ML20199G346
| ML20199G346 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199G198 | List: |
| References | |
| 50-295-97-23, 50-304-97-23, NUDOCS 9802040263 | |
| Download: ML20199G346 (36) | |
See also: IR 05000295/1997023
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U.S. NUCLEAR REGULATORY COMMISSION
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REGIONlli
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Docket Nos: 50-295,50-304
Report Nos: 50-295/97023(DRS); 50-304/97023(DRS)
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- Licensee: Commonwealth Edison Company
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Facility: Zion Nuclear Plant, Units 1 and 2
Location: 101 Shiloh Boulevard
Zion,IL 60099
Dates: September 8,1997, through December 16,1997
Inspectors: Z. Falevits, Reactor Engineer
1. Jackiw, Project Engineer
J. Guzman, Reactor Engineer
J. Yesinowski, Zion Resident Engineer, IDNS
Approved by: V. Patricia Lougheed, Acting Ch ef
Lead Engineers Branch -
- Division of Reactor Safety
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9002040263 900127
PDR ADOCK 050002 5
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EXECUTIVE SUMMARY
Zion Nuclear Plant, Units 1 and 2
NRC Inspection Report 50-295/97023(DRS); 50 304/97023(DRS).
Engineerina
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The inspectors determined that the licensee had made visible improvements to the
operability determination process at Zion in the last year. However, the inspectors
noted that additional improvements were needed and that it was too early to assess the
long term effectiveness of the operability determination program (Section E1.1).
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The inspectors noted that positive progress was made in the station's approach to 50.59
safety evaluations since the 1996 Zion engineering and technical support (E&TS)
inspection. However, shortcomings were noted in the 50.59 screening process (Section
E1.2).
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The inspectors identified that the licensee was developing an instrument
out-of tolerance trending program to respond to previous out-of tolerance (OOT)
problems. However, although the OOT problem was identified during the last E&TS
inspection, appropriate corrective actions were not taken. A violation was identified in
this area. (Section E2.2).
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The inspectors noted that programmatic improvements were made to address
significant testing and modification package closure deficiencies identified during the
previous E&TS inspection. However, the inspectors determined that the various
problems identification forms (PIFs) written in 1997 concerning testing and modification
, package closure deficiencies were not reviewed for common cause concerns, adverse
l trends and corrective actions (E2.3).
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An example of failure to adhere to scaffolding procedure requirements was noted
(Section E3.1).
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The int pectors identified that discrepancies in the 1992 emergency core cooling system
small t reak loss-of-coolant accident analysis were not reported pursuant to, and in
violation of,10 CFR 50.46(a)(3)(ii)(Section E4.2).
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The inspectors concluded that licensee's contractor craft and quality control inspector
training / certification process for Raychem splice applications was not always adequate
to ensure that individuals performing the Raychem splice applications and inspections
were well qualified for this specialized activity. This was considered a violation. In
addition, the extended time for retrieval of certification and training information by the
licensee was of concern. (Section E5.3).
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The inspectors determined that the licensee self assessment process had improved in
some areas. For example, a larger number of problems were being identified and
included in the corrective action program compared to the previous E&TS inspection in
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- 1996. Quality assurance audits appeared to be more comprehensive. The licensee's
Design Basis initiative and Engineering Assurance Group were viewed as positive
initiatives to irnprove engineering products at Zion (Section E7.1).
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Three apparent violations were identified involving cross-tying 125 Vdc buses from Unit
1 to Unit 2, with the battery and charger disconnected from the bus, without declaring
the associated buses inoperable (E.8.4).
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lli. Encin3erina flP 37550)
E1 Conduct of Engineering
E1.1 Review of the Ooerability Assessment Process
a, insoection Scooe
The inspectors examined licensee's actions taken to address deficiencies identified
during the engineering and technical support (E&TS) inspection conducted by the NRC
(IR96011)in 1996. The inspectors reviewed selected operability determinations and
interviewed engineering staff,
b. Observations and Findinas
During the E&TS inspection in 1996, the NRC identified some weak and inadequate
operability assessments. For example, the operability assessment for charging pump
degradation noted during emergency core cooling system full flow testing was
inadequate; the assessment failed to consider the pumps' ability to deliver the required
flows at design conditions. In addition, the NRC identified that the process to manage
the operability determinations and their corrective and compensatory actions was
inadequate.
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During this inspection, the inspectors determined that the licensee had made visible
improvements to the operability determination process since the E&TS inspection in
August 1996. For example: the licensee designated a program manager who has been
providing mentoring and guidance to the operability determination preparers; instituted
better interface with operations; and established a tracking program to track corrective
and compensatory actions noted in the operability determinations, in addition, the
- licensee reviewed approximately 200 previously completed operability determinations,
and identified and corrected noted technical and administrative deficiencies. A sample
of operability evaluations were reviewed by the inspectors and were found acceptable.
However, training and qualifications of a core group of operability determination experts
was not completed and problem identification forms (PIFs) issued documenting ,
operability determination deficiencies were not evaluated for adverse trends. In
addition, an operability determination was not performed as a conservative measure for
the zebra muscles issue until prompted by the NRC resident inspectors. The inspectors
could not fully assess the effectiveness of the operability determination process since
very few new operability determinations were issued in the three months prior to this
inspection.
c. Conclusions
The inspectors determined that the licensee had made visible changes to improve the
operability determination process at Zbn. However, the inspectors noted that certain
areas required improvements. It was too early to fully assess the effectiveness of the
operability determination program.
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E1.2 10 CFR 50.59 Safety Evaluation Program
a. insoection Scoce
The inspectors assessed the progress achieved by the licensee since the E&TS
inspection in 1996. The inspectors reviewed a sample of 10 CFR 50.59 safety
evaluations (SEs) and screenings,50.59 3E procedures,50.59 SE related PlFs and
other corrective action items, and licensee self assessments. The inspectors also
interviewed members of the licensee staff,
b. Observations and Findings
During the E&TS inspection conducted by the NRC in 1996, significant concerns were
identified with the 50.59 SE process. The NRC identified numerous deficiencies in the
sample of 10 CFR 50.59 SEs reviewed during the inspection. The concerns identified
indicated a continuing lack of quality, completeness and thoroughness relative to 50.59
SEs. Of note was the licensee's superficial approach towards certain safety
evaluations. In view of the repetitive nature of these deficiencies and of the licensee's
failure to implement effective corrective action for previous violations and self
assessment findings related to 50.59 SEs, the E&TS findings demonstrated significant
deficiencies in engineering activities and management oversight of the 50.59 SS
process.
During this inspection, the inspectors noted that the licensee had initiated and
implemented various efforts to improve the 10 CFR50.59 program at Zion. Actions
taken included: 1) retraining of all personnel that prepared Safety Evaluation
Screenings and creation of an " Advanced 50.59 Training Course" which was
administered to selected staff,2) implementation of a new comorate procedure for use
by all SE preparers at all Comed nuclear sites,3) development of a Safety Evaluation
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Review Committee (SERC) which was established to complete in-line review of all SEs,
and 4) development of the Zion Engineering Assurance Group (ZEAG), which was
reviewing all safety evaluations prepared by engineering. The inspectors noted that the
SERC was providing uniformity to the SEs and provided feedback to maintain a
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consistent level of quality in the SE writeup..
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The inspectors noted that, overall, the depth and quality of the 50.59 SEs was improved
from the SEs reviewed during the E&TS inspection in 1996. However, the inspectors
identified the following concems:
e inadequate 50.59 SE screenings were noted as a weakness by the inspectors.
For example, some screenings of procedure changes (mainly performed by the
operations staff) should have required full safety evaluations. These inadequate
screenings were also being identified by O&SA, and by other Zion organizations,
such as the ZEAG. The licensee was in the ,orocess of addressing these
concerns. Similar concerns were also identified by the licensee and corrective
actions were being taken, including preparation of appropriate safety
evaluations. Corrective actions planned to address these issues included
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instituting a method to monitor the quality of SE screenings. Further, the ZEAG
planned to review 50.59 SE screenings including those not generated by
engineering. Additionally, Design Engineering informed the inspectors that they
plan to perform a self assessment in the fall of 1997 to gauge the effectiveness
of these actions,
e As discussed in Section E8.4 the inspectors noted that the 125 Vdc crosstie
issue could have been better assessed and dispositioned had the procedure
changes received a full 50.59 evaluation instead of only a screening.
- The NRC also identified deficiencies in retrieving 50.59 safety evaluations for
procedures (URI 97013 04). Specifically, following licensee identification of an
overloaded motor control center (MCC) the licensee could not retrieve the SE for
the procedure which approved the use of adding temporary loads to phase B of
the 480-208/120 V distribution cabinet in MCC 2381B.
c. Conclusions
The inspectors noted that since the Zion E&TS inspection in August 1996, progress was
made in the station's approach to 50.59 SEs. However, weaknesses were noted in the
area of 50.59 SE screenings.
E1,3 Engineering Interface
a. Insoection Scoce
The inspectors evaluated the Zion engineering organization to determine the
effectiveness of interdepartmental communications and interface with other site
organizations.
b. Observations and Findings
The inspectors noted that, in response to issues raised in the E&TS inspection related to
weak engineering interfaces, the licensee had initiated steps to improve engineering
communication within the site and corporation. The inspectors interviewed supervisors
and the engineering staff and noted that, while some improvements were being made in
the interface between system engineering and operations, challenges still remained.
For example, an interface agreement between operations and systems / components
engineering was generated and approved in June of 1997. This interface document
discussed the roles, functional interfaces such as technical support and troubleshooting
or material condition, performance monitoring and clear delineation of responsibility for
completing actions and was considered a positive improvement. While the system
engineers appeared aware of their roles and responsibilities, and of the interface
agreement, the inspectors noted that a heavy workload affected full implementation of
the interface agreement. Continuing concerns with these interface agreements, such as
the poor communications between engineering and operations which was exhibited
during the 125 Vdc cross tie configuration issue, are discussed in Section E.8.3. Other
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Interface issues included a concern with the Zion engineering staff not being awaro of a
corporate policy regarding repeat instrument out of tolerance conditions and timely
implementation of nuclear department information transmittal (NDIT) requirements.
c. Conclusions
Overall, the conduct of engineering communications and interface improved somewhat
compared to the E&TS inspection conducted in 1996. The inspectors noted that
additional efforts were needed to fully implement the interface agreement.
E2 Engineering Support of Facility and Equipment
During the E&TS inspection in 1996, the NRC noted that engineering activities relative
to lube oil analysis, trending of equipment probleme and resolution of recurring
deficiencies were considered weak. Out of tolerance instrumentation and unsatisfactoy
o;l samples were not trended or investigated promptly. During this inspection, the
inspectors reviewed the lube analysis oil program and the out of tolerance
instrumentation program.
E2.1 Oil Samoling and Analvses
a. Insoection Scooe
The inspectors evaluated the oil sampling and analysis program at Zion.
b. Observations and Findings
The E&TS inspection conducted in 1996 identified concerns with the oil sampling and
ana: sis program. These concerns !ncluded: 1) the failure to write PlFs and take
- corrective action for unacceptable oil sample results,2) the failure to act on
recommendations from the analyses performing lab, and 3) the failure to track sample
performance or receipt of analyses. The report concluded that the purpose of the
system was defeated when no action was taken for unsatisfactory sample results.
Station mechanical equipment oil samples were required to be taken per procedure ZAP
300-12A, Station Oil Sampling Program, Revision 1.
During this inspection, the inspectors identified continuing problems with the oil sampling
and analysis program. The inspectors ider,tified one example of an elevated percent
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free water volume in an oil sample where a PIF was not written and an investigation was
not conducted. Specifically, on October 16,1996, the 2A containment spray (CS) pump
inboard bearing oil sample was taken. On November 24,1996, the System Material
Analyses Department (SMAD) notified the lube oil coordinator that the free water
volume in the oil sample was 15.00 percent which exceeded the SMAD 0.05 percent
free water volume upper limit. Limits for free water percent volume were specified in the
"SMAD Lube Oil Physical Testing Analyh" reports. The inspectors noted that a PlF
was not written and a root cause investigation was not performed for the oil sample.
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The inspectors also identified additional examples of elevated wear materials, sediment
percentage, and freewater volume percentage in various safety related pump oil
samples taken during late 1996 and early 1997 as follows:
(1) PlF 97-0076,"2B CS Pump / Motor Inboard / Outboard Bearings Oil Analysis,"
dated January 3,1997, documented high wear metals of iron and tin in the motor
outboard and pump inboard oil samples taken on November 16,1996. The PlF
stated that the increased metals were indicative of bearing wear or degradation.
The SMAD analysis report stated that the iron and tin levels were very high and
recommended checking any historical data from Herguth Labs for comparison.
The PlF further stated that pump vibration data was checked and no adverse
trend was noted. The justification for this resolution was that no failure occurred.
The PlF stated that an action request would be submitted and the bearings might
be changed at the next available opportunity. As of October 10,1997, the
bearings were not replaced. The elevated wear metals in the oil samples, a
condition adverse to quality, was resolved by changing oil as was routinely done
after the sample was taken and the licensee continued to monitor vibration data
and bearing temperatures during pump runs. There was no available data from
previous samples, consequently no cornparison was made.
(2) PIF 97 0075,"2C CS Pump inboard Bearing Analysis Anomaly," dated
January 6,1997, identified elevated wear metals (iron) and 0.25 percent free
water volume in the October 8,1996, oil sample results. SMAD recommended
that the oil be centrifuged and resampled based on the high level percent of
freewater and metals. The PlF was closed based on acceptable vibration data
and initiation of ARs, as deemed necessary.
(3) PlF 97-040,"0B SW Booster Pump inboard Bearing Oil Analysis Anomaly,"
dated January 3,1997, documented increased wear metal levels of copper, iron,
lead, and tin on the OB service water booster pump inboard bearing samples
taken on November 4,1996. SMAD recommendated documented checking
vibration / temperature data for possible causes. However, no temperature data
was taken. The immediate actions documented in the PIF were that vibration
data records were checked with no indication of problems noted and that the
system engineer should monitor pump performance and possibly write an AR for
pump repairs.
(4) PlF 97-0442," Diesel Driven Fire Pump Crankcase Oil Has High Wear Particle
Count," dated January 28,1997, documented high wear particle concentration in
the fire pump crankcase oil. The oil sample was taken on December 21,1996.
The PlF stated that the oil samples showed moderate quantities of wear debris
and various contaminants were found as follows: black oxides, indicative of high
operating temperatures and insufficient lubrication, and red oxides, indicative of
previous water contamination (rust) and a poor lubricant condition.
The immediate action taken was to notify the system engineer and to change the
oil.
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Items (1) - (4) noted above are considered an URI (50-295/97023-02(DRS);
50-304/97023-02(DRS)) pending NRC review.
Additionally, the inspectors noted that a formal process for tracking the receipt of oil
samples for equipment specified in procedure ZAP 300-12A, Station Oil Sampling
Program, Revision 1, did not exist. The inspectors found that the oil samples results for
safety related pumps OE component cooling water pump,2A and 2B charging pumps,
and 2A safety injection pump were not tracked and analyed for conditions adverse to
quality as required by the program.
Specifically, the inspectors determined that oil sample analyCs results were not
available for the following safety related pumps: 1) OE Component Cooling (CC) Water
Pump for 1995,1996, and 1997. The last OE CC pump oil samples were taken on July
29,1994; 2) the 2A and 28 charging pump gearset oil sample analyses were missing
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from the oil samples taken on June 13,1997. Also, the 2A and 2B charging pump oil
d reservoir sample analyses were missing from the oil samples taken on August 4,1997,
and August 8,1997, respectively; and 3) The 2A safety injection pump oil sample was
required to be taken, tracked, and analyzed every 18 months. The inspectors
determined that the 2A safety injection purvp motor inboard bearing oil sample taken on
June 5,1997, was not analyzed. The previous motor inboard sample was taken on
E December 14,1995, but also was not analyzed. For the motor outboard bearing, an oil
sample was taken on September 30,1994, and another on June 5,1997; however,
neither had been analyzed at the time of the inspetion. The last oil reservoir sample
taken was on December 14,1995.
Subsequently, on September 26,1997, after requests for the sample results by the
inspectors, the Zion Station lube oil analyst investigated the whereabouts of these
samples and wrote PIF Z1997-01955, which stated that the samples were taken but
i SMAD did not receive them. The inspectors determined that the licensee's failure to
track oil sampie performance was similar to the problem noted in NRC report 96011.
The inspectors concluded that the licensee continued to fail to track and perform
trending and analysis of oil samples at the inspection's conclusion in September 1997.
The licensee's failure to trend and analyze oil samples for an extended period of time for
conditions adverse to quality for the OE CC water pump in 1995,1996 and 1997; the 2A
and 2B charging pumps in June and August 1997; and the 2A safety injection pump in
June of 1997, as well as the failure tc write a PIF for the 2A CS pump in November 1996
is considered an example of violation of 10CFR Part 50, Appendix B, Criterion XVI
J. (50-295/97023-3a(DRS); 50-304/97023-3a(DRS)).
c. Conclusion
The inspectors concluded that the tube oil sampling, trending and analysis process
continued to be a significant weakness. Since identified during the NRC E&TS
inspection, the analysis of oil samples and trending of this data was still not being
performed as required. This was considered an example of a corrective action violation.
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E2.2 Out-of-Tolerance Instrumentation /Comoonent Controls
a. Insoection Scoce
The inspectors reviewed the licensee's activities to develop an instrument
out-of-tolerance (OOT) trending program. This review evaluated the licensee's present
program which included a database of all OOTs contained in PIF reports since June
1996.
b. Observations and Findinas
The NRC E&TS inspection in 1996 documented that there were numerous instances
where instruments were OOT over the past two years. The PIFs associated with these
instances were a category where no root cause would be performed. While the number
of consecutive PIFs should have triggered a root cause PlF to identify the cause of the
problem and rectify it, there was no procedural requirement which would trigger a root
cause evaluation.
While reviewing Zion Unit 2 transmitter OOT reports, inspectors noted that RCS flow :
transmitter 2FT-434 was determined to be OOT on October 4,1996, February 11,1997,
and July 15,1997. Further review of this matter indicated that procedure
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NES-EIC-20.03 " Evaluation Of Instrument Perfornance" dated May 5,1997, stated that
if an instrument was consistently found outside the administrative limit, the probability
was high that the instrument was starting to fall. The procedure also stated that in order
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to make a valid determination of an instruments' degradation, a trend of its performance
over time shall be documented. Recommendations in this procedure for corrective
actions stated that after three consecutive failures, the instrument shall be considered
misused or failed and shall be replaced. The inspectors determined that these
corrective actions were not taken for transmitter 2FT-434. In response to the inspectors'
concerns, licensee staff stated that implementation of the corporate NES procedure was
under redaw and had not yet become policy at Zion. Subsequent to raising the
concern, the licensee initiated action to address implementation of corporate procedures
into site procedures. Additionally, the inspectors determined that when the 2FT-434
transraitter was identified to be OOT on February 11,1997, a PlF was not issued.
Regarding the instrument OOT, the inspectors determined that the licensee failed to
implement an effective program to address a long standing issue regarding resolution of
COT conditions. Several instances of OOTs were identified in NRC inspection report
96011. The repetitive failures of transmitter 2FT-434 was evidence that the licensee
had not effectively corrected this condition adverse to quality. The inspectors informed
the licensee that failure to assure that conditions adverse to quality are promptly
identified and corrected is considered an example of violation of 10 CFR 50, Appendix
B, Criterion XVi (50-295/97023-3b(DRS); 50-304/97023-3b(DRS).
c. _ Conclusion
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The inspectors concluded that the licensee failed to implement an effective corrective
action program to address long standing OOT instrument issues, although similar issues
were identified in a previous NRC inspection in 1996. In addition, the failure to generate
a PlF for an OOT instrument was also identified by the inspectors. These items were
considered examples of corrective action and procedure violations.
E2.3 Modifications and Modification Testino
a. Insoection Scooe
The team reviewed selected design modification documents, calculations,50.59 SEs,
and operability assessments and procedures. The review included eight mechanical,
electrical and instrumentation plant changes and modification packages in various
stages of completion. The modification packages were reviewed for technical adequacy
and completeness and were compared to the quality of modifications noted during the
last E&TS inspection in 1996.
b. Observations and Findings
During the E&TS inspection in 1996, the NRC identified an apparent violation which
involved licensee failure to ensure that various field installed design change
modifications had been properly evaluated, tested and signed off as completed and
operable prior to placing them in service. The licensee's process for controlling
modifications to ensure adequate post-modification testing package closure had broken
down. Numerous modifications had been physically installed and placed in service,
even though the modification packages were not signed off as completed and not
authorized for use by operations.
The inspectors noted that significant programmatic improvements have been made
since September 1996 to address this problem. The licensee designated a modification
coordinator, revised modification procadures and trained plant staff to ensure that
modifications are properly tested and closed prior to declaring them operable. However,
the inspectors noted that although various PlFs have been written in 1997 concerning
identified testing and modification package closure deficiencies, the PlFs had not been
reviewed for common cause concerns, adverse trends and corrective action.
c. Conclusions
The modifications reviewed by the team were generally adequate. The inspectors noted
that significant programmatic improvements have been made since the E&TS inspection
in 1996 to address this problem. However, the inspectors determined that the various
PlFs written in 1997 concerning testing and mod package closure deficiencies have not
been reviewed for common cause concerns, adverse trends and corrective action.
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E2.4 HEPA Filters in Containment (Confirmatorv Action Letter (CAL) Item 7)
a. Insoection Scoce
The inspectors reviewed documents related to the identification of air filters containing
aluminum that were inadvertently installed in containment. This resulted in exceedance
of the design basis aluminum square foot limit estabih ad in the updated final safety
analysis report (UFSAR). The inspectors also reviewed licensee event report (LER)
50-295/304 97-008, and work requests and procedures related to resolution of the
commitments made in the LER. This issue was previously discussed in NRC Inspection
Report 295/304/97018.
b. Observations and Findings
The inspectors reviewed the licensee's action in response to comrris nents made in the
LER 50-295/304-97008 ( NRC CAL ltem # 7; Restart item C.7.1.g). The inspectors
determined that the HEPA filters containing aluminum had been replaced with
non-aluminum containing HEPA filters for Unit 2. Unit i replacements were not
completed pending decisions on the plant regarding future operational status. An
inventory of aluminum in the reactor containment buildings was completed to verify that
non-modification related parts were properly specified. The licensee reviewed all work
in Unit 1 and Unit 2 containments and did not identify other non-modification aluminum
parts.
l The inspectors noted that the licensee had initiated changes to the parts evaluations
process to ensure that the vehicle for non-like-for-like hardware changes would be
i processed as design changes, when appropriate, to ensure that replacements were in
f accordance with design documents. Work analysts procedures were under revision and
l- a " Suitability of Application Guideline" and Parts Expectation Sheet had been developed.
[. The applicable site material selection procedures were being revised and the licensee
was in the process of developing company wide guidelines. Further, the inspectors
confirmed that work analysts had been trained on the interim Parts Expectations
pending completion of the site and corporate procedure revision,
c. Conclusion.
The inspectors concluded that corrective actions to replace aluminum filters, which were
inadvertently installed in the containment resulting in a violation of Criterion XV as
described in NRC report 97018, had been completed. There were sufficient barriers to
ensure that non-like-for-like changes would be reviewed by engineering to ensure the
design basis. Licensee actions satisfactorily address CAL ltem #7, Closecut of this
issue is pending NRC review of the licensee's response to violation
50-295/304/97018-05a.
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E3 Engineering Procedures and Documentation
E3.1 Scaffolding Procedure Adherem
a, lasoection Scoog
The inspectors walked down selected systems and reviewed licensee actions related to
scaffolding erection and inspection deficiencies noted in the 1996 E&TS inspection. The
inspectors also reviewed scaffolding procedures, and interviewed maintenance staff and
supervisors involved with scaffolding erection.
b. Observations and Findings
The inspectors noted that the licensee had instituted a more structured approach to
reviews of installed scaffolding by engineering and operations since the 1996 inspection.
However, during an NRC walkdown of systems the inspectors noted that the scaffold
inspection tag for scaffolding erected adjacent to the 2D diesel oil storage tank 2D0002,
had not been signed off for seismic acceptability by the Site Engineer even though the
scaffolding had been installed approximately 10 days earlier. This was contrary to
procedure ZAP 920-01, Revision 01, Step G 3.b which required that the site engineer
initial and date the scaffold inspection tag within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of erection indicating approval
for seismic construction adequacy. The inspectors were concerned that similar
concerns were noted in the 1996 E&TS inspection, in response, the licensee generated
a PIF to complete the seismic review and reviewed the adequacy of scaffolding
installation with the inspectors. The scaffold was determined to be adequately installed
to seismic requirements and there was minimal safety significance. The failure to follow
the requirements delineated in procedure ZAP 920-01 is considered an example of a
violation of 10 CFR 50, Appendix B, Criterion V (50-295/97023-01(DRS);
50-304/97023-01(DRS)).
c. Conclusions
The inspectors concluded that the licensee failed to adhere to the scaffolding procedure
requirements. Similar concems were noted in earlier engineering inspections related to
engineering reviews of scaffolding installations. Tnis is considered an example of
procedure violation.
E3.2 D.C. Load Shed Profile ( CAL ltem #4)
a. Insoection Scoce
The inspectors reviewed licensee's corrective actions to implement the results of battery
calculations which included changes to the " Loss of All AC Power" procedure used to
shed loads during a postulated loss of offsite power concurrent with a loss of coolant
accident (LOCA) and a loss of the battery charger. This is restart item C.7.1.d.
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b. Observations and Findinas
The licensee's failure to update procedure ZPEOW-ECA-0.0, revision 23 " Loss of All
AC Power," to include various loads that must be shed off the bus as determined by a
design calculation was cited as a violation in IR 97018.
The inspectors reviewed the licensee's actions to address this violation and confirmed
that the licensee had revised procedure ZPEOW-ECA-0.0 to add the loads that were
required to be shed. Examples of these loads were included in section E 2.3 of
Inspection Report 97-018. The inspectors reviewed a revised copy of procedure
. ZPEOW ECA-0.0 revision 24, dated May 9,1997. The procedure was in the final
stages of being issued. The required training on this procedure was completed and
response time testing / verification on the simulator was in the process of being
completed at the end of this inspection.
c. Conclusion
The inspectors concluded that appropriate actions were being taken to revise procedure
ZPEOW-ECA-0.0 " Loss of All AC Power" to include the loads that need to be shed and
therefore satisfactorily addressed CAL ltem #4,
E4 Engineering Staff Knowledge and Performance
1
E4.1 Containment Soray System Issues
- a Incuection Scogg
The inspectors reviewed the containment spray system design bases and operation as
documented in the UFSAR, PlFs, procedures, supporting operability assessments and
j calculations, and the system action plans. Also, the system and design engineers were
interviewed,
'
b. Observations and Findinas -
The CS system engineer identified that during a postulated main steamline break
accident in containment, there would be low pH (4.5) of spray water for an extended
period of time. This condition was not analyzed for its environmental qualification (EO)
effect on containment equipment. A low pH condition would result because after
containment spray initiation, Zion Station emergency operating procedures did not direct
the operators to initiate recirculation flow from the containment recirculation sump within
two and one half hours, as assumed in a Westinghouse EQ analyses. As a result, the
containment equipment that would be exposed to a pH of 4.5 from the slightly acidic
refueling water storage tank injection fluid would not be " neutralized" by the recirculation
flow. PlF 97-1723, dated April 18,1997, was issued to address the pH concern for
acidic conditions in containment during a postulated accident also be a generic concern.
14
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c. Cooclusions
The inspectors considered the identification of the low pH issue by the system engineer
a commendable finding. The licensee issued PIF 97-1723 to addres the PH concern for
acids concems in the containment.
E4.2 Review of RETRAN Analvsis Umd in Zion Emergencv Core Cooling System (ECCS)
Analysis.
a. Insnection Scoce
The inspectors reviewed the 1992 RETRAN analysis used in Zion's ECCS small break
loss of coolant accident (SBLOCA) analysis and Procedure NNEP-16-63, " Reporting
Requirements for 10CFR50.46," revision 0, requirements,
b. Observations and Findings
During the E&TS inspection in August 1996 ' a NRC raised concerns relative to ECCS
pump degradation. Subsequently, the licensee provided the inspectors documentation
which indicated that the flowrates assumed in the ECCS RETRAN analyses were below
the degraded flowrates. The NRC reviewed the details of the RETRAN analysis and
determined that the wrong high pressure injection flow versus pressure curve was used
in performing the SBLOCA analysis. The NRC determined that the licensee had
assessed the impact of the error and that there was little or no impact on the SBLOCA
calculation results; however, the licensee did not report the discrepancy or its
assessment as reodired by 10CFR 50.46(a)(3)(ii). This section requires, in part, that for
each change or orror discovered in an acceptable evaluation model the licensee shall
report the nature of the change or error and its estimated effect on the limiting ECCS
analysis to the Commission. The licensee's failure to report the ECCS analysis
discrepancy until prompted by the NRC was considered a violation of 10 CFR
50.46(a)(3)(ii), (50-295/97023-04(DRS); 50-304/97023-04(DRS)).
In response, the licensee intended to amend the Spring 199710 CFR 50.46 submittal.
The inspectors confirmed that the action required to effect this submittal had been
added to the Z2R14 startup items list.
c. Conclusions
The NRC identified that discrepancies in the Zion ECCS SBLCCA analysis (while
assessed by the licensee and detern ined to have little impact on the analysis results)
were not reported pursuant to and in s tolation of 10 CFR 50.46(a)(3)(ii).
15
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ES Engineering Training and Qualification
ES.1 Trainino and Certification of Craft and Quality Control (OC)insoectors on Safety Related
Raychem Solic9 Aoplicdont
a. Insoection Scoog
As part of Zion engineering restart items review, the inspectors examined licensee
activities to address concems noted regarding non-qualified cables and transmitters
located in the main steam tunnel. During observations of field installations of Raychem
splices, the inspectors raised concerns relative to the adequacy of training and
certification process of contractor craft and QC Inspectors that performed the Raychem
splice applications for design change E22-2 97-251-B.
b. Observations and Findinos
Observation of Contractor Craft Personnel Performino Modification Work (S;te
Construction)
On July 24,1997, the inspectors observed Raychem Splice installation being performed
by licensee contractors as part of design change E22-2-97-251 B which required that
instrument cables in the Unit 2 steam tunnel be replaced and spliced under WR 97006711802. The inspectors observed that no procedures or drawings were used at
the place of activity; instead the craft used a single vendor sheet from the Raychem
manual. The inspector questioned the level of training provided to contractor craft
personnel assigned to perform and inspect the Raychem splice installation. PIF
21997-00877 was issued on July 25,1997, to investigate this concern.
The inspectors determined that the contractor craft personnel performing the Raychem
splices did not receive adequate training or certification to conduct this activity. The
contractor craft informed the inspectors that they had some previous experience
performing this activity and that they read the applicable procedures prior to performing
the Raychem splices. No documentation indicating craft past experience was available
for review. The inspectors determined that the contractor craft was required to take a
written examination, pecform a practical on-the-job training (OJT) and do a capability
demonstration to demonstrate that they were fully qualified to perform safety related
Raychem splicer applications. The inspectors noted that contractor training
requirements established in Comed Nuclear Station Work Procedure NSWP C-02,
paragraph 6.5 were inadequate in that they did not require that testing be given to
contractor craft that completed type D Training which included Raychem splice
applications. However, t!is inspectors noted that in contrast to the narrow scope of
training given to the contractor craft, the Zion electrical and instrument mechanics
(EM-lM) craft were required to successfully pass an eight hour classroom training which
included a written examination, a practical OJT and a capability demonstration to
demonstrate that they were fully qualified to perform Raychem splice applications.
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On July 24,1997, the coracactor craft supervisor stated that as part of OJT training he
observed the first Raychem splice performed by the craft a week earlier but when
questioned as to his evaluation of craft OJT performance and the basis for concluding
that the craftsman was qualified, he stated that he did not document his observations of
the craft performing the Raychem splice. The inspectors also noted that licensee
documentation that showed dates and duration of Raychem splice training administered
to the craft by the contractor was inconsistent and training dates were not accurate in
some cases. Subsequently, the licensee indicated that they would enhance the training
requirements and administer the appropriate training to the contractor electricians and
site construction field engineers in accordance with the EM's approved lesson plan
which required classroom training, a practical demonstration and a written examination.
The licensee also indicated that all training will be documented and requalification will be
required every two years. (Ref PIF 21997-01898 dated September 23,1997)
Electrical Maintenance Craft
In response to a violation in Report 50 295\86016 that identified unqualified Raychem
splice configurations in 10CFR50.49 designated applications, the licensee committed to
the NRC, among other things, that corrective actions to the violation willinclude
bi-annual qualification training for all personnel performing installation of EQ Raychem
splice irtstallations. Following recent NRC questioning relative to contractor Raychem
training requirement, the licensee examined the continued training provided to the Zion
ems and IMs. Subsequently, PlF 21997-01705 was issued on September 10,1997, to
document that the EM department was delinquent in providing Raychem Spllce
requalification training. The training should have been conducted in January 1996. The
licensee committed to the NRC (in 1993) that retraining on Raychem Splice applications
will be provided to EM craft at an interval no greater than every two years.
Subsequently, as soon as the training deficiency was identified, the licensee promptly
performed the requalification training required and evaluated the need to reinspect any
Raychem Splice performed by EM craft since January 1996. One splice was inspected
and found acceptable. No further concerns were noted with EM training.
Review of Licensee's Process to Certifv QC Insoectors
During interview of a site construction craft supervisor, the supervisor stated that if
contractor craft did not perform adequate Raychem splice applications it would have
been identified by QC since QC inspects all Raychem splice applications performed at
Zion. The inspectors examined the licensee's process used to certify the QC inspector
that inspected the Raychem splice applications performed on July 22,1997, for a
modification per work document 970067128. Procedure NSQCP-2, Rev 3, " Comed and
Vendor Nuclear Quality Control Inspector Qualification and Certification Procedure"
specified OC training and certification requirements.
The licensee used Procedure NSOCP-2, Paragraph 8.6.4 to cross certify the QC
inspector evaluated by the NRC. In a letter dated September 16,1996, the licensee
documented the justification for cross-certifying the QC inspector into several electrical
and mechanical certification areas. Specific requirements for the cross certification
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e
included: (1) General Me:hanical and Electrical QC Modules classroom training
completed with a score of 80% and above; (2) Mechanical, electrical and structural
NSWP classroom training completed with a score of 80% or above; (3) On-the-job (OJT)
training for Electrical configuration, electrical cable was successfully completed to the
satisfaction of a trained OJT evaluator; and (4) the required capability demonstration for
the electrical and mechanical areas were comple'ed to the satisfaction of a level 11 QC
inspector knowledgeable in the area of certification with a score of 80% or better.
The licenseo concluded that the QC inspector satisfied all the requirements of NSOCP-2
for certification using the cross certification process. However, the inspectors noted the
following concerns relative to QC training and certification requirements for Raychem
splice applications:
.
A written examination on the procedure and lecture material # NSWP-LE-1Q,
Exam 1, Rev 0, was given to the O.C. Inspector in August 1996. The exam
contained 25 questions which were randomly selected by the computer. The
inspectors determined that none of the 25 questions contained Raychem splice
related questions.
.
OJT checklists E-02-Exhibits B, Cable Splice Record" and E-02, Exhibit E,
" Instrument Control Cable Termination Checklist," were used on August 7,1996,
as part of the QC inspector certification process. The inspector being certified
had to identify acceptable and rejectable attributes in a Raychem splice which
contained several known defects placed earlier by the evaluator. The NRC
inspectors noted that there was no requirement that the QC inspector and
evaluator fill out and sign the checklists to document the specific test results and
the basis for satisfactory performance and demonstration of this podion of the
certification process.
.
The inspectors determined that OJT training requirements administered to the
QC inspector on August 7,1996, contained very limited Raychem splice
questions and the OJT test results were not documented as was done during the
capability demonstration testing, in addition, the certification form signed by the
evaluator and trainee on August 7,1996, failed to document the trainee's name.
.
The licensee yearly recertification requirement for QC inspectors specified that
only one electrical activity group capability demonstration be accomplished each
year (e.g. cable pulling or cable terminations, etc.) in order to qualify the
inspector in all electrical areas. Using this method it was possible that the QC
inspector would not get tested and recertified in some activity groups for many
years.
.
At the conclusion of the formal classroom lecture and OJT session, the evaluator
must indicate on the Training Administration System Course / Study Data Entry
Form that either the trainee successfully completed the session with a "P" for
pass or "F" for failed. This form for session N-GLE10 conducted in the summer
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of 1996 and used to certify the QC inspector could not be located by the I;censee
from August to November 1997. (Reference Braidwood PlF A1997-04602)
.
The training and certification process for the QC inspectors appeared to be very
cumbersome and difficult to follow.
The inspectors informed the licensee that failure to ensure that the established training
program provides for adequate indoctrination and tralr.ing of personnel performing
activities affecting quality as necessary to assure that suitable proficiency achieved and
maintained is considered a violation of 10 CFR 50, Appendix B, Criterion ll.
(50-295/97023-05(DRS); 50 304/97023-05(DRS))
c. Conclusion
The inspectors concluded that licensee's contractor craft and QC ',1spector training and
,
'
certification process for Raychem splice applications was very cumbersome and not
always adequate to ensure that individuals performing Raychem splice applications and
inspections were well qualified for this activity. Training requirements differed from the
EM and IM groups to the contractor craft for the same Raychem application, in addition,
the extended time for retrieval of certification and trsining Information for the QC
inspector by the licensee was of concern. This last issue was considered a violation.
E7 Quality Assurance in Engineering Activities
E7.1 Engineering - Site Quality Verification (SOV)
- a. Insoection Scoce
During the E&TS inspection in 1996, the NRC noted that Zion's self assessment
program had not identified many of the significant problems identified by the team, such
as the 50.59 screening problems noted in this report, modification testing and closeout
problems, and corrective action issues. During this inspection, the inspectors observed
performance and reviewed activities in the engineering and the nuclear performance
assessment departments regarding their effectiveness in identifying, resolving and
preventing problems. The records reviewed were primarily related to the corrective
action and self-assessment processes.
b. Observations and Findings
(1) Self Assessment and Audi+s Review
The inspectors selected a sample of self-assessment and audit reports for
detailed analysis to assess the licensee's ability to identify and correct problems.
Additionally, the inspectors evaluated the licensee's process for initial
identification and characterization of the specific problems, elevation of the
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problems to proper levels of management for resolution, disposition of any
operability /reportability issues and implementation of corrective actions, including
evaluation of repetitive conditions.
The inspectors reviewed the following reports focusing on the licensee's
identification and resolution of engineering issues involving Unit 2 restart.
.
Audit Report 22-97-04 " Design Control Audit"- The audit found that the
Zion station Design Control was overall technically acceptable. However,
the audit also pointed out that administrative deficiencies hampered the
process and needed improvement. Operability assessments were found
to be technically accurate but problems included corrective actions not
being statused within the Nuclear Tracking System (NTS) and not
'
completed as scheduled. The inspectors noted that deficiencies
identified in this audit, indicated improvement in the technical accuracy of
engineering work compared to a previous audit conducted last year.
.
" Design Control Self-Assessment of Zion,"- The inspectors noted that
licensee met their goal to confirm the technical adequacy of a high
probability risk assessment impact, safety system and confirm the
consistency among the design basis, technical specifications,
procedures, design documentation, and the physical plant; assess the '
effectiveness of the design control process and the adequacy of the
procedures and management controls that implement the process; and
demonstrate Comed's ability to perform effective self assessments,
l The inspectors also noted that the audit identified strengths and areas
- requiring improvements. The inspectors considered the level of detail
described by the issues indicative of an in-depth review by the Quality
and Safety Assessment Organizatkc
.
" Corrective Action Reports" (CAR)- The inspectors reviewed 23 CARS
since September 1996 and noted that they were being initiated and
resolved in accordance with the appropria% station procedures.
The inspectors also attended two Corrective Action Review Boards (CARBs) and
noted that, when compared to similar meetings in 1996, the CARBs appeared
productive and CARB members appropriately challenged presenters and
assumptions. The CARB meetings were well attended by various departments
and it was obvious the members were prepared and had read the information
prior to the meeting. The root cause investigator was challenged by the
members and overall the interaction appeared focused on ensuring the root
cause was understood and would be corrected.
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(2) Positive Licensee Engineering Initiatives
The inspectors reviewed Zion's dcsign br, sis initiative (DBI) program. The
program was designed to ensure that the design basis information contained in
the UFSAR, technical specifications (TSs) and NRC safety evaluation reports as
supported by station operating and test procedures, physical plant and
calculations, were correct, consistent, complete and readily identifiable and
retrievable by Comed personnel. At Zion, the DBI was in process of completing
line by-line reviews of the UFSAR. The inspectors interviewed the program
manager and reviewed findings to-date. Overall, the effort was viewed as very
positive as %e program appeared to be effective in identifying UFSAR
discrepancies in calculations, operations and surveillance procedures, and in
as-built conditions. The inspectors noted that the DBI staff consisted of
experienced engineers and the process was methodically reviewing applicable
design documents and the DBI staff had identifieo good technical as well as
compliance based findings. Further, these findings were promptly processed
through the existing corrective action system using PlFs.
The inspectors also reviewed the ZEAG plan and activities and found that ZEAG
was providing quality technical reviews and assessments of engineering
products. These reviews were used to mentor and provide a feedback loop to
ensure continual improvement within Zion engineering.
- c. Conclusion
The inspectors concluded that problems were being identified and corrective actions for
those problems specified. The licensee's self-assessment program relating, to
identification appeared effective and the inspectors considered that quality assurance
audits were more comprehensive. The licensee's Design Basis initiative and
Engineering Assurance Groups were viewed as positive contributors to improving the
overall quality of engineering products at Zion.
E8- Miscellaneous Engineering Issues
E8.1 Restart Plan items
a. Insoection Scoce
The inspectors reviewed selected 10 CFR 50.54(f) engineering related items from
Comed's response to the 50.54(f) letter to the NRC dated March 28,1997.
b. Observations and Findinos
The licensee could not easily retrieve the 10 CFR 50.54(f) Information requested since
the items were managed by the corporate organization. The inspectors then requested
the Zion specific 50.54(f) engineering items. Subseuently, the licensee provided NTS
items #198,207,209 and 212 which were assigned to Zion engineering for follow up.
21
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The inspectors noted that the Zion specific NTS items had been last updated on
May 23,1997. The inspectors deemed that increased management attention was
needed in this area.
The inspectors reviewed a number of issues contained in the licensee's Recovery Plan
related to the Unit 2 restart. The following recovery plan action items were selected for
review:
.
Item 8.3.2," Implement the Corrective Action Review Board (CARB)"- The
inspectors noted that on June 13,1997, approval was given to implement the
CARB function and establish roles and responsibilities of its members. An
assessment of the CARB is provided in Section E7.1.
.
Item 12.9.1,"SQV Department Self Assessment"- The objective of this
self-assessment was to determine the SQV Audit Group's readiness to assess
and overview the safe startup and operation of Zion Unit 2.
The inspectors confirmed that item 12.9.1 had been completed. As required for
this item, the self-assessment team was identified, the plan was developed and
, forwarded to the Zion Restart Panel.
.
Item 12.9.3," Implement Corrective Actions from the Self Assessment"-The
inspectors noted that corrective actions to address deficiencies in the SQV Audit
l Group were ongoing.
l
.
Item 13.8.1," Perform an Assessment of the Station's Readiness to implement
Technical Specification improvement Program (TS!P)" - The inspectors noted
that the assessment was completed on June 25,1997. This item will be tracked
in item 13.8.2.
.
The inspectors also reviewed selected licensca Recovery Plan items.
Specifically, items 6.1.1, 6.1.2, 6.1.4, 6.1.5, 6.1.7, 6.1.8, 6.1.10, 6.2.1, (N RC
restart plan items C.2.3.c, C.2.3.d, and C.4.a) which relate to improvements
needed in the operability determination process and with system engineering
roles and interfaces. Licensee improvements noted in the operability
assessment and engineering interface areas are discussed in sections E1.1 and
E1.3 respectively.
c. Conclusion
In general, the inspectors noted that while progress of the above recovery plan action
items was progressing, final completion and review of these items has not occurred.
These items will be evaluated during a subsequent NRC inspection. With regard to
10 CFR 50.54(f) items, the inspectors noted that the licensee updated these items in
May 1997 and could not easily retrieve the information requested. The inspectors
concluded that this matter required increased licensee attention.
22
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E8.2 Nuclear Trackina Svstem
a. Insoection Scoce
The inspectors reviewed licensee actions in response to restart iteins 11.5,11.6 (NRC
restart plan item C.2.1.b) and 11.7 which were created to address NTS Closed items
which may have had inadequate corrective actions prior to closure and also to ensure
that open Hems would be addressed in accordance with the current Recovery Program
guicelines.
b. Observations and Findings
j
in late 1996, the licensee identified that the NTS had not flagged approaching regulatory
commitments due dates. Further licensee reviews identified that poor documentation
was available to support closed NTS items. To address these issues, the licensee
revieweJ ver 4,000 NTS open and closed items with a focus on identifing any potential
restart it. 3. Over 400 items were identified as needing resolution prior to restart.
This included a population of 289 open items and 144 previously identified restart items.
The intpectors reviewed the process of resolving these issues and noted that the
licensee had taken aggressive actions to address self-identified deficiencies in the NTS
,
system. Weaknesses in the system were still being corrected. The licensee noted that
the NTS closure standards were weak as many commitments cou:d not be dispositioned
due to lack of information in the portion of NTS that support closing a commitment.
Further, the licensee noted that vendor technical information sent to Zion was not being
formally processed in accordance with the guiding NSWP. The licensee was revising
'
the NTS procedure to ensure standardization of NTS item closure documentation
!
requirements, and minimizing extension of due dates,
c. Conclusions
While the licensee was taking action to address self identified NTS shortcomings,
challenges included ensuring consistent documentation of commitment closeout
information and completing consistent reviews of operating experience items. The
licensee's NTS effort was considered a positive initiative to reassess long standing
engineering issues and commitments.
E8.3 Additional Sources of Hvdroaen Generation inside Containment
a, insoection Scoce
The inspectors reviewed the applicable sections of the UFEAR with respect to hydrogen
generation analyses and practices for limiting hydrogen generating materials inside
containments, in addition, the inspectors interviewed members of the engineering staff
with regards to the above subjects. The UFSAR sections reviewed included Appendix
1 A, " Compliance to AEC Safety Guides," and Section 15.6.5.6, " Reduction of Hydrogen
in Containment After a Loss-of-Coolant Accident."
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b. Observations and Findinas:
The hydrogen generation analysis asults credited in the UFSAR did not account for zine
materials (such as galvanized steel)Inside the containments. UFSAR Section
15.6.5.6.2.2 stated "that only aluminum will corrode at a rate that will significantly add to
the hydrogen accumulation in the containment atmosphere." Although some analyses
were performed to quantify the amount of hydrogen generated from zinc-based coating
systems used for the containment liners in the containments, the zinc-based coatings
wer6 not considered a source of hydiogen for the licensing basis hydrogen generation
analysis results reflected in UFSAR Table 15.6-37. UFSAR Sections 15.6.5.6.3 and
15.6.5.6.4 stated that hydrogen generated from zinc-based coatings was not included
because Safety Guide 7, " Control of Combustible Gas Concentrations in Containment
Following a loss of Coolant Accident," dated March 10,1971, did not explicitly mention
production of hydrogen from zine materials. The inspectors noted that the analyses
performed showed that hydrogen generated from the zinc-based coatings on the
containment liners would only amount to abat 0.27% of the containment volume.
However, the analyses dd not account for hydrogen generated from ziric-based
coatings other than those used for the containment liners and other zinc sources, such
as galvanized steel, within the contcinments.
The inspectors noted that hydrogen generation analyses for other plants showed that
zinc could contribute a substantive portion of the tot'I amount of hydrogen generated
after an accident. For example Figure 6.2-35 of the UFSAR for Byron and Braidwood
(two other Comed pressurized water reactor plants) showed that the contribution from
zine paint corrosion and zinc corrosion made up roughly half of the total amount of ;
hydrogen generated following a loss of coolant accident. The inspectors specifically
noted that the Zion analysis results for zinc-based coatings, showing minimal
contribution towards hydrogen generation, was not consistent with the analysis results
for Byron and Braldwood. Both the Zion UFSAR and the Byron /Braidwood UFSAR
(Section 6.2.5.3.1) referenced Oak Ridge Nation Laboratory reports ORNL-TM-2368
l
and ORNL TM-2425 for the experimental test data used for the Zion and
Byron /Braidwood analyses. Given that the same experimental data was used and
rela'ive similarity of the plants, the significant differences in analysis results were not
.readily explainable. In response, Zion engineering personnel stated that there was no
quantified inventory of zinc materials inside the containments nor was the amount of
zine material inside the containments tracked. The personnel stated that the amount of
zinc materials were not tracked because the Zion UFSAR analyses assumed that the
contribution towards hydrogen generation from zinc materials was insignificant.
Appendix 1 A of the UFSAR specified that Comed was committed to Safety Guide 7 for
Zion. Regulatory Position C.5 of Safety Guide 7 stses: " Materials within the
containment that would yield hydrogen gas due to corrosion from the emergency cooling
or containment spray solutions should be identified and their use should be limited as
much as practical." Given that zinc could provide a substantive contribution to hydrogen
generation and that the amount of zine materialinside the containments was not known
nor tracked, the inspectors questioned whether Regulatory Position C.5 of Safety
Guide 7 was being met for limiting hydrogen generating materials inside containment.
24
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The inspectors also questioned the appropriateness of not considering zinc materials for
the licensing basis hydrogen generation analyses. This issue will be tracked as on
unresolved item pending further NRC review (URI 50 295/07023 06(DRS), URI
50-304/97023-06(DRS)).
c. Concluslom:
The appropriateness of not considering zinc materials for the hydrogen generation
analyses and not tracking the amount of zinc materialinside the containments was
questioned. One unresolved item was identified to track this issue.
Ee.4 Review of Previousiv identMed Unresolved and Ooen items
[Qoen) IFl 50-295/304 95003-06(DRP): In 1994, the licensee identified that there were
no isolation switches to isolate the EDG room vent fan (five tctal) circuits in the event of
a control room fire (Appendix R) to ensure EDGs operability. The 10CFR Appendix R
safe shutdown analysis failed to consider the EDG room ventilation fans as required
equipment and subsequently did not analyze the associated cables for applicability to
Appendix R This resulted in a cable separation criteria deficiency. Subsequently, the
licensee has established the appropriate fire watches in the affected Zones. Recently,
design engineering issued modification E22 2 96 201 on May 29,1996, to address the
design deficiency. The modification was completed for unit 1. This item remains open
pending completion of the modification for unit 2 prior to plant restart. (CAL ltem #5)
(Closed) Violation (50-304/96011-03b(DRS)): The inspectors reviewed the licensee's
actions in response to the charging pump test control violation and determined that the
actions taken ensured that the acceptance criteria for sumoillance and inservica testing
of the charging pumps was acceptatie. Action tak >n inc:,ade Zion and Nuclear Fuels
Services (NFS) engineering reviews of the pump performance requirements, addition of
aweptance criteria and reviews of test date by multi-disciplined teams to confirm that all
assumptions in the ECCS analysis were met. Further, management emph3 sis on
better communication between Zion System Engineering and NFS had been initiated.
Additionally, other NFS responses and recommendation were revieweo by Zion
engineering. This violation is closed.
.
'
(Closed) Unresolved item (50-304/96011 06(DRS)): A potential flow imbalance
stemming from discrepancies in the differenti pressures obtained in the four enarging
injectio, paths. This issue was considered unr6cived pend!ng verification of flow
l Independently of the differential pressure method. The inspectors reviewed the
- subsequent charging and safety injection full flow teste conducted using TSS 16.6.84
l
which was performed during the Z2R14 outage as well as trouble shooting plans
l (TSGP 188) which were initiated to verify the flowrates using ultrasonic flowmeter
i
equipment. The inspectors confirmed that the flowrates measured using the ultrasonic
flowmeters were consistent with the flowrates obtained using the differential pressure
method. The ultrasonic testing methods provided satisfactory confirming evidence that
the branch lines flowrates were not out of balance and validated the measured
differential pressure flowrates. This URI is closed.
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(Goted) Unresolved item (50 295/9701610: 50-304/97016-10): Teflon used in
Containment Hatch Seals. The licensee identified that the Teflon seals utilized on
containment escape hatch shafts may potentially not be qualified for the postulated
maximum post accident radiation fields and could result in a direct leak path from the i
containment atmosphere to the environment. The licensee notified the NRC of tne
problem in accordance with 10 CFR 50.72 on July 16,1997, but retracted the event on '
July 29,1997. The inspectors reviewed licensee actions, including an analysis, to l
resolve the containment escape hatch shaft seal qualification concern which led to the
retraction. Calculation 22S B 026E 038 titled," Analysis of Teflon Material used in
Escape Hatch," evaluated the functional capability of the seals and seats used in the
hatches under a radiation environment. The analysis identified the escape hatch parts
made of Teflon and their location, identified the type of Teflon used in these parts,
determined the postulated radiation environment at the actuallocation of the Teflon
parts, determined the raClation effects on the mechanical properties (such as
compression) of the Teflon material, reviewed industry testing performed on Teflon in
similar radiation environments and evaluated the functional capability of the Teflon parts
in the radiation environment. Overall, the analysis used conservative assumptions and
reasonable empirical data on Teflon properties when exposed to radiation to conclude
that the Zion Teflon seals would perform their required safety function under the
postulated radiation environment. The inspectors agreed with the retraction. This URI
is closed.
(Ocen) URi 50 295/304/97018-01(DRS): Concerns with Main Steam Line Pressure
Transmitters and Cables Located in the Steam Tunnel (During a High Energy Line
Break (HELB)) . The licensee determined that steam generator pressure transmi'ter
cables routed via the steam tunnel had unacceptable cable leakage current. In addition,
four of the twelve transmitters wers known to be not environmentally qualified. To
address this problem, The licensee developed modifications and replaced the four
Fisher Porter transmitters, and the existing instrument cables to the transmitters. (Ref.
LER 97 011).
Subsequent review of the 50.59 SE by the ZEAG noted that UFSAR Appendix 3A,
"Analys;a of the Effects of a Main Steam or Feedwater Pipe Break Outside the
Containment," stated that "All electrical cables associated with the nuclear safety relateo
(autoclose) operation of the main steam isolation valves is routed outside of the main
steam pipe tunnel through areas of the station which would not expose them to
environment resulting from a rupture of the main steam lines...." However, the cabling
for the main steam line pressure transmitters, which input into the ESF logic to close the
MSIVs, were, in fact, routed through the pipe tunnel.
On October 3,1997 PlF # Z1997-02222 was issued to document additional concerns
t with Reg. Guide 1.97 compliance, specifically, the potential loss of containment isolation
i valve position indication for various valves located in the steam tunnel. The licensee
determined that the valve cables were routed in the steam tunnel and were not
l environmentally qualified during a main steam line break outside containment accident.
26
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The licensee was in the process of performing an analysis to determine the significance i
of this configuration. This ite,m remains unresolved pending completion of licensee
evaluation of the issues and NRC review of proposed resolutlan prior to restart. (CAL
item #6)
[Qgen) URI 50-295/304/91a&Q20BS) The licensee recently identified that
insufficient voltage existed to energize safety related 4.16kv and 480Vac breaker coils.
To address this problem, the licensee has Initiated modifications E22 2 97 232 and
E22197 232B. This item will remain unresolved pending completion of the
modifications prior to plant restart and NRC review. (CAL ltem #3)
(Closed) URI (50 295M04 /97018-04(DRS)). This issue concerns use of 125 Vdc
cross tie configurations since 1975 without declaring the associated buses inoperable.
The inspectors examined concerns relative to cross tying a 125Vdc battery bus from
one Unit to a second unit in order to supply the design basis accident duty cycle for the
same division battery of the unit which had its battery and charger disconnected from
the bus for testing or charging activities.
The licensee had been cross-tying 125 Vdc buses of the same division between Unit 1
and 2 without restricting loads on the bus since TS 3.15.2.E was amended in 1975 to
allow this configuration under certain plant conditions. The cross ties were done so that
the direct current (DC) buses of units 1 and 2 could be interconn6cted during
maintenance, testing and charging of the batteries. During the cross t e configurations,
a battery and a charger would be disconnected from the bus of the unit being tested.
The 125 Vdc buses used during the cross tle configurations should have been declared
inoperable, because one battery could not supply the design bases duty cycle for both
cross tied buses. However, this was not done. No technical basis to support the
cross tie configuration existed.
Thu DC system design allowed for the single failure or loss of either redundant DC bus
on each unit (any one of three ESF DC buses 111,112 and 011 1 for unit 1 and 211,
212 and 0112 br unit 2) during the design basis accident (DBA) and loss of offsite
power conditions without adversely affecting the safe shutdown of the plant,
in March 1996, a system engineering supervisor requested that design engineering
perform an analysis to determine if cross-tying of buses was technically acceptable,
since no technical basis or evaluation existed.
Six months later, in September 1996, the licensee performed a cross tie design
calculation and analysis. Calculation 22S-B-007E 026, dated September 30,1996,
concluded that it was NOT acceptable to cross-tie a battery from a unit in modes 5,6 or
defueled to supply the complete design basis duty cycle for the same division of the
opposite unit in modes 14. The cross-tie was not acceptable because the 125 Vdc
battery would not be capable of supplying the cross tie loads and neither of the cross-
27
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tied buses could fulfill their design bases requirements during a design bases event
while cross tied.
No PIFs were issued until Spring 1997 to identify the cross tie historical operability
issue, the deficient cross tle procedures and erroneous TSs, or to determine root cause
and resolution. A PIF should have also been issued by the system engineering
supervisor In March 1996 when he requested that an analysis be performed.
1
The results of the design calculation were transmitted to system engineering via NDIT
ZDE 90 026 in September 1996. System engineering was tasked with revising and
promptly issuing operating procedure SOI-63K using the calculation results to prevent
operations from performing the undesired cross tie configuration in the future. The
inspectors noted that the regulred procedure changes were not implemented in a timely
manner until September 1997. Engineering failed to 'ranslate the calculation results into
appropriate procedures.
The inspectors noted that TS 3.15.2.E and improved TS 3.8.4 bases, page B3.8 55,
erroneously stated that the cross tie configuration was allowed to fulfill the operability
requirement of the unit in modes 1-4. In addition, operating and engineering procedures
also allowed this configuration without a technical evaluation in place.
The cross tle configuration occurred between either bus 111 with 211,112 with 212, and
011 1 with 211 and 011-2 with 111 using breakers that were mechanically interlocked
with a key lock. The following cross tie configurations were used at Zion in the past:
.
from a unit in mode 5, t, or defueled to a second unit at power, in order to supply
the complete DBA battery duty cycle for the same division of the other unit at
power,
e from a unit at power to a second unit in modes 5,6 or defueled, in order to
supply the same division of the shutdown unit's normal operating DC system
loads,
. with both units at full power between two 125 Vdc buses of the same division of
both units. The cross tie configuration was performed each weekend until 1993,
on a different station battery in order to conduct a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> equalizing charge of
the station batteries following completion of the monthly and quarterly battery
surveillance, and
. with both units shutdown.
Prior to 1993, cross tying was allowed with both units at power. Since then, the
cross-tie configurations were only performed with one unit operating and one unit
shutdown and the battery and charger of one of the units disconnected from the bus.
The buses were not declared inoperable. The cross-ties were typically performed every
18 months
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and lasted for approximately four days. However, more frequent iterations did occur.
For example, the buses were cross tied from October 17 22,1996, and again from
November 3-6,1996.
In March 1997, inspectors raised concerns during discussions with the de system
e
qgineer and supervisor relative to prohibiting future cross tying of 125 Vdc buses,
t ~ tween March and August 1997, the licensee issued three Operation Standing Orders
to prohibit planned Isolation of one battery or battery charger supplying two DC buses
without system engineering and operations management concurrence, however, Zion
cross tied the buses on June 12, July 2 and August 15,1997, with both units shutdown
without a technical justification or analys's to perform the cross tie under these plant
conditions.
The inspectors concluded that management expectations of engineering were
inconsistent in resolving this issue, in addition, there was a lack of communication and
interface between system engineering, design engineering, operations and regulatory
assurance personnel rehtive to addressing this issue in a timely manner. The
inspectors noted a lack of adequate interface between operations and engineering in
that engineering was informed by operations about the performance of the cross-tio
configurations; however, the responsible system engineer assumed that the operators
were declaring the buses inoperable during the cross-tie evolutions, in addition, attrition
and lack of system engineering continuity and ownership contributed to this problem. In
the last several years, at least four DC system engineers and three supervisors were
involved with this issue. The inspector determined that the present system engineer
appeared to be more aggressive in addressing this concern.
The inspectors noted that the potential safety consequence to the plant was high based
on the potential unavailability of an indeterminate number of redundar,t components had
a loss of offsite power (LOOP) occurred during the cross tie configuration. Redundant
equipment could have been inoperable in the event of LOOP while cross tied. Under a
125 Vdc cross tie configuration the supply battery would not have sufficient capacity to
support the current and voltage needs of both units during a limiting design basis event.
When in the cross tie configuration, the operating unit would probably not be able to
respond to a LOOP-LOCA as designed and would have been in an unanalyzed
condition that could have significantly compromised plant safety.
Additionally, the licensee had not translated or incorporated the cross tie design
calculation results into the appropriate emergency, engineering and testing procedures
and the operability determinations manual (ZODM)in a timely manner. The inspectors
further concluded that neither operations nor engineering appeared to completely
understand the ramifications of the design calculation results upon the plant. Also,
corrective action from September 1996 to August 1997 was inadequate. For example,
Zion engineering staff failed to recognize reportability, revise the appropriate procedures
and Tech 3pec's and operations failed to follow Standing Orders to prohibit cross tying
without approval and management expectatior:s were inconsistent.
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The inspectors concluded that the licensee failed to:
(1) take prompt and aggressive corrective action to address a design deficiency
which was identified during a calculation performed in September 1996. This
calculation concluded that it was not acceptable to cross tie 125 Vdc buses and
supply the design badis accident duty cycle for these cross tied buses. The
inspectors informed the licensee that this is considered an apparent violation of
10 CFR Part 50, Appendix B, Criterion XVI,' Corrective Actions"(eel
50 295/304/97023 07(DRS)).
(2) ensure that the design basis (calculation results) was correctly translated into
appropriate operations, engineering and testing procedures and documents.
This is considered an apparent violation of 10 CFR Part 50, Appendix B,
Criterion Ill, " Design Control" (eel 50 295/304/97023-08(DRS)), and
(3) adhere to the requirements of TS 3.15.2.E which stated that, "From and after the
date that one 125 Vdc battery and/or its distribution system for a unit (111,112,
or 011 for unit 1; 211,212 or 011 for unit 2)is not operable, the reactor of that
unit shall be placed in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the
battery and/or its distribution system is soon made operable." This is considered
an apparent violation of TS 3.15.2.E. (eel 50-295/304/97023-09(DRS)).
(4) report to the NRC an event or condition that was outside the design basis of the
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plant within 30 days after the discovery of the event or condition. This is
considered a violation of 10 CFR 50.73 (VIO 50 295/304/9702310)(DRS)).
Specifically, the licensee determined In September 1996 that during 125 Vdc
cross tie configuration the plant would be outside the design bases. However
this had not been reported until August 5,1997.
This unresolved item is considered closed.
IV. Plant Support
F2 Status of Fire Protection Facilities and Equipment
F2.1 OhitIYation of Plant Areas
a, insoection Scone
The inspector toured the site's buildings to observe fire protection and safety equipment,
such as hose stations, fire extinguishers, eye washes and emergency lights.
b. Observations and Findinas
The material condition of the majority of the fire protection equipment observed was
good. The inspector noted that the location of three fire extinguishers in the auxiliary
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building (elevations 542' and 617') were not clear, Some numbers in the markings on
the walls were missing. However, the inspector verified that the location was correctly
noted on the tags attached to the fire extinguishers. #
c. Conclusl0nt
The mat 91 condition of the majority of the fire protection equipment observed was
good.
F3 Fire Protection Pre Fire Plan, Procedures and Documentation
F3.1 Fire Pre Plan
a. Insoection Scone
The Inspector reviewed the plant Pre Fire Plan and the periodic test procedures used
,
for fire protection equipment. The inspector also reviewed the licensee's periodic review
l of the Pre Fire Plan,
b. Observations and Findings
The Inspector observed during a walk down of the turbine building that some fire -
protection equipment (such as a fire cart and dry chemical extinguishers) shown in the
middle of the 642 feet elevation (operating floor)in the Pre Fire Plan was actually
located near the west side wall. Similarly the inspector noticed foam fire fighting
equipment (Angus AF 20 model) near column F 23 on the 592 feet elevation (Ground
Floor) of the turbine building. This fire protection equipment was not included in the
Pre-Fire Plan and was not included in the periodic test procedures for monthly or annual
inspections,
The inspector reviewed the plant's PlFs and work requests to identify any previous
problems with the Pre-Fire plan. The inspector noted that PIF 96-4482, issued on
November 18,1996, identified that the Pre Fire Plan was not revised to include changes
made for security modification E22-0 96 245A. The licensee identified the root cause
for this omission as a procedural inadequacy, which resulted in the modification package
not identifying the need to revise the Pre Fire Plan.
The inspector also reviewed PIF 97-0790, issued on February 14,1997, which indicated
that some changes were needed in the Pre Fire plan. The Pre Fire plan did not include
manual actuation for fixed fire protection systems, in addition, it did not account for the
dangers of CO, systems on lower elevations of the plant. The due date for the
corrective action for the PlF was initially July 17,1997, but it had been extended till
Novernber 21,1997. The action item for following this corrective action,
205 20197-CAOD-079001, indicated that the reason for the delay was lack of
resources. The inspector also noted that a work request 970067146 was issued on
June 20,1997, for an annual review of the Pre Fire Plan.
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The plant's Fire Report, by reference a part of the UFSAR, required the issuance of a
Station Pre Fire Plan. The latest Pre Fire Plan revisions was issued in December 1993.
The Zion Station Administrative Program, ZAP 900-01," Zion Fire Protection Program",
(Revision 3) requires in Section G.4.m that the Station Fire Marshall review the Pre Fire
Plan annually. The Fire Marshall stated that an annual review of the Pre Fire Plan was
performed; but this review was not documented. The Fire Marshall stated that the next
review of the Pre Fire Plan, expected by the end of 1997, would be documented.
Pending further corrective actions by the licensee to update the Pre Fire Plan and to
verify the as built configuration, this is considered an inspection followup item.
(50 295/9702311(DRS); 50 304/9702311(DRS)).
c. Conclusl0D
The inspectors concluded that the Pre Fire Plan required by the plcnt's USAR (and the
Fire Report) was not adequately controlled and updated to reflect the plant
configuration. This item will be considered an inspection followup item.
V. Management Meetings
X1 Exit Meeting Summary
The inspection results were presented to members of licensee management at the preliminary
exit meetings on September 30. October 15, and at the final exit meeting on December 16,
1997, The licensee acknowledged the findings presented,
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PARTIAL LIST OF PEP. DONS CONTACTED
Licensee
J. Brons, Site Vice President
D. Bump, Restart Manager
M. Burns, System Engineering
R. Godley, Regulatory Assurance Manager
F. Gogliotti, Design Engineering
R. Jelsy, Ouality Control Supervisor
F. Jones, Regulatory Assurance
G. Lauber, Design Basis initiative
T. Luke, Engineering Manager
, T O'Connor, Operations Manager
L. Peterson, Mndification Administration Supervisor
T. Schiffley, Regulatory Assurrance
G. Schwartz, Engineering Programs
R. Starkey, Plant General Manager
W. Stone, Regulatory Assurance
R. Zyduck, Site Quality Verification Manager
blRC
Z. Falevits, Reactor Inspector
J. Guzman, Reactor inspector
1. Jackiw, Reactor inspector
IDNS
J. Yesinowski, Zion Resident Engineer, IDNS
B
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INSPECTION PROCEDURES USED
IP 37550 Engineering
IP 40500 Effectiveness of Identifying and Resolving Technical Issues
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
50 295/304/07023-01 VIO Fallure to follow scaffold inspection procedure
50-295/301/97023 2 URI Lube oil analysis concern
50 295/304/97023 03a VIO Failure to trend and analyze oil samples
50 295/304/97023-03b VIO Failure to implement an effective program to resolve long
standing OOT issues
50 295/304/97023 04 VIO Failure to report ECCS analysis descrepancies per 10
CFR 50.46
50-295/304/97023-05 VIO Failure to ensure adequate training for personnel
performing Raychem splices applications
50 295/304/97023 06 URI Failure to consider zinc materials for Safety Guide 7
50-295/304/97023-07 eel Failure to take corrective actions for 125Vdc issues
50-295/304/97023 08 eel Failure to ensure design basis (calculations) translated into
appropriate documents
50-295/304/97023 09 eel Failure to adhere to Tech Spec operability requirements
50 295-304/97023 10 VIO Failure to report conditions outside design basis (50.73)
50-295/304/97023-11 IFl Failure to document an annual Pre Fire Plan
ClosAd
50-304/9601103b VIO Failure to adequately control test activities
50-304/96011-06 URI Potential flow imbalance in charging injection paths
50-295/304/97016-10 URI Teflon used in containment hatch seals
50-295/304/97018-04 URI Use of 125Vdc Cross Tie configuration
34
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QLicuisad
50 295/304/95003-00 IFl No isolation switches for EDG room fans
50 295/304/97018 01 URI Main steam cables in steam tunnel
50 295/304 97018-02 URI insufficient voltage to energize safety related breakers
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35
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LIST OF ACRONYMS USED
AEC Atomic Energy Commission
CAR Corrective Action Report
CARB Corrective Action Review Board
DBA Design Basis Accident
DBI Design Bases initiative
DC Direct Current
ECCS Emergency Core Cooling System
EDG Emergency Diesel Generator
eel Escalated Enforcement item
i EO Environmental Qualification
l ESF Engineered Safety Feature
E&TS Engineering and Technical Support
'
IP Inspection Procedure
LER Licensee Event Report
LOCA Loss of Coolant Accident
LOOP Logs of Office Power
MCC Motor Control Center
N/A Not Applicable
!
NRC Nuclear Regulatory Commission
NTS Nuclear Tracking System
OTT Out of Tolerance
PlF Problem Identification Form
OC Ouality Control
O&SA Quality and Safety Assessment
SBLOCA Small Break Loss of Coolant Accident
SE Safety Evaluation
SERC Safety Evaluation Review Committea
SMAD System Material Analysis Department
TS Technical Specification
TSS Technical Specification Surveillance
UFSAR Updated F!nal Safety Analysis Report
URI Unresolved item
VIO Violation
ZAP Zion Administrative Procedure
ZEAG Zion Engineering Assurance Group
ZODM Zion Operability Determinations Manual
36