IR 05000295/1987012

Safety Insp Repts 50-295/87-12 & 50-304/87-15 on 870518-28. No Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Insp of Electrical & Instrumentation Corrective & Preventative Maint Activities

ML20215G362
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/16/1987
From:	Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215G314	List: IR 05000295/1987012 ML20215G311
References
50-295-87-12-01, 50-295-87-12-1, 50-304-87-15, NUDOCS 8706230224
Download: ML20215G362 (9)

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, U.S.' NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. . 50-295/87012(DRS); 50-304/87015(DRS)

t Docket Nos. 50-295; 50-304

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Licenses No.'DPR-39; DPR-48

. Licensee: Commonwealth Edison Company Post Office Box-767 i Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, Illinois Inspection Conducted: May 18-28, 1987 I Inspector: Zelig.Falevits 6[/6/87 Date M k- ~

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Approved'By: Ronald N. Gardner, Chief Plant Systems-Section b// b/87 Date Inspection Summary  ;

Inspection on May 18-28, 1987 (Reports No. 50-295/87012(DRS);

No. 50-304/87015(DRS))

Areas Inspected: Routine,' announced safety inspection of licensee action on previous. inspection. findings; inspection of electrical and instrumentation corrective and preventative maintenance activities; review of procedures, work requests and drawings; and training (92702, 62704, 62705, 41400).

Results: Of the four. areas inspected, no violations or deviations were-identifie PDR ADOCK 05000295 G PDR

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

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• K. Depperschmidt, Electrical Maintenance Scheduler

• R. Johnson, Assistant Superintendent Maintenance

• T'Niemi, Master Mechanic

• J. Ballard, Supervisor Quality Control

• D. Johnson, Stores Supervisor

• F. Tschakert, Instrument Maintenance Scheduler

• J. Rappeport, Quality Assurance Engineer

• J.'Yost, Quality Control Inspector

• C. Schultz, Regulatory Assurance Supervisor

• D. Wozniak, Engineer, SNED

• Stone, Quality Assurance Superintendent

• R. Budowle, Assistant Superintendent Technical Services

• G. Plim1, Station Manager

• T. Rieck, Services Superintendent

• E. Fuerst, Production Superintendent T. Chladek, EM Foreman S. Hazelriggner, EM Foreman M. Baily, Environment Qualifications Coordinator G. Fanning, Technical Staff Engineer S. Sassaman, Technical Staff Engineer S. Petrovski, Staff Engineer

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U.S. NRC

• Holzmer, Senior Resident Inspector ,

• P. Eng, Resident Inspector '

• R. Sutphin, Regional Inspector i

• T. Vandel, Regional Inspector

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• Denotes these present during the exit interview on May 28, 198 The inspector also contacted other licensee and contractor personnel during the course of this inspectio . Licensee Action on Previous Inspection Items (Closed) Violation [295/86023-01(DRS); 304/86022-01(DRS)]: On September 20,1986, Unit 2 reactor tripped during an EHC transient which was due to a valving error whereby the instrument mechanic, after replacing turbine impulse pressure transmitter 2PT-MS24, inadvertently opened the test connection valve rather than the isolation valve as required by desig l I

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Subsequently, the licensee had taken disciplinary action with the !

responsible individual. Licensee management discussed this event with the Technical Staff and maintenance personnel. The applicable procedure was rewritten to separate the MS24 instrument loop into an independent procedure, and a second verification was incorporated into the applicable instrument loop procedur The inspector reviewed licensee corrective actions and found them adequate to resolve this issu (Closed) Violation [295/86023-02(DRS); 304/86022-03(DRS)]: This item !

concerned an Operational Analysis Department (OAD) test engineer who opened test switches without using the proper procedures. The opened test switch prevented the D.G. 480V transformer feed breaker from closing automatically as required by design. The licensee determined the root cause of this event to be the failure of the Technical Staff engineer to coordinate the troubleshooting activitie The inspector ;

reviewed licensee completed and proposed corrective action which included: training of engineers on the OAD calibration methodology; changes in administrative procedure, and the use of the work request form to identify test switches which are to be opened or closed during troubleshooting activitie Licensee action appeared to be adequate. This item is considered close . Inspection and Review of Electrical and Instrumentation Corrective and Preventative Maintenance Activities The purpose of this inspection was to ascertain whether corrective j and preventative maintenance activities relative to electrical and i instrumentation components and systems were conducted in accordance with )

licensee-approved procedures, instructions, and latest drawings; that !

activities were performed by preplanned schedules and as required to maintain the units in safe operating condition; that the procedures, instructions, and drawings used met the requirements of technical (

specifications, regulatory guides, and industry codes and standards committed to by the license The inspector observed selected maintenance activities in progress and reviewed the procedures and documents for the corrective and preventative maintenance program relative to electrical and instrumentation maintenanc The attributes examined included: the appropriate approval signatures l obtained from operations prior to conducting the activity and at the time !

of returning the system to service; use of latest approved drawings, instructions or vendor manuals; establishment of QA/QC hold points and appropriate acceptance criteria; provisions for assuring that the applicable Technical Specifications and plant operation modes were noted; provisions for calibration of tools, equipment used and designation of required tests; provisions to insure that materials, parts, and components, are suitable for their intended use including environmental qualification; control of housekeeping; control of jumpers and lifted leads; provisions

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to insure that personnel qualifications necessary to perform the maintenance activities have been delineated; measures established to perform trend analysis for repetitive component failures based on maintenance history (root cause failure); responsibility for reporting to licensee management details concerning deficiencies identified during maintenance; a method to insure that service information, 10 CFR 21 ;

Notices, IE Information Notices and Bulletins are available to the proper i maintenance personne l The inspector also conducted interviews with selected personnel relative to their trainin Observation of Maintenance Activities in Progress (1) The inspector observed an inspection and maintenance performed on limitorque motor operated Valve No. 2MOV-FW0050, "S/G 28 Aux FW Stop Valve." This task was conducted under WR No. 257122, dated !

February 19, 1987, and WR No. 253285, dated September 12, 1986, and to the requirements of maintenance Procedure No. E022-1, i Revision 5.Section I of the procedure delineated the required inspection check points and provided for documenting any discrepancies noted and recommended-action to resolve the Section II of the procedure included the required step by step check points and data to be recorded under the repair and maintenance activities. The electrical maintenance craftsman (EM) appeared to be knowledgeable in the task being performed; all required applicable attributes were addresse (2) On May 21, 1987, the inspector observed a performance test conducted on Unit 2, Battery Charger 212, using Procedure No. TSS 15.6.388, Revision 8, dated August 25, 1983. This test was required by Technical Specification Section 4.15.1.E. and was done to. comply with surveillance test requirements to test for proper equalized voltages of the battery charge At the beginning of the test, the 480V feed breaker to the battery charger located in Bus 238 switchgear, Cubicle 2C, had tripped on closure. Attempts made by the operator to reset the breaker locally had failed. The electrician then manually repositioned the overcurrent time delay plunger assembly located inside the breaker. This action reset and reclosed the breaker (the plunger was stuck, apparently due to dusty conditions in the unit). The inspector noted that the Technical Staff engineer continued the test without documenting the fact that the breaker had failed to clos In addition, l the test procedure lacked the provisions for documenting the !

test summary, problems, or deficiencies noted during the !

conduct of the test. The test engineer stated that at the conclusion of the test (which lasted 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) he would note the identified problems or deficiencies in a letter and would attach the letter to the procedure. The inspector informed !

the licensee that this does not appear to be an acceptable f

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method of documenting identified deficiencies. A review of the previous corrective maintenance performed on the same breaker in September 1985, under work request No. Z45099, revealed that the identical problem had occurred with the same breaker, whereby, the breaker tripped while the battery was on equalize charge and could not be reclosed. Work performed in 1985 to resolve the problem involved the recalibration of the associated Ampetector overcurrent relay. The functional test conducted subsequent to the calibration, which was performed in December 1985, indicated that the relay tripped within 49 m.sec. (the acceptance criteria was set at <50 m.sec.). Had it tripped at

>50 m. sec. the breaker would have then required a complete i maintenance and cleanup (the breaker located upstream, which feeds l the entire switchgear, is set to trip at > 50 m. sec. ) . During i an identical test conducted in April 1983 on the same overcurrent J relay, the relay tripped within 30 m. sec. The inspector expressed his concern that the licensee did not appear to have an adequate trending program to identify repeat component failures or generic component i failure j At the completion of the test on May 21, 1987, the licensee issued WR No. Z606223 to investigate the cause of the failure of the breaker to close and stay closed. The breaker was bench tested and the overcurrent time delay plunger assembly was i cleaned and replaced. The inspector noted that work request, WR No. Z606223, did not require that the breaker be retested at the conclusion of the troubleshooting and repair. In addition, the WR stated that "Further testing may be needed as problem seems to be occurring when AC is turned on to the 212 charger."

The inspector expressed the concern that the root cause of the problem appears to still be indeterminate. The licensee indicated that a review of this issue would be conducted to determine the root caus licensee action and This review NRC issue [295/87012-01(DRS);

is considered unresolved pending(DRS)].

304/87015-01 (3) The inspector observed Instrument Mechanics (IMs) perform troubleshooting to WR No. 260162, dated May 19, 1987, to identify a ground fault located in an annunciator circui The inspector noted that the IMs had exhibited technical difficulty during the troubleshooting activity, specifically, in the use of the proper drawing for the activity and in the interpretation of the voltage readings observed during the performance of this troubleshooting activity. Finally, with the assistance of the EM, the ground fault was identified and traced to a bare spare conductor (which should have been taped)

inside device 1TSH-CD678. The licensee stated that taping of spare conductors is a " Skill of Craft" activity, which is not required to be noted in a procedure. The licensee indicated that the new TSH switches (recently installed) will be inspected and that all spare conductors would be tape .

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No deviations or violations were identifie b. Maintenance Program Review (1) The inspector conducted interviews with personnel of various seniority levels in several departments, including operations, Technical Staff, Maintenance and Quality Assurance. Relative to maintenance, licensee personnel noted that the preventative maintenance program at Zion is designed to anticipate and prevent equipment failure and degradation, thereby, increase equipment life and improve its performance. This task is being accomplished through routine scheduled maintenance tests, inspections, equipment overhauls and surveillance The inspector reviewed the licensee's Total Job Management (TJM)

system used to plan and organize maintenance activities ar.d to ensure that the work is done effectively and efficiently and in compliance with all set requirement The central focal document used to implement the TJM program is the new Work Request, Form No. 86-2228-(s). In addition, the TJM program emphasizes good communications within departments as an essential element in performing an effective job and delineates maintenance job responsibilities and assignment The TJM program is compatible with the Quality Assurance Program at Zion. Furthermore, the TJM program appears to be an effective system for planning and accomplishing maintenance work activitie During this inspectico, a revie., of the TJM pending work request subsystem weekly status report indicated that as of April 9, 1987, a total of 3668 work requests were pending for Units 1 and 2; and as of May 15, 1987, a total of 4097 work request were pending for Units 1 and (2) Corrective maintenance activities at Zion are performed with Administrative Procedures and are indicated by the logging and routing of a work request (WR). Any Zion staff member can initiate a WR upon discovering the need for repair, maintenance or modification. Responsibilities of personnel involved in the routing and completion of a WR are defined in Zion Administrative Procedure ZAP-3-51-1 and in the TJM progra Management awareness of maintenance activities and problems at Zion is accomplished by numerous reports, meetings and committees. The data is used by managers and plant personnel to focus attention to those areas where it is most needed to enhance operations and eliminate problem No violations or deviations were identifie j l

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4. Review of Procedures, Work Requests and Drawings During this inspection, the inspector reviewed the following documents related to electrical and instrumentation corrective and preventive maintenance activities:

l WR No. 233515, dated April 22, 1987 - 2A D.G. Control Solenoid l WR No. Z33514, dated May 15, 1987 .2B D.G. Control Solenoid l Zion Administrative Procedure No. ZAP-3-51-1, Revision 23 - Origination and Routing of Work Request l Q.A. Surveillance QAS-22-87-059, Page 5 and QAS 22-87-050, Page 10 - Surveillance Area Hold Point l WR No. 254967, dated April 1, 1987 - E.Q. Inspection of Limitorque Per E022- l Inspection and Maintenance of Limitorque E.Q. MOV, Procedure No. E022-1, Revision 5 - on Valve 2MOV-SI9011 l 7.5KVA Instrument Inverter Circulating Current Test, PT-33, Revision 0 - Unit 1 test performed on May 20, 198 l Jumper / Lifted Lead / Block /8ypass Field Verification - Monthly PT-105 test, Revision 6, Verification done May 19, 198 l Maintenance Department Administrative Instructions, MDAI-3-51-8B, Preventive Maintenance Program, Revision 1 l Electrical Maintenance Initial Training List Matrix - EM' l Work Request Statistical Report for Month of March 198 l Zion Administrative Procedure ZAP 5-51-5, l Revision 27, - Procedure Content and Forma l Total Job Management (TJM) - Nuclear Station ,

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l Westinghouse - Instructions for Low Voltage Power Circuit Breakers Type DS and DS (ETI No. 000014) The inspector's review identified the following concerns:

(1) On April 7, 1987, an EM mechanic performed an inspection and preventative maintenance on safety related Valve 2MOV-SI9011 l The mechanic used maintenance Procedure No. E022-1 and WR 54967, dated April 1, 1987, to perform this activit Section II, Steps 12 and 13 of Procedure No. E022-1 which required motor rotation checks and operability checks had been signed off by the EM as completed and acceptabl In addition, j t

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Step 9 of the Station Traveler, found in the work package, which required adjustments to the valve limit switches and to the torque switches and a functional test was signed off as

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acceptable and dated April 12, 198 On April 19, 1987, during the review of.WR 54967, associated with. Valve No. 2MOV-SI9011A, the inspector noted that the work i package contained a 3 " x 5" index sheet which stated '

"2MOV-SI9011A won't manually engage to set limits properly."

The index sheet was dated May 7, 1987, and signed off by the E The inspector raised'the concern that although the E022-1 procedure contained a " comments" section in which this deficiency should'have been noted,.the EM elected to note the deficiency on the index sheet contrary to the requirements of the. procedure. In addition, although the Traveler appeared to indicate that.the problem had been corrected, the index sheet was still in the work package indicating that the problem had" .

not.been resolved. No audit trail could be established to j determine what was done to correct.the problem. The licensee informed the inspector that a review will be conducted to address the inspector's concern (2) The following documents listed the title of Valve 2M0V-SI9011A '

as " Cold Leg Injection Isolation Valve" rather than " Hot Leg Injection Isolation Valve."

(a) Work Request WR No. Z54967 (b) Station Maintenance Computer Program (c) MOV Nameplate Data (

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(3) WR No. Z54967 Station Traveler, signed and dated May 9, 1987, by the QC Supervisor and QA Engineer / Inspector was classified as

.non-safety related for work on safety-related Valve 2MOV-SI9011 j J

(4) WR No. 253285 contained a signature but no date under " Shift J authorization to start work."

(5) WR No. Z55112 contained a signature but no date under " Shift Supervisor Approval" and under the " Maintenance Department" block (6) WR No. 260162, dated May 19, 1987, requested work to be performed on a B0P circuit. This WR was erroneously classified as safety-related. Also, the " Requested By" block was not filled i '(7) ' Station Travelers attached to WR No. Z33513 and No. Z33514 which installed spike suppression devices in the D.G.'s circuitry contained Q.A. Hold Points. Apparently somebody other than Q.A. filled in the requirements noted in the Hold Point blocks. The licensee could not determine who filled in the requirements for Q.A. to witness the installation of the spike

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suppression devices. WR No. Z33513 Traveler indicated by the ,

EM's signature and date that the spike suppression devices had been installed on April 22, 1987, while the Q A. engineer signed and dated the (witness) Hold Point block on April 21, ,

1987. In addition, Page 5 of Hold Point Log No. QAS-22-87-059 '

noted that the Q.A. inspection required by the Hold Point was performed on April 23, 198 i WR'No. Z33514 Traveler requested.that Q.A. witness the installation of four Varistors; three were installed on May 13, 1987, and one was installed on May 15, 1987; the Q.A. Hold Point block was signed and dated May 13, 1987. The inspector expressed the concern that Q.A. Hold Points requirements had been filled in by an unknown individual; ', hat Q.A. elected to witness a portion of the requirements noted in the hold point without changing the requirements. Also, dates of the inspection and witnessing on the WR, Traveler and Hold Point Log Appear to contradict. Although items (2) and (7) above appear to have minor safety significance, they are indicative of the.need for licensee personnel to pay more attention t ;

detail Items (1) through (7) noted above are considered unresolved pending licensee action and NRC review [295/87012-02(DRS);

304/87015-02(DRS)].

5 .- Training

.The effectiveness of the licensee's training program was reviewed by the inspector during the witnessing of the licensee's ,,erformance of maintenance and surveillance activities. The EM personnel appeared to be knowledgeable of the task being performed. Observation of IM personnel conducting troubleshooting indicated that additional training in this area is warrante No violations or deviations were identifie . Unresolved Items

'An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraphs 3.a(2) and . Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of.the inspection on May 28, 1987. The inspector summarized the purpose and findings of the inspection. The licensee acknowledged this information. The inspector also discussed the likely informational content of the inspection report with regard to

. documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents / processes as proprietar . - _ _ . . . - -