review showed that the program e

, would not identify these wiring connection errors if they were

"

outside the scope of the modification packages. The team observed i many other wiring discrepancies, including: terminal block TBS 10, ,

,

l' point 8, was not in accordance with drawing 22E-1-4587; and terminal ;

block TBS 11, point 12, and terminal block TBS 10, point 4, was not in '

accordance with wiring diagram 22E-1-4593. It is the licensee's belief that wiring configuration errors will be identified as the equipment is worked on. A formal progran to update the drawings was not considered to be required.

During followup inspections, the licensee acknowledged that discrepancies between the field installation and the wiring ciagrams

.

existed and that technical staff engineers and others who aceded to

use the drawings could not rely on the accuracy of the wiring diagrams. The licensee stated that although wiring diagrams were in ,

' error, the equipment had been functionally tested and was considered '

to be operable.

.

,

The fact that the wiring is not in accordance with the design drawings is an unresolved item pending further verification of the !

current drawings with field installation conditions (295/88003-08). ,

3. Conclusion

.

The many miscellaneous examples of failure to comply with administrative procedural requirements identified during observation j

of electrical modifications were determined to be a result of CECO's ;

lack of attention to details and their failure to demand a high !

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level of procedural compliance. For example, the failure to specify f i the scope of the visual check for loose, missing, or broken parts 35  :

P

_ . - - - -- -- -

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e contributerd to the failure of the inspector performing the visua ; inspection to identify the missing conduit hanger bolts. Followup

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inspections conducted by the team indicated that Ceco recognized this issue and had initiated extensive corrective measure .

The use of Speed Letters in documenting deficient conditions is l

considered to be a violation. Wiring not in accordance with design

, wiring diagrams will be further reviewed to determine the extent of ,

the problem and the associated safety significanc ., Electrical and Instrumentation Modifications - Testing 3.2 1 Scope

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The scope of the inspection of testing of electrical and instrumentation modifications'was limited. The modifications made during this outage were small, and the testing of level, pressure, and flow transmitters was accomplished using normal calibration procedures rather than special modification testing. Some testing '

was observed, and some results of testing were reviewed by the team.

3 Procedures for preparing, reviewing, and testing were reviewed to -

assess their adequacy.

l 3. Discussion 3.2.2.1 Modification M22-1-86-16  ;

Modification M22-1-86-16 consisted of the removal of diesel ,

generator automatic starting by use of jumpers. The following .

were noted

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- Electrical construction test procedure 19 "Control Circuits," l l and procedure TSSP 19-88, "Functional Test of Modification

, '422-1-86-16," were used to test the modification. These tests i

were not referenced on the PWRE letter, work requests 250104, .

250105, or the maintenance modification procedure for the work l request l

.

' TSSP 19-88 had uninitialed changes to the test revision dat This methed of changing quality records is contrary to the !

requirements of CECO quality procedure QP 17-51, "Quality

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Assurance Records for Operations - Control of Station Records."

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3.2 2.2 Modification M22-1-86-33 I Modification M22-1-86-33 consisted of replacement of three containment ,

spray flow transmitters. The fcilowing were noted: l The modification work request, maintenance / modification

;

procedure, and traveler did not specify the calibration l procedure (s) to be used for the as-found calibration or the post-installation calibratio zap 3-51-1 requires

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listing the procedures to be used in block 38 of the work reques {

36 i

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l Completed as-found calibration test results for containment spray flow transmitters CS01, CS02, and CS03, which had been obtained on March 19, 1988, were reviewed. Steps 6.25 through 6.29 on all procedures had not been completed or marked as not applicable. Although it appeared that appropriate sections of the procedure had been completed, some sections of the procedure '

were marked completed, some were marked not applicable, and some

'

were left blank. The procedure did not address the basis for this, t

3.2.2.3 Modification M22-1-86-38

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Modification M22-1-86-38 consisted of replacement of the reactor coolant system wide-range pressure transmitters. The test-required block (block 9) of work request 266741 was checked "yes"; however, the tests performed were not listed as required by ZAP 3-51-1,

"Origination and Routing of Work Requests."

3.2.2.4 Moaification M22-1-87-03

!

Modification M22-1-87-03 consisted of installation of an electronic reactor vessel level-indicating system. The following were noted:

l Step 8 of the station traveler for work request 266877 stated: '

, "Perform construction tests if required, test reviewed and i approved by OAD ...." This step was broad and nondefinitive >

in that the traveler did not delineate required work as part of the formal modification approval process. Performance ,

<

of acceptance testing should be specified by test number and clearly defined in the modification package. Details, such as the number of tests, portions of the modification package

they apply to, and when each is to be conducted should be '

j preplanned and preapproved, with a clear audit trail required ,

,

of a quality recor '

, Calibration procedure IL-RC2?, "Reactor Refueling Level,"

, completed on April 22, 1988, was reviewed. No discrepancies '

were note . During review of test procedures, it was noted that the requirements of QP 3-51, "Design Control for Operations-Plant !

Modifications," for establishing a modification test committee '

had not been implemented at the Zion station.

'

)

3.2.2.5 Modification M22-1-86-35 '

Modification M22-1-86-35 consisted of rerouting breakers and ;

relay contact closures for manual actuation of safety injection, i safe shutdown, and diesel generator load test systems to the ;

process computer, j Observation of special test TSSP-92-87, which was a functional test 4 of this modification, was accomplished during this inspectio l

. 5

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t

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The test was performed in three distinct parts, and parts B and C were monitored by the inspection tea Part B, which verified the operability of the new simulated safety injection test switches was completed successfully up to step 1.M of the procedure. This step required actuation of a pushbutton and subsequent verification of test-light indication The absence of power to the bus feeding these circuits, however, precluded this test ste The lack of power appeared to be the result of translating requirements from operational procedure PT-10 to test procedure TSSP-92-87 without

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p*oper incorporation of test prerequisites and consideration of plant condition Further investigation by the licensee concluded that the subject test lights were not required to verify proper operation of the test switche Procedural change TA-88-287 was initiated to delete the test-light requirement from the procedure, and test TSSP 92-87 was again performed and completed successfull Part C of the test functionally verified the operability of the new simulated 2/3 service bus undervoltage test switches. Steps 9 and 10 of the test procedure required the following: visually verify relay M427X is actuated 10. verify that the following relays are actuated by verifying an open circuit between the following contacts:

427/T17 Pts. 13 and 15 427/T18 Pts. 13 and 15 427/T19 Pts. 13 and 15 During performance of the test, the relays specified in steps 9 and 10 failed to actuate. Investigation disclosed that two wires in the original circuit had not been installed as shown on approved design documents. This deficiency was found on terminal block LA of the 416-V switchgear bus 142 cubicle 7. The licensee initiated a discrepancy report (88-0077) to document, evaluate, and correct this condition. The affected wiring was then reterminated to reflect the original design configuration, and the circuit wa:, retested successfully in accordance with procedure TSSP 92-87. Preliminary evaluation of the identified deficiency by the licensee indicated that this condition was the result of original construction. While this deficiency directly impacted the performance of this test, further evaluation indicated that it did not impact plant or system operabilit In summary, the problems encountered during this test did not adversely affect successful completion of test activitie Folluwing licensee-initiated corrective actions, all problems were corrected and the test activities completed. The problems indicated, however, weaknesses in program implementation, specifically with regard to review of test procedures for accuracy, technical content, and application. As discussed in other sections of this report the licensee has not implemented the requirements of Quality Procedure 3-51, Section 4.4, for establishing a modification test review committee. This requirement when properly implemented should provide ~ additional-assurance that test activi'.ies will be performed as intende I

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3. Conclusion In the electrical area, the modifications that were reviewed were found to h0ve been adequately tested. Important elements such as the establinheent of a modification test review committee were not, however, implemented as required. Fragmentation of records of modification testing into construction testing, Operations Analysis Department.(OAD) testing, modification testing, and operability testing into several different documents within the modification package created boundary interfaces that increased probability of error. Tne modification package lacked a single document that specified all testing authori:ed, all testing planned, and all testing conducted for one modification. Inspectors concluded that the madification tests described in the PWRE letter were not well specil'ied, and the formal approval process did not always extend to all testing (for example, PWRE did the front end work and left it to the station to determine what vehicles accomplished the testing).

Inadequate tett procedures and control were discussed in Paragraphs 2.2.?.3 and 2.3.2.3. of this repor .3 Electrical Separation During examination of plant modifications, numerous cable and raceway configurations were observed that did not meet the licensee's commitment for independence of redundant circuits. The Zion station FSAR, Sections 8.4.2,3 and 8.4.2.4, provides specific criteria for physical

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separation of electrical circuits to assure that no single credible event, such as short circuit, pipe rupture, or missile, would prevent operation of redundant function Safety-related cables at the Zion station were designed to be routed through raceway systems (either conduit or cable tray) to assure physical independence of the circuits and protection of cables from potential damage from exposure to other plant components. In cases where the required physNal separation distance could not be maintained between the raceway systems, the FSAR provided for use of cable tray covers as an acceptable fire barrie The separation deficiencies observed involved cables that had been routed outside the designed raceway system; rable trays that were missing the covers necessary to allow reduced physical separation; cables that had been routed around piping and pipe supports; cables that had been pulled very tightly at vertical tray intersections, with resultant potential for damage due to tensioning; and cables that had been looped outside the designed divisional tray systems and therefore did not have the minimum allowable separation distance While the inspection team could not make a final determination, it appeared that many of the deficiencies were the result of modifications or maintenance work that altered previously-acceptable installation Another concern involved violations of both electrical separation and voltage segregation requirements. One division of control cables for the manual reactor trip control switches were free-air routed from their

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divisional tray through a nondivisional tray segment' to make entry'into' l a floor sleeve. The nondivisional tray contained power cables that f serviced the rod drhe switchgear. The Zion station FSAR provides .

specific criteria prohibiting the routing of divisional cable into '

nondivisional trays and the mixing of control and power circuits within i a common tray. This deficiency appeared to be the result of original construction and was not in accordance with design requirements, which :

specified that the control circuits be routed through a separate condui :

As a result of this observaticn, the licensee initiated a deviation '

report DVR 88-060 to document and correct this deficiency. The I licensee's technical evaluation indicated that these safety-related control circuits would not have been adversely affected by normal or )

abnormal operation of tne power cables in the same tra :

r The team also questioned the adequacy of the station's compliance with l 10 CFR Part 50, Appendix R, requirements for safe shutdown capabilit .

It was noted that a thorough reassessment was accomplished by the l licensee and documented in a report dated July 1987. The report !

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described the circuits essential to safe shutdown and provided detailed

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methods of conformance for designated fire areas- In a number of areas,

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conformance with Appendir R requirements necessitated the rerouting of +

safety-related cables, such as component cooling water and centrifugal ;

charging pump motor cable l

, While no specific violations of the licensee's Appendix R analysis were l coted in this area, the inspectors did observe tray segments in the ,

i auxiliary building whose configuration exhibited a potential violation of Appendix R requirement Cable trays 2784DB (Division 27),2784FB !

(Division 28), and 27840A (Division 29) were found to contain redundant ;

power feeds for auxiliary building ventilation. -These tray segments !

were stacked vertically, and did not have the tray covers or barriers i necessary to prevent propagation of fire from one tray to anothe !

Through discussion with the licensee, the NRC Region III Office and the NRC Office of Nuclear Reactor Regulation, the team found that the i Appendix R classification of the auxiliary building ventilation i system at the Zion station was an NRC open ite (See NRC Inspection !

Reports 295/87034 and 304/87035)

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In response to the team's findings, the licensee issued a general work !

request and placed a number of cables back into the trays. Howeve .

these measures lacked sufficient documentation and evaluation. These !

safety-related cables were clearly not in accordance with plant design requirements, and there should have been documentation of this cn the i appropriate corrective action form to provide for tracking and evaluatio l No evidence was available to indicate that the cables involved had been I evaluated for damage or reinstalled in the correct tray ~ segment. No provisions were made for determination of the root cause of the i deficiencies, t 10 CFR Part 50, Appendix B, Criterion XVI requries that measures shall be (

established to assure that conditions adverse to quality such as l deficiencies, deviations, and nonconformances are promptly identified and ;

l corrected. In the case of significant conditions adverse to quality, the

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t.seasures shall assure that the cause of the condition is determined and f

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corrective action taken to preclude repetition. The identification of .!

the significant condition tdverse to quality, the cause of the condition, ,

, and the corrective action taken shall be documented. However,-the l

documentation associated with the safety-related cables placed back into l l the trays did not indicate whether this was the appropriate tray for the {

cable or whether this was the appropriate tray fer thh cable or whether .

. cable damage and occurred. The failure to determine the cause of the l condition or determine appropriate corrective action prior to  ;

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implementation is an example of a violation (295/88003-078).  ;

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! In response to these findings, the licensee established and implamented .

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a program to walkdown the cable tray. systems of both Units 1 and l

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S&'. projc:t instruction PI-ZI-41, "Cable System Walkdown and Review,"  ;

Revidon 0, dated May 12, 1988, was reviewed by the team during a  !

followup inspection on May 16-18, 1988, and was considered to be i j acceptabl ';

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l 1 The S&L walkdown group consisted of six designers with design and  ;

construction experience divided in three teams, with one coordinator t acting as the team leader. On May 17, 1988, the NRC team observed an  !

S&L team walkdown inspection in the Unit 2 lower cable-spreading roo ;

i Effective implementation of project instruction PI-ZI-41 was observe l t

During a second followup inspection on May 31, 1986, the team inspected e

the control room auxiliary electric equipment control panels of Units 1 '

j and 2. They found reduced separation of cables of redundant divisions in i

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cabinets ICB 30 and ICB 35. A subsequent records search indicated that  !

l the deviations were evaluated and accepted by the licensee's A- !

l 3.4 Mechanical Modifications - Installation  !

T 3. Scope

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Mechanical modifications were evaluated by reviewing procedures, observing work in progress and completed work, reviewing records

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of comp'oted work, and discussions with responsible CECO and  !

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contractor personnel. Nine modification packages were evaluated  ;

for conformance to design, procedural, and regulatory requirement ,

i In addition, one maintenance work request was reviewed to ensure j j compliance with the modification progra ,

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j 3. Discussion i

l 3.4. Modification M22-1-87-01 I i

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! Modification M22-1-87-03 consisted of installation of a reactor l 1 vessel water-level-indicating system (RVLIS) for use during i refueling. Pipe, tubing, level transmitters, and associated j i components were installed to provide a permanent level-indicating i system for use during refueling. The modification was examined j

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by the inspection team from the isolation valves at the pressurizer *

through the level transmitter stations in the basement of the '

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containment building. Numerous discrepancies were noted in hardware installations, documentation, and in corrective actions taken to resolve discrepancies. None of the discrepancies found by the inspection team were identified by CECO QA/QC personnel who inspected and accepted the installations. The deficiencies observed by the team included: Two five-valve manifolds did not have lockwashers on the mounting bolts, as specified on $&L design drawing M-806, sheet 2, Restraint 28 on S&L dcawinC M-806, s' -+ 1 did not have locknuts on either leg of the U-bi ; *'straint 27 on the same drawing did not have a ! 't w n una U-bolt

leg, as required by the drawing.

, The bracket to baseplate weld foi .ansm!cter ILT-RC-228

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was discontinuous for at least 1 i,._ . an '~.erference with

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a concrete expansion anchor. Design drawing > #99, shtet 196, i specified a continuous wel . Three concrete expansion anchors on the inboard side of

the bastplates for the five-valve manifolds and the le ol 4 transmitters violated the minimum concrete-free-edge distance requirements of the contractor procedure and S&L standard 1778-B. The actual distance was approximately j $/8-inch; the requirement it a minimum of 5-inches, j One of the contractor's pipe bending process sheets for work on i work request 266874 had craft and QC personnel signatures for

six cends when only five had been made. A craft foreman signed off for work performance four days after the work had been inspected by QC personnel. Contractor welding process sheet 1574-1 for welds 911, 914, 918, and 922 did not have

! the "data entered by" blocks signed until nine days after completica, of the welds

]; In response to the finding of the noncunforming conditions on the fasteners for the five-valve manifolds and pipe restraints, the l contractor corrected the conditions without proper documentatio l ZAP 3-51-1B required documentation of these cerrections of j nonconforming conditions in accordance with quality procedur6 QP-15-1, i

"Nonconformances." Failure to properly document these corrections bypassed the root-cause analysis and long .orm corrective action evaluationt

During review of the modification packages, the team noted that the designer's and insta11er's walkdowns were poorly documented. These

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i walkdowns are part of Ceco's new modification program, as described in Directive NSDD-M14. "Design Control for Operations - Plant J

Modifications," and implemented by the Zion station administrative

! procedure ZAP 3-51-18 "Plant Modification program." The format, j walkdown documentation, and resolution of identified problems i

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were inadequately addressed in the station, procedures. For this modification, the walkdown checklists completed by the responsible PWRE engineer did not specify the dates'of the walkdown(s) and did not include the. signature and date of preparation. The resolution record sheets were nonspecific as to the observations noted, the resolutions proposed, and the applicable checklist steps reference .4.2.2- Modification M22-1-2.7-05-Modification M22-1-87-OL consisted of installation of drain lines and valves to the auxiliary feedwater (AFW) pump bearing oil reservoir .4.2.2.1 Documentation Short drain lines and valves for AFW pumps were installed to facilitate taking oil samples and draining the reservo'rs for maintenance. The installations on all three pumps wei4 examined by the inspection team. All were in accordance with design requirements. The following documentation discrepancies.were noted, however: The modification procedures and ti.velers (contracto" process sheets) did not specify that oil drained from the reservoirs in order to make the modification was to be replace Discussions with licensee personnel indicated that this was not '

necessary because other maintenance work was concurrently being performed on the pumps and oil replacement would be controlled by other documents. The work requests provided by the licensee '

that documented this maintenance did not require refilling nor indicate that it was done. Performance test PT-7 for the AFW pumpc did, however, have a prerequisite to verify the oil level prior to operation. Work procedures and instructions should have provided specific action statements requiring reinstallation of permanent materials removed during the modification process or referenced other specific documents that required the reinstallatio . The modification procedures and travelers did not specify disassembly of the soft-seated isolation valves prior to '

welding but did provide for documentation of reassembly on a mechanical-joint process sheet. The work instruction was considered to be incomplet . CECO QC field inspection sheets for the final weld inspections of each pump were com/leted but not sigred and dated by the inspector. After discussion with the licensee, the sheets were signed and dated 17 days after the inspections were performed, l with an annotation to che date of actual inspection. The QC i inspector signed the inspections on the contractor's traveler i on the day of the inspection but failed to complete the CECO l documentatio l

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Although the team considered these discrepancies to be mhor, they reflect a general carelessness _with regard to accuracy in quality--

-related instructions and documentatio .4.2.2.2 Work Request Z67093 A CECO QA representative placed a statement on.the modification traveler that the holdpoint visual inspection to "verify mechanical-installation per visual checklist" was only a dimensional-verification of components because the line had already been removed from the oil cooler by the CECO mechanical maintenance personne When questioned about when the line had been removed, the licensee staff provided a completed work request, Z67093, in which the requested action was to' flush the water side of the' coole The following discrepancies were noted on this work request: The work instruction block of the work request provided only brief action items, such as "remove cooler," "flush and clean as necessary," "test per MMF direction," and "install cooler."

Testing of the cooler (to some unspecified pressure, medium, time period, and acceptance criteria) revealed that the cooler was defective and had to be replaced. A station traveler was issued to document a weld cutout and reweld, but the work request was never changed to indicate the additional work to be performed or to reference other work instruction . Replacement material part numbers for four Flexitallic gaskets for the oil and water inlet and outlet lines were not listed on the work reques . No mechanical-joint closure sheets were completed for the two oil line flanged joint .4. Modification M22 l-87-07 Modification M22-1-87-07 added short drain lines and isolation i valves to the two centrifugal charging pump spr.ed increaser bearing  !

lubrication systems to facilitate oil sampling and drainin The ,

field installation at pump 1B was examined by the team and was found l to be in conformance with design documents, but there were minor I documentation discrepancies similar to those stated in Paragraph 3.4.2.2. l

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3.4. M ification M22-1-87-08 Modification M22-1-87-08 added a short drain line and an isolation  ;

valve to the ce.cainment spray pump 1C diesel engine crankcase to  !

facilitate oil sampling and draining. The installation was examined by the team and found to be in conformance with design documents, but there were minor documentation discrepancies similar to those stated in Paragraph 3.4.2.2. _ _ _ _ - - - _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ _ _ - - _ _ _ _ _ _ _ _ . - _ _ __ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -

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During the field observation'of this modification, the team noted

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deficient conditions on two adjacent large-bore containment spray i system pipe restraints. 0n strut CSRS 1112, the load pin between '

the pipe clamp and the strut paddle had no locking devices. It had

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slipped down through one-half of the pipe clamp and would prc,bably have dropped completely out if subjected to any significant movement, On strut CSRS 1113, the load pin was a bolt with no l nut or other locking device. Since the bolt head was.on top of the '

assembly, oriented vertically, it would not be dislodged by gravit '

These problems were subsequently corrected by the licensee 1 utilizing wnrk request .4.2.5 Modification M22-1-86-38 i a

Modification M22-1-86-38 replaced existing Barton reactor coolant i system wide range pressure transmit;ars PT-403 and PT-405 with environmentally qualified Rosemount units. The work involved disconnection of tubing and wiring, mounting of the new  ;

transmitters, and reconnecting tubing and wiring. Completed l installation of both transmitters were examined by the inspection ;

team, and the discrepancies found included the following:  !

! The installed pressure tubing slope did not conform to drawing requirements. The traveler's work instruction stated: "Route i tubing as described on S&L Drawing M-499, Sheet 285." Note 6 on this drWing, referenced on the + cwing diagram along the i tubing run to the transmitter, re: 'd horizontal runs sloping downward one inch per foot (minimun. . The installations in the !

field for both transmitters diC ot nieet this requirement. The l tubing was twisted and made mn; upward and downward direction i change l l

The team noted that the modification approval letter and design !

drawing M-499, sheet 285, stated that tubing was not to be replaced for these two transmitters. The deviation from design l drawing requirements should have been identified and resolved '

at many different points in the modification process; that is, during the designer's walkdown, ~ the installer's walkdown, the contractor craft signoff on the traveler, the contractor's QC signoff on the traveler, the CECO technical staff engineer's signoff of the tra eler, CECO QA witnessing of the mounting

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i on PT-403, the contracter and CECO QC stafi signoffs of the traveler, and the user's walkdow . Drawing notes and modification instructions were in conflict as to tubing diameter. Note 12 on S&L design drawing M-499, sheet 196, stated: "Tubing to transmitter shall be one quarter inch 0.D. per PDT B." This note was circled with a reference to this modification and the job number for the revision issued to accomplish this modification. However, the existing tubing, which according to the modification approval letter and M-499, sheet 255, was not to be replaced, was one-eighth inch m

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t 3.4.2.6 Modification M22-1-86-37 .

Modification M22-1-86-37 consisted of removing piping and valves _

associated with the four safety-injection system accumulator relief ~

and manual vent valves and reorientation of the assemblies so that the relief valves would be positioned vertically instead of horizontall The existing safety and vent valves were refurbished and reuse All work related to this package was completed prior to the inspection, and thus irspection efforts were directed toward a-review of the work documentation and verifying compliance of the as-built installation with design document The installation and records were satisfactory, but there were several places where the work instructions lacked sufficient ~

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detail, such as the following: There was no instruction or guidance provided to the workers pertaining to preinstallation inspection of.the refurbishment of components and material . There were no instructions for pipe remova . There was no instruction or precaution In the travelers or other referenced documents regarding the entry of foreign material into the accumulator tanks during the period when the nozzles were open (piping not installed). There .ss no direction or guidance in the modification package that .mcified the requirements for new material used in the installatio .4.2.7 Modification M22-1-86-09 Modification M22-1-86-09 consisted of installation o'f new pressure !

switches at the suction of each of the RHR pumps. Sensing lines !

(1/4 inch stainless steel tubing) were installed from the existing i taps to the new pressure switche The inspection included H verification of the as-built configuration'and compliance with instructions and design documents. At the time of the inspection, the modification had been made, but not completely QC verifie The installation met the requirements of the applicable design and construction documents. During review o' the associated work travelers, however, it was discovered that the sequence of work was !

changed without revising the traveler. This allowed the tubing to l be installed prior to a QC holdpoint for a cleanliness chec The inspection team noted that the sensing lines had been installed improperly with inadequate bend radii, improper support hardware, and missing lockwashers on th2 switch mounting brackets. Upon being informed of these problems, the contractor proceeded to correct the nonccnformities by installing new tubing, brackets, and lockwashers, in conformance with the design drawings. In the process of the reworking activities, the contractor (the Hunter Corporation) failed

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to meet the requirements of their QA Progran (SIP 4.000), which requires rework to be documented on the respective traveler to assure that the work and associated QC hold and witness points are sequenced as intended by the original work instructions. Specifically, the contractor failed to: Invalidate previously accepted QC holdpoint signo,'fs for the required cleanliness inspection . Properly document work and inspections performe4 in'the course of the rework. The only documentation of any ework was overwritten dates and initials in the inspect'an acknowledgement spaces and notes marked on margins of previotily completed document .4. Modification M22-1-86-33 Modification M22-1-86-33 consisted of replacirj three existing containment spray flow transmitters. The meclanical. scope of the work included fabricating new transmitter moanting brackets and rerouting the pressure sensing lines (1/4-1.ch stainless steel tubing) from the valve manifolds to the transmitters. The inspection ,

related to this package consisted of a roiew of the completed documentation package and observation of the installation. For all three transmitters, the horizontal sections of the tubing.were installed essentially flat instead of sloped at one-inch per foot as required by Sargent & Lundy Drawing No M-499, Sheet 285, Revision .4. Modification M22-1-84-68 Modification M22-1-84-68 consisted of replacing the conte nment spray pump couplin The replacement was intended to reduce pump vibra 'on thought to be transmitted from_ the diesel engine via the pump-to-driver coupling The new coupling was purchased as a commercial grade item and upgraded onsite for use in this safety-related application. All work had been completed at the time of the inspection. All documentation regarding this modification was in order except the procurement and receint inspection of the new coupling. CECO engineering document CEC-004-1 provided the technical basis and justification for upgrading the coupling c.nd established specific requirements for the receipt inspection of the coupling, including a certificate of conformance from the manufacturer stating compliance with the specified assembly drawing, and onsite inspection and dimensional verification of all parts of the coupling upon receipt. Neither of these items was documented in the modification package. The requirement for manufacturer documentation was not ;

imposed via the purchase order as required by the CECO Quality '

Assurance Manual (QP-4-51, Paragraph 6.0) and the inspection and dimensional verifications were not identified as a requirement on the receipt inspection documentation shee After these issues were raised by the team, the licensee took steps ;

to acquire the necessary documentatio The technical group engineer '

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attested to the fact that receipt inspection and dimensional verification were performed but not documente .4.2.10 Maintenance Work Request No. Z61335'

Work request Z61335-specified replacement of the charging pump room

. cooler; however,1this work request was initially intended for repair of the cooler. When the cooler was determined-to be beyond repair, it was replaced during the refueling outag The work scope and prescribed details of the work were insufficient to adequately define the work bounds. Specifically, the work instructions on the work request did not call for replacement of the cooler, but simply made note that, should the cooler require replacement, a fire watch would be needed. The inspections required in the traveler were vague and nonspecific-with respect to removing and replacing the cooler and associated hangers and supports. The work traveler did not authorize any work on the charging pump, although there was documentation in the work package showing that work had been performe . Conclusion Similar to the conclusion drawn after the inspections of electrical installations (paragraph 3.1.3), the many p-ocedural violations and discrepancies documented were attributed to CECO's lack of attention to details. This included examples where installation nonconformances and deficiencies had been inspected and accepted by .

QC personnel. The team noted during followup inspections that C5Co had initiated an extensive program to correct the problem. The CECO program will be monitored by the NRC Region III offic .5 Mechanical Modifications - Testing 3. Scope The testing of mechanical portion, of modifications was evaluated by reviewing test procedures and completed test documentatio The inspectors were able to witness only one mechanical testing activity. Test procedures were reviewed to determine whether they were clearly defined, complete. and. adequately controlled and addressed all test requirements of the designer's modification approval lette Test documentation was reviewed for completeness, accuracy, proper resolution of deviations, and proper review . Discussion l

3.5. Modification M22-1-87-03 '

Modification M22-1-87-03 consisted of installation of a reactor vessel water-level-indicating system for use during refueling. Testing required in the designer's modification approval letter included a 50 psi pneumatic leak test of the reliability portion of the piping l

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I and valvos and a leak test of safety-related valves and piping at RCS operating ' pressure during the hot shutdown mode. Technical ' staff !

special procedure TSSP 39-88, "Modification Test M22-1-87-03,"'wa I reviewed. The stated purpose of this test was to check.the l

"reliability-related" piping and valves and the safety-related isolation valves. This procedure did not comply with the guidance provided in ZAP 5-51-5, "Procedure Content and- Format," and did not meet the requirements of ANSI N18.7-1972,'"Administrative Controls for Nuclear Power Plants," Section 6.2, "Test Procedures." Specific deficiencies included: The procedure was not designated or marked c: required b Paragraph H of ZAP 5-51-5 as a "Mandatory In-Hand". procedur . The purpose did not clearly state the scope and type of~ test

to be performed, as recommended in Paragraph E.4 of ZAP 5-51- For example, it did not inriicate what part of the PWRE modification letter applied, define how piping and valves were to be tested, nor specify the type of test (seat leak, mechanical or weld joint leak, packing leak, etc.).to be conducte . As required by another site procedure, an ASME Code visual ~

inspection (VT-2) was performed concurrently with this procedure, however, this inspection activity was not indicated as required or listed in.the references or text of the modification test procedure TSSP 39-8 . Procedure TSSP 39-88 did not contain any prerequisites or precautions, as required by ANSI and recommended by ZAP 5-51-5, even though it was performed on a hot and contaminated system pressurized to over 220 psi and involved opening of valves and the collection of system leakag . The procedure did not specify any hold time for either the pneumatic test or the valve seat leak test. Although this is not a specific requirement of the Code or the Administrative Procedure, it is an important parameter of any leak-tes The possibility or probability of water already existing in the lines and draining during valve manipulations was not mentioned in the procedur . The procedure contained no mention of, or reference to, any radiation or contamination control aspects of the test, although it involved opening a contaminated system in the containment. No discussion of collection devices for the leak test was provide . The last page of the test procedure did nos have the word

"final" above the page number as is required by Paragraph E.12 of ZAP 5-51-5.

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See Paragraph 2.3.2.3 of this report wegarding inadequate post-modification testing procedures. These are more examples of the violation discussed ther .5.2.2 Modification M22-1-87-05 Modification M22-1-87-05 consisted of installation:of. drain lines and valves for AFW pump bearing' oil res'ervoirs. The design modification approval letter required functional varification by opening an closing ~ the valve to ensure that oil flowed freely'from the reservoir and by performing ten-minute visual leak tests of.the entire new installation out to the threaded'end cap with the reservoir full in the configurations of valve-open pump off, valve open pump on, valve closed pump off, and valve closed pump on, Procedure TSSP 31-88 was written to prcvide for the required testin Several discrepancies were identified by the-inspection' team, including: The test procedure did not mention three screwed joints that-were to be verified leak tight nor did it include any acceptance criteria, as required by ANSI N18.7-1972'or CECO QR 10.0 and QP 3-51, The procedure was written for the test to be performed only with-the AFW pump off, although the test letter stated that testin was also to be completed with the pump runnin . There were addition documentation problems, such as quality-documents being rovised without signatures and date The first two discrepancies are examples where design requirements were not incorporated into the testing procedure as required by Criterion XI of 10 CFR Part 50, Appondix B. This is a violatio (295/88003-04C).

During a review of work request Z67093 for maintenance work on AFW pump 18 to flush the oil cooler, the team identified similar concerns relative to the documentation of testing on work requests as discussed in the NRC resident inspector's inspection, report No. 50-295/8701 l l

3.5.2.3 Modification M22-1-87-07 l

Modification M22-1-87-07 consisted of installation of drain lines and isolation valves for the centrifugal charging pump speed increaser bearing lubrication system. The testing required by the designer for this modification was the same as for Mcdification M22-1-87-05 on the AFW pump In accordance with procedure l TSSP 24-88, the testing was performed successfully and appeared to have met the test requirements. During the review of the procedures and documentation, however, it was noted that there was no listing of all the test procedures. Different modification package documents specified different testing requirements. For example, the work

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request _specified a "visual inspection / leak test" by the technical staff, while the station modification checklist specified an

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"inservice test."

t 3.5.2.4 Modification M22-1-87-08 Modification M22-1-87-08 consisted of installation-of a drain line and an isolation valve on.the containment spray pump diesel engine crankcase. The modification testing requirements for this modification were identical to those for M22-1-87-05 and M22-1-87-07.-

Completed tests prescribed'by procedure TSSP 23-88 were reviewed, ard no discrepancies were noted. The tests met the designer's requirements. The comments discussed above regarding inconsistency in specifying test procedures also apply to this modificatio .5.2.5 Modification M22-1-86-38 Modification M22-1-86-38 consisted of replacing the reactor coolant system wide-range pressure transmitters. The desigr. modification approval letter required a leak test of piping and valves and a_ visual inspection of the transmitters to verify that the sensing lines were in ;alled properl Occumentation existed to show that the sensing-li e connection _ inspection and a leak test of the transmitters were a: :eptably performe i 3.5.2.6 Modification M22-1-86-37 Modification M22-1-86-37 consisted of reorienting the safety injection system accumulator relief valve. The post-modification testing for this modification consisted of a pressure test at normal system pressure, and inspection of the new piping installation using soap solution to find gas leaks. The test had been completed, and the only documentation was a statement included in the modification tes letter attesting that the test was performed-satisfactorily. There were no written procedures or instructions directing testing activities or establishing acceptance criteri This is contrary to CECO ZAP 3-51-1B, CECO Quality Assuranc.e Manual, Section QP 3-51, a Criterion XI of Appendix B to 10 CFR P.'rt 50, which explicitly require written instructions for performing tests. As a result of the' lack of instructions and documentation, key test parameters, such as test pressure and valve lineup during the test, were not identified-or recorded. This is a violation (295/88003-04D).

3.5.2.7 Modification M22-1-84-68 1 l

Modi #ication M22-1-84-68 provided for replacement of the l contairment spray pump coupling in an effort to reduce vibratio !

The post-modification testing consisted of performing vibration '

surveillance test PT-6 and containment spray system tests and i check The inspection team observed that the testing was performed i sati sf actoril In comparing the pre- and post-codification test data, there appeared to be little improvement in the overall vibration levels. The licensee stated that they were investigating the matter to determine future actions for resolving the vibration proble I 51 l l

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3. Conclusion Although only one test _was observed,' program weaknesses and improper implementation were identified similar to those noted for installation activities. .The modification testing procedures and acceptance criteria needed to meet design requirements were not clearly delineated. Tests were performed without written test procedures, and completed work packages were accepted by site supervisors before required testing was performed or when improper testing (no procedure)

had been performed. Clanges to quality records.were improperly documente .0 UNRESOLVED ITEMS Unresolved items are matters about which more information.is~ required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during this inspection are '

discussed in Paragraphs 2.2.2.1 and 3.1.2.10 of this repor .0 PERSONNEL CONTACTED Many people were contacted during the inspectio The following is a brief list of the key personnel invnive Commonwealth Edison Company CECO

+*C. Reed, Senior Vice President T. Maiman, Vice President, PWR Operations

+*K. Graesser, General Manager, PWR Operations L. De1 George, Assistant Vice President N. Wandke, Assistant Vice President

• G. Plim1, Zion Station Manager

• G. Marcus, Director, Technical Services, Projects and l Construction Services (PACS)

+*B. Shelton, Manager, PWR Engineering (PWRE)-

M. Pietraszewski, Power Section Engineer  :

+ Rieck, Services Superintendent, Zion Station l E. Fuerst, Superintendent of Production, Zion Station '

E. Martin, Director of QA (Engineering and Construction)'

+T. VanDeVoort, Zion Station QA Superintendent

+*R. Cascarano, Technical Staff Supervisor, Zion Station

+ Bliss, Nuclear Licensing Manager

+ Johnson, Assistant Superintendent, Maintenance, Zion Station

+* Kurth, Assistant Superintendent, Operations, Zion Station l

+ Leblond, Rad-Chem Supervisor, Zion Station

+ i Reiss, Field Engineering Supervisor (PWRE), Zion Station l

+ Wozniak, Station Project Engineer, Zion Station '

+* Cole, Lead Mechanical Engineer (PWRE), Zion Station

+* Amoroso, Lead Electrical Engineer (PWRE), Zion Station l

+* Schultz, QC Supervisor, Zion Station i

+* Moravec, PACS Site Superintendent, Zion Station

+* Gilmore, Assistant Superintendent, Planning, Zion Station

+ Stone, Regulatory Assurance Supervisor, Zion Station  :

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+E. Campbell, Master Instrument Mechanic

+R. Benvenuti, General Foreman, Substation Construction

+*C. Simon, . INP0/ Modifications. Coordinator, Zion Station

+R. Squires, Nuclear Safety, General Office, Zion Station

• J. Sahlberg, QC_ Foreman, Substation Construction

+ Schulte, Supervisor, Mechanical Maintenance

• G. Trzyra, Nuclear Licensing Administrator F. G. Lentine, Power Licensing Superviso '+H. Studtman, Director of QA (Maintenance)

H. Kaczmarek,. Technical Staff Engineer B. Soares, Technical Staff Inservice Inpsection Lead Engineer J. Hutsebaut, Technical Staff Engineer P. Beinecke, Technical Staff Engineer L. Oberembt, QA Engineer J. Nykolayko, Modifications Coordinator J. Zecca, Technical Staff Engineer M. Sullivan, Field Engineer M. Pigon, Technical Staff Engineer M. Lesnet, Technical Staff Engineer Sargent and Lundy Engineers

+*R. Hameetman, Project Manager

+*W. Cleff, Project Director

• W. Berger, Senior Electrical Project Engineer

+J. Reddy, Project Engineer R. Odegard, QAP Coordinator M. Rauchhorst, Field Engineer J. Steiner, Electrical Engineer S. Bertheam, Senior Structural Engineer R. Kalita, Control and Instrumentation R. Chittenden, Mechanical Engineer P. Olsen, Supervisor, E. S. Putnam, Supervisor, Design Engineering Cygna K. Roberts, Project Manager T. Snyder, Manager, Midwest Office  ;

Reedy and Associates i l

R. Reedy, Consultant R. Swain, Consultant l Stearns Catalytic /VE&C N. Kaplan, Mechanical Engineer R. Patel, Project Manager i

Westinghouse Corporation H. Ott, Structu al Engineer  !

P. Kotivicki, Piping Technology

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Nutech, In 'l G. MiM igan, Staff Engint9r C. Warchal, Mechanical Engineer q A. Feddersen, Electrical Supervisor l T. Mitoraj, QA Administrator Hunter Corporation-

+ Bock, Project Manager M. Burke, Project Engineer

+S. Siatta, QA Supervisor J. Sterns, QC Inspector G. Norwelski, Foreman U.S. Nuclear Regulatory Commission (USNRC)

+* Miller, Director, Division of Reactor Safety, Region III

+ Wright, Chief, Operations- Branch, Region III

+*C. Haughsey, Chief, Special Inspections Branch, NRR

W. Forney, Chief, Projects Branch 1, Region III

• M. Phillips, Chief, Operational Programs Section, Region III

+*M. Holzmer, Senior Resident Inspector,-Zion Site

+*P. Eng, Resident Inspector, Zion Site  ;

G. VanSickle, Project Inspector, Region III J. Hinds, Chief, Reactor Projects Section 1A, Region III

• Attended the design inspection exit meeting on April 15, 1988.

+Attenried the installation and testing inspection exit meeting on April 29, 198 Attended the management exit meeting on July 6,198 .0 MANAGEMENT MEETINGS The inspectors met with the licensee representatives denoted in Paragraph 5.0 above at the conclusion of each phase of the inspectio The inspectors summarized the scope and findings of the design portion of the inspection on April 15, 1988. Similarly, the scope and findings of the installation and test portion of the inspection were discussed on April 29, 198A A management exit meeting was held on July 6,1988, to characterize those findings which had been determined to be apparent violations of NRC requirements and to present the overall conclusions reached by the inspection team. The inspectors also discussed the likely content of this inpsection report during these meetings. The licensee acknowledged the information presented and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur