IR 05000295/1987015

Insp Repts 50-295/87-15 & 50-304/87-18 on 870702-30. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Summary of operations,870707 Containment Fan Cooler Automatic Start & LER

ML20238A987
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/18/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20238A975	List: IR 05000295/1987015 ML20238A972
References
50-295-87-15, 50-304-87-18, NUDOCS 8709010021
Download: ML20238A987 (16)

Text

a

!

,, ..  !

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/87015(DRP); 50-304/87018(DRP)

Docket Nos. 50-295; 50-304 Licenses No. OPR-39; DPR-48 L1censee: Commonwealth Edison Company j Post Office 80x 767 Chicago, IL 60690 I Facility Name: Zion Nuclear Power Station, Units 1 and 2 l Inspection At: Zion, Illinois l

'

Inspection Conducted: July 2-30, 1987 Inspectors: M. M. Holzmer P. L. Eng N. R. Williamsen

,

'

/ -

L ,

4 .

Approved B - J. H. Hinds, ie 8 16 87 eactor Projects Section 1A Dite Inspection Summary i Inspection on July 2 through July 30, 1987 (Reports No. 50-295/37015(DRP); 1 l

50-304/87018(DRP))  !

Areas Inspected: Routine, unannounced safety inspection of licensee action I

on previous inspection findings; summary of operations; July 7, 1987 reactor l

. containment fan cooler automatic start; July 17, 1987 reactor trip breakers i l opening during safeguards testing; July 23, 1987 reactor trip breakers opening during safeguards testing; plant startup from refueling; operational safety i verification and engineered safety feature (ESF) system walkdown; surveillance observation; maintenance observation; licensee event reports (LERs); training; response to Region III requests; July 28-29, 1987 inservice testing (IST)

program meeting; INP0 site visi ,

Results: Of the 14 areas inspected, no violations or deviations were identified '

in 12 areas, and one violation was identified in each of the remaining two areas (inadequate corrective action in response to previous violation (295/87015-01(DRP); 304/87018-01(DRP) - Paragraph 2; and inadequate corrective action resulting from a non material false statement (295/87015-07(DRP) -

Paragraph 11).

8709010021 870826 5 DR ADOCK 0500 L

~ . . . . . . . .

. . .

..

.

. .

,

a

. . - .

. .

i l

'

DETAILS Persons Contacted

• Plim1, Station Manager E. Fuerst, Superintendent, Production

• T. Rieck, Superintendent, Services j

• W. Kurth, Assistant Station Superintendent, Operations 1

• R. Johnson, Assistant Station Superintendent, Maintenance i J. Gilmore, Assistant Station Superintendent, Planning

• R. Budowle, Assistant Station Superintendent, Technical Services ,

• L. Pruett, Senior-0perating Engineer 'l M. Carnahan, Unit 1 Operating Engineer i N. Valos, Unit 2 Operating Engineer

• R. Cascarano, Technical Staff Supervisor A. Ockert, Training Supervisor C. Schultz, Regulatory Assurance Administrator j V. Williams, Station Health Physicist i

• J. Ballard, Quality Control Supervisor j W. Stone, Quality Assurance Supervisor j T. Broccolo, Assistant Operating Engineer

• 0. Loeber, Foreman, Mechanical Maintenance {

• Indicates persons present at exit intervie . Licensee Actions on Previous Inspection Findings'(92701 and.92702)

(Closed) Open Item (295/81009-03(DRP); 304/81005-03(DRP)): Technical Specification (TS) revisions to reflect correct containment isolation valves (CIVs) installed in the sample system. Sample system modifications had been performed which added solenoid operated valves (SOVs) as CIV i TS Table 4.9-3, " Containment Isolation Valve. List," was not revised to i reflect the change. Following a November 1986 event in which two other CIVs (which were also omitted from Table 4.9-3)~were found open during power operations, the licensee submitted a TS amendment to correctly identify CIVs. A letter dated June 23, 1987, and its enclosed Safety Evaluation Report (SER) approved the TS amendment, which included the correct sample system CIVs. This item is considered close (Closed) Open Item (295/85002-08; 304/85002-08(DRS)): Documentation of valve stroke time testing method. The inspector interviewed six nuclear station cperators (NS0s) and determined that all six individuals knew how to perform stroke time testing of valves as specified in'Section XI of the American Society of Mechanical Engineers' Boiler and Pressure Vessel Code (ASME Code). Also, the inspector reviewed training records for NS0s and noted that all operators had been trained on how to perform stroke time testing. The-inspector noted that the method to be used for valve stroke time testing will be included in the periodic test (PT) procedures which are currently being revised. This item is considered close L_._________._______..____ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . . _ . _ _ . _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _

_ .

.

.. ** l

. * l

!

(0 pen) Violation (295/85002-09; 304/85002-09(DRS)): Failure to calibrate ;

stopwatches used for obtaining valve stroke time The inspector reviewed i licensee procedure ZAP 3-52-5, " Timepiece Accuracy Checks," which was identified in the licensee's response to the violation as placing Zion j Station in compliance with the requirements of 10 CFR 50, Appendix B, j Criterion XII. The inspector noted that the licensee does not actually

" calibrate" the timepieces but compares timepieces being checked to the clock in the Technical Support Center (TSC), which is not traceable to a National Bureau of Standards (NBS) standard. The inspector stated that all measuring and test equipment used to determine equipment operability, )

as noted in the licensee's approved Quality Assurance Topical Report CE-1-A, Sections QP 12-51 and QP 12-1, is to be " certified and periodically calibrated with traceability to an NBS or recognized Industry Standard."

The licensee stated that it was unaware of any available time standard traceable to NBS; consequently, it was using the clock in the TSC, which is driven off the system grid. The inspector noted that several other licensees in Region III had identified NBS time standards and had implemented calibration procedures using such standard The licensee stated that it would investigate available NBS traceable time standards for use in calibrating timepiece During performance of PT-27, " Miscellaneous Valve Tests," in support of Unit 2 startup activities, as discussed in Paragraph 7 of this report, the inspector noted that the procedure used to verify valve operability ,

did not require recording of the identification number of the timepiece ased to obtain valve stroke times. The fact that licensee periodic tests ased to verify valve operability did not require that the timepiece identification number be recorded was discussed in Inspection Report No. 295/85002; No. 304/85002, in Paragraph 9.b of the report text accompanying the subject violation. The licensee stated that its understanding of the violation was that the accuracy of the stopwatches !

used for valve stroke time testing be checked on a periodic basis, and not that the obtained data should be traceable to an individual stopwatc The inspector reiterated, as discussed in the previously referenced inspection report, that since there is no provision for determining which timepiece is used to obtain valve stroke times, should a stopwatch fail its calibration, the licensee would be required to question the validity of all times used to determine equipment operability. The inspector noted that a review of tests used for post-maintenance testing for valves could be conducted to assure that all times taken in order to prove component operability are taken using properly calibrated timepieces. The licensee stated that pertinent periodic test procedures were currently being revised to require that stopwatch identification numbers be recorded in the test record Failure to assure that controlled, traceable measuring and test equipment is used to obtain data, from which a component is determined to be operable, as previously discussed in Inspection Report No. 295/85002; No. 304/85002, is considered to be an example of inadequate corrective action and a violation of 10 CFR 50, Appendix B, Criterion XVI (295/87015-01; 304/87018-01).

One violation was identifie ,

_ - _ _ - _ _ - _ - _ _ - _ - _ _ - _ _ _ _ _ _ _ __ _

, .'

l Summary of Operations  !

Unit 1 i

Unit 1 operated for the entire inspection period in Mode 1 at levels !

up to 95% power. Power levels were limited due to excessive generator I frame vibrations, spiking steam flow transmitters, and excessive 1 electro-hydraulic control (EHC) pump cycle time Unit 2 l Unit 2 began the inspection period in Mode 5 (Cold Shutdown).

Hot Shutdown, Mode 4 (T-avg above 200F) was reached on July 27, 1987, and Hot Shutdown, Mode 3 (T-avg above 350F) was reached on July 2 . July 7, 1987, Reactor Containment Fan Cooler Automatic Start (93702)

On July 7, 1937, with Unit 2 in cold shutdown following refueling, the 2A ,

reactor containment fan cooler (RCFC), an engineered safety feature (ESF) '

component, automatically started during post-maintenance testing on 4160V ESF bus logic circuits. A licensed operator and a Technical Staff engineer had performed an electrical lineup preparatory to testing these ESF logic circuits. As part of the electrical lineup, the test procedure required several 120V circuit breakers to be placed in the "off" position so that testing of the logic circuits would not lead to an ESF actuatio Both personnel failed to verify the on/off designation and then turned the 120V circuit breakers on when they should have left them off. When the test was performed, the RCFC automatically started as designe The 120V breakers in question are located in panels housing two rows of .

breakers, side-by-side. The breakers that control safeguards actuation !

had been painted red to emphasize their importance; however, the red paint obscured the "on/off" designations, making them difficult to rea Corrective actions were initiated the next day and included enhancing the

"on/off" indications for the breakers and counselling the personnel who performed the lineup on the importance of verifying breaker position Subsequently, embossed placards were installed next to each breaker to enhance identificatio l This is considered an Unresolved Item pending NRC review of the licensee's 30-day LER (304/87018-02).

No violations or deviations were identifie One Unresolved Item was identifie I i

-

___ __

__ - ____-__ ____ -___ ___ _ - _ _ _ _ _ _ _ _ _ _

.

.

_ July 17, 1987, Unit 2 Reactor Trip Breakers Opening During Engineered Safety Features Testing (93702)

l i

On July 17, 1987, at approximately 10:20 p.m., with Unit 2 in cold shutdown (Mode 5), the Unit 2 reactor trip breakers (RTBc) opened during ESF logic tetting. At the time, all four steam generators (SGs) were drained for maintenance, and resistors were installed to simulate normal SG levels for testing. Without the resistors, reactor trip signals would be generated because actual SG levels are below the 10% narrow range indication reactor trip setpoint. At the conclusion of the test, the test procedure (PT-10C, " Safeguards Logic Testing at Cold Shutdown Only") required the removal of the simulated load resistors, but failed to specify that the RTBs be opened first. When two of three simulated loads for the A SG were removed, the 10% SG level reactor trip logic was completed, and the RTBs opened as designe The control rods were already on the bottom during the test, so no rod motion occurre This is considered an Unresolved Item pending NRC review of the licensee's 30-day LER (304/87018-03).

No violations or deviations were identified. One Unresolved Item was identifie . July 23, 1987, Unit 2 Reactor Trip Breakers Opening During Safeguards Testing (93702)

On July 23, 1987, at approximately 9:30 p.m., with Unit 2 in cold shutdown (Mode 5), the Unit 2 reactor trip breakers (RTBs) opened during ESF logic testing. At the time, all reactor trip bistables were tripped for power range nuclear instrumentation (NI) Channel 2N43 while instrument mechanics (IMs) were performing maintenance. In addition, Instrument Bus 212, which supplies power to another power range NI channel, 2N42, was supplied from an @0V/120V transformer instead of from its instrument inverter, which is protected by one of the station batteries. The subject 480V/120V transformer is supplied by 4160V ESF Bus 242. When 4160V Bus 242 was de-energized for ESF logic testing as required by the test procedure (PT-10, " Safeguards Actuation, Unit 2"), Instrument Bus 212 was immediately de-energized, causing power range Channel 2N42 to be lost and tripping all of its associated reactor trip bistables. With 2N43 bistables already tripped. the two-of-four reactor trip logic was completed for all trips fed from the power range NI The reactor trip breakers opened on high flux rate, as indicated by the first-out annunciator. The control rods were already on the bottom during the test, so no rod motion occurre ,

This is considered an Unresolved Item pending NRC review of the 30-day LER (304/87018-04).

No violations or deviations were identifie One Unresolved Item was '

identified, i

.. ..

. . Plant Startup From Refueling (61715 and 71711)

The inspectors reviewed portions of the licensee's Unit 2 startup package,.

including General Operating Procedures (GOPs), Technical Staff procedures and pts to determine whether-activities conducted to support the unit startup and heatup were properly performed and documented in accordance with approved procedures. ' System and control board lineups were reviewed for completeness and conformance with licensee procedures. Activities observed are listed in Paragraphs 8 and 9 of this report. Specific comments related to these activities are noted belo The inspector observed portions of PT-27 and reviewed the test documentation. Identified concerns are discussed in Paragraph 2 of this repor During the review of Procedure MI-2, " Reactor Coolant System,.

Fill and Vent," the inspector noted that several temporary procedure changes had been added to. the procedure, and that:

• in several instances, both old and revised pages existed in-the procedure, e operators had signed off steps on both old and revised pages following the revisions, and

• procedure steps were not properly renumbered following two of the revisions (one of these errors was verified to be promptly corrected after the inspector informed the licensee and neither example appears to have led to operators performing steps in the wrong order).

None of these discrepancies resulted in an-immediate safety concern. The inspector also suggested that in addition to operator initials, dates and times be recorded to provide a more detailed event histor The inspector observed two non-licensed operators clearing out-of-service cards. The operators performed the assigned tasks carefully, using proper records, procedures, communications, and reporting of off-normal conditions, The inspector reviewed the completed Procedure TSSP 14-87, "IEB 85-03 Auxiliary Feedwater Motor Operated Valve Stroke Test," and observed that:

• there were four temporary changes made to the procedure, which made the procedure difficult to follow, and

• unsat'isfactory test results were correctly identified in the test evaluation, including the work request which resolved the discrepanc .

. .

-___ _ _ _ _ _ _ - _ _ _ _

.. .

. .

.. . .

.

..

. The inspector questioned the licensee regarding a portion of PT-20,

" Centrifugal Charging System Power Operated Valve Tests," which states that, following valve cycling, if the boron injection tank j (BIT) inlet or outlet valves do not properly seat, then an operator j may manually manipulate the valves in order to get them to sea '

The procedure specifies that in making this manipulation, the torque may not exceed three foot pound The inspector was concerned that manually torquing the valves could cause them to seat so firmly that the motor operators may not be able to open them on demand, and the inspector questioned how the licensee assured that the value of three foot pounds was not exceeded. The licensee responded that these valves have double disk gates and that it is unlikely that they could be jammed into the seat Furthermore, if these valves are stroked too far, they will not seat properly, and any seat leakage would persist. The licensee also stated that the manipulation was a matter of judgement, with the operator working under the direction of an experienced forema The inspector also noted that PT-20 has no provision to record whether manual manipulation is performe The inspector requested q that the licensee demonstrate how BIT inlet and outlet valves are not overtorqued during the performance of PT-20, and requested that PT-20 be revised to record manual manipulations, if performed. The licensee stated that the manual torque statements would be remove This is considered an Open Item pending NRC review of the licensee's evaluation and revised PT-20 (295/87015-02; 304/87018-05). The inspectors observed containment personnel hatch testing in accordance with procedure TSS 15.6.10c,'" Type B Leak Rate Test For the Personnel and Escape Locks," and discussed the following findings with the licensee:

• The hatch interlock portion of the test failed initially, due I to the installation (at the beginning of the outage) of a device j which defeated the interlocks. The device, which was installed i under the direction of a vendor technical representative, was not i described in the vendor manual or in station Procedure P/PP000-1N, i

'

" Personnel Lock / Escape Hatch." P/PP000-IN includes the method of defeating the hatch interlocks which is specified in the vendor manual. The unauthorized interlock defeat was not j described in the work instructions and was not recorded in l the " work performed" block of Work Request Z57422, under the direction of which the vendor technical representative's inspection and adjustments were performe The defeated interlock was identified by TSS 15.6.10c prior to entering a mode in which the hatch was required to be operabl This is considered an Unresolved Item pending a review of the licensee's corrective actions for this event (304/87018-06). ,

• The test box (Serial 1243) used to perform the test included a pressure gage (Ashcroft, 0 - 100 psig) which was marked only with a Dymo tape which stated " TSP 1243," and did not appear to be traceable to the calibration record for Test Box 124 _ - - _ _ - _ _ .

.

..

. -

l The licensee stated that the flow meters in the test box were l calibrated prior to and following each outage. The-inspector j noted that the last calibration' sheet in the official calibration i file, for the Ashcroft pressure gauge,'was' dated May 9, 1986,- I which was over a year before the current Unit 2 outage, and i that there did not appear to be'a calibration performed following 1 the Unit 1 September 1986 - March 1987 outag The' licensee then j produced a calibration sheet dated May 4, 1987 for the Ashcroft ;

pressure gage, and inserted a copy into the test box recor When asked if the pre-outage and post-outage calibrations were !

included in the licensee's program, the licensee respon<ied that- 1 they were not, but that the responsible engineer ensured ~that-calibrations were done as state Control of deficiencies associated with the calibration of instruments l used in containment type B and C leak rate testing is considered'an ,

l Unresolved Item (295/87015-03; 304/87018-07).

)

l The inspector accompanied a station man foreman during performance I of GOP-0, Checklist' E, " Containment Closecut Prior to Heatup." The l inspector noted that the station man foreman performed his duties ;

efficiently, paying attention to detail and in a. manner which kept I his acquired dose as low as reasonably achievable. Items which were left in containment for ongoing work were noted and communicated-to !

appropriate management personnel in a timely manner, j No violations or deviations were identifie Two Unresolved Items and

-

one Open Item were identifie . Operational Safety Verification and Engineered Safety Features System 1 Walkdown (71707 and 71710)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from July 2-30, 198 During these discussions and observations, the inspectors ascertained that the operators were alert, fully cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriat The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and turbine buildings were conducted j to observe plant equipment conditions, including potential fire hazards, i fluid leaks, and excessive vibrations-and to verify that maintenance requests had been initiated for equipment in need of maintenanc ,

i The inspector independently verified that portions of the following valve lineups were as required by the following procedures:

501-4, Appendix 8-2 Unit 2 Containment Spray System Valve and Electrical Lineup  !

S01-10, Appendix A-2 Auxiliary Feedwater Valve and Electrical Lineup

_

- ',' y By observation and direct interview,'the inspectors verified that selected physical security activities were being implemented in accordance with the station security pla The inspectors observed plant housekeeping and cleanliness conditions and .

verified implementation of radiation protection control From July 2-30, i 1987, the inspectors walked down the accessible portions of the containment I spray, auxiliary electric power, and auxiliary feedwater systems to verify '

operabilit These reviews and observations were conducted to verify that facility ,

operations were in conformance with the requirements established under j Technical Specifications, 10 CFR, and administrative procedure The following comments were provided to the licensee:

' Procedures PT-0, Appendix J1, " Normal and Reserve Off Site AC Power Shift Check Sheet," and Appendix J2, "On Site AC & DC Power Availability," were reviewed, and the inspector walked through these procedures with a licensed nuclear station operator (NS0) and an equipment operator (E0). The inspector noted that in some cases appropriate acceptance criteria were not provided. In addition, portions of the procedures did not correspond to actual plant hardware installation. The NSO and E0 were able to obtain the needed information despite the weaknesses in the procedure These procedures are being revised as part of a human factors revision to all pts and GOP The inspector provided these comments to the licensee for consideration as part of its review process. This is considered an Unresolved Item pending review of the licensee's completed revisions to PT-0, Appendices J1 and J2 (295/87015-04; 304/87018-08). Several PT-14, " Inoperable Equipment Surveillance Tests," packages were reviewe The inspector noted that in several cases, blanks on ,

the PT-14 forms were not filled in or marked "not applicable." The )

PT-14s reviewed appeared to have sufficient information to identify ;

and track inoperable equipment, and records of necessary surveillance ;

tests required by Technical Specifications were up to dat Previously identified deficiencies involving inconsistent and incomplete recording of hourly fire watch patrols in control room logs were redressed during the inspection perio ; During control room observations, the inspector noted that some controlled drawings kept in the control room were blurred to the extent that valve numbers were illegibl During subsequent discussions the licensee informed the inspector of its long range plans to improve drawing control, including drawing quality. The inspector requested that short term actions be taken to provide legible copies of controlled drawings and piping and instrument drawings (P&lDs) in the control room. The licensee agreed to audit the control room controlled drawings and P& ids and to obtain legible

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

_ .

~

.. t

.

.

copies from its architect engineer (Sargent and Lundy). This is considered an Unresolved Item pending review of the licensee's audit and upgraded drawings (295/87015-05; 304/87018-09). ,

No violations or deviations were identifie . Monthly Surveillance Observation (61715, 61720 and 61726)

The inspectors observed TS required surveillance testing on various systems in order to support the startup of Unit 2 and verified whether  :

testing was performed in accordance with approved procedures, whether .

test instrumentation was calibrated, whether limiting conditions for operation were met, whether component operability was demonstrated, and whether any deficiencies identified during the testing were properly identified and resolved by appropriate management personne The inspector witnessed portions of the following test activities: l GOP-0 Plant Startup Documentation Requirements GOP-1 Plant Heatup MI-2 Reactor Coolant System - Fill and Vent PT-6 Containment Spray System Tests and Checks PT-7 Auxiliary Feedwater System Checks and Tests PT-10 Safeguards Actuation Test Unit 2 PT-27 Miscellaneous Valve Tests TSSP 14-87 Auxiliary Feedwater M0V Stroke Test TSS 15.6.2c Type B Leak Rate Test for the Personnel and Escape Locks  !

The inspectors reviewed the completed test documentation for the I following test activities:  !

PT-2J RHR Pumps-Tests and Checks PT-8A Monthly Operability Test of Component Cooling Pumps PT-11 Diesel Generator Loading Test PT-16 Functional Test for Boric Acid Transfer Pumps  !

Containment Isolation Valves-Stroke Time Verification

~

PT-300 Specific comments related to the above surveillance tests are found in Paragraph 7 of this repor No violations or deviations were identifie . Monthly Maintenance Observation (62703)

Station maintenance activities on safety-related systems and components l listed below were observed or reviewed to ascertain whether they were  !

conducted in accordance with approved procedures, regulatory guides, industry codes or standards and in conformance with Technical Specification :

,. *

.

.

+ 28 charging pump outboard seal leak repair (WR Z57195) j

• 1 A0V-MS0057 diaphragm replacement {

• Post-maintenance run on the 2A Containment Spray pump j

• Post-maintenance run on the "0" Diesel Generator  ;

The following items were considered during this review: the limiting !

conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the ,

work; activities were accomplished using approved procedures and were i inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related j equipment maintenance which may affect system performanc Following completion of maintenance, the inspector verified that the following components had been returned to service properly: Regarding the seal repair on the 28 charging pump, the shaft seal sleeve was replaced three times under its work request due to galling on the pump shaft during installation or during removal (following an improper reassembly which was detected by the licensee prior to completion of the job). The QA red tags for the three shaft I seal sleeves used did not contain the same information (for example, l one red tag did not have the stores item number as did the other two).

In addition, the shaft seal sleeves were modified to plate the inner diameter with a chrome alloy and to relocate the shaft seal 0-ring

,

'

groov The licensee produced correspondence from the pump vendor, Pacific Pumps, approving each of the changes, but there appeared to be no method to assure that parts ordered for future shaft seal sleeves would be modified in the same manner as the shaft seal sleeves used. In addition, the inspector questioned how modified parts were identified to distinguish them from each other, and whether the vendor would supply chrome plated parts using a different part number. This will be considered an Unresolved Item pending determination of whether part identification and design controls for shaft seal sleeves were proper (304/87018-10). The inspector reviewed the maintenance history of the air-operated steam stop valve (No. MS-57) for the 1-A steam driven Auxiliary Feedwater Pump. This review showed that there had been four replacements of the MS-57 diaphragm since June 198 The most l recent diaphragm failure occurred just thirteen days following l the prior replacement.

l

,

The licensee's ongoing investigation indicated that the problems I of multiple diaphragm failures may be linked to the fact that the diaphragm vendor uses the same part number for two different

,

. . . .

. .

diapn r,ct.s, both of which fit the MS-57 air operator. Specifically, the last diaphragm which failed had no steel reinforcing, whereas the replacement diaphragm di This is an Unresolved Item pending further investigation ,

(295/87015-06).

No violations or deviations were identifie Two unresolved items were identifie . Licensee Event Reports (LERs) Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that deportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification The LERs listed below are considered closed:

UNIT 1 LER N DESCRIPTION i

l 87005 Reactor Trip on Low-Low Steam Generator Level Caused by Opening Main Steam Isolation Valve Bypass Due to Personnel Error in Communications 87005-01 Reactor Trip on Low-Low Steam Generator Level Caused by Opening Main Steam Isolation Valve Bypass Due to Personnel Error in Communications 87007 Lake Discharge Tank Release With Radiation Monitor Isolated Due to Personnel Error 87011 Unit 1 Reactor Trip As a Result of Source Range IN31 High Flux Level Trip Signal Due to Noise UNIT 2 LER N DESCRIPTION 87002 Auxiliary Feedwater Pump Autostart During Steam Generator Draining Due To Inadequate Procedures Regarding LERs 295/87005 and 295/87005-01, the inspector determined that one corrective action reported as complete was still outstandin The LER stated:

"An entry was added to the Maintenance Department's computerized work instruction system, notifying the Maintenance Work Analyst of the Technical Specification requirements on these valves, and

u

- ______ __-_ _____

.. ..

. .

instructing him not,to schedule work which would defeat the valves'

'

fail-closed ability unless the unit is in cold shutdown or measures are taken to mechanically hold the valve shut."

The inspector learned that the work instruction system had not been updated as stated above. 10 CFR 50, Appendix'B, Criterion XVI, as implemented.by the licensee's approved Quality Assurance Topical Report CE-1-A, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected. Failure to promptly implement

.

corrective actions as stated is considered a violation (295/87015-07)..

The inaccurate information described above would probably not have resulted l in regulatory action lor in the NRC seeking additional information had the correct information been available. Interviews with station manage-ment and the LER author indicated that the inaccurate information probably resulted from a misunderstanding or a failure to properly communicat z Verification of information regarding this corrective action by LER  !

reviewers also appeared to be inadequat l Regarding LER 295/87007, this event was reviewed by NRC Region III l

inspectors from the Division of Radiation Safety and Safeguards in Inspection Report No. 295/87008(DRSS). The event is being tracked by Unresolved Item No. 295/87008-01 and No. 295/87008-0 Regarding LER 295/87011, reactor trip due to noise on source range ]

nuclear instrument 1N31, the proposed corrective actions included (a) replacing the source ran 4 l

, the next refueling outage, (ge tube in the 180-degree well duringb) reviewing GOP '

l that would allow the operators to open the reactor trip breakers when ,

the flux level is reduced below 1E-8 amps on the intermediate range nuclear instrument channels during a controlled shutdown, and (c) correcting G0P-4 (Rev. 2, May 1987) where it incorrectly directs the operator to manually reinstate the source range nuclear instrument channels at a flux level of IE-10 amps in the intermediate range instead l of using the correct value of less than or equal to SE-11 amps. Review l of the licensee's corrective actions is considered an Open Item I (295/87015-08).

Regarding LER 304/87002, this event resulted in violation 304/87007-0 Corrective actions will be tracked by the violation and this LER is considered close One violation and no deviations were identified. One Open Item was identifie . Training (41400) l During the inspection period, the inspectors reviewed abnormal events and unusual occurrences which may have resulted, in part, from training deficiencies. Selected events were evaluated to determine whether the classroom, simulator, or on-the-job training received before each event ,

was sufficient to have either prevented the occurrence or to have mitigated

'

- - .

--

_ _ ...

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

.. .

. .

its effects by recognition and proper operator actio Personnel qualifications were also evaluate In addition, the inspectors determined whether lessons learned from the events were incorporated into the training progra Events reviewed included the events discussed in this report. In addition, LERs were routinely evaluated for training impact. No events reviewed this period was found to have significant training deficiencies as contributor No training sessions were attended by the resident inspector An Institute for Nuclear Power Operations (INPO) site team was onsite during the period July 13-17, 1987, to assess the status of seven training programs prior to submittal of the licensee's programs to the Training Accreditation Board. The training programs reviewed were:

Mechanical Maintenance Personnel Electrical Maintenance Personnel Instrument Maintenance Personnel Radiological Protection Technician Chemistry Technician Shift Technical Advisor Technical Staff 1 Followup of Region III Requests (92701)

On July 21, 1987, regional personnel requested information regarding containment penetrations manufactured by the Tube Turns Corporation installed at Zion. On July 23, 1987, the licensee reported that 128 mechanical containment penetrations for each unit are installed at Zio These penetrations were hydrostatically tested to one and one-half times the penetration design pressure as required by ANSI B31.1 by Tube Turns prior to installatio Following installation, the penetration bellows were pneumatically tested to approximately 54 psig by the contractor who installed the penetrations. The licensee stated that several of the bellows failed the pneumatic test and were returned to Tube Turns. Replacement bellows were also subjected to the pneumatic test and were not accepted unless they successfully passed the pneumatic test to 54 psig. The licensee also stated that the contairaant penetration pressurization (PP)

system in use at Zion provides some leak detection capability in that both the PP system pressure and flow rates are alarmed to indicate leakag . July 28-29, 1987, In-Service Testing (IST) Program Meeting (30702)

On July 28-29, 1987, a working meeting was held onsite among three members from EG & G, the IST program reviewer from the Mechanical Engineering Branch (MEB) of NRR, three region based inspectors from the Operational Programs section, the Ceco corporate In-service Inspection (ISI) Coordinator, site personnel and the resident inspector regarding the licensee's relief requests from the requirements of 10 CFR 50.55a(g) as they pertain to IST. Questions transmitted to the licensee by letter

- ____-___ -____

.. .. \

. .

from J. A. Norris to D. L. Farrar, dated March 31, 1987, were discussed as were the testing methods employed by the licensee to verify component operability as required by Section XI of the ASME Cod l The licensee has agreed to revise and resubmit.its IST program for consideration by EG & G and MEB before the end of the year. A separate trip report documenting those topics addressed at the meeting will be l issued by MEB. A list of meeting attendees is attache i l 15. INP0 Team Visit Twenty members of INP0 were onsite for the period July 27 through August 7,1987, for a periodic review of licensee performanc . Open Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot Two Open Items disclosed during this inspection are discussed in Paragraphs 7e and 1 l 17. Unresolve_d Items Unresolved items are matters about which more information is required l in order to ascertain whether they are acceptable items, items of '

noncompliance or deviations. Eight Unresolved Items disclosed during this inspection are discussed in Paragraphs 4, 5, 6, 7f, 8 and 1 . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection conducted from July 2-30, 1987, to summarize the scope and findings of the inspection activitie The licensee acknowledged the inspectors'

comments. The inspectors also discussed the likely informational content .

of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar __---.-

-

. , . ..

. -

l

{

ATTACHMENT 1 INSERVICE TESTING WORKING MEETING ATTENDEES f

JULY 28-29, 1987 ZION STATION

l

.

COMMONWEALTH EDIS0N T. Rieck Superintendent, Services, Zion Station 1 P. LeBlond Nuclear Licensing Administrator, Zion l A. Bless Regulatory Assurance {

C. Gosch Maintenance Staff Engineer i L. Holden Regulatory Assurance A. Rasmussen Maintenance ftaff Engineer M. Madigan ISI Coordinator, Zion Station j W. Reecher Technical Staff Engineer, Zion Station i B. Soares IST Coordinator, Zion Station '

D. Zebrauskas Corporate ISI Coordinator f

NRC S. Eick Inspector, Operational Programs Section P. Eng Resident Inspector, Zion Station {

Y. Huang IST Program Reviewer, MEB, NRR M. Huber Inspector, Operational Programs Section '

P. Wohld Inspector, Operational Programs Section i

EG & G f j

t R. Hartley IST Program Reviewer j W. Hemming IST Program Reviewer i

H. Rockhold IST Program Reviewer j

i

l l

?

o

l

!

l

)

___ _ _ _ _ _ _ _

@ g

• O

,!

p 4/

N

//

(, $ $ !?-

r%

,

l

.

G' Q, o

93 reg. ..

9e, v.;

_

'

p ;p '

c:,

• l3

-

$ ' y, -.

6- N o 3 h:' 24 'k

,

/@Tlllt\"

_ _ _ _ _ .